MEMORANDUM

TO: Steam Electric Rulemaking Record

FROM: Elizabeth Gentile, ERG

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 handling 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 remote submerged scraper conveyor volume.

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

EPA, ERG, and CBPG. The email communications 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 25,2014 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 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.

1.0 NOTES FROM CALL WITH CLYDE BERGEMANN POWER GROUP ON JANUARY 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 there 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 of 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 transport 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, grinders 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 since 1977. Wet fly ash handling systems 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 costs 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 dry 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.

Some plants use both wet and dry fly ash handling systems 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 scenario 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 out 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 dewatered 

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).

The cost estimates provided to EPA by CBPG for a submerged scraper conveyor installation 

included the demolition of the existing equipment underneath the boiler. The other wet sluicing 

equipment (e.g., piping to the pond) does not need to be demolished for system operation and 

was not included in the costs 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 handling 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 type 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 standard 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 the 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 addition 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). Some plants may not be 

able to install the DRYCONTM due to space constraints underneath the boiler. The 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 there 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 noted 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).

2.0 NOTES FROM MEETING WITH CLYDE BERGEMANN POWER GROUP ON APRIL 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 to 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 related 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 the 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 system 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. Gentile 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 explained 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., fiber 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 type 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 SE05927). This file is confidential business information. 

3.0 NOTES FROM CALL WITH CLYDE BERGEMANN POWER GROUP ON JUNE 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 bottom 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 submerged 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 submerged 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 Costs (SE04165_Cost Methodology Questions for CBPG_06092014 - RESPONSES 06102014.pdf)).
Memorandum

September 30, 2015

Page 7

Ms. Gentile and Mr. Mooney discussed the remote 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 storage 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 were interchangeable among the generating units (increasing redundancy). 

Additionally, because 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 

scraper 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. This is the only maintenance that requires the system to be 

drained. 

4.0 NOTES FROM CALL WITH CLYDE BERGEMANN POWER GROUP ON AUGUST 28, 2014

On Thursday, August 28, 2014, Elizabeth Gentile, ERG called Gary Mooney, CBPG to discuss 

fly ash silos and surge capacity 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). Redundant 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 about 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 required 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. Plants 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 conveyor

installation (DCN SE05928), one dewatering bin installation (DCN SE05929), and one 

DRYCONTM installation (DCN SE05930) for review. These files are confidential business 

information. 

5.0 NOTES FROM CALL WITH CLYDE BERGEMANN POWER GROUP ON SEPTEMBER 19, 2014

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 provided 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 height 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 DCN 

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 and Improved availability using 

environmentally friendly Dense_Phase conveying solutions Power Point (Eraring 

Project CBMH Australia.pdf)

o Attachment 2: Circumix Mixer in Dense Slurry System of GEA EGI Co. Ltd. 

Power Point (Circumix_dense_slurry_technology.pdf)

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 

Responses.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 Gentile, 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 CIRCUMIXR 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 CIRCUMIXR 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 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 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 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,

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 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

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: +1 610-560-4302
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>, 

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. 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 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, 

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] [attachment "SE04165_Cost Methodology Questions for CBPG_06092014 -

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