Final Notes from Site Visit at Monongahela Power Company’s Fort Martin Steam Electric

Plant on February 4 , 2010

EPA conducted a site visit at Monongahela Power Company’s Fort Martin Steam Electric Plant (Fort Martin) located in Maidsville, WV on Thursday

, February 4 , 2010 to learn about the operations at the plant

, including the operation of the flue gas desulfurization ( FGD ) wastewater

treatment system

. Table 3 identifies the site visit participants. A water balance diagram for the plant is included as At tachment 1.

Plant Overview

• Fort Martin operates two coal

- fired electric generating units. Fort Martin was previously partially owned by Allegheny Energy Supply

. The table below contains some general information on the current operation of each steam ele ctric generating unit.

Table 1. Fort Martin Steam Electric Generating Units Operation

Unit Installation

Date Gross Net Capacity

(MW) Particulate

Control NOx Control SO 2 Control

1 1967 552 ESP SNCR*, low NO

x burners FGD (Nov 2009)

2 1968 552 ESP SNCR* , low NO

x burners FGD (Dec 2009)

* SNCR is not operated year round. The system o peration is driven by NO

x credits.

• On average, Fort Martin burned 2.7 million tons of coal per year from 1993

- 2009. Currently, Fort Martin burns a blend of 16

- 25% PRB and 75

- 85% bituminous

coal. The chloride content of the coal blend ranges from 0.06

- 0.15 % and the

sulfur content is approximately 2 percent . The FGD systems are designed for a coal sulfur content up to four percent . As soon as Fort Martin’s current contracts
wit h its coal suppliers end s , the plant will start purchasing the cheapest coal

available that still allows them to meet their air emission limits , which will likely be coal with a higher sulfur content.

• Fort Martin receives shipments of c oal via barge. The c oal pile runoff generated at the plant is transferred to the ash settling basin.

• Runoff fro m the limestone pile and the gypsum pile is collected in the pumping station, which transfers the runoff to the plant lagoons.

• The plant has around 13,000 acres o f land, but much of th e land is not flat enough

to build on.

• The plant operates two lined lagoons in series. Plant w astewater s are pumped to

the south lagoon . The overflow from the south lagoon flows to the north lagoon.

The north lagoon discharges to th e Monongahela River via outfall 002. ThePage 2

lagoons are dredged once a year , but the dredging is completed one at a time, to

ensure that at least one lagoon is operating at all times

. All plant wastewater other

than FGD wastewater goes to the ash settling bas ins and then to the lagoons. The wastewater associated with the FGD system is treated in the F GD wastewater
treatment system and then sent to the lagoons, bypassing the ash settling basins

.

• Ever since the plant began operating, Fort Martin has handle d all the fly ash dry

. As long as the fly ash has a loss on ignition ( LOI ) of less than 5%, t he plant sells the fly ash. Most of the fly ash goes to mine reclamation. Any f ly ash that cannot

be marketed is transferred to the plant’s on

- site landfill.

• Fort Mart in handles the b ottom ash using a wet system . Bottom ash is sluiced the plant sluices the bottom ash to hydrobins for dewatering

. O verflow from the hydrobins i s transferred to the ash settling basins and then to the lagoons. The plant uses c ooling tower bl owdown as bottom ash sluicing water. Fort Martin

sells all of the bottom ash. Some of the bottom ash is directly used for road grid.

The remainder of the bottom ash is transported to the landfill where Belmont screens it and hauls it away

.

• Fort Martin has an old landfill and a new portion of landfill. The new portion of

the landfill is double lined

, has a leachate collection system

, and a leak detection

system

. The old landfill also has a leachate collection system with four ponds surrounding the landfill . The leachate and runoff from both the old and new

p ortion of the landfill is transferred to the cooling towers. Fort Martin uses the

c ooling tower blowdown as ash sluice water. The wastewater produced from the

bottom ash sluicing process is transferred t o the ash settling basins and the lagoons. The new landfill was first lined with a layer of bottom ash. All g ypsum will be stored in the new lined portion of the landfill because t he plant is not allowed to put gypsum in the old landfill because it is not lined. Furthermore, Fort

Martin personnel state d that in West Virginia and Pennsylvania all newly

constructed landfills must be lin ed. The old landfill is nearing capacity, but has

not been closed.

• Fort Martin received a letter from R egion 3 from Andrew S eligman , who is part

of EPA’s Office of E nforcement, requiring the plant to monitor for total dissolved solids (TDS), sulf ates , chlorides, and conductivity daily for an 18

- month period. The plant is being required to sample their discharge to the Monongahe la River as well as take samples upstream and downstream of their discharge. The requirement was issued because of the high concentrations of TDS in the Monongahela River . Fort Martin is working on reducing the daily sampling requirement to one day a week from January to May and two days a week from June to December unless the conductivity is high and then the plant would be required to sample 5 days a week.Page 3

Flue Gas Desulfurization System

• A design mass balance of the Unit 1 FGD system at Fort Martin is i ncluded as

A ttach ment 2

.

