Draft Notes from Site Visit at 

Consumers Energy’s Karn/Weadock Generating Complex 

on September 22, 2009 

 EPA conducted a site visit at Consumers Energy’s Karn/Weadock Generating Complex 

(Karn/Weadock) located in Essexville, MI on Tuesday, September 22, 2009 to learn about the 

operations at the plant. Table 1, located at the end of this memorandum, identifies the site visit 

participants. The presentation that the Karn/Weadock personnel gave during the site visit is 

provided in Attachment 1 of this memorandum. 

This memorandum describes the information collected during the site visit. 

Plant Overview 

 The Karn/Weadock Generating Complex includes the D.E. Karn and J.C. Weadock power 

plants. Karn/Weadock has been in production since the 1940’s. The site covers 

approximately 2,400 acres, as well as some additional outlying property the plant has 

acquired. [QUESTION FOR KARN/WEADOCK: What is the size of the outlying property 

and where is it located?] The 2,400 acres includes the outlying area. It is located at 2742 

Weadock Highway Essexville, MI . The complex is located at the mouth of the Saginaw 

River, which discharges to the Saginaw Bay and ultimately combines with Lake Heron. 

Karn/Weadock pumps service water from the Saginaw River and discharges pre-treated 

NPDES permit authorized effluent to Saginaw Bay via Outfall 001. A discharge flow 

diagram for Karn/Weadock is provided in Attachment 2 of this memorandum. 

 Karn/Weadock employs 381 personnel, with supplemental company and contracted 

employees. Roughly, Karn/Weadock employs 250 personnel to operate the units. 

 Karn/Weadock has 12 electric generating units on site. Six of these twelve are retired 

Weadock units, while six are still in operation. The units still in operation are coal-fired units, 

Karn Units 1 and 2 and Weadock Units 7 and 8, and oil/natural gas-fired units, Karn Units 3 

and 4. Karn/Weadock stated that retired Weadock Units 1-6 are “standard”, once- through 

steam electric generating units that were extremely inefficient when operated. They were 

retired in the early 1980’s. The table below contains some general information for each 

operating electric generating unit. 
Page 2 

Unit Boiler 

Description 

Installation 

Date 

Net Rated 

Capacity 

Power 

(MBTU per 

hour) 

Fuel Blend Particulate 

Control 

NOx 

Control 

Karn Unit 1 

Dry 

Bottom; 

Tangentialfired 

1959 255 MW 

Baseload 2,500 

75 % PRB 

25 % 

Eastern 

bituminous 

2 cold-side 

electrostatic 

precipitators 

(ESPs) in 

series; 

Sulfur 

trioxide 

system 

available to 

enhance 

efficiency 

SCR 

installed in 

2004; 

Year round 

operation of 

SCR began 

in 2009 

Karn Unit 2 

Dry 

Bottom; 

Wall-fired 

1961 260 MW 

Baseload 2,540 

75 % PRB 

25 % 

Eastern 

bituminous 

2 cold-side 

ESPs in 

series; 

Sulfur 

trioxide 

system 

available to 

enhance 

efficiency 

SCR 

installed in 

2003; 

Year round 

operation of 

SCR began 

in 2009; 

Low-NOx 

burners 

installed in 

1998 

Karn Unit 3 

Natural gas 

and fuel oilfired (dual 

fuel) 

1975 630 MW 

Peaking 7,290 

# 6 fuel oil 

and natural 

gas 

None Low-NOX

burners 

Karn Unit 4 

Natural gas 

and fuel oilfired (dual 

fuel) 

1977 630 MW 

Peaking 8,030 

# 6 fuel oil, 

and natural 

gas 

None Low-NOX

burners 

Weadock 

Unit 7 

Dry 

Bottom; 

Tangentialfired 

1955 155 MW 

Baseload 1,610 

80 % PRB 

20 % 

Eastern 

bituminous 

Cold-side 

ESP; 

Sulfur 

trioxide 

system 

available to 

enhance 

efficiency 

Low-NOX

burners 

(Operational 

May 2010) 

Weadock 

Unit 8 

Dry 

Bottom; 

Tangentialfired 

1958 155 MW 

Baseload 1,610 

80 % PRB 

20 % 

Eastern 

bituminous 

Cold-side 

ESP; 

Sulfur 

trioxide 

system 

available to 

enhance 

efficiency 

Low-NOX

burners 

(Operational 

March 

2010) 

[QUESTION FOR KARN/WEADOCK: Do Weadock Units 7 and 8 have any NOx controls? 

