## MEMORANDUM

TO: Steam Electric Rulemaking Record

FROM: Elizabeth Gentile , E RG

DATE: September 30, 2015

SUBJECT: Ash Handling Documentation from Communications with Clyde Bergemann Power Group

EPA published proposed revisions to the effluent limitations guidelines and standards (ELGs) for the Steam Electric Power Generating category (40 CFR Part 423) on June 7, 2013 (78 FR 34431). Based on public comments received from the proposed rule, EPA and ERG contacted Clyde Bergemann Power Group (CPBG) several times between January 9, 2014 and September 30, 2014 to collect additional information on fly and bottom ash handling conversions. This file is a compilation of the call notes between EPA, ERG, and CBPG. The call notes included in the following sections of this memorandum are listed below by date:

• January 9, 2014: Call between EPA, CBPG, and ERG to discuss fly ash and bottom ash
handling conversions.

• April 15, 2014: Meeting between CBPG and ERG to discuss the response to questions
delivered April 7, 2014 and provided design data for one remote submerged scraper

conveyor installation.

• June 2, 2014: Call between CBPG and ERG to discuss bottom ash handlin g technology
options.

• August 28, 2014: Call between CBPG and ERG to discuss bottom ash remote mechanical
drag systems and delivery of three bottom ash cost estimates.

• September 19, 2014: Call between CBPG and ERG to discuss methodology for
estimating remot e submerged scraper conveyor volume.

Additionally, Appendix A of this memorandum includes all of the email communication between

EPA, ERG, and CBPG. The email communication s included in the Appendix to this

memorandum are listed below by date.

• January 9, 2014 and February 10, 2014: Email documentation of the CBPG dense slurry
installations from Gary Mooney, CBPG to Elizabeth Gentile (Sabol), ERG.

• April 7, 2014: Response to follow up questions on fly ash and bottom ash costs delivered
by ERG on March 25,20 14 from Gary Mooney, CBPG to Elizabeth Gentile (Sabol),

ERG.

### Memorandum September 30, 2015 Page 2

• June 10, 2014: Response to follow up questions on fly ash and bottom ash costs delivered
by ERG on June 9, 2014 from Gary Mooney, CBPG to Elizabeth Gentile, ERG.

• June 19, 2014: Email documentatio n of sales tax information from Gary Mooney, CBPG

to Elizabeth Gentile, ERG.

• September 30, 2014: Email documentation of high pressure pumps (cost and service life)
from Gary Mooney, CBPG to Elizabeth Gentile, ERG.

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### 9, 2014

On Thursday, January 9, 2014, EPA and ERG participated in a call with CBPG to discuss fly ash and bottom ash handling conversions. Participants on the call included representatives from EPA, ERG, and CBPG, as listed in Table 1.

Table 1. List of Participants

Name Organization
Gary Mooney CBPG

Ron Grabowski CBPG

Ron Jordan EPA Phillip Flanders EPA

Jezebele Alicea EPA

Deb Bartram ERG (contractor to EPA)

TJ Finseth ERG (contractor to EPA) Ryan Novak ERG (contractor to EPA)

Elizabeth Gentile ERG (contractor to EPA)



### Ms. Alicea began by providing a brief introduction stating that EPA would like to collect additional information on fly ash and bottom ash handling conversions in response to public

comment received on the proposed rule. The remaining topics discussed included: the dense slurry fly ash handling technology, backup wet sluicing systems for fly ash, submerged scraper conveyors, remote submerged scraper conveyor systems, and dry mechanical conveyors (DRYCONTM).

Dense Slurry System

Mr. Mooney provided background information on dense slurry systems. He stated these types of systems are a viable handling option within the industry, particularly at those plants that may add limestone to the boiler, and noted that th ere are several systems installed and operating in Europe and one in the United States (JEA Northside). Mr. Mooney explained that these systems can be used for fly ash or bottom ash, but may be better to convey fly ash (due to the consistency of fly ash). Mr. Mooney further noted that the JEA Northside installation is different from the rest of the industry because the plant operates CFB boilers, in which both the fly ash and bed ash are a similar consistency.

Mr. Mooney discussed that in the conversion o f a traditional fly ash wet sluicing system to a dense slurry system, the plant would need to install different pumps (diaphragm pumps or GEHO pumps) to transport the slurry to the final destination . The existing fly ash equipment can be reused to transpor t the fly ash to the mixing point where it becomes slurry. Plants would likely

### Memorandum September 30, 2015 Page 3

have to dewater existing ponds to use that space as the disposal for the dense ash slurry. No grinder is needed if the dense slurry system is transporting fly ash. However, grin ders would have to be installed to transport economizer or bottom ash using the dense slurry system.

Back Up Wet Sluicing Systems for Fly Ash Handling

Mr. Mooney stated that there have been many wet

- to

- dry fly ash handling conversions in the industry sin ce 1977. W et fly ash handling system s are actually dry until fly ash is mixed with

water at a vacuum producer before it flows to a storage impoundment. Because the system components directly underneath the boiler to the vacuum producer are dry, plants do not need to remove the wet sluicing system, they need to install a diverter valve and/or a dry vacuum source.

Mr. Mooney explained that there is redundancy within dry fly ash handling conversions, and that plants do not need to keep wet handling systems in addition to the dry handling systems for a successful conversion. Specifically, the CBPG co sts provided to EPA by CBPG to estimate fly ash handling conversions included sufficient redundancy (e.g., two vacuum pumps per fly ash vacuum line, one standard and one backup). Mr. Mooney explained that plants actually gain redundancy by converting to dr y fly ash handling systems because redundancy is automatically built into the system. With a wet sluicing system, many plants don’t have any redundancy and when the system is plugged the system is down.