• Fort Martin operates FGD systems on b oth units. Both FGD s are l imestone forced oxidation systems, which have two dual trays and five spray headers. Unit 1 was

manufactured by Combustion Engineering and U nit 2 was manufactured by

B abcock & Wilcox

.

• Fort Martin receives shipments of l imestone via barge. The limestone is unloaded and piled near the barge site. The plant keeps enough limestone on site to run at full power for 14 days. Fort Martin has two ball mills on site, one per un it , to
crush the limestone . The limestone slurry used in the FGD systems contain 25

- 28% solids.

• Fort Martin uses water from the Monongahela River as the source for m ake

- up water for the FGD system.

• Fort Martin blows down from the FGD scrubber based prima rily on the level of

solids. Once the solids concentration reaches 21% solids , the plant blows down to reduce the solid level to approximately 17 percent . Additionally, blowdown from the absorber helps the plant maintain a chloride s con centration in the ab sorber to

between 12,000 and 13,000 ppm. The system is designed for a chlorides

concentration of 12,500 ppm ; however, t he absorber can handle a max imum

chlorides concentration of 20,000 ppm, but other valves in the system can only handle 15,000 ppm.

• Blowd own from the absorbers typically lasts for 10 to 12 hours per blowdown

event . There is typically a break of 10

- 12 hours before the next blow down event

.

• Blowdown from the absorber is processed through two sets of primary hydrocyclone s (one per unit). The u nderflow from the primary hydrocyclones is

transferred to one of three vacuum belt filters to dewater the FGD gypsum . The

filtrate from the vacuum belt filter s goes to the reclaim tank. The overflow from the primary hydrocyclone s is either sent to the recl aim tank or to the secondary hydrocyclone s (one per unit). The overflow from the secondary hydrocyclone s (the FGD system purge stream) is sent to the FGD wastewater treatment system. The underflow from the secondary hydrocyclone s is sent to the reclaim tan k. Wastewater in the reclaim tank is recycled back to the absorber.

• The chloride s concentration in the absorber largely determines whether primary hydrocyclone overflow is transferred to the secondary hydrocyclone s or whether

it is transferred to the r eclaim tank and eventually transferred back to the

absorber. If the chlorides concentration in the absorber i s greater than 10,000 mg/L , then the plant sends the wastewater to the secondary hydrocyclones, but i f

the chlorides concentration is below 10,000 mg/L , then the plant sends thePage 4

wastewater to the reclaim tank and back to the absorber to further cycle up the chlorides in the system.

• All the gypsum produced by the plant is sent to the landfill via a covered pipe conveyor. Since the gypsum is not sold , Fort Martin does not wash the gypsum.
However, Fort Martin has all the equipment necessary to wash the gypsum,

should a market become available in the future. If Fort Martin were to begin washing gypsum, plant personnel stated that the wash water be hand led with the vacuum belt filter filtrate, which is transferred to the reclaim tank.

• T he secondary hydrocyclone overflow is typically transferred to the FGD
wastewater treatment system for four hours at a time. The plant blows down each

unit at different t imes.

• There are sampling points at each set of secondary hydrocyclone s (one per unit)

to collect sample s of the FGD wastewater treatment system influent . However,

the sampling locations only represent one unit and not the combined secondary hydrocyclone o verflow for both units.

FGD Wastewater Treatment S ystem

• A process diagram for the FGD wastewater treatment system at Fort Martin is

included as A ttach ment 3

.

• Fort Martin first transferred FGD w astewater to the treatment system in

Nov ember 2009.

• Fort Martin operates the FGD wastewater treatment system in batches. The plant

waits for the equilization (EQ) tank to completely fill up and then runs the entire

system so there is 8 to 12 hours of discharge at a time

. The plant estimates that discharge from t he wastewater treatment system is on average 100

- 150 gpm per day. The wastewater treatment system is designed to treat 330 gpm. The design value is larger because the wastewater treatment system was originally designed with the assumption that Fort Martin would be washing gypsum.

• Secondary hydrocyclone overflow is first sent to the EQ tank. Secondary hydrocyclone overflow at the plant can have a solids content of 3.5 to 9 percent

. The FGD wastewater treatment system is designed for an influent with 3 perce nt solids. The plant is working on reducing the solids level to less tha n 2 percent

. The current high solids level in t he secondary hydrocyclone overflow is causing the plant to have problems operating the wastewater treatment system. The flow rates and pr ocesses provid ed below describe the operating p rocedure s at the time of the site visit; these procedures may change as Fort Martin optimizes the

system.

• W astewater is transferred into the EQ tank by three pipes, which contain

wastewater from the se condar y hydrocyclone s, the sumps from the wastewater treatment building, and th e sumps from the dewatering building . Even though thePage 5

EQ tank is open at the top, the pipe transferring wastewater from the secondary hydrocyclone s is not in an optimal location for s ampling. The flows for all three pipes are monitored so that if sampl es w ere collected downstream of the EQ tank, the plant could calculate where the wastewater came from.

