MEMORANDUM 

TO: Ron Jordan, EPA 

FROM: Kurt Blohm, ERG 

 Sarah Holman, ERG 

DATE: 6 January 2010 

SUBJECT: Notes from EPA Conference Call with Headwaters Resources 

On December 2, 2009, EPA’s Office of Water/Engineering and Analysis Division (OW/EAD) 

held a conference call with Headwaters Resources (Headwaters) to discuss the design and 

operation of dry ash handling systems at power plants and ash marketing. The following people 

participated in the conference call: 

EPA 

Ron Jordan 

Headwaters 

Mike Adams – Regional Vice President (Eastern United States) 

Tom Smoltz – Corporate Environmental Director 

Lance Staron – Capital Projects Manager 

Peter Fote – Director of Capital Projects 

ERG

Deb Bartram 

Kurt Blohm 

Sarah Holman 

This memorandum details the topics that were discussed during the call. 

EPA’s Introduction 

 EPA went over the main objectives of the conference call for the call participants 

and introduced the Steam Electric Effluent Guidelines (ELGs). 

 EPA stated that through communications with Headwaters, EPA hopes to 

understand Headwater’s role in ash handling and to better understand what is 

involved with wet-to-dry ash handling conversions at power plants, including the 

ash handling equipment that can be reused and the new equipment that is typically 

installed. 

 EPA stated that Headwaters can claim information discussed with or provided to 

EPA as confidential business information (CBI). Headwaters stated that being in 
Memorandum 

January 6, 2010 

Page 2 

the coal combustion product (CCP) business, they do need to be careful about 

their clients’ (power plants’) confidential information. EPA explained the 

Agency’s CBI handling procedures and how information may be made public, but 

only in an aggregated format that precludes the tying of information to certain 

plants or companies. 

Ash Handling Discussion 

 ERG asked Headwaters to give a brief introduction to their company, including 

information on all aspects of ash handling in which Headwaters is involved. 

Headwaters stated that they deal solely with CCP recycling and operate at over 

100 utility sites in the United States. The services they provide to plants include 

disposal and marketing of ash, and providing equipment to utilities to collect, 

store, or transport fly ash and bottom ash. Headwaters stated that they landfill 

approximately 20 million tons of CCP annually and that they market 50 percent of 

all fly ash used in the U.S. for concrete manufacturing. 

 Headwaters stated that power plants in need of ash management services will 

approach Headwaters to supply equipment, design ash handling systems 

(Headwaters’ capital projects group does the design), market/transport the ash, or 

all of these. Headwaters stated that power plants sometimes use a combination of 

Headwaters’ design and other vendors’ design for their ash handling systems. 

Headwaters stated that the installation of the dry ash handling system at DTE 

Energy’s Monroe Power Plant is an example of a situation in which Headwaters 

was contracted to design the fly ash handling system in addition to marketing the 

fly ash. Headwaters stated that they own and operate the entire dry fly ash 

handling and storage system at Monroe. Headwaters stated that Monroe has 

retained the ability to sluice the fly ash to the ash pond. Headwaters stated that 

the quality of the ash at Monroe is monitored approximately once every eight 

hours. 

 ERG inquired about the factors that affect the ash quality and marketability. 

Headwaters stated that each plant is unique and that ash quality depends on the 

efficiency of the plant and the type of coal burned. 

 Headwaters stated that they primarily deal with the storage, marketing and reuse 

of dry collected fly ash. Headwaters stated that in 90 to 95 percent of their 

projects, the power plant had already installed all or most of the dry fly ash 

handling equipment and Headwaters was contracted to manage the marketing 

and/or disposal of the fly ash. In some cases, Headwaters installs dry ash storage 

facilities (silos) for plants that have already installed dry fly ash collection 

equipment, or upgrades the fly ash handling equipment such as installing rail 

load-out equipment. Headwaters noted that each contract that they have with 

power plants explicitly lays out where the division line is regarding responsibility 

for the ash handling system. Typically, Headwaters’ area of responsibility begins 

at the silo and includes the loading equipment. At approximately 20 percent of 

the projects, the Headwaters area of responsibility also includes the transfer of ash 

from hoppers to the silo. 
Memorandum 

January 6, 2010 

Page 3 

 Headwaters stated that ash may be transported locally, or across large distances. 

Ash is typically transported by truck if the distance between the plant and the 

market is less than 100 miles, and by rail if the distance is greater than 100 miles. 