S ome plants use both wet and dry fly ash handling sy stems after a conversion so that the “best” ash is in the silo for plants that market dry fly ash. In this scenario, plants may sluice economizer or air heater ash and only transfer marketable fly ash dry to the silo. In order to manage this type

of scenar io without a wet sluicing system, CBPG stated that two separate silos could be used to keep ash of differing qualities stored separately.

Mr. Mooney explained that demolition of the existing fly ash wet sluicing system is not typically

included in conversion costs and that there is no pressing reason to get rid of the system after the dry fly ash handling retrofit.

Submerged Scraper Conveyor

Mr. Mooney explained that most under the boiler submerged scraper conveyors convey

dewatered bottom ash ou t from the boiler wall to a bunker right outside the boiler wall. He noted that it is uncommon to go much further than right outside the bunker wall; however, a longer conveyance distance can be accommodated by adding a belt conveyor to convey the dewatere d bottom ash any amount of distance to a common dewatering bunker. Mr. Mooney estimated that a belt conveyor is approximately half the price of the submerged scraper conveyor (based on the conveyance distance required).

T he cost estimates provided to EPA by CBPG for a submerged scraper conveyor installation included the demolition of the existing equipment underneath the boiler. T he other wet sluicing equipment (e.g., piping to the pond) does not need to be demolished for system operation and

was not inclu ded in the cost s CBPG provided to EPA

.

Mr. Mooney stated that many new generating units are installing submerged scraper conveyors compared to wet sluicing systems. However, he reiterated that some plants cannot convert

### Memorandum September 30, 2015 Page 4

existing wet sluicing bottom ash h andling systems to submerged scraper conveyors due to space

constraints in the boiler house.

Remote Submerged Scraper Conveyor

Mr. Mooney provided a brief overview of the remote submerged scraper conveyor . He stated that plants typically look into this t ype of bottom ash handling system because the plant cannot fit a submerged scraper conveyor or a DRYCONTM underneath the boiler. He explained that it is standard procedure to drain the remote submerged scraper conveyor once every five to six years

for stand ard maintenance. Other maintenance on the system includes re

- threading the 2 strands of drag chain used for dewatering the bottom ash. Mr. Mooney confirmed that estimating compliance costs for one remote submerged scraper conveyor per generating unit at th e plant would be accounting for sufficient redundancy. He explained that plants typically keep the option in to sluice to the surface impoundment.

During the conversation, Mr. Mooney explained that the remote submerged scraper conveyor

does not take the place of settling and/or surge tanks, it simply dewaters bottom ash. Therefore, plants that partially close their system may have a high fines carryover. 1 

### He stated that a heat exchanger or bath (e.g., tank or pond) may be necessary to allow the bottom ash transport water time to cool prior to being recirculated back to the boiler house for additional bottom ash sluicing. 2 

### There have been several bids by CBPG for the remote submerged scraper conveyor system that include both a clarifier with chemical additi on to remove ash and control pH and a recirculation or storage tank. However, it is CBPG’s experience that many plants are holding off on bottom ash system conversions until the CCR rule and ELG are finalized.

Dry Mechanical Conveyor (DRYCONTM)

Mr. Mooney provided a brief overview of the DRYCONTM bottom ash handling system and noted that there are two plants operating this type of system in the United States: Seminole Generating Station (Palatka, FL) and Crystal River ( Crystal River , FL)

. S ome pla nts may not be able to install the DRYCONTM due to space constraints underneath the boiler. T he outage time

associated with the DRYCONTM is approximately 4

- 6 weeks. He believes the DRYCONTM is likely the most cost effective conversion for bottom ash because t here are savings associated with the following:

• Maintenance (approximately $650,000/year in labor, spare parts, and operating
personnel);

• Power Savings (approximately $125,000/year);

• Water usage (greater than $200,000/year);

• Water Heat Reduction (greater than $300,000/year in head loss reduction); and

• Boiler Efficiency (not estimated).

1 

### CBPG noted that there are no CBPG remote submerged scraper conveyor installations with some form of treatment for fines; however, there are several operating systems in the remote equipment category that use clarifiers (at TVA installations). CBPG also no ted two systems that currently do not use a clarifier.

2 

### CBPG noted that there are no known installations of remote submerged scraper conveyors that use a heat exchanger because all installations have nearby spare conveyors that can serve as a reservoir or bath to help cool

water if needed.

### Memorandum September 30, 2015 Page 5

CBPG is working on quantifying the savings associated with boiler efficiency (reduced loss on ignition and fuel consumption).

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### 15, 2014

On Tuesday, April 15, 2014, Gary Mooney, CBPG and Elizabeth Gentile, ERG met at the CBPG Material Handling Product office in Malvern, PA to discuss fly ash and bottom ash handling conversions, particularly the responses provided t o follow up questions on ash handling conversions provided to EPA and ERG on April 7, 2014.

Mr. Mooney began by providing a brief overview of how plants typically initiate an ash handling conversion. He described that plants typically hire an engineering firm, who works with the plant to draft engineering procurement and construction specifications and develop a request for proposal to capture several design and supply tasks. In this scenario, CBPG would submit a proposal for design and supply tasks relat ed to ash handling.

Mr. Mooney described that a turnkey fly ash system is a system where everything (including installation) is included in the design and cost. We discussed that CBPG fly ash bids are typically not turnkey fly ash systems, and therefore t he costs provided by CBPG represent purchased equipment and the other elements outlined in CBPG’s response to questions provide on April 7,

2014

.