Yes, JCW Units 7 &8 now have LNB's, but they were not in place and operational at the time 

of EPA's site visit in September 2009.] 

 Karn/Weadock stated that there is no significant difference in operation between the type of 

boilers (tangential versus wall) for Karn Units 1 and 2. There is no significant difference in 

the amount or split of ash (bottom versus fly ash) or the efficiency of the boilers. 

Karn/Weadock installed a wall-fired boiler for Karn Unit 2 mostly due to market competition 

at the time. 

 Karn Unit 1 was down for maintenance during the site visit. Karn/Weadock stated that Karn 

has 30 to 60 days of outage planned for cleaning and maintenance throughout the year. 
Page 3 

 Karn Units 1 and 2 and Weadock Units 7 and 8 use fuel oil for startup and supplemental cofiring for flame stabilization and mill outages. 

 In 2008, Karn Units 1 and 2 and Weadock Units 7 and 8 burned a total of 1,947,422 tons of 

coal to produce 3,873,186 net MWh. 

 Karn Units 3 and 4 have identical, front-fired boilers units with 30 burners (3 decks of 10). 

Each burner on each boiler must burn the same amount of BTU for balancing. The boilers 

are started with natural gas, and then typically burn a blend of natural gas and oil. Each 

burner is capable of burning both natural gas and oil at the same time, but Karn/Weadock 

does not do that. In years past, Karn/Weadock would typically burn about 40 percent natural 

gas and 60 percent oil in the boilers, but the plant has recently been burning more natural gas 

in these boilers because it has been so inexpensive. The plant is limited to burning 60 

percent natural gas due to boiler reactions. The radiant flame affects the way the water walls 

absorb heat. Karn/Weadock controls sulfur dioxide emissions with a “ratio burn” of natural 

gas to oil. The burning of the medium sulfur oil, which contains more than 1 percent sulfur, 

is balanced with burning of natural gas to meet the plant’s permitted sulfur dioxide limit. 

 Karn Units 1 and 2 and Weadock Units 7 and 8 each have a sulfur trioxide injection system 

to enhance the performance of the ESPs. Karn/Weadock has found that the these sulfur 

trioxide injection systems have not been necessary and they have not been used recently due 

to the year round operation of the SCRs. Heat tracing and thermal insulation systems were 

installed to allow SCR system operation through the winter. 

 Karn/Weadock has plans to install dry FGD systems on Karn Units 1 and 2, possibly within 

two years; however, these plans are currently on hold. The plant has also considered 

installing activated carbon injection (ACI) systems to reduce flue gas mercury emissions, but 

these plans depend on future mercury regulations. Fabric filter baghouses, which are 

currently being constructed, will replace the ESPs on Karn Unit 2 in November 2010 and 

Karn Unit 1 in February 2011. The primary ESPs will be retired on site and the secondary 

ESPs will be removed. 

 Once through cooling is used for Karn Units 1 and 2 and Weadock Units 7 and 8. 

 Karn Units 3 and 4 use closed loop, mechanical draft cooling towers. 

Ash Generation, Handling, and Wastewater Treatment 

Ash Generation 

 Karn Units 3 and 4 are oil/natural gas-fired units. They produce very little ash. Soot blowers 

exist on each unit; however, are presently never used because no precipitators are installed on 

these units. Without precipitators, operating the soot blowers would cause ash to exit the 

stack with the flue gas and air pollution control limits would be exceeded. The soot blowers 

on these units were last operated in the 1970’s. 
Page 4 

Bottom Ash Handling 

 Karn/Weadock operates a wet bottom ash handling system on Karn Units 1 and 2 and 

Weadock Units 7 and 8. About ten percent of all ash produced at the plant is bottom ash. Mill 

rejects are collected dry and then handled wet with the bottom ash. The Weadock bottom ash 

sluice is directed to the Weadock bottom ash pond through a series of channels, discharged 

via Outfall 001H, and ultimately discharged to Saginaw Bay via Outfall 001A. An aerial 

view of the Weadock property, with labeled ponds, channels, and outfalls, is provided in 

Attachment 3 of this memorandum. 