 EPA asked whether the cement industry is large enough to reuse all fly ash 

generated by power plants in the United States if the fly ash were classified as 

non-hazardous. Headwaters stated that the concrete industry would not be able to 

reuse all of the fly ash generating in the United States if it were classified as 

nonhazardous because not all fly ash would be of the appropriate quality for use 

in cement. Headwaters stated that another market for the reuse of fly ash, which is 

not as large as the concrete market, is cement production. 

 ERG asked Headwaters to identify the quality parameters affecting the ability of 

ash to be marketed. Headwaters stated that the quality requirements are different 

for each beneficial reuse market. Headwaters stated that the loss on ignition (LOI) 

of the ash (the amount of unburned carbon) negatively affects the ability of the 

ash to be used as a raw ingredient in concrete. Headwaters stated that fine (i.e. not 

coarse) ash is also desirable for use in concrete. Headwaters stated that the 

American Society for Testing and Materials (ASTM) standards ASTM C 618 and 

ASTM C 311 provide all acceptance criteria for fly ash used in concrete mixes. 

Headwaters stated that ash quality may fluctuate significantly at power plants 

depending on many factors. 

 Headwaters stated that some plants are turning to ash beneficiation as a way to 

increase the quality of the ash so that it may be marketed. Headwaters informed 

EPA of their two beneficiation technologies: one is a proprietary chemical that is 

added to the ash to coat the unburned carbon in the ash rendering it more suitable 

for use in concrete, and the other is a chemical that will neutralize the ammonia in 

the ash that is carried over from SCR/SNCR systems. 

 Headwaters stated that the two most common beneficiation technologies in the 

industry for reducing the LOI of the ash are electrostatic precipitation and carbon 

burn out. Electrostatic precipitation consists of separating the carbon in the fly ash 

from the mineral content by applying an electric field. Carbon burn out involves 

reburning the ash, which reduces the carbon content of the fly ash and produces 

heat that is reused to increase the overall thermodynamic efficiency of the plant. 

 ERG, asked how prevalent beneficiation technologies are in the coal-fired power 

generating industry currently. Headwaters stated that most beneficiation 

technologies are brand new and are not widely used, mainly due to the large 

capital investment required and the relatively long payback period. 

 EPA asked Headwaters to identify the power plants in the United States where all 

of Headwaters’ wet-to-dry conversions have taken place. Headwaters discussed 

the ash handling/wet-to-dry conversion projects that they have been involved with 

at four power plants: Miller (AL), Edwards (IL), Monroe (MI), and Schahfer (IN). 

At Miller, Headwaters was involved with the expansion of the dry system to 
Memorandum 

January 6, 2010 

Page 4 

increase the amount of dry fly ash produced. The conversion at Edwards 

consisted of installing an ash storage silo and ash transport piping. The Monroe 

conversion was not a complete wet-to-dry conversion because the storage silo 

does not have the ability to moisten the fly ash in preparation for storage in a 

landfill. 

 EPA asked Headwaters to describe the equipment changes necessary to convert a 

wet fly ash handling system to a dry system. EPA stated that this information will 

help ensure that EPA’s questionnaire obtains the information needed to predict 

the cost of wet-to-dry fly ash handling system conversions. Headwaters stated that 

most plants have rows of hoppers under the ESPs that collect the ash. Wet ash 

handling systems typically have wet vacuum equipment that pulls the ash into the 

sluice water. A wet-to-dry conversion typically involves tying in to the piping 

used to draw the ash into the wet system, and installing a new dry vacuum system, 

filter/separators, and pressure equipment used to blow the ash to storage silos. 

Headwaters noted that some plants retain the wet system in place as a backup in 

case the dry fly ash is unmarketable. 

 ERG asked if there is typically any redundancy designed into a dry ash handling 

system if a plant converts to a completely dry system and no wet system is used as 

a backup. Headwaters stated that incorporating redundancy into a dry system 

depends on the factor of safety desired by each plant. Headwaters stated that for 

redundancy plants may choose to add a backup vacuum pump, for example, or 

they may double the entire system. Additionally, a system with a high factor of 

safety would also allow for an increase in the capacity (horsepower) of the 

pressure equipment needed to blow the ash to storage silos. Headwaters stated 

that plants may install moisturizing equipment in their storage silos (and may 

have a separate silo) in case the fly ash becomes unmarketable and they need to 

landfill the fly ash. Headwaters noted that ash quality is tested before the ash 

enters the storage/loading silo. 

 ERG asked how the cost of transporting the ash increases as the distance the ash 

needs to be transported to storage silos increases. Headwaters stated that the cost 

of transporting the ash various distances is a major feature of their ash handling 

system designs and that this information is proprietary. 

