RE: Coal Creek fly ash cost documentation 

Dendy, Lewis H. to: Gail Fallon 06/20/2011 06:55 AM 

Cc: "Semerad, Jim L.", "Bachman, Tom A." 

From: "Dendy, Lewis H." <Idendy@nd.gov> 

To: Gail Fallon/R8/USEPAlUS@EPA 

Cc: "Semerad, Jim L." <jsemerad@nd.gov>, "Bachman, Tom A." <tbachman@nd.gov> 

History: This message has been replied to. 

Gail, GRE's response to your question below is at the beginning of the 


attached message string. 


Lew Dendy 


Environmental Scientist 


ND Division of Air Quality 


918 E. Divide Ave., Bismarck, ND 58501-1947 


Ph 701.328.5188, Fax 701.328.5185 


http://www.ndhealth.gov/AQ/Airhomepage.htm 


-----Original Message----­

From: Fallon.Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] 


Sent: Thursday, June 16, 2011 11:30 AM 


To: Dendy, Lewis H. 


Cc: Semerad, Jim L.; Bachman, Tom A. 


Subject: RE: Coal Creek fly ash cost documentation 


Hi Lew, 


Did GRE provide any explanation of why their original sales price of 


$36/ton was so far off? 


Thanks for coordinating this. 


Gail 


Gail Fallon 


Regional Haze Program Manager 


Air Quality Planning Unit (8P-AR) 


US EPA Region 8 


1595 Wynkoop Street 


Denver, CO 80202-1129 


Phone: 303-312-6281 


Fax: 303-312-6064 


Email: Fallon.Gail@epa.gov 


From: "Dendy, Lewis H." <ldendy®nd.gov> 


To: Gail Fallon/R8/USEPA/US@EPA 


Cc: "Bachman, Tom A." <tbachman@nd.gov>, "Semerad, Jim L." 


<jsemerad@nd.gov> 

Date: 06/16/2011 05:51 AM 

Subject: RE: Coal Creek fly ash cost documentation 
Gail, 

The attached documents are provided in response to your request below . 

The two GRE emails you requested below were mentioned in the 12/2/09 

NDDoH response to Department of the Interior (DOI) comments on the Coal 

Creek BART determination which said: "GRE emails dated 8/8/08 and 

8/17/08 provide additional information on this issue (ash sales), as 

does a summary of a University of Kentucky study on the matter." 

The first attachment above is the 8/8/08 GRE email. The second 

attachment is the 9/17/08 GRE email which was mistakenly referred to as 

dated 8/17/08. This email contains the abstract of the University of 

Kentucky study. A review of our response to DOI comments indicates we 

addressed the sale of fly ash and not the mitigation of ammonia in fly 

ash. The third attachment is the document from our Coal Creek BART file 

that I was recalling which mentioned the mitigation of ammonia from fly 

ash. 

The last attachment is the email we received from GRE responding to your 

request. 

Please let me know if we can be of further assistance. 

Thanks, 

Lew Dendy 

Environmental Scientist 

ND Division of Air Quality 

918 E. Divide Ave., Bismarck, ND 58501-1947 

ph 701 . 328.5188, Fax 701.328.5185 

http://www.ndhealth.gov/AQ/Airhomepage.htm 

-----Original Message----­

From: Fallon .Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] 


Sent: Wednesday, June 01, 2011 1:31 PM 


To: Bachman, Tom A.; Dendy, Lewis H. 


Subject : Coal Creek fly ash cost documentation 


Tom and Lew, 


Per our phone conversation yesterday, we are looking for additional 


documentation to support your NOx BART determination for Coal Creek. 


Specifically, we are interested in the following cost information 


pertaining to lost fly ash sales which is a large component of the cost 


for SCR and SNCR: 


1. Supporting documentation (such as invoices/bills of sale) for fly 

ash pricing and tonnage 

- Several years of data would be helpful to show any 

price 

and 

tonnage fluctuations 

2. Supporting documentation regarding landfill costs 

3 . Cost to remediate the ammonia in the ash 

- Headwaters Resources' web literature indicates 

that it 

can add a 

chemical reagent to the ash to convert the ammonia 
to 

harmless 

compounds . The cost of this process would seem to be relevant to the 

BART analysis . 

