Project No.: 0172.09.029.043 DISTRIBUTION Page _1 _ of __2

_ Project Name: Steam Electric Rulemaking TELEPHONE CALL RECORD Outgoing Call Date: 4/21/2011 Time: 10:30 AM

Company Name: United Conveyer Corporation (UCC) Contact Name: Kevin McDonough Phone No.: 847-473-5900 ext. 350 Name: EPA and ERG (See Below) GENERAL SUBJECT : Conversion from Wet to Dry Ash Handling Systems – Fly and Bottom

TOPICS DISCUSSED AND ACTION TAKEN On November 8, 2010, ERG sent an e-mail to Kevin McDonough (see DCN SE02018) requesting information on wet to dry fly/bottom ash handling conversions including equipment, operations, capital costs, and operation costs. Mr. McDonough responded to the e-mail request on April 13, 2011 (see the attached responses below, UCC Ash Handling Response). Based on the response, ERG, EPA, and UCC participated in a conference call to ask follow up questions on the information provided on April 21, 2011. A list of participants on the call is provided below:
EPA Ron Jordan Jezebele Alicea-Virella
UCC Kevin McDonough Mike Kipnis
ERG TJ Finseth Elizabeth Sabol
Notes: UCC stated with new generating units, the mechanical drag system (MDS) is more cost effective than the wet sluicing system. They explained that the majority of the new systems installed are MDS or completely dry mechanical systems. However, UCC mentioned that for existing unit, and existing infrastructure, these conversions can be difficult based on space constraints. UCC stated that plants are considering a remote MDS rather than installing a completely dry system, which requires the replacement of the wet hopper with a dry hopper. UCC also stated that these dry systems (particularly the pipelines from the boiler to dry bottom ash silos) are more expensive than the remote MDS alternative. UCC stated that the costs for the remote MDS are comparable to the MDS conversions, maybe slightly more expensive. UCC stated that there savings associated with remote MDS conversions at plants where there are multiple units. At these plants, one remote MDS is desi gned to handle bottom ash from multiple generatingunits (referred to as multiple unit synergies). UCC stated that there is an overwhelming response to these systems because it does not require any boiler work or extended outages. UCC confirmed that no plants were currently operating a remote MDS; however, a handful of plants were looking into the option. UCC explained that the size of the remote MDS is based on the existing sluice flow rate, ash generation, and pipeline size of the wet handling system. UCC stated that flow rate is generally a function of ash generation (in tph) and the distance the bottom ash is conveyed. Next, complete recycle systems, particularly chemical treatment for recycle systems, were discussed. UCC explained that the closed loop system consumes water (moisture content or removed bottom ash). UCC mentioned that chemical additional is not currently being utilized in any of their systems and pH control is only used in a minimal amount of systems to reduce scaling. For fly ash, UCC estimates that 66 percent of the handling systems in the industry are already dry. Additionally, all new installations are mechanical exhausters (no hydrovacs for wet pneumatic systems). Finally, EPA, ERG, and UCC discussed the timing for the proposed rulemaking. UCC stated that it may take approximately six years to complete fly ash handling conversions to the remaining wet fly ash sluicing systems in the industry. UCC provided the estimate considering the outage time, time for piping and getting control systems up and running, and pre-outage time, which includes the set up of the filter separator and all other piping/silo equipment. UCC stated that completing bottom ash handling conversions for the entire industry would likely take longer (approximately seven years) because of the large number of bottom ash wet sluicing systems requiring conversion. UCC stated that it would be a challenging timeframe for completion. Additionally, UCC stated that because the remote MDS and complete recycle systems do not require any outages, so they may be more attractive conversion options for the industry. After the call, ERG delivered a request for more information, particularly cost data, for bottom and fly ash handling conversions. Please find the additional requests and UCC responses in the attachments provided below. The attachments to this telecon include: 1. Email from Kevin McDonough, UCC on April 13, 2011 delivering UCC’s response to EPA’s ash request November 8, 2010. 2. PDF attachment to the email from Kevin McDonough on April 13, 2011 providing UCC’s responses to EPA’s ash request. 3. Email from Kevin McDonough, UCC on May 10, 2011 delivering UCC’s response to follow up questions from the teleconference held April 13, 2011. 4. Attachment to the email from Kevin McDonough on May 10, 2011 providing UCC’s responses to EPA’s follow up requests.From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] Sent: Wednesday, March 30, 2011 2:25 PM To: McDonough, Kevin Cc: Alicea.Jezebele@epa.gov; jordan.ronald@epa.gov; Deborah Bartram Subject: RE: Ash Information for EPA Steam ELGs Kevin, As previously discussed, EPA is still requesting the ash handling cost information sent in November 2010. In an effort to move forward with our cost methodology, we've prepared a prioritized list of the information that is necessary for our analysis. Please provide infor mation you have on the following subjects as soon as it is available, regardless if some of the other information isn't pulled together. 1. Fly ash conversion costs (capital and O&M) for dry vacuum systems based on conveyance distance and capacity (tons per hour (T PH) of fly ash); 2. Fly ash conversion costs (capital and O&M) for combination vacuum/pressure systems based on conveyance distance and capacity (TPH of fly ash); 3. Silo costs (capital and O&M) based on tons of fly ash; 4. Bottom ash conversion costs (capital and O&M) for mechanical drag systems based on TPH of bottom ash; and 5. Bottom ash conversion costs (capital and O&M) for a dry vacuum system based on TPH of bottom ash. Please provide this information as quickly as possible. Please call me directly if you have any questions (703 - 633 -1659). Thanks, Elizabeth