 Karn/Weadock dredges the bottom ash pond a couple of times a year and uses the bottom ash 

for roadbed. The roads are constructed of about two feet of bottom ash, a geotech fabric, and 

about two feet of stone. Karn/Weadock also has plans to use bottom ash as landfill cover 

material. 

 Karn Units 1 and 2 have a similar wet bottom ash handling system. The Karn bottom ash 

sluice is directed to the Karn bottom ash pond, discharged via Outfall 001B, and ultimately 

discharged to Saginaw Bay via Outfall 001A. An aerial view of the Karn property, with 

labeled ponds, channels, and outfalls, is provided in Attachment 4 of this memorandum. 

 Karn/Weadock estimates that there is about six to eight years of capacity left for the bottom 

ash pond. The facility will continue to develop more options for bottom ash sluice closer to 

that time. 

 Karn/Weadock previously developed scoping-level cost estimates for converting to a bottom 

ash handling system that would use dewatering bins. [NOTE TO KARN/WEADOCK: Please 

provide the cost estimate that was developed. If developed as part of a report or similar 

evaluation such as vendor proposal, provide the report/proposal.] Plant personnel stated that 

if the bottom ash were sent to a dewatering bin, the plant would need to consider the cost for 

treatment of the recovered water, though reuse of the water is a possibility. The dewatered 

ash may need to be hauled. 

Fly Ash Handling Overview 

 Karn/Weadock operates a dry fly ash handling system on Karn Units 1 and 2 and Weadock 

Units 7 and 8. These systems are identical in operation, but the Weadock system is smaller. 

There are fewer hoppers overall for the Weadock units. In both the Karn and Weadock 

systems, ash collected from the precipitators, air heaters, and economizers is handled dry. 

For the Karn units, the air heater and economizer ash is collected in separate sets of hoppers, 

whereas for the Weadock units, the air heater and economizer ash is collected together in the 

same hoppers. 

 

 The dry fly ash handling system (on Karn Units 1 and 2 and Weadock Units 7 and 8) is a 

conversion from the previously operated wet fly ash handling system. This conversion took 

place from 2006 to 2009, with initial operation of the dry fly ash handling system occurring 

in 2008. The dry fly ash handling system was designed by United Conveyor (UCC) in 2006. 

The dry fly ash flow diagram is provided in Attachment 1 of this memorandum. 
Page 5 

 Some of the fly ash sluicing equipment is still in place at Karn/Weadock, mainly due to the 

cost of removal. Karn/Weadock has no plans to use the sluicing equipment again. Plant 

personnel stated that there is no need because there is ample capacity and redundancy in 

current dry fly ash handling system (and fly ash can be diverted from the Karn to Weadock 

systems or vice versa). Additionally, plant personnel stated that it might not be possible to 

use the sluicing system as is: valves and other equipment would need to be 

removed/replaced. 

 Karn/Weadock discussed why they switched from the hydroveyors, which were used with 

the wet sluicing system, to mechanical exhausters to pull the fly ash by vacuum out of the 

hoppers. The mechanical exhausters are more reliable, and in general, the plant wants to 

reduce water use as much as possible. Additionally, the hydroveyor system would not have 

been able to pull enough vacuum to transfer the dry fly ash from the hoppers to the transfer 

station/tank. 

 New equipment additions for the dry fly ash systems include piping (some piping from the 

wet fly ash handling systems is still in use for the dry fly ash handling systems), valves, the 

exhaust systems, the transfer station/tanks, and the loading silo. 

 Headwaters Resources (Headwaters) markets the dry fly ash produced at the Karn/Weadock 

facility. The amount of fly ash sold depends on the availability of projects in the Michigan 

area. Lafarge Company purchases about 200 tons of the Karn/Weadock fly ash per day to 

manufacture cement. 