Perhaps some of this information has already been provided somewhere in 

the SIP. Lew mentioned you may have provided something in response to 

FLM comments on ammonia mitigation. In Appendix J.l.2 of the SIP, I 

found where ND references a couple of Great River Energy emails and a 

Univ. of Kentucky study regarding ammonia in fly ash that are supposed 

to be attached but are not. Maybe there is something relevant there. 

Please provide these attachments as well . 

Thanks for any assistance you can offer. 

Gail 

Gail Fallon 

Regional Haze Program Manager 

Air Quality Planni"ng Unit (8P-AR) 

US EPA Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 

Phone: 303-312-6281 

Fax: 303-312-6064 

Email: Fallon.Gail@epa.gov 

[attachment "GRE 8 8 08 Email.pdf" deleted by Gail Fallon/R8/USEPA/US) 


[attachment "GRE 9-1~ 08 Email.pdf" deleted by Gail Fallon/R8/USEPA/US) 


[attachment "Removing NH3 From Fly Ash.pdf" deleted by Gail 


Fallon/R8/USEPA/US) 


----- Message from "Nelson, Debra GRE-MG" <dnelson@grenergy.com> on Wed, 


15 Jun 2011 16:09:56 -0500 ----­

To: 	 "Dendy, Lewis H." <ldendy@nd . gov> 

cc: 	 "Bachman, Tom A." <tbachman@nd.gov>, "Semerad, Jim L." 

<jsemerad@nd.gov> 

Subject: RE: Coal Creek fly ash cost documentation 

Lew, 


We respectfully submit our response to the questions raised by US EPA 


Region 8. 


1. Fly ash Pricing and tonnage: Fly ash sales at Coal Creek Station 

are paid from the weigh tickets obtained from the fly ash loaded trucks. 

The marketer of the fly ash will pay GRE directly from the accumulated 

truck weigh tickets on a monthly basis. GRE does not invoice the 

marketer for the ash. The existing records for sales are the individual 

truck weigh tickets. The attached document, FlyashSales2006-2010.pdf, 

contains the total fly ash sales in tonnage and in dollars received, and 

a calculated $/ton. This data was compiled from the thousands of 

individual weigh tickets obtained from the ash haulers. If there is 

still a need for the supporting documentation for these years we can 

provide copies of all the weigh tickets. This process will take some 

time to complete and some resources dedicated to completing. Please let 

me know if further documentation is required. 

2. Landfill disposal costs: During the development of the Coal 
Creek Station BART analysis, CCS was also re-evaluating the model for 

landfill disposal costs. When the revised BART analysis was submitted to 

NDDH the Landfill model was predicting a $6/ton disposal cost - the 

model was not finalized at that time . The value used in the BART 

analysis was $6/ton based upon an email message from the plant to the 

engineering firm contracted to conduct the analysis . Upon refinement and 

finalization of the model, the final value contained within the model 

puts our landfill disposal costs at $7.19/ton (in 2007 dollars). The 

attached document, LandfillDisposal.pdf, is a presentation of the final 

model values. 

3 . Inclusion of ammonia mitigation in BART analysis: A quick 

evaluation of the BART Analysis data reveals that the inclusion of 

ammonia mitigation technology has the same effect on the BART analysis 

as land filling the ash. The estimated installed cost for ammonia 

mitigation was roughly estimated by Headwaters at $5-$10 per ton of ash. 

Landfill costs are estimated by the final landfill model at around $7.19 

(in 2007 dollars) per ton of ash. The attached tables 

(NH4MitigationCosts.pdf) include the ammonia mitigation technology in 

the SCR and SNCR economic analysis. The final cost summary table has 

remained virtually the same . Whether the analysis utilizes landfill 

costs or ammonia mitigation costs, it does not change the conclusions of 

the BART analysis that SCR and SNCR technologies are not cost effective. 