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com<mailto:elizabeth.sabol@erg.com> Phone:703-633-1659
From: "McDonough, Kevin" <KevinMcDonough@unitedconveyor.com> To: Elizabeth Sabol <Elizabeth.Sabol@erg.com> CC: "Alicea.Jezebele@epa.gov" <Alicea.Jezebele@epa.gov>, "jordan.ronald@epa.gov" <jordan.ronald@epa.gov>, Deborah Bartram <Deborah.Bartram@erg.com>, "Kipnis, Michael" <MichaelKipnis@unitedconveyor.com>, "Long, Gerald" <GeraldLong@unitedconveyor.com> Date: 4/13/2011 1:07 PM Subject: RE: Ash Information for EPA Steam ELGs Attachments: EPA UCC_Ash Handling Attachment 041311.pdf Elizabeth, Draft attached. After you have had a chance to review, we are available for a conference call to discuss. Kevin L. McDonough Director, Sales - Americas United Conveyor Corporation 2100 Norman Drive West Waukegan, IL 60085-6753 Phone: 847-473-5900 ext.350 Fax: 847-473-5959 Email: kevinmcdonough@unitedconveyor.com<mailto:kevinmcdonough@unitedconveyorsupply.com> Website: www.unitedconveyor.com<http://Website:%20www.unitedconveyor.com>

________________________________ This electronic mail message and any attached files contain information intended for the exclusive use of the individual or ent ity to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or exempt from disclosure under applica ble law. If you are not the intended recipient, you are strictly prohibited from disclosing, copying, distributing or using any of this information . If you received this communication in error, please contact the sender immediately and destroy the material in its entirety.Page 1 Introduction EPA is currently developing a methodology to estimate the cost of conversions from wet to dry fly ash handling and the installation/conversion of bottom ash handling systems with systems that do not discharge sluice water. Below please find a brief overview of this methodology and a list of questions/cost requests that will assist EPA is further developing this methodology. Cost Methodology Background Fly Ash Conversion EPA is developing a methodology that will estimate costs associated with the conversion from wet to dry fly ash handling at coal-fired power plants. The methodology will account for costs associated with the conveyance, intermediate storage, and transport/disposal portions of the fly ash handling system. This component-level approach to the ash handling system mirrors how EPA requested cost information in the questionnaire. The four dry fly ash handling systems that EPA is evaluating include:

Wet vacuum (pneumatic): System retrofit that utilizes the existing wet vacuum exhauster to pull vacuum for the dry system;
Dry Vacuum: System that uses a mechanical exhauster to move air to entrain and convey dry fly ash particles (ideal for short distances);
Pressure: Pressurized system that uses air produced by a positive displacement blower to convey ash to a certain destination (ideal for longer distances); and
Combination vacuum/pressure: System that utilizes the vacuum equipment underneath the hoppers to transport fly ash by vacuum to a transfer station, where it is introduced to positive pressure and transported longer distances. The methodology will evaluate the existing ash handling system, as well as the conveyance distance and ash capacity associated with each plant to determine the most appropriate dry fly ash handling system to be installed.
Bottom Ash Conversion/Installation EPA is developing a methodology that will estimate the costs for bottom ash handling system conversions and new installations. The bottom ash handling methodology will account for costs associated with the conveyance, intermediate storage, and transport/disposal portions of the bottom ash handling system. The three bottom ash handling systems that EPA is evaluating include:Page 2Complete Recycle System: Bottom ash system that utilizes dewatering bins and corresponding tanks to recycle all sluice water back to the system (Note: this system is a closed complete recycle system and does not include the use of ponds);
Mechanical Drag System: Drag chain system that works on an incline to pull bottom ash from the quench water underneath the boiler to an intermediate or final storage destination;
Pneumatic Handling Systems: Dry bottom ash handling system that grinds up bottom ash at the bottom of the hopper and transfers it pneumatically to an intermediate or final storage destination.
Vibratory Handling Systems: Dry bottom ash handling system that grinds up bottom ash at the bottom of the hopper and transfers it by vibratory motion to an intermediate or final storage destination. Questions Regarding Fly and Bottom Ash System Operations and Costs In order to properly develop the methodology to evaluate the installation and conversion costs for the industry, EPA would like to request system-level operating and cost information from you. Please respond to the following questions below to ensure that the cost model reflects appropriate information/costs. General Fly Ash System Design Characterization 1. Please provide your estimate for the maximum capacity (tons/hour) and maximum distance that should be assumed for wet vacuum (pneumatic), dry vacuum, pressure, and combination vacuum/pressure systems.

WetVacuum(Pneumatic)System:Awetvacuumsystemessentiallyhasthesamecapacitycapabilitiesasadryvacuumsystemeventhoughthewetvacuumsystemcouldtechnicallyoperateataslightlyhighervacuum.WaterpoweredHydroveyorExhausterscangenerateslightlyhighervacuumlevelsthantypicaldryvacuumgenerators(e.g.MechanicalExhausters,VacuumPumps).Attheseelevatedvacuumlevels,theincreasedcapacityismarginal.DryVacuumSystem:o Upto90tons/hratadistanceof200300fto Approximately30to50tons/hratdist ancesupto15001600ftPressureSystem:o Upto200tons/hratdistances upto30004000ft.o Pneumaticconveyingdistancescanreach50008000ft,butatreducedconveyingcapacity.Page 3CombinationVacuum/PressureSystem:Sameasinformationnotedabove,withproportionaladjustmenttodistancewithcombinationsystem.AcombinationVacuum/VacuumSystemisalsotechnicallypossible,butwouldbelimitedincapacityanddistanceconsistentwiththemaximumvaluesabove.Seechartbelowforreference.Figure1.FlyAshConveyingSystemPerformanceConsiderations(Note:confidential/proprietaryinformationnotfordistribution)2. When evaluating the conversion of an ash handling system from wet to dry, are there any circumstances that specifically require the installation of a pressure fly ash handling system (e.g., capacity requirement exceeds maximum capacity of vacuum or combination vacuum/pressure systems)?