 Long term, the facility is looking to sell about 50,000 tons of ash per year. Karn/Weadock 

produces about 160,000 tons of fly ash per year. 

 The mixture of coal that Karn/Weadock uses to operate their units produces a valuable ash 

product. It is not Class C ash, but there is still a market for it. Karn/Weadock stated that the 

Campbell power plant burns a 100 percent western coal, which produces a more valuable 

Class C ash with a lower loss on ignition (LOI). Karn/Weadock stated that the major 

difference between the types/classes of ash is the final color. 

Detailed Dry Fly Ash Handling System Operation 

 The fly ash is collected dry from the bottom of the precipitator and economizer hoppers and 

pulled by vacuum (generated by mechanical exhausters) to the transfer tank. The Karn and 

Weadock dry fly ash systems each have one transfer tank. The precipitator and economizer 

hoppers are emptied based on time intervals or levels of ash. The Karn transfer tank has the 

capacity to hold about two to three days worth of fly ash (from Karn Units 1 and 2 

combined), but the transfer tank is typically operated at about 20 percent of its capacity. 

Karn/Weadock estimated that the distance from the Karn Unit 2 hoppers to the transfer tank 

is about 400 to 600 feet (and about an additional 200 feet from the Karn Unit 1 hoppers). 

 Located on the side of each transfer tank is an emergency loading dock and pin mixer (pug 

mill) that can be used to unload ash from the transfer tank in case there is a system failure or 

the loading silo requires maintenance. The pin mixer conditions (i.e., adds moisture to) ash in 

preparation for loading, typically to about 15 to 20 percent moisture. The emergency pin 

mixer can condition ash at a rate of 50 tons per hour. 
Page 6 

 Dry fly ash that enters the transfer tank (from the precipitator and economizer hoppers) is 

transferred into filter/separators. The filter/separators contain bag filters and separate the fly 

ash from the transfer air, which is exhausted. The fly ash is then transferred into air-locked 

transfer hoppers. As the ash is dropped into the hoppers, fugitive dust is pulled through the 

filter/separators and captured by bin vent filters on top of the transfer tank, ensuring that no 

dust exits through the stack. Operators routinely check monitors that indicate if there any 

breaks in the filters. 

 As the top of transfer hopper closes, separating the ash from the vacuum pressure, the bottom 

of the hopper opens, introducing the ash to a positive air pressure system. The ash is blown 

by compressed air to the 2,700 ton storage silo, which is 2,300 ft away from the Karn transfer 

tank and over 4,000 ft away from the Weadock transfer tank. NUVA pressure feeders are 

used to introduce the ash to the positive pressure system. Relief valves were installed on the 

transfer hopper to ensure that they don’t contract as the change in air pressure occurs. 

 From the storage silo, dry fly ash is either loaded pneumatically into trucks for sale or 

moisture conditioned, loaded into trucks and landfilled. Currently, Karn/Weadock unloads 

ash, either for landfill or sale, five days per week during daylight hours only. It is cost 

prohibitive for Karn/Weadock to install lights on the roads to the silo at this time. 

 Dry fly ash for sale is transferred to the trucks pneumatically, under negative pressure, with a 

double annular spout. A vacuum is pulled through the outer annulus of the spout, creating a 

tight seal with the truck. Ash is delivered through the inner annulus of the spout into the 

truck. The vacuum captures any fugitive dust and pulls it back into the silo. Karn/Weadock 

stated that with this system, the ash flows easily into the trucks, “like a liquid”. Trucks are 

each loaded with approximately 50 tons of dry fly ash. Plant personnel stated that the 

moisture content of the dry fly ash stored in the silo is very low. Any significant amount of 

moisture would cause sedimentation in the silo. 

 Bagfilters are located at the top of the silo. There is a transmitter analog gauge to monitor the 

quality of the bags. Visual checks are also performed and logged periodically by operators. 

The conveying piping is also visually checked for any leaks. 