In the response to questions provided by CBPG on April 7, 2014, he stated that the controls

included in the s ystem were “assumed to be only system logic for integration into existing plant DCS systems, not new PLC systems.” Mr. Mooney elaborated stating that modern power plants typically have a distributed control system (DCS). The controls included in the costs for the fly ash handling conversions include the system logic so the DCS programmer at the plant can run the new dry handling system in concert with the other systems at the plant. ERG confirmed with Mr. Mooney that costs for programmable logic controllers (PLC) were not included in the cost estimates and are not needed because the plant only needs the system logic for the DCS.

Ms. Gentile requested information on cost estimates for insulation, heat tracing, or other winterization equipment for dry fly ash handling conversions. Mr. Mooney stated that some heat wrap may be necessary for some plants in northern climates. Mr. Mooney stated that large engineering firms may have rules of thumb for pricing heat tracing or other winterization equipment.

Ms. Genti le explained that EPA and ERG are looking into public comments on redundancy for dry fly ash handling systems. As shown in the responses provided by CBPG on April 7, 2015,

the costs for a second filter

- receiver were requested and received. Mr. Mooney expla ined that it is common to include an extra standby pump or blower in a design to account for redundancy, and that adding capital costs for a second filter

- receiver accounts for additional redundancy. Ms. Gentile explained that EPA and ERG are also looking into additional capital costs for vacuum pumps and pressure blowers for redundancy costs for plants that operate dry fly ash handling

### Memorandum September 30, 2015 Page 6

systems with wet sluicing systems as back up (and require additional redundancy to handle all fly ash dry). 3



### Mr. Mooney stated that the remote submerged scraper conveyor may have an issue with particulate control causing too much wear over the equipment. He also stated that the temperature of the sluice water may have an impact on the bottom ash falling from the boiler.

For example, when bottom ash falls from the boiler into cool water, the water cracks and cools the ash. In warmer water, bottom ash is less likely to crack and will have more irregularity. Mr. Mooney recommends having a water clarifier and/or cooling tank for the remote submerged

scraper conveyor and estimated that it would cost approximately $1 million. He stated that the potential issue with a high concentration of fines could affect the type of piping required to return the water back to the system (e.g., f iber glass vs. carbon steel), valves, and nozzles on jet

pumps.

Mr. Mooney and Ms. Gentile discussed the use of surface impoundments in conjunction with the remote submerged scraper conveyor system. Mr. Mooney explained that some plants installing this ty pe of system could use the existing pipes, pumps, and chemical addition associated with an existing surface impoundment to achieve zero discharge.

Mr. Mooney provided a copy of design data for one remote submerged scraper conveyor installation (DCN SE0 59 27 ). This file is confidential business information.

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### 2, 2014

On Monday, June 2, 2014, Elizabeth Gentile, ERG called Gary Mooney, CBPG to discuss bottom ash handling technologies for slagging cyclone boilers and additional details about the remote submerged scraper conveyor

.

Ms. Gentile asked Mr. Mooney about the bo ttom ash handling technologies available for handling slag from cyclone boilers. Mr. Mooney explained that the DRYCONTM is not a feasible technology because of the way the slag drops from the bottom of the boiler (in the slag neck).
However, he noted that s ubmerged scraper conveyors can be used, and that one plant in the United States (Kansas City Power & Light’s La Cygne Generating Station) is successfully operating this type of system on a cyclone boiler.

Mr. Mooney also explained that the remote submerge d scraper conveyor would also work because at the point of the jet pumps the system looks exactly like a pulverized coal boiler. He further described that a cyclone boiler may even be easier for the remote submerged scraper

conveyor to handle because there are no fines and the material is heavier (resulting in easier settling). Mr. Mooney did not suggest that a clarifier would be necessary for a remote submerged

scraper conveyor installation on a cyclone boiler.

3 

### The cost estimates provided by CBPG can be found in Attachment 6 to this memorandum ( Additional Post
Proposal Follow Up Questions for Clyde Bergemann Power Group With Responses, Including Updated Fly Ash

Conversion Cos ts (SE04165_Cost Methodology Questions for CBPG_06092014

- RESPONSES 06102014.pdf) ).

### Memorandum September 30, 2015 Page 7

Ms. Gentile and Mr. Mooney discussed the rem ote submerged scraper conveyor and the need for a clarifier and recirculation/surge tank for pulverized coal boilers. Mr. Mooney stated that to estimate the size of a surge tank required for each plant, we would need to estimate 5

- 10 minutes

worth of stora ge time based on the pump rating and sluice line sizes (which vary plant to plant). Mr. Mooney explained that including a clarifier could help with temperature control and achieving TSS concentrations down to 30 ppm ( which would be required to discharge to surface

water under the current BPT limitation)

.

Ms. Gentile and Mr. Mooney also discussed the number of remote submerged scraper conveyors required at a plant for redundancy, as multiple units can be serviced by one remote submerged

scraper conveyor . Mr. Mooney stated that the reliability of one remote submerged scraper

conveyor is higher than one submerged scraper conveyor underneath the boiler. We discussed an example for a plant that had four generating units. In this scenario, two units were smaller requiring a smaller conveyor and two units were larger requiring a larger conveyor. Mr. Mooney

stated that three remote submerged scraper conveyors could be installed, all sized for the larger units so that they wer e interchangeable among the generating units (increasing redundancy). Additionally, b ecause plants only sluice and dewater bottom ash once per 8 or 12 hour shift (which lasts approximately 2 hours) that multiple units can sluice to one remote submerged

scr aper conveyor during one shift.

Mr. Mooney stated the maintenance associated with the remote submerged scraper conveyor includes the replacement of a wear plate at the bottom of a section of the trough that the scraping flight bars will wear over time. Th is is the only maintenance that requires the system to be

drained.

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### 28, 2014

On Thursday, August 28, 2014, Elizabeth Gentile, ERG called Gary Mooney, CBPG to discuss fly ash silos and surge capaci ty for draining remote submerged scraper conveyors

.