WearenotawareofanycircumstancesthatwouldrequireaPositivePressureFlyAshConveyingSysteminlieuofaCombinationVacuum/PressureSystem.TheconveyingdistanceandcapacityprovidedbyaCombinationVacuum/PressureSystemwillmatchthatofastraightPressureSystem.However,ifaparticularinstallationrequiresthattheintermediateashstoragesilocannotbelocatedneartheboilerhouse(largelyduetoavailablephysicalspaceneartheAQCequipment),orifincreasedcapacityisnecessarytoproperlyaccountforelevatedash[REDACTED - Confidential Business Information]Page 4generation,thentheonlytechnicalalternativesarethePositivePressureFlyAshConveyingSystemoraCombinationVacuum/PressureSystem.Avacuumsystemalonecannotprovideforelevatedcapacitiesorextendedconveyingdistances.3. Is there a type of dry ash handling system typically used to retrofit existing power plants? If yes, what about that particular system makes it preferable (e.g., ease of installation, capital, O&M)?

Inmostcases,awetvacuumconveyingsystemisreplacedbydryvacuumsystem.IftheplanthasavailablespaceneartheAQCequipment,anintermediateashstoragesilocanbeaddedwithseparating/filtrationequipmentandconditioning/unloadingequipment.Inthisscenario,muchoftheexistingequipmentdirectlyunderneaththeAQCequipment(ashintakes,piping,valves,supports,etc.)canremaininplacemakingitmoreeconomicalthanacompletesystemreplacement.Inaddition,O&Mcostsforavacuumconveyingsystemaremoreeconomicalthantheothertechnicalalternatives.4. For each dry fly ash system, what is the typical length of outage required for the installation (or conversion to) the system?

46weeksifallequipmentbeneaththe AQCequipmentcanberetained.Ifthisequipmentisreplaced,theoutagecanextendto812weeks.If known, what is the typical outage per year associated with scheduled and unscheduled maintenance of each type of dry fly ash system conversion?

Normalashhandlingsystemmaintenancedoesnotrequirea”scheduled”outage.Mostwearcomponentscanbereplacedwhiletheunitisoperating.UCCengineeringguidelinesprovideforconveyingcapacitiesthatallowformaintenancewindows(e.g.approximately4hoursforevery8hourshift).Inaddition,mostsystemdesignsincorporatesufficientredundancythatprovidesforadditionalmaintenancewindowswhilemaintainingboileroperation.Can the conversion be implemented within normal scheduled maintenance outages, or must the maintenance outage be extended (and if so, for how long)?

Conversiontypicallycanbedoneduringnormalscheduledmaintenanceoutage.Page 5 5. Please describe how the design of the fly ash handling system would differ for a plant using petroleum coke instead of coal.

Petroleumcokehasareducedashconte ntthantypicalcoals.However,thetypeofashproducedhassomeofthecharacteristicsofashproducedwhenfiringwithoil(seebelow).Thepipediameterswouldtypicallybesmallerforapetcokefiredplantthanacoalfiredplantduetoreducedashquantities.Smalldensephaseconveyinglinescanbeusedinlieuofthetraditionalvacuumsystems.6. Please describe the type of fly ash handling equipment used for oil-fired boilers. Please describe how the design and operation differ from coal-fired fly ash handling equipment.

Currently,therearevacuumtypeandpressuretypesystemsinserviceforoilash.Thebestsystemforoilashapplicationisdensephasepressuresystem.Themaindifferencebetweenflyashsystemsandoilashsystemsisthatoilashsystemairmustbeheatedandsystemcomponents(pipe,airlocks,silos,etc.)mustbeheattracedandinsulated.Inaddition,thesystemmustberuncontinuously.Wehaveasayingsummarizingoilashsystem:“Keepithotandkeepitmoving”.Wet Vacuum (Pneumatic) Fly Ash Handling System Characterization 7. Please describe the prevalence of wet vacuum (pneumatic) fly ash handling systems in industry.

Historically,thevastmajorityofflyashconveyingsystemswerewetvacuum.Overthelast1525years,approximately2/3oftheU.S.fleetnowutilizesdryconveyingtechnologies.Theprimaryfactorsforwettodryconversionswereasfollows:o PRBFuelSwitchingInitiativeso DryScrubberAdditionso WaterAvailability/WastewaterTreatmento AshPondCapacity/IntegrityLimitationso AshMarketability/BeneficiationSomeinstallationsstillusewaterpoweredvacuumgenerators(HydroveyorExhausters)butseparatetheashpriortomixingwiththewater.What percent of new installations utilize wet vacuum systems?Page 6Nearlyallnewinstallationsinthelast1020yearshaveutilizeddryconveyingtechnologies.8. What equipment can typically be retained when converting from a wet fly ash handling (sluicing) to a wet vacuum (pneumatic) system?

Hopperisolationvalves,flyashintakes,branchlineconveyorpiping(assumingflyashsilosorvacuumpressuretransferstationscanbelocatedreasonablyclosetotheAQCequipment),andlineisolationvalvescanallberetained.Inaddition,theexistingwetvacuumexhausterscanberetainedasavacuumgeneratoraslongasthenewequipmentincludesfiltration/separationequipmentupstreamofthewetexhausters.What major equipment is required for conversion?

FlyAshSilosAshConditioning/UnloadingEquipmentatsiloVenting/FiltrationEquipmentatsiloAshFluidizingBlowersatsiloFilter/Separators(ontopofashsilos),or;Filter/SeparatorTransferStations(vacuum/pressuretransfersystem)PressureBlowers/Compressors(vacuum/pressuretransfersystem)PowerdistributionfornewequipmentControlsfornewequipment9. What equipment is required for conversion from wet vacuum (pneumatic) fly ash handling systems to dry vacuum fly ash handling systems?

Hopperisolationvalves,flyashintakes,branchlineconveyorpiping(assumingflyashsilosorvacuumpressuretransferstationscanbelocatedreasonablyclosetotheAQCequipment),andlineisolationvalvescanallberetained.Newequipmentincludesthefollowing.FlyAshSilosAshConditioning/UnloadingEquipmentatsiloVenting/FiltrationEquipmentatsiloAshFluidizingBlowersatsiloFilter/Separators(ontopofashsilos),or;Filter/SeparatorTransferStations(vacuum/pressuretransfersystem)MechanicalExhausters/VacuumPumps(fulldryconversion)PressureBlowers/Compressors(vacuum/pressuretransfersystem)PowerdistributionfornewequipmentPage 7Controlsfornewequipment10. Do wet vacuum (pneumatic) fly ash handling systems generate a waste stream? If yes, how much wastewater is typically generated? What is the wastewaters usual destination? What percent of fly ash becomes entrained in the water used to create the vacuum?