If there are further questions please feel free to contact me. I will be 

unavailable June 16 & 17th but will be available to address further 

questions starting June 20th. 

Deb Nelson 

Environmental Services 

Great River Energy 

(763)445-5208 

dnelson@grenergy.com 

- - ---Original Message----­

From: Dendy, Lewis H. [mailto:ldendy@nd.gov] 

Sent: Wednesday, June 01, 2011 2:23 PM 

To : Nelson, Debra GRE-MG 

Cc: Bachman, Tom A.; Semerad, Jim L. 

Subject: FW: Coal Creek fly ash cost documentation 

Hello Deb, 

Please see the EPA/R8 email below for an additional request for 

supporting information to assist them with their decision on BART for 

Coal Creek Station. We request that GRE provide any available 

information in response to the questions. I'll review our file for 

anything that we might have. 

Please let Tom or I know if we can be of assistance. 

Thanks, 

Lew Dendy 

Environmental Scientist 

ND Division of Air Quality 

918 E. Divide Ave., Bismarck, ND 58501-1947 

Ph 701.328.5188, Fax 701.328.5185 

http://www.ndhealth.gov/AQ/Airhomepage.htm 
-----Original Message----­

From: Fallon . Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] 

Sent: Wednesday, June 01, 2011 1:31 PM 

To: Bachman, Tom A.; Dendy, Lewis H. 

Subject: Coal Creek fly ash cost documentation 

Tom and Lew, 


Per our phone conversation yesterday, we are looking for additional 


documentation to support your NOx BART determination for Coal Creek . 


Specifically, we are interested in the following cost information 


pertaining to lost fly ash sales which is a large component of the cost 


for SCR and SNCR: 


1. Supporting documentation (such as invoices/bills of sale) for fly 

ash pricing and tonnage 

- Several years of data would be helpful to show any price and 

tonnage fluctuations 

2. Supporting documentation regarding landfill costs 

3. 	 Cost to remediate the ammonia in the ash 

- Headwaters Resources' web literature indicates that it can add 

a 

chemical reagent to the ash to convert the ammonia to harmless 

compounds. The cost of this process would seem to be relevant to the 

BART analysis. 

Perhaps some of this information has already been provided somewhere in 

the SIP. Lew mentioned you may have provided something in response to 

FLM comments on ammonia mitigation . In Appendix J.1 . 2 of the SIP, I 

found where ND references a couple of Great River Energy emails and a 

Univ. of Kentucky study regarding ammonia in fly ash that are supposed 

to be attached but are not. Maybe there is something relevant there. 

Please provide these attachments as well. 

Thanks for any assistance you can offer . 

Gail 

Gail Fallon 

Regional Haze Program Manager 

Air Quality Planning Unit (8P-AR) 

US EPA Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 

Phone: 303-312-6281 

Fax: 303-312-6064 

Email : Fallon.Gail@epa.gov 

NOTICE TO RECIPIENT: The information contained in this message from 

Great River Energy and any attachments are confidential and intended 

only for the named recipient(s). If you have received this message in 

error, you are prohibited from copying, distributing or using the 

information. Please contact the sender immediately by return email and 

delete the original message. 
[attachment "NH4MitigationCosts.pdf" deleted by Gail Fallon/R8/USEPA/USl 

[attachment "FlyashSales2006-2010.pdf" deleted by Gail 

Fallon/R8/USEPA/USl [attachment "NDDH- Landfill.pdf" deleted by Gail 

Fallon/R8/USEPA/USl 

----- Message from "Nelson, Debra GRE-MG" <dnelson@grenergy.com> on Thu, 16 Jun 2011 15:24:24 

-0500 ----­

To: "Semerad, Jim L." <jsemerad@nd.gov> 

cc: "Bachman, Tom A." <tbachman@nd.gov>, "Dendy, Lewis H." <Idendy@nd.gov> 

SUbjec~ RE: Coal Creek fly ash cost documentation 

Jim, 


The $36/ton was a error propagated with our 2nd "original" submittal in 2007. I looked into our original 


2006 submittal (which we had recalled) and the $/ton was $5. So in reconfiguring the spreadsheets the 


value was mistyped and GRE submitted the improper number. 