Ms. Gentile asked Mr. Mooney about the redundancy required for dry fly ash silos. Mr. Mooney stated that he has not seen two silos located at a plant purely for redundancy. He explained that some plants elect to install two silos if the capacity for one silo is so large that it is more economical to install two smaller silos. Some plants may also elect to install a sale silo and a

non

- sale silo (for marketing dry fly ash). R edundant equipment in a fly ash handling system would include the blowers and pugmills (two per silo). He stated that level indicators may not be appropriate to separate saleable and non

- saleable ash in a silo because the ash mixes within the

silo.

Ms. Gentile also asked Mr. Mooney ab out estimating the water volume of a remote submerged

scraper conveyor

. He stated that this information depends on the design of the remote submerged

scraper conveyor at a particular plant, the size of the bottom ash hopper (and therefore volume of

water r equired to fill the bottom ash hopper), and the piping in the system. Mr. Mooney stated that there is no rule of thumb for sizing the remote submerged scraper conveyor and that it purely depends on the bottom ash sluice flow rate at the plant.

Ms. Gentile and Mr. Mooney discussed options for surge capacity for when the remote submerged scraper conveyor needs to be drained for maintenance (once every five years to

### Memorandum September 30, 2015 Page 8

replace a wear plate). Mr. Mooney stated that an onsite surge tank or concrete basin could be sized for each system to handle the volume of water during system maintenance. Another option discussed was renting tanks for additional surge capacity

. P lants with more than one remote submerged scraper conveyor also have additional surge capacity because additional remote submerged scraper conveyors at a plant can serve as surge tanks.

In order to review some design information for the types of systems discussed during our call, Mr. Mooney mailed copies of design data for one remote submerged scraper con veyor installation (DCN SE0 5928 ), one dewatering bin installation (DCN SE0 5929 ), and one

DRYCON TM installation (DCN SE0 5930 ) for review. These files are confidential business

information.

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### 19, 2 014

On Friday, September 19, 2014, Elizabeth Gentile, ERG called Gary Mooney, CBPG to discuss ERG’s proposed methodology to estimate remote submerged scraper conveyor volume based on the design data for remote submerged scraper conveyor installations provi ded by CBPG.

Ms. Gentile asked Mr. Mooney if it would be appropriate to draw a relationship between two design parameters presented in the design data: bottom ash produced (in tons per hour) and remote submerged scraper conveyor volume. Mr. Mooney agreed and confirmed that for all design proposals, the remote submerged scraper conveyor is assumed to store bottom ash for up to eight hours. Mr. Mooney also noted that adding additional storage time has an impact on the length and he ight of the remote submerged scraper conveyor design.

However, Mr. Mooney did state that the remote submerged scraper conveyor volume presented in the design data is actually the storage volume. Therefore, he recommended multiplying the

storage volume by two to estimate the full volume of water that could be held in the remote submerged scraper conveyor to draw the relationship between bottom ash produced and remote submerged scraper conveyor volume.

### APPENDIX A

– Email Communication between EPA, ERG, and CBPG

The email communications included in this Appendix to this memorandum are listed below by

date. Any attachments included in the emails are noted below and can be found in DC N

SE05823.A1

.

• January 9, 2014 and February 10, 2014: Email documentation of the CBPG dense slurry
installations from Gary Mooney, CBPG to Elizabeth Gentile (Sabol), ERG, which
included the following attachments:

o Attachment 1 : Power plant life extension an d Improved availability using
environmentally friendly Dense_Phase conveying solutions Power Point ( Era ring
Project CBMH Australia.pdf)

o Attachment 2: Circumix Mixer in Dense Slurry System of GEA EGI Co. Ltd.
Power Point ( Circum ix_dense_slurry_technology.pd f)

o Attachment 3: Clyde Bergemann Materials Handling Installations of High
Concentration Slurry Disposal (HCDS) System ( CBD Ref List

- HCSD System

2

- 10

- 14.pdf)

• April 7, 2014: Response to follow up questions on fly ash and bottom ash costs delivered
by ERG on March 25,2014 from Gary Mooney, CBPG to Elizabeth Gentile (Sabol),
ERG, which included the following attachments:

o Attachment 4: Post Proposal Follow Up Questions for Clyde Bergemann Power
Group with Response ( SE04697_CBPG_Followup_03252014 With CBPG

Res ponses. pdf)

o Attachment 5: Fly Ash Conversion Costs ( EPA FLY ASH SYSTEM COST

SUMMARY

- APRIL 7 2014.pdf)

• June 10, 2014: Response to follow up questions on fly ash and bottom ash costs delivered
by ERG on June 9, 2014 from Gary Mooney, CBPG to Elizabeth Gent ile, ERG, which
included the following attachments:

o Attachment 6: Additional Post Proposal Follow Up Questions for Clyde
Bergemann Power Group With Responses, Including Updated Fly Ash
Conversion Costs ( SE04165_Cost Methodology Questions for CBPG_06092014

- RESPONSES 06102014.pdf )

o Attachment 7: Wet to Dry Fly Ash Conversions Power Point ( Wet Vacuum
System.pdf )

• June 19, 2014: Email documentation of sales tax information from Gary Mooney, CBPG

to Elizabeth Gentile, ERG.

• September 30, 2014: Email documentation of high pressure pumps (cost and service life)
from Gary Mooney, CBPG to Elizabeth Gentile, ERG.From: gary.mooney@us.cbpg.com

To: Elizabeth Sabol
Subject: CBPG & High Concentration Slurry Disposal

Date: Thursday, January 09, 2014 4:24:00 PM

Attachments: Attachment name not found.plain Attachment name not found.plain

Good Afternoon, Elizabeth: I have received some information from our Doncaster , England, office
on these dense phase slurry systems for fly ash.