Wetvacuumsystems,withfiltration/separationequipmentupstreamofthewetvacuumgenerator,donotgenerateanappreciablewastestream.Thedesignefficiencyoftheashfiltration/separationequipmentremovesthemajorityoftheash(>99.9%)priortocomingintocontactwithwater.However,shouldaleakinthefiltermediaoccur,anyashleakingthroughwouldcomeintocontactwithwater.Typically,wastewaterisdischargedintoandwater/ashstoragepond.Theoretically,thewatercouldbecollectedinatemporarystoragetankandrecycledinaclosedloopsystem.Thishasbeenattemptedinthepastwithunsuccessfulresultsduetoheatbalanceissues,thoughitisstillatechnicalpossibility.However,mostinstallationshaveelectedtoconvertwetvacuumgeneratorstodryvacuumgeneratorsifdischargetoastoragepondisnolongeranoption.Lessthan0.1%oftheashbecomesentrainedinthewaterusedtocreatethevacuum.Page 8 General Bottom Ash System Characterization 11. Please describe the prevalence of pneumatic and vibratory bottom ash conveyance systems in industry. What percent of new installations utilize each? What percent of wet-to-dry conversions are pneumatic versus vibratory systems?

Inthelast25years,therehavebeennonewU.S.utilityplantswithPCboilersbuiltwitheitherpneumaticorvibratorytechnology.UCChasonlyrecentlyintroducedthevibratorytechnology.Inthatsametime,therehasonlybeen(1)newU.S.plantcontractedtoinstalla100%drybottomashsystem(mechanicalstainlesssteelbelttypeconveyor)anditisnotyetoperational.AllothernewPCboilerinstallationsarebasedonthesubmergeddragchaintechnology.ThreeutilityPCUnitshavebeenconvertedfromwetconveyingsystemstodrypneumaticconveyance.Manyoftheolder,industrialunitsutilizedrypneumaticconveyance.Theoverwhelmingmajority(>90%)stillutilizewetconveyancetoashstoragepondsordewateringsystem.12. Are there certain boilers that are una ble to be retrofitted with a pneumatic bottom ash conveyance system (e.g., older boilers)?

Inmostcases,existingbottomashsystemscanberetrofittedwithapneumaticsystem.However,thistypeofconversionrequiresremovingtheexistingbottomashhopperwithanewtypeofdryhopper.Duetotheuniquecharacteristicsofthedryhopperdesign(steeperminimumhopperangles),someinstallationsmaynotpossesssufficientverticalheadroomtoallowfortheconversion.Inaddition,thistechnologydoeshavesomelimitationsoncapacityandconveyingdistance.Asaresult,theplantmusthavephysicalspaceneartheboilerhouse(within200300ofthebottomashhopper)tolocateabottomashsiloorintermediateseparatingstation.13. For each dry bottom ash system, what is the typical length of outage required for the installation (or conversion to) the system?

Therearetwotypesofclosedrecirculationsystemsusedinthepowerindustry.Thetraditionalsystemusesmultiplereceivingandstoragevessels(DewateringBins)andthenSettlingandSurgeTanksinflowsequencetoclarifyandstorethewaterforreuse.ThenewerdesignsystemusesaremotelylocatedSubmergedFlightConveyorthatprovidesallthreefunctions(dewatering,settlingandsurge)intoasingleunit.Bothsystemscanbeconstructedwiththeboileronlineandcanbetiedintothesystemwithoutamandatoryoutage.SomecustomerswillplantomaketheconversionduringaplannedoutageifPage 9changestothewatersupplypipingarenecessitatedbyconversiontoaclosedlooprecirculationdesign(Higheroperatingpressure,constructionofanewdrainsystemintheplanttocollectoverflowwateranddrains,etc.).Thisoutageworkwouldnotnormallyrequiremorethanafewdaysandcanfitwithinthetypical2weekshortoutage.AretrofittoanSFCwouldtypicallyrequire48weeks.Drypneumaticandmechanicalbottomashsystemswouldtypicallyrequireaminimumof6weeksandtypicallycloserto8weeksforaretrofitconversion.Areducedschedulecanbeaccomplishedbyincorporatingmultipleshiftsandovertimelaborbuthigherinstallationcostswillbeincurred.TypeofConversion ApproximateOutageRequirementClosedLoopDewateringSystems(RemoteSFC’sorDewateringBins)02weeksSubmergedFlightConveyor68weeksPneumaticAshExtractor(PAX)68weeksVibratoryAshExtractor(VAX)68weeksIf known, what is the typical outage per year associated with scheduled and unscheduled maintenance of each type of dry bottom ash system conversion?

Noneofthesystemsinthemselveswillrequireanoutageforservice.Provisionsforonlinemaintenanceandstandbyequipmentareincorporatedintothesystemdesignsthatallowanyinternalmaintenancetobeperformedduringthenormallyscheduledboileroutages.14. Please describe how the design of the bottom ash handling system would differ for a plant using petroleum coke instead of coal.Page 10Petroleumcokehasaverylowashcontentsoifthereisabottomashhopper,itcanbesignificantlysmaller.Thetransportconveyorcanalsobedesignedatalowercapacityifoneisused.Seeresponsetoquestion15below.15. Please describe the type of bottom ash handling equipment used for oil-fired boilers. Please describe how the design and operation differ from coal-fired bottom ash handling equipment.

Oilfiredboilersmaynothavebottomashhandlingsystems.Thereisusuallyarectangularboxplacedbelowtheboilerandperiodically(every23months),theunitisshutdownandtheashescollectedareremovedviaamobilevacuumtruck.Complete Recycle Systems 16. For a complete recycle bottom ash handling system, do you include any costs associated with water treatment to prevent or eliminate the build up of dissolved solids? Please describe the type of treatment that is used to eliminate the build up of dissolved solids.