 Dry fly ash that is not sold is moisture-conditioned in pin mixers and then loaded into one of 

two trucks. The pin mixers at the storage silo are much larger than the emergency pin mixer 

near the transfer tank. The pin mixers at the storage silo moisture-condition the ash to about 

17 to 18 percent. The inside of the pin mixer contains large bars (till bars) made out of nylon 

anti-stick material that mix the ash with the water, which is sprayed into the mixer. The pin 

mixers are also operated under vacuum to control fugitive dust. 

 One truck holds 42 tons of ash that has been conditioned to a moisture content of about 17 to 

18 percent (about 37 tons of dry fly ash and 5 to 6 tons of water). A 6,500-gallon service 

water truck regularly drives around the perimeter of the silo area wetting the ground to 

control fugitive dust. 

 The trucks that load the moisture-conditioned ash place it in the landfill/ash pond area. A 

bulldozer spreads the ash and compacts it to the desired density. The bulldozer operator uses 

a compaction hammer to test the density of the surrounding area once every 104 truckloads 
Page 7 

or 4 ft of ash displaced. Lab tests are done to determine the exact density and moisture 

content of the ash placed. In order to obtain an accurate reading for the elevation, surveying 

would have to done. 

 After trucks have loaded moisture-conditioned ash, some water is released to the silo area 

through a drain hose. Sumps around the area drain to a collection ditch and small sediment 

pond where sediment and ash are dredged and stacked. 

Dry Fly Ash Handling Conversion Timeline and Costs 

 Butch Braun, the System Engineer for the dry fly ash handling system, presented 

Karn/Weadock’s conversion plan and the related costs during the site visit. The presentation 

given by Mr. Braun is provided in Attachment 5 of this memorandum.

 The scope of the project was to convert the wet fly ash handling systems on Karn Units 1 and 

2 and Weadock Units 7 and 8 to dry fly ash handling systems that pneumatically convey fly 

ash from the precipitator, economizer, and air heater hoppers to the storage silo for landfill 

and/or sale.

 The project was started in 2005 with the development of a dry fly ash handling study, which 

updated a previous study performed in 2002. Mr. Braun mentioned that a report was 

generated that documents the 2005 study. [NOTE TO KARN/WEADOCK: Please provide 

this report] The foundations for the new dry fly ash handling system were laid in 2006. The 

year 2007 focused on the engineering and mechanical/electrical designs. Activities in 2008 

included the construction, start-up, and testing of the final design. Karn/Weadock is closing 

out the project during the year 2009. 

 UC Services developed the overall system design and provided the major equipment 

(compressors, blowers, tanks, piping, etc) as well as the redundant equipment used 

throughout the system. UCC designed and provided the ash storage silo. 

 Karn installed isolation valves during a forced outage for Karn Unit 1 in 2006. Karn Unit 2 

was installed during a planned outage in 2007. Weadock Units 7 and 8 isolation valves were 

installed during a forced outage in 2006. With these isolation valves, the facility was able to 

isolate the wet system from the new dry system and perform tie in work while the generating 

units were still in operation. 

 The total budget for the conversion was $50 million. This is nearly double the cost estimated 

in the 2005 plan. 

 When asked about specific costs, Mr. Braun used the conversion for Karn Units 1 and 2 as an 

example. Mr. Braun estimated that the Karn installation was about $19 million (and the 

Weadock installation was about $24 million and the silo was about $7 million). He provided 

the following rough, breakout for the Karn materials/installation cost (Note: the attached 

“Project Construction Cost Breakdown” presentation includes another version of this 

breakout):

 UC Services major equipment: $4 million;

 Buildings: $2 million;
Page 8 

 Piping to the silo: $2 million;

 Electrical: $2 million;

 Mechanical installation: $3 million; and

 Cement foundation for silo: $1.5 million 

 The conversion for Weadock was more expensive than Karn due to challenges the facility 

encountered with spacing and location. The Weadock system required more piping to reach 

the transfer tank and storage silo. Some system equipment (e.g., compressors and 

filter/separators) also had to be split between two buildings for spacing issues. Additionally, 

the compressor pumps needed to be placed on the roof to save space, which resulted in the 

added construction of a platform for support.

 Challenges that Karn/Weadock encountered during the conversion included equipment and 

underground work interferences, manpower availability, weather, and the availability of the 

contractor to install the silo. Karn/Weadock was able to use regular scheduled outages to 

complete the conversion over the four-year period.