We, as Clyde Bergemann Power Group, CBPG, have supplied two High Concentration Slurry Disposal,

HCSD , systems:

The first one was for Eraring Power Plant in Australia where we used Feluwa high pressure piston
diaphragm pumps to convey HCSD about 7 kilometers (~23,000 feet) to an ash lagoon.
We presented a paper at PowerGen Europe in 2009 on this project - see attached.
All four Units have been running well for nearly 2 years now. Here we used our own design using a primary screw mixer and a secondary mixing tank.

The second one was a project in Serbia at Kostolac where we used multistage centrifugal pumps to

convey 300 cubic meters per hour about 4.5 kilometers (~14,800 feet).

In addition to Feluwa, we could also use Dutch GEHO pumps which are part of the Weir Minerals
group (WARMAN pumps et al).

Another technology that we could use is supplied by GEA EGI Contracting Engineering Co in Hungary.

They market a CIRCUMIX R system. They have installations in Hungary, Romania and one in the USA at Jacksonville North Side
Generating Station.

I will forward a slide show from their web site. It does show some photos of the Jacksonville
equipment. We met them at a recent World of Coal Ash show in Denver and have a contact: Ferenc Horvath, VP
Balance of Plant Sales, in Hungary.
We also have contacts a North Side, if you don't.

So if and when these systems become viable as part of the future EPA decisions on ash ponds, we
are ready.



### Gary



## Your attachment has been removed and stored for download

Eraring Project CBMH Australia.pdf download

The password to download this file is erg.

This file will be kept for 30 days.



## Your attachment has been removed and stored for download

### Circumix_dense_slurry_technology.pdf download

The password to download this file is erg.

This file will be kept for 30 days.From: gary.mooney@us.cbpg.com

To: Elizabeth Sabol
Subject: Re: CBPG & High Concentration Slurry Disposal

Date: Monday, February 10, 2014 12:49:00 PM

Attachments: CBD Ref. List - HCSD System 2-10-14.pdf

Good Afternoon, Elizabeth: In follow-up to below, here is an Installation List for our Clyde
Bergemann Power Group HCSD Systems.

Regards,

Gary D. Mooney Product Manager, Ash Technology
Clyde Bergemann Power Group Americas Inc. Materials Handling Product Division

----------------------------------------------------- >>CLEAN ENERGY SOLUTIONS<<

-----------------------------------------------------

Phone: +1 610-560-4302

Cell: +1 610-715-4558

Fax: +1 610-695-9724

Email: gary.mooney@us.cbpg.com

Internet: www.cbpg.com

Clyde Bergemann Power Group Americas Inc. | Materials Handling Product Division | 33 Sproul Road | Malvern | Pennsylvania | 19355

From: Gary Mooney/CBDD/Clyde Bergemann
To: elizabeth.sabol@erg.com,

Date: 01/09/2014 04:29 PM

Subject: CBPG & High Concentration Slurry Disposal

Good Afternoon, Elizabeth: I have received some information from our Doncaster , England, office
on these dense phase slurry systems for fly ash.

We, as Clyde Bergemann Power Group, CBPG, have supplied two High Concentration Slurry Disposal,

HCSD , systems:

The first one was for Eraring Power Plant in Australia where we used Feluwa high pressure piston
diaphragm pumps to convey HCSD about 7 kilometers (~23,000 feet) to an ash lagoon.
We presented a paper at PowerGen Europe in 2009 on this project - see attached.
All four Units have been running well for nearly 2 years now. Here we used our own design using a primary screw mixer and a secondary mixing tank.

The second one was a project in Serbia at Kostolac where we used multistage centrifugal pumps to

convey 300 cubic meters per hour about 4.5 kilometers (~14,800 feet).In addition to Feluwa, we could also use Dutch GEHO pumps which are part of the Weir Minerals
group (WARMAN pumps et al).

Another technology that we could use is supplied by GEA EGI Contracting Engineering Co in Hungary.

They market a CIRCUMIX R system. They have installations in Hungary, Romania and one in the USA at Jacksonville North Side
Generating Station.

I will forward a slide show from their web site. It does show some photos of the Jacksonville
equipment. We met them at a recent World of Coal Ash show in Denver and have a contact: Ferenc Horvath, VP
Balance of Plant Sales, in Hungary.
We also have contacts a North Side, if you don't.

So if and when these systems become viable as part of the future EPA decisions on ash ponds, we
are ready.



### Gary

[attachment "Eraring Project CBMH Australia.pdf" deleted by Gary Mooney/CBDD/Clyde Bergemann] [attachment "Circumix_dense_slurry_technology.pdf" deleted by Gary Mooney/CBDD/Clyde Bergemann]From: gary.mooney@us.cbpg.com

To: Elizabeth Sabol

Cc: Alicea, Jezebele ; Deborah Bartram ; Flanders.Phillip@epa.gov ; Jordan, Ronald ; Ryan Novak ; Thomas Finseth ; ron.grabowski@us.cbpg.com
Subject: Re: CBPG Fly and Bottom Ash Responses to Questions

Date: Monday, April 07, 2014 4:20:26 PM

Attachments: SE04697_CBPG_Followup_03252014 With CBPG Responses.docx EPA FLY ASH SYSTEM COST SUMMARY - APRIL 7 2014.pdf

Good Afternoon, Elizabeth et al:

We enclose our comments and responses to your March 25 set of questions regarding our previous
cost studies for Fly Ash & Bottom Ash Systems.

We also enclose a revised Fly Ash Cost chart showing the additional cost for a redundant FilterReceiver in each of our scenarios.