 Headwaters stated that because the design of ash handling systems is complex and 

plant-specific, if they were to put together a system cost estimate right now (with 

no plant specifics), they would need to include a contingency of 50 percent (or 

more, as was mentioned by Headwaters later in the conversation). EPA asked 

Headwaters for input as to what the Agency can do to come up with a good cost 

estimate for wet-to-dry fly ash handling system conversions. 

 ERG asked Headwaters to identify the main factors that affect the cost of dry fly 

ash handling systems and the feasibility of converting from wet to dry fly ash 

handling. Headwaters provided the following factors: 
Memorandum 

January 6, 2010 

Page 5 

o Ash marketability – If ash cannot be marketed, it needs to be landfilled, 

and there are significant costs associated with landfill 

installation/operation. 

o Distance transported to storage – Increasing the distance the ash must be 

transferred from ESPs/hoppers to storage/loading silos increases the 

system costs. 

o Type/size of storage/loading silos – The type of silos depends on the 

markets to which the ash is sold. Silos range in costs depending on 

capacity and whether or not the ash needs to be handled completely dry, 

conditioned with water, or both. If a plant is located in a warm climate 

(e.g., Florida, where construction occurs all year), it would not need extra 

silo storage space to hold the ash temporarily during winter months; 

whereas in a cold climate, it would. 

o Plant efficiency – The efficiency of a plant can affect the consistency of 

the ash quality. 

o Landfill permitting costs – If a plant is not going to use an ash pond and 

cannot market the ash produced, it must dispose of it in a landfill, either in 

an on-site or commercial landfill. 

 EPA asked Headwaters about the effect that flue gas mercury control systems can 

have on fly ash, and noted some process options to prevent fly ash contamination, 

such as injecting activated carbon downstream of the ESP or in the latter stages of 

the ESP. Headwaters stated that the affect on the fly ash is plant-specific and 

depends on the type of activated carbon used, but that typically activated carbon 

injection precludes the use of fly ash for concrete. Headwaters stated that if the 

activated carbon is injected downstream of the ESP, that the fly ash marketability 

is not affected. Headwaters stated that they have no role associated with mercury 

control systems, other than to test fly ash to determine if it is marketable. EPA 

asked Headwaters about a possible new type of mercury control that reportedly 

doesn’t affect the marketability of ash to the concrete industry, and Headwaters 

stated that they are retaining their opinion until they have more information. 

 ERG asked Headwaters to describe a typical contract between Headwaters and a 

power plant and asked Headwaters to discuss who receives the revenue from 

marketing the ash. Headwaters stated that each contract that they have with power 

plants is unique, so there is not a “typical” contract. Headwaters explained that 

when they act as a marketing agent, they often are not paid by the plant, but they 

(Headwaters) receive the revenues for the sale of the ash. When they act as an ash 

disposal agent, they are often paid by the plant. When they act as a marketing and 

disposal agent, they may receive ash sale revenues and payment from the plant, 

but again, the contract conditions vary. 

 Headwaters stated that with the vast majority or their contracts with power plants, 

Headwaters is solely the byproducts recycler and they do not have any control 

over the types of coal that the plant burns or any coal changes that the plant 

makes, which may affect ash marketability. 
Memorandum 

January 6, 2010 

Page 6 

 EPA explained that the Steam Electric Information Collection Request (ICR) is 

currently in the 1st Federal Register Notice (FRN) public comment period and 

encouraged Headwaters to provide EPA with feedback on the draft questionnaire. 

Lance Staron, Headwaters stated that he is aware of the Steam Electric 

questionnaire and has reviewed Part C (Ash Handling) of the questionnaire. Mr. 

Staron stated that he would review Part C of the questionnaire in greater detail, 

circulate it within Headwaters, and provide EPA with comments. 

 ERG asked if Headwaters would be able to provide any engineering reports or 

studies from the ash handling projects they have been involved with. Headwaters 

stated that they do not have these types of reports/studies and that EPA would 

need to request these from the power plants. 

 EPA further explained that as part of the Steam Electric ELGs effort, EPA 

anticipates estimating costs for dry ash system installations and wet-to-dry ash 

handling conversions to assess potential ELGs options, and would appreciate 

Headwaters’ input to help EPA estimate the costs as accurately as possible. 

 EPA asked if Headwaters also designs dry bottom ash handling systems or 

markets dry bottom ash. Headwaters stated that they have not worked on dry 

bottom ash handling systems in a long time, but that they worked on a few bottom 

ash handling projects in the past.