• Wastewater from the EQ tank flows into the desaturation tank. Fort Martin add s l ime to the top of the desaturation tank to increase the pH from 5.5 S.U. (pH in the absorber) to around 8.2 S.U

.

• From the desaturat ion tank, the wastewater is transferred to reaction tank 1

, where the plant adds ferric chlor ide and orga nosulfide to the waste water

.

• From r eaction tank 1 , the wastewater then flows to reaction tank 2. Fort Martin adds a p olymer to the top of reaction tank 2. T he plant also has the capability of adding additional ferric chloride and organosulfide to reaction tank 2 ; h owever, the plant only adds these two chemicals to reaction tank 1. The pla nt is designed in this way so th e plant can more easily optimize the system

.

• The wastewater flows fro m reaction tank 2 to the two clarifiers , operated in parallel

. The clarifiers in the syste m are different than the solids contact clarifiers typically operated at other plants. The clarifier has two sides, with a partition between the two sides, but the partition does not go all the way to the floor of the clarifier; therefore, there is a conne ction between the sides at the bottom of the

clarifier. The wastewater is fed to one of the clarifier and is forced to flow down to the bottom of the clarifier to get to the other side. The other side of the clarifier

contains tube settlers, which go one third of the way dow n the clarifier

. The

w astewater flows up through the tube settlers before leaving the clarifier. This desig n encourages the solids to settle and remain at the bottom of clarifier.

• The sludge from the clarifiers is transferred to the s ludge holding tank. Because the concentration of solids entering the FGD wastewater treatment system is well above the design value , t he sludge from the clarifiers contains around 60% so lids when ideally it should contain only 6 % solids . Therefore, service water is added

to the sludge holding tank to dilute the sludge before sending the sludge to the filter presses for dewater ing . The filter presses will not function properly if the sludge contains more than 15% solids. Filtrate from the filter presses is

t ransferred to the wastewater treatment sump, which empties into the EQ tank.

• Fort Martin does not use sand filters as a final treatment after the clarifier. Personnel stated that sand filters are not necessary because the treated FGD wastewater is proce ssed through the lagoons prior to discharge. Furthermore, the wastewater treatment system, as it was designed, without sand filters, is still guaranteed a design mercury level below the limit required for discharge, which is 0.05 mg/L, as shown in Table 2. The limits imposed on outfall 002 (FGD wastewater combined with the plant’s other low volume wastewater treatment system) require a mercury concentration of 0.049 ug/L daily maximum and a monthly average of 0.0244 ug/L. The plant indicated that these l imits were stayed pending the outcome of permit appeal and have yet to be resolved.Page 6

• The overflow from the clarifier s is transferred to the effluent tank

, where it is

monitored for pH and turbidity. There is a sample point between the effluent tank

and the effluent pump. This sample point represents only the wastewater that is discharged from the wastewater treatment system.

• In the lagoons, the treated FGD wastewater com m ingles with other wastewaters at the plant prior to discharge via final O utfall 002. Fort Mar tin’s NPDES permit

does not have internal limits for the treated FGD wastewater , or require any monitoring of the FGD wastewater

. However, the plant does ha ve permit limits

a nd monitor ing requirement for O utfall 002

.

• Table 2 summarizes the profe ssional guarantees for the FGD wastewater

treatment system.

Table 2. Professional Guarantees for the FGD Wastewater Treatment System

Pollutant Limit

Aluminum 0.264 ppm Arsenic, soluble 0.021 ppm Barium, soluble <2 ppm Boron, total 3.9 ppm Cadmium, soluble 0.028 ppm Chromium, total 0.04 ppm Mercury 0.05 ppm

Iron <1 ppm

Lead <0.1 ppm Manganese, soluble 1.9 ppm pH 6

- 9

Selenium 0.6 ppm Temperature 130°F

TSS 15 ppmPage 7

Table 3 . Site Visit Attendees

Name Organization (Representing) Telephone E

- mail

Wally Bulford Allegheny Energy 304

- 598

- 5226 wbulfor@alleghenyenergy.com

Joe Lapcevic Allegheny Energy 724

- 838

- 6099 jlapcev@alleghenyenergy.com

Wayne Lingenfeller Allegheny Energy 724

- 838

- 6457 wlingen@alleghenyenergy.com

Chris Linger Allegheny Energy, Fort Martin 304

- 598

- 5261 clinger@alleghenyenergy.com

Chris Lassa k Allegheny Energy, Fort Martin 304

- 598

- 5244 classak@alleghenyenergy.com

Donna Hil l Southern Company/UWAG 205

- 257

- 5234 dbhill@southernco.com

Josh Hall EPA 202

- 566

- 1002 hall.josh@epa.gov

TJ Finseth Eastern Research Group 703

- 633

- 1698 thomas.finseth@ erg.com

Becky Schwantes Eastern Research Group 703

- 633

- 1715 becky.schwantes@erg.com