We also point out that the activity level for quoting closed loop water recirculation systems for retrofit
bottom ash systems is picking up now that the December 19, 2014 deadline is fast approaching.

We cannot enclose any confidential active proposals at this time but pricing is very competitive.

Thank you again for allowing Clyde Bergemann Power Group, CBPG, to assist both the Eastern
Research Group and the EPA.

Regards,

Gary D. Mooney Product Manager, Ash Technology
Clyde Bergemann Power Group Americas Inc. Materials Handling Product Division

----------------------------------------------------- >>CLEAN ENERGY SOLUTIONS<<

-----------------------------------------------------

Phone: +1 610-560-4302

Cell: +1 610-715-4558

Fax: +1 610-695-9724

Email: gary.mooney@us.cbpg.com

Internet: www.cbpg.com

Clyde Bergemann Power Group Americas Inc. | Materials Handling Product Division | 33 Sproul Road | Malvern | Pennsylvania | 19355

From: Elizabeth Sabol <Elizabeth.Sabol@erg.com>
To: "gary.mooney@us.cbpg.com" <gary.mooney@us.cbpg.com>,
Cc: "Alicea, Jezebele" <Alicea.Jezebele@epa.gov>, "Jordan, Ronald" <Jordan.Ronald@epa.gov>, "Flanders.Phillip@epa.gov" <Flanders.Phillip@epa.gov>, Deborah Bartram <Deborah.Bartram@erg.com>, "Ryan Novak" <Ryan.Novak@erg.com>, Thomas

Finseth <Thomas.Finseth@erg.com>

Date: 03/25/2014 12:08 PM

Subject: Fly and Bottom Ash Questions for CBPGGary,

First, thank you for all of the fly ash and bottom ash design and cost information you’ve provided to date. As you
know, we used these data to estimate compliance costs associated with fly ash and bottom ash handling

conversions for the Proposed Steam Electric ELGs.

As we discussed during our conversation back in January, EPA is now evaluating the proposed cost methodology

to identify any potential updates, if needed. Therefore, in addition to the information we discussed during our
call, EPA would like to request responses to the questions in the attached file to ensure that we are correctly

interpreting your data.

If any of the information associated with the attached questions is confidential business information (CBI), please

do not send the answers back electronically. Instead, please send the response to the following address:

Eastern Research Group, Inc.

Attention: Ryan Novak

14555 Avion Parkway

Suite 200

Chantilly, VA 20151

EPA is requesting this additional information by April 8, 2014. We look forward to your answers and comments
regarding costs associated with fly and bottom ash handling. We would appreciate your feedback and thank you in

advance for your time and effort.

If you have any questions about the attached file, or would like to discuss the request, please give me a call at

610-344-0829.

Thanks,

Elizabeth

Elizabeth A. Sabol

Environmental Engineer

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

elizabeth.sabol@erg.com

Phone: 610-344-0829

[attachment "SE04697_CBPG_Followup_03252014.docx" deleted by Gary Mooney/CBDD/Clyde Bergemann]From: gary.mooney@us.cbpg.com

To: Elizabeth Gentile

Cc: Alicea, Jezebele ; Deborah Bartram ; flanders.phillip@epa.gov ; Jordan, Ronald ; Ryan Novak ; Thomas Finseth ; ron.grabowski@us.cbpg.com
Subject: Re: Ash Handling Conversions - Additional Questions

Date: Tuesday, June 10, 2014 10:39:50 AM

Attachments: SE04165_Cost Methodology Questions for CBPG_06092014 - RESPONSES 06102014.pdf Wet Vacuum System.pdf

Good Morning, Elizabeth:

We are pleased that our meeting in April was helpful to you, ERG and the EPA as you sort through
and respond to all of the comments received for the Proposed Rule.

Here are our responses to your latest set of questions. If I missed something or need to clarify further,

we still have time before June 20th.

Regards,

Gary D. Mooney Product Manager, Ash Technology
Clyde Bergemann Power Group Americas Inc. Materials Handling Product Division

----------------------------------------------------- >>CLEAN ENERGY SOLUTIONS<<

-----------------------------------------------------

Phone: +1 610-560-4302

Cell: +1 610-715-4558

Fax: +1 610-695-9724

Email: gary.mooney@us.cbpg.com

Internet: www.cbpg.com

Clyde Bergemann Power Group Americas Inc. | Materials Handling Product Division | 33 Sproul Road | Malvern | Pennsylvania | 19355

From: Elizabeth Gentile <Elizabeth.Gentile@erg.com>
To: "gary.mooney@us.cbpg.com" <gary.mooney@us.cbpg.com>,
Cc: "Jordan, Ronald" <Jordan.Ronald@epa.gov>, "Alicea, Jezebele" <Alicea.Jezebele@epa.gov>, "flanders.phillip@epa.gov" <flanders.phillip@epa.gov>, Deborah Bartram <Deborah.Bartram@erg.com>, "Thomas Finseth" <Thomas.Finseth@erg.com>, Ryan

Novak <Ryan.Novak@erg.com>

Date: 06/09/2014 09:49 AM

Subject: Ash Handling Conversions - Additional Questions

Gary,

Thank you for your time and the information you provided back in April. We have a few additional questions thatwe’d like to follow up on. Please see the attached file.

Similar to the previous requests, if any of the information associated with the attached questions is confidential

business information (CBI), please do not send the answers back electronically. Instead, please send the response

to the following address:

Eastern Research Group, Inc.

Attention: Ryan Novak

14555 Avion Parkway

Suite 200

Chantilly, VA 20151

EPA is requesting additional information by June 20. We look forward to your answers and comments regarding

costs associated with fly and bottom ash handling. We appreciate your feedback and thank you in advance for

your time and effort.