 Karn/Weadock stated that the silo started operating on December 9, 2008 and started 

landfilling ash on December 18, 2008. Both dry fly ash handling systems were in full 

operation on February 21, 2009. 

 Karn/Weadock stated that the annual O&M cost, including labor, for the silo is $225,000. 

This includes the O&M costs for two pickup trucks, the bulldozer, and the service water 

truck. [QUESTION FOR KARN/WEADOCK: What is the total operator time included in the 

annual O&M costs? Specifically, please include the number of persons, hours per day, and 

days per week.]

 Karn/Weadock stated that there has been only a minimal increase in O&M costs for the dry 

system from the wet system thus far. Karn/Weadock estimated that start up time for the dry 

system is about one hour, compared to the 20 minutes for the wet system. The difference in 

start up time could be partly related to learning how to operate the new dry system. 

Karn/Weadock stated that maintenance costs have been low so far, but predicted that they 

will rise due to the complexity of the new system (e.g., additional valves). 

 The design of the Karn/Weadock dry fly ash handling system is similar to the Campbell 

power plant system. Karn/Weadock looked to the Campbell system design for lessons 

learned during the conversion. The one major difference between the two systems is that the 

Campbell system has two loading silos: one for dry fly ash sale and one for moistureconditioned landfilling. 

 Karn/Weadock discussed that they would like to modify the ash loading area for separate 

loading areas for dry fly ash sale and moisture-conditioned landfilling. With two separate 

loading areas, moisture-conditioned ash and dry ash could be loaded at the same time. This 

would eliminate the timely process necessary to switch from the moisture-conditioned 

loading equipment and the dry spout between truck loads. Two loading bays versus two 

loading silos were also discussed.
Page 9 

Karn/Weadock Ash Ponds and Landfills

 Karn/Weadock operates a network of ash ponds. This network includes a series of ponds and 

channels that was created (and most useful when) fly ash was sluiced. The network of 

channels was created to increase retention capacity. The earliest ponds that were constructed 

on the plant property were filled prior to 1969. 

The Karn ash field (landfill) is about 170 acres and the Weadock ash field is 292 acres. There 

are no leachate collection systems for these landfills. 

 The Karn fly ash ponds/landfill are currently full. All Karn ash that is not being sold is being 

used to fill in the Weadock ash ponds or landfill. In Michigan, ash impoundments must be 

closed as landfills are with a cover. Karn/Weadock plans to use dredged bottom ash for this 

cover material. 

 Karn/Weadock built a slurry wall along the entire pond system as part of the plan for vertical 

expansion of the ash pond/landfill area. 

 As the Karn fly ash ponds were running out of capacity, Karn/Weadock could no longer meet 

their TSS limits on the ash pond discharge. Because of this and Karn/Weadock’s overall 

goal to use and discharge less water (partly due to trends of tighter regulations on 

discharges), Karn/Weadock converted to a dry fly ash handling system. 

 Karn/Weadock mentioned that they are considering building a new electric generating unit 

with cooling towers on top of the old Karn ponds. 

 Karn/Weadock recently conducted a potential failure mode analysis of their ponds with the 

company, AECOM, and report(s) of the analysis are being drafted. Prior to that, 

Karn/Weadock conducted inspections of their ponds; these were not formal geotechnical 

inspections, but what Karn/Weadock described as general inspections. 

 Karn/Weadock has conducted groundwater monitoring around the ash pond/landfill area 

since 1982, with a particular focus on boron and arsenic. Typically, the leachate in the area 

contains about 2 ppb of boron, but closer to 100 ppb is measured during groundwater testing. 

Metal Cleaning Wastes 

 

 The plant determines when boiler cleaning (or washing) is necessary for Karn Units 3 and 4 

based on gallons of oil burned. When cleaning is required, the boiler is shutdown and cleaned 

using water wash. The water used is plant service water (Saginaw river water). There are no 

chemicals added to the boiler water wash. Used boiler water wash is transferred to the Karn 

ash ponds. 