Completerecycle(closedloop)systemscanhaveachemicaldepositionofcalciumcarbonateifthefuelsourceishighincalcium.SomecustomersaddressthisduringtheirnormaloutagesandsomemayinjectacidtohelpadjustthepHofthewatertoreducematerialdeposition.Wearenotawareofanyothermeasurestoaddressdissolvedsolidsinclosed looprecirculationsystems.What costs are included in the installation and operation of a complete recycle system?

Additionalequipmentrequiredforcompleterecycle(closedloop)system:RemotelylocatedSubmergedFlight(dragchain)Conveyors,or;RemotelylocatedDewateringBins/Settling&SurgeTanksReturnWaterPumpsPipingandValvesPowerdistributionfornewequipmentControlsfornewequipmentPage 11 What water (make-up, cooling water, re-circ water) and power requirements are needed to operate the system?

Thereisminimalmakeupwaterrequirement(2040gpm/system)andtypicallynoneedforadditionalcoolingwater.Theoperatingpowerrequirementsvarywiththedistancetherecirculationequipmentisplacedfromthebottomashhopper.Itiscommontoneedconveyingpumpsproducing300350psigwatersupplytotheventurieducatorpumpsforatraditionalrecirculationsystemand250–300psigforaSFCrecirculationsystem.Atraditionalrecirculationsystemhas1015HPsludgereturnpumpsatboththesettlingandsurgetanks(noneneededforSFC.Silo Configuration 17. Please describe the process for sizing a silo for intermediate ash storage. Specifically, is each silo individually designed for a specific plant, or are there several standard silo designs selected from based on amount of ash generated?

Silosizingisbasedonashgenerationratesandcustomerspecificationfordesireddurationofashstorage.Silosaretypicallydesignedforaminimumof72hoursofstorage,whichaccommodatesanextendedweekend(3days)ofashstoragepriortounloadingandtransport,butisitnotuncommontosizethestoragesilosfora4daystorageperiodorlonger.18. What factors drive the number of silos installed at a facility? Are silos typically sized to hold one unit’s ash, or is a silo typically shared among multiple units that generate ash with similar characteristics?

Itisgoodengineeringpracticetouseapairofsilosformultipleunits.However,numerousplantshavehadasinglesiloservingmultipleunits.Customersnowrealizethatserviceonasiloservingmultipleunitsisalmostimpossibleasitwouldrequirethatallunitsbesimultaneouslyshutdowntodoanysilomaintenance.Anotherfactorfordeterminingthenumberofsilosisbasedontheashgenerationandnumberofdaysofstorage.Extremelylargesiloscanbemorecostlythan(2)smallersilos.19. What materials of construction are typically used for silos and how is the appropriate material of construction determined? Provide range of costs for typical materials of constructions for a typical silo.Page 12Smallersilos(2030ftindiameter)aremostcommonlymadeofsteelandareofweldedconstruction.Largersilos(>30ftindiameter)aretypicallyofweldedsteelconstructionormadeofconcrete.Boltedsilosarealsoutilizedbutarelesscommon.Theinstalledcostofconcretesilosaretypicallylowerby30%to75%thansteelweldedsilos.Thepricedifferencedependsonsilosize;thelargerthesilo,themorefavorablethepricedifferenceinfavorofconcrete.Typically,thecostofboltedsilosarelessthaneitherweldedsteelorconcretesilosbutrequiresubstantiallymoremaintenanceandhavesomedesignlimitations.Costs for Fly and Bottom Ash Handling Systems EPA is seeking system-level cost information for wet to dry fly ash handling conversions and bottom ash handling conversions/installations. EPA would like to obtain these costs broken out for the conveyance portion of the system (e.g., from the hopper to intermediate storage) and the intermediate storage portion of the system (e.g., silo). EPA is aware that cost varies greatly depending on boiler configuration, capacity, conveyance distance, and number of units. For the purposes of providing cost data, please assume average industry operating conditions and no special circumstances (e.g., headroom below the boiler). In order for us to properly evaluate the cost data, please provide the list of variables and assumptions used during the development.

UCChasprovidedapproximatecostdatabelowbasedonrecentprojectandproposalactivity.Severalkeyvariablescanalsogreatlyimpacttotalprojectcost: o #ofUnitso AvailableSpaceforNewEquipmentandConstructionAccesso DistanceofConveyingSystem/Equipment(silolocation/dewateringequipmentlocation/etc.)o PowerAvailabilityo Geotechnical/FoundationIssueso PondClosureand/orLandfillDevelopmentCosts(notincludedbelow)Page 13 Fly Ash Please provide capital and O&M cost curves for fly ash conveyance (please do not include silo costs), based on tons per hour (tph) of fly ash, for the following conversion types:

Conversion from wet sluicing to wet vacuum system;
Conversion from wet sluicing to dry vacuum system;
Conversion from wet sluicing to pressure system; and
Conversion from wet sluicing to combination vacuum pressure system.

TypeofConversion(assumes1unit@600MW) Approx.EquipmentCostApprox.InstallationCostWetSluicingtoWetVacuumSystem(assumeswaterwillbeclosedloop) $4M$812MWetSluicingtoDryVacuumSystem$4M$812MWetSluicingtoPressureSystemN/AN/AWetSluicingtoCombinationVacuumPressureSystem(installedcostaccountsformultiple(2)unitsynergies)$1015M$15$30MFlyAshO&MCosts:

Wearestillcompilingthisdata.Oneofthecomplicatingfactorsisthatmanywettodryflyashconversionswerenotsimpleconversions(removehydroveyors/addlocalsilos,filter/separators&exhausters,etc).ManywenttoVacuum/PressureTransferSystemsthataddedasecondconveyingsystemtomoveashfromtheboilerareatoremotesilos,whichaddmorecomponentsandhorsepower.Moretimewillberequiredtocompileandpresenttrulyaccuratedata.KeyVariables:

RemoveHighPressureWaterSupplyPumps(approx.200HP)forHydoveyorExhaustersAddMechanicalExhaustersforVacuumGener ation(approx.75150HP)AddFilter/Separators,TransferValves,Line& BinIsolationValves,VentValves,Etc.AddFluidizingBlowers(approx.5075HP)AddAshConditioners/Unloaders(approx.4060HP)Page 14 Bottom Ash Please provide capital and O&M cost curves for bottom ash conveyance (please do not include silo costs), based on tph of bottom ash, for the following installations or conversion types:

Conversion from wet sluicing to mechanical drag system;
Conversion from wet sluicing to pneumatic system;
Conversion from wet sluicing to vibratory system;
Conversion from wet sluicing to a dewatering bin system with complete recycle (including dewatering bin, surge tank, and settling tanks costs);
Installation costs for mechanical drag systems;
Installation costs for pneumatic systems; and
Installation costs for vibratory systems.