Thanks,

Elizabeth

Elizabeth A. Gentile

Environmental Engineer

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

elizabeth.gentile@erg.com

Phone: 610-344-0829

[attachment "SE04165_Cost Methodology Questions for CBPG_06092014.docx" deleted by Gary
Mooney/CBDD/Clyde Bergemann]From: gary.mooney@us.cbpg.com

To: Elizabeth Gentile
Subject: RE: CBPG Fly and Bottom Ash Responses to Questions

Date: Thursday, June 19, 2014 8:27:54 AM

Good Morning, Elizabeth:

We never include or pay any Sales Tax. We assume all of our Utility clients are exempt. Many send
their tax exempt certificate in the RFQs.

I would say you do not need to add anything.

We are talking about sales taxes mostly, like 6% here in PA. I bet an national average is more like

3%. Lost in the Budgetary nature of these quotes anyway.

Okay, My Friend?

gary

From: Elizabeth Gentile <Elizabeth.Gentile@erg.com>
To: "gary.mooney@us.cbpg.com" <gary.mooney@us.cbpg.com>,

Date: 06/19/2014 07:58 AM

Subject: RE: CBPG Fly and Bottom Ash Responses to Questions

Good morning Gary,

In the responses provided to these fly and bottom ash questions back in April, you mentioned that tax is not

included in the original cost estimates (just freight). Can you confirm that this is because plants don’t pay tax on

this equipment? Or is this something we should be accounting for in our cost estimates?

If tax is typically included, is there a standard percentage we should use?

Thanks,

Elizabeth

From: gary.mooney@us.cbpg.com [ mailto:gary.mooney@us.cbpg.com ]

Sent: Monday, April 07, 2014 4:29 PM

To: Elizabeth Sabol

Cc: Alicea, Jezebele; Deborah Bartram; Flanders.Phillip@epa.gov; Jordan, Ronald; Ryan Novak; Thomas Finseth; ron.grabowski@us.cbpg.com Subject: Re: CBPG Fly and Bottom Ash Responses to Questions

Good Afternoon, Elizabeth et al:

We enclose our comments and responses to your March 25 set of questions regarding our previous
cost studies for Fly Ash & Bottom Ash Systems.

We also enclose a revised Fly Ash Cost chart showing the additional cost for a redundant Filter-Receiver in each of our scenarios.

We also point out that the activity level for quoting closed loop water recirculation systems for retrofit
bottom ash systems is picking up now that the December 19, 2014 deadline is fast approaching.

We cannot enclose any confidential active proposals at this time but pricing is very competitive.

Thank you again for allowing Clyde Bergemann Power Group, CBPG, to assist both the Eastern
Research Group and the EPA.

Regards,

Gary D. Mooney Product Manager, Ash Technology
Clyde Bergemann Power Group Americas Inc. Materials Handling Product Division

----------------------------------------------------- >>CLEAN ENERGY SOLUTIONS<<

-----------------------------------------------------

Phone: +1 610-560-4302

Cell: +1 610-715-4558

Fax: +1 610-695-9724

Email: gary.mooney@us.cbpg.com

Internet: www.cbpg.com

Clyde Bergemann Power Group Americas Inc. | Materials Handling Product Division | 33 Sproul Road | Malvern | Pennsylvania | 19355

From: Elizabeth Sabol < Elizabeth.Sabol@erg.com > To: " gary.mooney@us.cbpg.com " < gary.mooney@us.cbpg.com >, Cc: "Alicea, Jezebele" < Alicea.Jezebele@epa.gov >, "Jordan, Ronald" < Jordan.Ronald@epa.gov >, " Flanders.Phillip@epa.gov "

< Flanders.Phillip@epa.gov >, Deborah Bartram < Deborah.Bartram@erg.com >, "Ryan Novak" < Ryan.Novak@erg.com >, Thomas

Finseth < Thomas.Finseth@erg.com >

Date: 03/25/2014 12:08 PM Subject: Fly and Bottom Ash Questions for CBPG

Gary,

First, thank you for all of the fly ash and bottom ash design and cost information you’ve provided to date. As you

know, we used these data to estimate compliance costs associated with fly ash and bottom ash handling

conversions for the Proposed Steam Electric ELGs.

As we discussed during our conversation back in January, EPA is now evaluating the proposed cost methodology

to identify any potential updates, if needed. Therefore, in addition to the information we discussed during ourcall, EPA would like to request responses to the questions in the attached file to ensure that we are correctly

interpreting your data.

If any of the information associated with the attached questions is confidential business information (CBI), please

do not send the answers back electronically. Instead, please send the response to the following address:

Eastern Research Group, Inc.

Attention: Ryan Novak

14555 Avion Parkway

Suite 200

Chantilly, VA 20151

EPA is requesting this additional information by April 8, 2014. We look forward to your answers and comments

regarding costs associated with fly and bottom ash handling. We would appreciate your feedback and thank you in

advance for your time and effort.

If you have any questions about the attached file, or would like to discuss the request, please give me a call at

610-344-0829.

Thanks,

Elizabeth

Elizabeth A. Sabol

Environmental Engineer

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

elizabeth.sabol@erg.com

Phone: 610-344-0829
[attachment "SE04697_CBPG_Followup_03252014.docx" deleted by Gary Mooney/CBDD/Clyde Bergemann]From: gary.mooney@us.cbpg.com

To: Elizabeth Gentile
Subject: Re: FW: Ash Handling Conversions - Additional Questions

Date: Tuesday, September 30, 2014 9:42:26 AM

Good Morning, Elizabeth;

I am back in the office after two solid weeks of business development.

I have not bid high pressure sluice pumps for fly ash for a long time. These systems are being phased

out, not reintroduced.