Deb Nelson 


Environmental Services 


Great River Energy 


(763)445-5208 


dnelson@grenergy.com 


-----Original Message----­

From: Semerad, Jim L. [mailto:jsemerad@nd.gov] 


Sent: Thursday, June 16, 2011 11 :42 AM 


To: Nelson, Debra GRE-MG 


Cc: Bachman, Tom A.; Dendy, Lewis H. 


Subject: RE: Coal Creek fly ash cost documentation 


Deb: 


I am attaching an email from EPA that poses a follow-up question to the submittal referenced below. 


Please reply so that we can respond to EPA. 


Note that Lew is out until next week. 


Thanks. 


Jim Semerad 


Division of Air Quality 


State Dept. of Health 


(701) 328-5188 

jsemerad@nd.gov 

Division Website: 

http://www.health.state.nd.us/AQ/Airhomepage.htm 
-----Original Message----­


From: Dendy, Lewis H. 


Sent: Thursday, June 16, 2011 6:53 AM 


To: Nelson, Debra GRE-MG 


Cc: Semerad, Jim L.; Bachman, Tom A. 


Subject: RE: Coal Creek fly ash cost documentation 


Deb, 


I appreciate your effort and GRE's quick response. 


Thank you very much, 


Lew Dendy 


Environmental Scientist 


NO Division of Air Quality 


918 E. Divide Ave., Bismarck, NO 58501-1947 Ph 701.328.5188, Fax 701 .328.5185 


http://www.ndhealth.gov/AQ/Airhomepage.htm 


-----Original Message----­

From: Nelson, Debra GRE-MG [mailto:dnelson@grenergy.comj 


Sent: Wednesday, June 15, 2011 4:10PM 


To: Dendy, Lewis H. 


Cc: Bachman, Tom A.; Semerad, Jim L. 


Subject: RE: Coal Creek fly ash cost documentation 


Lew, 


We respectfully submit our response to the questions raised by US EPA Region 8. 


1. Fly ash Pricing and tonnage: Fly ash sales at Coal Creek Station are paid from the weigh tickets 

obtained from the fly ash loaded trucks. The marketer of the fly ash will pay GRE directly from the 

accumulated truck weigh tickets on a monthly basis. GRE does not invoice the marketer for the ash . The 

existing records for sales are the individual truck weigh tickets. The attached document, 

FlyashSales2006-201 O.pdf, contains the total fly ash sales in tonnage and in dollars received, and a 

calculated $/ton. This data was compiled from the thousands of individual weigh tickets obtained from the 

ash haulers. If there is still a need for the supporting documentation for these years we can provide copies 

of all the weigh tickets. This process will take some time to complete and some resources dedicated to 

completing. Please let me know if further documentation is required. 

2. Landfill disposal costs: During the development of the Coal Creek Station BART analysis, CCS was 

also re-evaluating the model for landfill disposal costs. When the revised BART analysis was submitted to 

NDDH the Landfill model was predicting a $6/ton disposal cost - the model was not finalized at that time. 

The value used in the BART analysis was $6/ton based upon an email message from the plant to the 

engineering firm contracted to conduct the analysis. Upon refinement and finalization of the model, the 

final value contained within the model puts our landfill disposal costs at $7.19/ton (in 2007 dollars). The 

attached document, LandfiliDisposal.pdf, is a presentation of the final model values. 