TypeofConversion(assumes1unit@600MW)Approx.EquipmentCostApprox.InstallationCost Approx.O&MCostsWetSluicingtoMechanicalDragSystem$23M$57M$250/MWYRWetSluicingtoPneumaticSystem $45M$810MTBDWetSluicingtoVibratorySystem $56M$1012MTBDWetSluicingtoDewateringBinSystem(canaccommodatemultipleunits)$67M$1012M$9501,100/MWYRWetSluicingtoRemoteSFCSystem(canaccommodatemultipleunits)$34M$48M$800950/MWYRKeyConsiderations:

WetSluicingtoMechanicalDragSystem:Sensitivetoboileraccessandconfigurationandamountofdemolition.Requiredoutagetimeisalsoasignificantfactor.WetSluicingtoPneumaticSystem:SensitivetofinallocationofBottomAshStorageSilo(s)andMultipleUnitSynergies.Requiredoutagetimeisalsoasignificantfactor.WetSluicingtoVibratorySystem:SensitivetofinallocationofBottomAshStorageSilo(s)andboileraccess.Requiredoutagetimeisalsoasignificantfactor.Page 15WetSluicingtoDewateringBinSystem:Sensitivetoavailablespacenearboilerhouseandlengthofclosedloopsluiceconveyingsystem.Outageconsiderationsmakethisveryfavorable.WetSluicingtoRemoteSFCSystem:Sensitivetoavailablespacenearboilerhouseandlengthofclosedloopsluiceconveyingsystem.OutageconsiderationsmakethisveryfavorableIntermediate Storage Please provide the following data for silos:

Silo cost curves (capital and O&M) as a function of capacity (please provide separate silo capital cost curves for typical materials of constructions used). Please assume that the silo has both wet and dry loading capabilities.

TypeofConversion(assumes1unit@600MWandConcrete/SteelWeldedSilos) Approx.SiloInstalledCostWetSluicingtoWetVacuumSystem$23MWetSluicingtoDryVacuumSystem$23MWetSluicingtoPressureSystemN/AWetSluicingtoCombinationVacuumPressureSystem$56MPlease include a detailed list of components included for each system level cost curve provided. Also, please provide an explanation of any underlying assumptions made while developing the cost curves (i.e., if outage time or maintenance time was factored in the price).

Informationnotpresentlyavailable.Page 16 Petroleum Coke-Fired Fly Ash and Bottom Ash Costs Please provide capital and O&M cost curves for fly ash and bottom ash handling systems associated with the handling of ash from petroleum coke-fired units, if different than coal-fired units. Please provide cost curves with the same details that are included in the request above.

Informationnotpresentlyavailable.Oil-Fired Fly Ash and Bottom Ash Costs Please provide capital and O&M cost curves for fly ash and bottom ash handling systems associated with the handling of ash from oil-fired units. Please provide cost curves with the same details that are included in the request above.

Informationnotpresentlyavailable.From: Alicea.Jezebele@epamail.epa.gov [ mailto:Alicea.Jezebele@epamail.epa.gov] Sent: Monday, April 25, 2011 4:22 PM To: McDonough, Kevin Subject: Action Items-EPA Call with UCC Importance: High
Kevin, Thank you again for helping put together the conference call last Thursday, April 21, 2011, to discuss the costs associated with ash handling technologies. It was a very helpful meeting for us to better understand how these systems work and to give context to the information that you provided previously. Based on the call, a list of action items that we discussed during the meeting is included in the document attached. Please note that these action items are listed in priority order. We would appreciate if you could provide us the information from the action items no later than Monday, May 9th, 2011, which is two weeks from today. However, feel free to send us the information piecemeal if you are able to put some of it together before May 9th. Please let me know if you have any questions. I look forward to hearing from you. Sincerely, Jezebele Alicea-Virella
From: McDonough, Kevin Sent: Thursday, April 28, 2011 8:42 AM To: Kipnis, Michael Subject: FW: Action Items-EPA Call with UCC Importance: High Mike, Please review the attached document. I’d like you to lead this effort. Kevin L. McDonough Director, Sales - Americas United Conveyor Corporation 2100 Norman Drive West Waukegan, IL 60085-6753 Phone: 847-473-5900 ext.350 Fax: 847-473-5959 Email: kevinmcdonough@unitedconveyor.com Website: www.unitedconveyor.com