However, the same types of pumps ARE coming back into use in the closed loop water recirculation
systems for bottom ash.

The nozzles in bottom ash jet pumps and the nozzles in the water jet exhausters used for wet fly ash
systems both need high pressure water in the 250# to 300 psig range.

The bottom ash system do require more gallons per minute due to the pipeline sizes involved.

Fly ash systems may need anywhere from 1,000 GPM to 3,000 GPM while bottom ash systems use up
to 5,000 GPM in supply pumps.

There are two types of pumps we can use.

For Recirculation systems with closed loops and therefore a concentration on ash fines in the water,
we can use heavy duty slurry pumps such as the Weir/Warman and Duechting product lines.

For once through systems where the incoming water is filtered river water or perhaps condenser/turbine exhaust water, we can use so called clear water pumps from Goulds or Flowserve or
a number of other pump suppliers.

I would put a set of clear water pumps for fly ash service at $150,000 to $250,000 each with always at

least two with one a 100% spare.
The Horsepower for the motors would range from 500 to 1250 HP.

All of these pumps have replaceable parts so the whole pump is not thrown away after 5 years.

Okay, my friend?

Regards,

Gary D. Mooney Product Manager, Ash Technology
Clyde Bergemann Power Group Americas Inc. Materials Handling Product Division

----------------------------------------------------- >>CLEAN ENERGY SOLUTIONS<<

-----------------------------------------------------

Phone: +1 610-560-4302Cell: +1 610-715-4558

Fax: +1 610-695-9724

Email: gary.mooney@us.cbpg.com

Internet: www.cbpg.com

Clyde Bergemann Power Group Americas Inc. | Materials Handling Product Division | 33 Sproul Road | Malvern | Pennsylvania | 19355

From: Elizabeth Gentile <Elizabeth.Gentile@erg.com>
To: "gary.mooney@us.cbpg.com" <gary.mooney@us.cbpg.com>,

Date: 09/19/2014 11:40 AM

Subject: FW: Ash Handling Conversions - Additional Questions

Hi Gary:

Thank you again for your time on the phone this morning.

As I mentioned, I wanted to see if you could provide additional cost information for high-pressure sluice water

pumps for a fly ash wet sluicing system.

In the attached PDF (SE04165), for Fly Ash Questions 4 and 5, we requested service life and cost information for

hydrovactor nozzle replacement, air separator tank, and convey pipe. We’d also like to ask about high-pressure

sluice water pumps. Is it reasonable to assume a 5-year service life for high-pressure sluice water pumps?

Additionally, can you provide a capital cost estimate associated with high-pressure sluice water pumps?

Thank you,

Elizabeth

From: gary.mooney@us.cbpg.com [ mailto:gary.mooney@us.cbpg.com ]

Sent: Tuesday, June 10, 2014 10:49 AM

To: Elizabeth Gentile

Cc: Alicea, Jezebele; Deborah Bartram; flanders.phillip@epa.gov; Jordan, Ronald; Ryan Novak; Thomas Finseth; ron.grabowski@us.cbpg.com Subject: Re: Ash Handling Conversions - Additional Questions

Good Morning, Elizabeth:

We are pleased that our meeting in April was helpful to you, ERG and the EPA as you sort through
and respond to all of the comments received for the Proposed Rule.

Here are our responses to your latest set of questions. If I missed something or need to clarify further,

we still have time before June 20th.

Regards,

Gary D. MooneyProduct Manager, Ash Technology
Clyde Bergemann Power Group Americas Inc. Materials Handling Product Division

----------------------------------------------------- >>CLEAN ENERGY SOLUTIONS<<

-----------------------------------------------------

Phone: +1 610-560-4302

Cell: +1 610-715-4558

Fax: +1 610-695-9724

Email: gary.mooney@us.cbpg.com

Internet: www.cbpg.com

Clyde Bergemann Power Group Americas Inc. | Materials Handling Product Division | 33 Sproul Road | Malvern | Pennsylvania | 19355

From: Elizabeth Gentile < Elizabeth.Gentile@erg.com > To: " gary.mooney@us.cbpg.com " < gary.mooney@us.cbpg.com >, Cc: "Jordan, Ronald" < Jordan.Ronald@epa.gov >, "Alicea, Jezebele" < Alicea.Jezebele@epa.gov >, " flanders.phillip@epa.gov "

< flanders.phillip@epa.gov >, Deborah Bartram < Deborah.Bartram@erg.com >, "Thomas Finseth" < Thomas.Finseth@erg.com >, Ryan

Novak < Ryan.Novak@erg.com >

Date: 06/09/2014 09:49 AM Subject: Ash Handling Conversions - Additional Questions

Gary,

Thank you for your time and the information you provided back in April. We have a few additional questions that

we’d like to follow up on. Please see the attached file.

Similar to the previous requests, if any of the information associated with the attached questions is confidential

business information (CBI), please do not send the answers back electronically. Instead, please send the response

to the following address:

Eastern Research Group, Inc.

Attention: Ryan Novak

14555 Avion Parkway

Suite 200

Chantilly, VA 20151

EPA is requesting additional information by June 20. We look forward to your answers and comments regarding

costs associated with fly and bottom ash handling. We appreciate your feedback and thank you in advance for

your time and effort.

Thanks,

ElizabethElizabeth A. Gentile

Environmental Engineer

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

elizabeth.gentile@erg.com

Phone: 610-344-0829

[attachment "SE04165_Cost Methodology Questions for CBPG_06092014.docx" deleted by Gary
Mooney/CBDD/Clyde Bergemann] [attachment "SE04165_Cost Methodology Questions for CBPG_06092014 -

RESPONSES 06102014.pdf" deleted by Gary Mooney/CBDD/Clyde Bergemann]