3. Inclusion of ammonia mitigation in BART analysis: A quick evaluation of the BART Analysis data 

reveals that the inclusion of ammonia mitigation technology has the same effect on the BART analysis as 

land filling the ash. The estimated installed cost for ammonia mitigation was roughly estimated by 

Headwaters at $5-$10 per ton of ash . Landfill costs are estimated by the final landfill model at around 

$7.19 (in 2007 dollars) per ton of ash. The attached tables (NH4MitigationCosts.pdf) include the ammonia 

mitigation technology in the SCR and SNCR economic analysis. The final cost summary table has 

remained virtually the same. Whether the analysis utilizes landfill costs or ammonia mitigation costs, it 

does not change the conclusions of the BART analysis that SCR and SNCR technologies are not cost 

effective. 
If there are further questions please feel free to contact me. I will be unavailable June 16 & 17th but will be 


available to address further questions starting June 20th. 


Deb Nelson 


Environmental Services 


Great River Energy 


(763)445-5208 


dnelson@grenergy.com 


-----Original Message----­

From: Dendy, Lewis H. [mailto:ldendy@nd.gov] 


Sent: Wednesday, June 01, 2011 2:23 PM 


To: Nelson, Debra GRE-MG 


Cc: Bachman, Tom A.; Semerad, Jim L. 


Subject: FW: Coal Creek fly ash cost documentation 


Hello Deb, 


Please see the EPAJR8 email below for an additional request for supporting information to assist them 


with their decision on BART for Coal Creek Station. We request that GRE provide any available 


information in response to the questions. I'll review our file for anything that we might have. 


Please let Tom or I know if we can be of assistance. 


Thanks, 


Lew Dendy 


Environmental Scientist 


ND Division of Air Quality 


918 E. Divide Ave., Bismarck, ND 58501-1947 Ph 701.328.5188, Fax 701 .328.5185 


http://www.ndhealth.gov/AQ/Airhomepage.htm 


-----Original Message----­

From: Fallon.Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] 


Sent: Wednesday, June 01,20111:31 PM 


To: Bachman, Tom A.; Dendy, Lewis H. 


Subject: Coal Creek fly ash cost documentation 


Tom and Lew, 


Per our phone conversation yesterday, we are looking for additional documentation to support your NOx 


BART determination for Coal Creek. 


Specifically, we are interested in the following cost information pertaining to lost fly ash sales which is a 


large component of the cost for SCR and SNCR: 


1. Supporting documentation (such as invoices/bills of sale) for fly 


ash pricing and tonnage 


- Several years of data would be helpful to show any price and 


tonnage fluctuations 


2. 	 Supporting documentation regarding landfill costs 

3. 	 Cost to remediate the ammonia in the ash 


- Headwaters Resources' web literature indicates that it can add a 

• 

chemical reagent to the ash to convert the ammonia to harmless 


compounds. The cost of this process would seem to be relevant to the 


BART analysis. 


Perhaps some of this information has already been provided somewhere in the SIP. Lew mentioned you 

may have provided something in response to FLM comments on ammonia mitigation. In Appendix J.1.2 of 

the SIP, I found where ND references a couple of Great River Energy emails and a Univ. of Kentucky 

study regarding ammonia in fly ash that are supposed to be attached but are not. Maybe there is 

something relevant there. 

Please provide these attachments as well. 

Thanks for any assistance you can offer. 

Gail 

Gail Fallon 

Regional Haze Program Manager 

Air Quality Planning Unit (8P-AR) 

US EPA Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 

Phone: 303-312-6281 

Fax: 303-312-6064 

Email: Fallon.Gail@epa.gov 

NOTICE TO RECIPIENT: The information contained in this message from Great River Energy and any 

attachments are confidential and intended only for the named recipient(s). If you have received this 

message in error, you are prohibited from copying, distributing or using the information. Please contact the 

sender immediately by return email and delete the original message. 

NOTICE TO RECIPIENT: The information contained in this message from 

Great River Energy and any attachments are confidential and intended 

only for the named recipient(s). If you have received this message in 

error, you are prohibited from copying, distributing or using the 

information. Please contact the sender immediately by return email and 

delete the original message.