-----"Kipnis, Michael" <MichaelKipnis@unitedconveyor.com> wrote: ----- To: Jezebele Alicea/DC/USEPA/US@EPA From: "Kipnis, Michael" <MichaelKipnis@unitedconveyor.com> Date: 05/06/2011 10:11AM Subject: RE: Action Items-EPA Call with UCC Jezebele, I want to make sure that you really want the price information on steel silos? If you recall we originally suggested to use concrete silos as most economical option specially for larger silo sizes. Michael Kipnis 1 847 473 5900 ext. 430From: Alicea.Jezebele@epamail.epa.gov [ mailto:Alicea.Jezebele@epamail.epa.gov] Sent: Monday, May 09, 2011 9:05 AM To: Kipnis, Michael Subject: RE: Action Items-EPA Call with UCC Importance: High Yes, we are interested on price information on steel silos. You can include information about concrete silos too if this won't delay the delivery date of the information requested by us. Also, I take the opportunity to check the status on delivering the information requested. Your prompt response will be highly appreciated, as you may know our contractor are in great need of this information to keep moving forward with the cost estimate for ash handling without delaying our schedule. Thanks in advance for your help and time. Looking forward to hear from you. Sincerely, Jezebele Alicea
From: Kipnis, Michael Sent: Monday, May 09, 2011 4:04 PM To: 'Alicea.Jezebele@epamail.epa.gov' Cc: McDonough, Kevin Subject: RE: Action Items-EPA Call with UCC Jezebele, Sorry for delay, but it may take us extra day or two to complete. Michael Kipnis
From:"Kipnis, Michael" <MichaelKipnis@unitedconveyor.com> To:Jezebele Alicea/DC/USEPA/US@EPA Cc:"Long, Gerald" <GeraldLong@unitedconveyor.com>, "McDonough, Kevin" <KevinMcDonough@unitedconveyor.com> Date:05/10/2011 12:34 PM Subject:Action Items-EPA Call with UCC

Jezebele, Please refer to the attached document addressing your questions. Give me a call if you need further clarifications. Regards, Michael Kipnis Manager, North American Sales 1 847 473 5900, ext 430 >>> <Alicea.Jezebele@epamail.epa.gov> 5/10/2011 3:03 PM >>> Hi,
Please let me know if you have any questions or concerns that need to be addressed back to Kevin. Thanks! (See attached file: EPA.docx) (Embedded image moved to file: pic05035.jpg) ----- Forwarded by Jezebele Alicea/DC/USEPA/US on 05/10/2011 03:01 PMThis electronic mail message and any attached files contain information intended for the exclusive use of the individual or entity to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are strictly prohibited from disclosing, copying, distributing or using any of this information. If you received this communication in error, please contact the sender immediately and destroy the material in its entirety.

This electronic mail message and any attached files contain information intended for the exclusive use of the individual or entity to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are strictly prohibited from disclosing, copying, distributing or using any of this information. If you received this communication in error, please contact the sender immediately and destroy the material in its entirety.Please note that these action items are listed in priority order.
Bottom Ash 1. Please provide capital costs (equipment and installation), O&M, and a detailed list of any assumptions and pieces of equipment included in the costs for the following conversions: a) Conversion from Wet Sluicing to Submerged Flight Conveyor (SFC) based on bottom ash generation rate in tons per hour (tph) for one generating unit; and b) Conversion from Wet Sluicing to Remote SFC based on wet sluicing flowrates in gallons per minute (gpm). Assumptions: -system type: remote SFC w/ closed loop recirculation system -bottom ash generation rate: up to 8tph (most of the power plants) -location of remote SFC: up to 700-800ft List of major equipment: -(1) remote SFC including Hydraulic Power Unit (HPU) -(2) Pumps supplying water for Jetpulsion Pumps -(2) Pumps supplying water to Bottom Ash Hopper -(2) Pumps for overflow from Bottom Ash Hopper -(2) sump pumps -(1) overflow tank -10” conveying pipe , water pipe, pipe supports, valves, etc. -instruments, controls, MCC System and assumptions as described above shall cover vast majority of the utility size units. Approximate price for above system/scope is $2,500,000-$3,500,000 Approximate price for installation and BOP scope: $5,000,000-$7,000,000. BOP design and supply scope includes civil/foundation, buildings, pipe racks, power cables, field wire, trays, etc.) “Deviations” from above assumptions will result in the following cost impact:

-conveying line diameter increase from 10” to 12” which will result in larger SFC, pumps, motors, etc. Price adder for equipment scope is approx. $300,000. Price adder for installation/BOP scope is approx. $300,000 -conveying distance increase beyond 700-800ft. This would require a set of additional High Pressure Pumps so that two pumps will operate in series to produce required head. Price adderfor pumps, motors, MCC, etc. is approx. $300,000 Price adder for installation/BOP scope is $500,000 2. Please also provide the frequency and cost for the drag chain replacement. Please provide the cost as a function of ash generation rate. The service life of the chain in general depends on the following factors( and not only a function of ash generation rate): -ash characteristics: abrasive ash (eas tern) vs less abrasive (PRB). Depending on the ash characteristics the service life of chain may fluctuate from 2-3 years up 4-6 years -ash generation rate: in general th e higher the ash generation rate the higher chain speed and the chain wear/service life is the function of the chain speed -mode of operation continuous vs intermittent The cost of replacing chain and some worn out components (L&M) is $150,000-$200,000 Fly Ash Please provide capital costs (equipment and installation), O&M, and a detailed list of any assumptions and pieces of equipment included in the costs for the following conversions: a) Conversion from Wet Sluicing to Dry Vacuum based on fly ash generation rates in tph (please note any assumptions made to calculate fly ash conveyance rate based on fly ash generation rate); and Assumptions: -conveying distance: 300-400ft -ash generation rate: 20-25tph -conveying capacity: 40-50tph -silo stor age capacity: 72hrs of ash generation -silo construction: concrete (r efer to info below regarding steel vs concrete silos) List of Major Equipment : -(2)vacuum blower/motor(100-150HP/each) packages (1oper and 1 spare), -(2) Filter/Separators, bin vent filter, etc. - conveying pipe, air pipe, pipe supports, valves, etc. - (1) concrete silo - Silo fluidizing system (fluidizing elements, 2 blowers/motors (50-75HP/each), (1) air heaters (50-75KW), valves, etc. -silo unloading equipment (2 wet unloaders w/ 50HP motor) 1 dry spout) -instruments, controls, MCCCapital and Maintenance Cost Approximate price for above system/material scope is approx. $4,000,000. Estimated system maintenance cost: $150,000/year Approximate price for installation and BOP scope: $10,000,000. “Deviations” from above assumptions will result in the following cost impact: Price adder to supply 60-80tph system (instead of 40-50tph) is $1,000,000 Price adder to install 60-80tph system (instead of 40-50tph) is $1,500,000 Price deduct to supply 20-35tph system (instead of 40-50tph) is $1,000,000 Price deduct to install 20-35tph system (instead of 40-50tph) is $1,500,000