 Karn Units 3 and 4 boilers are usually cleaned twice a year. Karn has to balance cleaning the 

boilers with the efficiency of the units. Time and money are lost when the boiler is shut down 

for cleaning; however, when the boiler is not clean, the ash that has coated the reheater, 

superheater, and economizer tubes/surfaces decreases the efficiency of the boiler. 

Karn/Weadock stated that when the Karn Units 3 and 4 boilers are not clean, they are 

typically about 10 percent less efficient than when clean. 
Page 10 

 Unlike Karn Units 3 and 4, the coal-fired units on site produce so much ash that soot blower 

operation is necessary to maintain efficiency. The coal ash that collects on the water wall and 

steam tubes affects the heat absorption rate. The soot blowers, which consist of rotating 

lances that eject compressed air, run frequently while the unit is operating to remove the ash 

off the wall and tubes. Air pollution control is not an issue, as would be with Karn Units 3 

and 4, because the coal-fired units are equipped with ESPs. Water lances are also used while 

the unit is operating, but less frequently, to clean the water wall/tubes of the coal-fired 

boilers. Water from this operation immediately evaporates. 

 Karn/Weadock stated that the Karn Units 1 and 2 boilers are chemically cleaned every seven 

years. Thermal evaporation of the metal cleaning waste is preferred by the plant, but the 

waste can be treated for discharge. 

 Karn/Weadock operates two chemical treatment ponds systems on site, one for Karn and one 

for Weadock. The metal cleaning wastes are treated, transferred to the respective ash ponds, 

and ultimately discharged via Outfall 001A in compliance with the terms and conditions of 

the NPDES permit. 

 Plant personnel stated that treatment depends on the type of waste entering the chemical 

treatment site. Typically the process focuses on settling out iron and copper so that limits are 

met prior to transfer to the ash ponds. [QUESTION FOR KARN/WEADOCK : What types 

of metal cleaning wastes are treated in the “chemical treatment facilities”, how often are they 

generated/transferred, and how much is generated/transferred?] Karn and Weadock Unit 

boiler cleaning waste steam consists of boiler metal cleaning waste (typical metals, minute 

amount of EDTA, Fe and Cu) plus initial rinse water. Cleanings are typically performed on 

each boiler once every 5-7 years. Karn Unit 1 has been treated once since 2000 using K CTF; 

Unit 2 last treated using K CTF in 2004; CTF waste stream was treated to NPDES standards 

before mixing w/ other waste streams in ash pond. Untit 2 treatment total volume was 

approximately 140,000 gallons. Unit 1 total volume 90,000 gallons. Weadock Unit 7 has 

been treated twice since 2000, last treated in 2007 using same process in W CTF ; total 

volume 70,000 gallons. W Unit 8 has only been treated once since 2000 using the same CTF 

process; total volume 70,000 gallons. 
 Table 1. Site Visit Attendees 

Name Organization (Representing) Telephone E-Rick Hall CECO KW Environmental (989) 891-3464 rghall@cmseneGary Dawson CECO LWM Corp (517) 788-2432 gadawson@cmJR Register CECO LWM Corp Not provided Not provided Jenny Crawford CECO LWM Corp (517) 788-1469 jacrawford@cmDave Marshall CECO, Site Ash Handling Supervisor Not provided Not provided Dave Walter CECO, Karn 1&2 Production Lead Not provided Not provided Butch Braun CECO KW Dry Fly Ash System Engineer Not provided Not provided Jim Lalonde CECO, Karn 1&2 Production Engineer Not provided Not provided Roberto Falco CECO, Results Supervisor Not provided Not provided Dennis Dobbs CECO, Site Business Manager Not provided Not provided Larry Dewitt CECO, Site Production Manager Not provided Not provided Donna Hill UWAG/Southern Co. (205) 257-5234 dbhill@southerRon Jordan EPA/Office of Water (202) 566-1003 jordan.ronald@Jezebele AliceaVirella EPA/Office of Water (202) 566-1755 alicea.jezebele@Sarah Holman ERG (Contractor to EPA) (703) 633-1661 sarah.holman@Elizabeth Sabol ERG (Contractor to EPA) (703) 633-1659 elizabeth.sabol@