Draft Fort Martin Site Visit Notes

Draft Notes from Site Visit at Allegheny Energy’s Fort Martin Steam Electric Plant on 

February 4, 2010

EPA conducted a site visit at Allegheny Energy’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 

Attachment 1.

Plant Overview

• Fort Martin operates two coal-fired electric generating units. Monongahela Power 

Company owns 25% of the plant, while Allegheny Energy Supply owns 75% of 

the plant. The table below contains some general information on the current 

operation of each steam electric generating unit.

Table 1. Fort Martin Steam Electric Generating Units Operation

Unit

Installation 

Date

Gross Net

Capacity 

(MW)

Particulate 

Control NOx Control SO2 Control

1 1967 552 ESP SNCR*, low NOx

burners

FGD (Nov 2009)

2 1968 552 ESP SNCR*, low NOx

burners

FGD (Dec 2009)

* SNCR is not operated year round. The system operation is driven by NOx 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 

with its coal suppliers ends, 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 coal via barge. The coal pile runoff generated at 

the plant is transferred to the ash settling basin.

• Runoff from 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 of land, but much of the land is not flat enough 

to build on. 

• The plant operates two lined lagoons in series. Plant wastewaters are pumped to 

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

The north lagoon discharges to the Monongahela River via outfall 002. The 
Draft Fort Martin Site Visit Notes

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 basins and then to the lagoons. The 

wastewater associated with the FGD system is treated in the FGD wastewater 

treatment system and then sent to the lagoons, bypassing the ash settling basins.

• Ever since the plant began operating, Fort Martin has handled all the fly ash dry. 

As long as the fly ash has a loss on ignition (LOI) of less than 5%, the plant sells 

the fly ash. Most of the fly ash goes to mine reclamation. Any fly ash that cannot 

be marketed is transferred to the plant’s on-site landfill.

• Fort Martin handles the bottom ash using a wet system. Bottom ash is sluiced the 

plant sluices the bottom ash to hydrobins for dewatering. Overflow from the 

hydrobins is transferred to the ash settling basins and then to the lagoons. The 

plant uses cooling tower blowdown 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 

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

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

bottom ash sluicing process is transferred to the ash settling basins and the 

lagoons. The new landfill was first lined with a layer of bottom ash. All gypsum

will be stored in the new lined portion of the landfill because the plant is not 

allowed to put gypsum in the old landfill because it is not lined. Furthermore, Fort 

Martin personnel stated that in West Virginia and Pennsylvania all newly 

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

not been closed.

• Fort Martin received a letter from Region 3 from Andrew Seligman, who is part 

of EPA’s Office of Enforcement, requiring the plant to monitor for total dissolved 

solids (TDS), sulfides, chlorides, and conductivity daily for an 18-month period. 

The plant is being required to sample their discharge to the Monongahela 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.
Draft Fort Martin Site Visit Notes

Flue Gas Desulfurization System

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

Attachment 2.

• Fort Martin operates FGD systems on both units. Both FGDs are limestone forced 

oxidation systems, which have two dual trays and five spray headers. Unit 1 was 

manufactured by Combustion Engineering and Unit 2 was manufactured by 

Babcock & Wilcox.

• Fort Martin receives shipments of limestone 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 unit, 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 make-up 

water for the FGD system.

• Fort Martin blows down from the FGD scrubber based primarily 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 chlorides concentration in the absorber to 

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

concentration of 12,500 ppm; however, the absorber can handle a maximum 

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

handle 15,000 ppm.

• Blowdown 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 blowdown event.

• Blowdown from the absorber is processed through two sets of primary 

hydrocyclones (one per unit). The underflow from the primary hydrocyclones is 

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

filtrate from the vacuum belt filters goes to the reclaim tank. The overflow from 

the primary hydrocyclones is either sent to the reclaim tank or to the secondary 

hydrocyclones (one per unit). The overflow from the secondary hydrocyclones 

(the FGD system purge stream) is sent to the FGD wastewater treatment system. 

The underflow from the secondary hydrocyclones is sent to the reclaim tank. 

Wastewater in the reclaim tank is recycled back to the absorber.

 

• The chlorides concentration in the absorber largely determines whether primary 

hydrocyclone overflow is transferred to the secondary hydrocyclones or whether 

it is transferred to the reclaim tank and eventually transferred back to the 

absorber. If the chlorides concentration in the reclaim tank if high, then the plant 

sends the wastewater to the secondary hydrocyclones, but if the chlorides 

concentration is low, then the plant sends the wastewater to the reclaim tank and 

back to the absorber to further cycle up the chlorides in the system. [QUESTION 
Draft Fort Martin Site Visit Notes

FOR FORT MARTIN: What is the cutoff chlorides concentration for determining 

where to send the primary hydrocyclone overflow?] 

• 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 handled with the 

vacuum belt filter filtrate, which is transferred to the reclaim tank.

• The 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 times.

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

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

the sampling locations only represent one unit and not the combined secondary 

hydrocyclone overflow for both units. 

FGD Wastewater Treatment System

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

included as Attachment 3.

• Fort Martin first transferred FGD wastewater to the treatment system in 

November 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 the 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 percent

solids. The plant is working on reducing the solids level to less than 2 percent. 

The current high solids level in the secondary hydrocyclone overflow is causing 

the plant to have problems operating the wastewater treatment system. The flow 

rates and processes provided below describe the operating procedures at the time 

of the site visit; these procedures may change as Fort Martin optimizes the 

system.

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

wastewater from the secondary hydrocyclones, the sumps from the wastewater 

treatment building, and the sumps from the dewatering building. Even though the 
Draft Fort Martin Site Visit Notes

EQ tank is open at the top, the pipe transferring wastewater from the secondary 

hydrocyclones is not in an optimal location for sampling. The flows for all three 

pipes are monitored so that if samples were 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 adds

lime 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 desaturation tank, the wastewater is transferred to reaction tank 1, where 

the plant adds ferric chloride and organosulfide to the wastewater.

• From reaction tank 1, the wastewater then flows to reaction tank 2. Fort Martin 

adds a polymer to the top of reaction tank 2. The plant also has the capability of 

adding additional ferric chloride and organosulfide to reaction tank 2; however, 

the plant only adds these two chemicals to reaction tank 1. The plant is designed 

in this way so the plant can more easily optimize the system.

• The wastewater flows from reaction tank 2 to the two clarifiers, operated in 

parallel. The clarifiers in the system 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 connection 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 down the clarifier. The 

wastewater flows up through the tube settlers before leaving the clarifier. This 

design encourages the solids to settle and remain at the bottom of clarifier.

• The sludge from the clarifiers is transferred to the sludge holding tank. Because 

the concentration of solids entering the FGD wastewater treatment system is well 

above the design value, the sludge from the clarifiers contains around 60% solids 

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 dewatering. The filter presses will not function properly if the 

sludge contains more than 15% solids. Filtrate from the filter presses is 

transferred 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 processed 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. 

[QUESTION FOR FORT MARTIN: What is the design mercury level and

mercury limit?]

• The overflow from the clarifiers is transferred to the effluent tank, where it is 

monitored for pH and turbidity. There is a sample point between the effluent tank 
Draft Fort Martin Site Visit Notes

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 commingles with other wastewaters at 

the plant prior to discharge via final Outfall 002. Fort Martin’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 have permit limits

and monitoring requirement for Outfall 002.

• Table 2 summarizes the professional 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 ppm
Draft Fort Martin Site Visit Notes

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 Lassak Allegheny Energy, Fort Martin 304-598-5244 classak@alleghenyenergy.com

Donna Hill 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