b) Conversion from Wet Sluicing to Combination Vacuum/Pressure based on fly ash generation rates in tph. Assumptions: -vacuum system conveying distance: 300ft -pressure system conveying distance: 3000ft -conveying capacity: 40-50tph -Filter/Separator Transfer stations to be utilized (not a surge bins) -silo stor age capacity: 72hrs of ash generation -silo construction: concrete (r efer to info below regarding steel vs concrete silos) List of Major Equipment : -(2)vacuum blower/motor(100-150HP) packages -(2) Filter/Separators Transfer Stations including Nuvafeeder Vessels - conveying pipe, air pipe, pipe supports, valves, etc. -(2) pressure blowers or air compressors/motor (500-600HP) packages - (1) concrete silo - Silo fluidizing system (fluidizing elements, 2 blowers/motors (50-75H)), 1 air heaters (50-75KW, ) valves, etc.) -silo unloading equipment (2 wet unloaders w/ 50HP motor, 1 dry spout) -instruments, controls, MCC Capital and Maintenance Cost Approximate price for above vacuum/pressure system/scope is approx. $12,000,000.Approximate price for installation and BOP scope: $24,000,000. Estimated system maintenance cost: $200,000/year

“Deviations” from above assumptions will result in the following cost impact: Price adder to supply 60-80tph system (instead of 40-50tph) is $3,000,000 Price adder to install 60-80tph system (instead of 40-50tph) is $5,000,000 Price deduct to supply 10-20tph system (instead of 40-50tph) is $2,000,000 Price deduct to install 10-20tph system (instead of 40-50tph) is $4,000,000 Price adder to supply 4000ft long pressure system (instead of 3000ft) is $1,500,000 Price adder to install 4000ft long pressure system (instead of 3000ft) is $3,000,000 Price deduct to supply 2000ft long pressure system (instead of 3000ft) is $1,500,000 Price deduct to install 2000ft long pressure system (instead of 3000ft) is $3,000,000

3. Please also provide capital (equipment and installation) costs and O&M costs as a function of the distance from the hoppers to the silo for both of the conversions identified above. Please refer to the answers above.
Silo Please provide capital costs (equipment and installation), O&M, and a detailed list of any assumptions and pieces of equipment included in the costs for the installation of a basic steel silo. Please include information used to size the silo (i.e., three days storage time, density). The price of the concrete silo and related equi pment was included in total ash handling system cost described above. Below is approximate break out price for the silo and silo fluidizing and unloading equipment. Key assumptions for silo sizing: Storage capacity: 72hr of ash generation Ash density for silo sizing: 45-50lb/ft3 Ash density for structural design: 90-120lb/ft3Ash Generation 72hr Silo Storage Capacity, Silo Diameter, ft Steel Silo, $$$ mil Steel silo Installed

Cost, $$$, Mil Concrete Silo, Installed,

$$$ mil Unloading and fluidizing equipment Design and Material, Installation Installed Cost $$$, mil 10-17 720-1224 25-30 0.6-1.0 0.4-0.7 1.0-1.5 0.9-1.5 0.8
20-25 1440-1800 30-38 1.1-1.3 0.8-1.0 1.9-2.3 1.4-1.8 1.0
30-40 2160-2880 38-45 2.4-1.8 1.3-1.7 2.7-3.5 2.0-2.6 1.3
For maintaining silo unloading and fluidizing equipment assume $20,000 cost/year for either silo size.

Additional Topics 4. Summary/factors of multiple unit synergies and corresponding plant savings for the remote SFC and the combination vacuum/pressure system. Multiple unit synergies examples, Remote SFC -single unit plant as a minimum should have (1) remote SFC. But it could be possible to design three or even four unit plant with two or three remote SFC potentially reducing system cost by 30% to 50%. Multiple unit synergies examples , Combination Vacuum/Pressure System -single unit plant as a minimum should have (1) Combination Vacuum/Pressure System But it could be possible to design two unit plant with two vacuum system but only with one pressure system (common for both units) potentially reducing system cost by 15% to 25%.

5. Please provide information on “typical” fly ash conveying times versus fly ash generation. B times.
Typical fly ash system is designed to convey at a rate equal to two (2) times of ash generation rate. 6. Please provide information on “typical” bottom ash conveying times versus bottom ash generation times.Typical bottom ash system utilizing jetpumps to convey ash from water impounded hopper is designed to operate 1-2hr per 8hr shift. In the beginning of the ash conveying cycle when hopper is full of ash conveying capac ity could be in range of 50t ph to 100tph. As ash quantity in the hopper is rapidly reduced so the ash conveying capacity. The remote SFC is designed to receive ash from the existing jetpump system at the above mentioned rate of 50tph to 100tph. But since remo te SFC has “surge c apacity” it is typically designed to convey/dewater ash at a rate of 2tph to 20tph 7. Summary of the types (i.e., operating engineer, engineering technician) and number of workers required to operate and maintain each type of system.

With the new Emerson systems, usually the unit operator is in the control room and runs the ash system as well as all the other equipment. If there is a local PLC then the AUO(axillary unit operator) will run the system. Besides the unit operator there is always an AUO assigned to the system should they need to go check something since the unit operator can’t leave the control room. Sometimes the AUO won’t be needed for weeks at a time and times when hoppers need to be poked or limit switches, or pressure switches are a problem they may be needed several hours a day. Most of the bottom ash systems are not automated so the unit operator turns on the booster pumps for the JP then the AUO pulls the bottom ash hopper(usually not longer than an hour) at the hopper locally. Most maintenance like bags, crushers and valves are replaced during outage unless it is an emergency. When maintenance like valve, fittings , pipe or jetpumps need to be replaced on line it usually takes a team of 3 about 3-4 hours. Typically the replacement of limit switches and solenoids are done by one electrician and takes less than one hour.