### Mr. ColeAnderson WDEQIAQD 

### HerschlerBuilding 122 W. 25th 

### Street Cheyenne, Wyoming 82002

RE: BART Conference Call AlstomReports DearCole. 

# - Gener.al**~Chem/eal**

June 9, 2010 GREENRIVER SODAASHOPERATIONS P.O. Box 551 GREEN RIVER, WYOMING 82935.0551 (307)-875-3350



### Attached are two copies ofthe correspondence from Alstom as a result oftheir visitto theplantto tune C andD Boilers inFebruary 20IO. They were not attachedto the letter we submitted dated May 27, 2010. A copy was also submitted to Tony Hoyt in Lander. Ifyouhave any questions, please contactme at (307) 872-3445.

## ;i~CerelY, A ()

# n**·W'1-..~** Michael J. Dah\. Supr.-EnvironmentalEngineering CC: TonyHoyt

### Page 1of! Dahl, Mike From: Johler, Paul N. Sent: Monday, March 15, 2010 12:11 PM To: Pitts, Randy; Braman, Vic Cc: Dahl, Mike Subject: FW: General Chem, Green River: NOxsystem evaiuation Randy and Vic, Here is the response from ArtAdamswith Alstom giving the reasoning fortheir recommendation to now gowith a Secondary Over Fire Air (SOFA) system instead ofthe originally proposed Low NOx Burner (LNB) system. I have more notes from our conversations and ifyou are interested in more details or ifyou have any otherquestions. Thanks, Paul.


### From: arthur.adams@power.alstom.com [rnailto:arthur.adams@power.alstom.comj 

### Sent: Monday, March 15, 2010 11:38 AM 

### To: Johler, Paul N. 

### Cc: rnichael.taber@power.alstom.com; jeff.edwards@power.alstom.com; c1iff,oconnell@power.alstom.com 

### Subject: General Chern, Green River: NOxsystem evaluation
This is my response to your requeston the issue ofburneronly modifications (ourLNCFS P2) versus a SOFAsystem (LNCFS 

### 111). Let me know ifthis is sufficientforyourneeds. Also, justa reminderfrom our phone conversation today, you maywish to try ciosing down the coal airdampers into the 30% open range to see it's impacts on NOx. Thistestwould be run with the more desirable NOxsettings aiready established during the NOxtuning that gave the 0.40
- 0.42 results on boiler"C",

General Chemical operations, in conjunction with Alstom TS, has completed a baseline evaluation/optimization tuning effortto establish baseline NOxemissions, Boiler"C" was able to reduce full load NOxfrom an as found conditionof 0.52 ibs/MBtu down to the 0.40
- 0.42 range. "0" boiler reduction was slightly less going from 0.54Ibs/MBtu down to the 0.45
- 0.46 range afteroptimization. The proposed Wyoming NOx limitforGeneral Chemical is 0,32 Ibs/MBtu. Alstom has previously discussed the possibility of using it's patented LNCFS P2 system to reduce NOx. This system historically has been able to achieve a 10
-25% reduction in NOxfrom baseline conditions. The largerreduction capability took into account tuning optimization which has been completed at Gen Chem, Because ofthe newoptimized baseline, Alstom wouid predictonly an additional 10% reduction or lesswith the LNCFS P2 hardware. This would not meetthe proposed Wyoming regulation for NOx. Alstom would recommend an LNCFS III system to meetthe targetof 0.32 Ibs/MBtu. The LNCFS III is essentially a separated overfire air (SOFA) system. Therewould be 4 SOFA registers with 2 located on each boilersidewall above the main windbox elevation. Airforthe SOFA Is obtained from the secondary airduct upstream ofthe main windboxes. The main windbox nozzle tips would be downsized to accountforsecondary airthat is re-distributed to the SOFA registers. Re-sizing the air nozzle tips is designed to maintain nozzle tip exitvelocity's for proper mixing ofairand fuel.

CONFIDENTIALITY: This e-mail and any attachments are confidential and may be privileged. If you are not anamed recipient, please notify the sender immediately and do notdisclose the contents to another person, use itforany purpose orstore orcopy the information in any medium.

## Power Boiler & Environmental Plant Services 

### March 

### 5, 2010 General Chemical Mr. Paul Johler P.O. Box

### 551 Green River, WY 

### 82935

Re: Units 'C' 

### & '0' Orignal CE 

### C/N NOx Optimization Tuning
Attention: Mr. Paul Johler
Dear Paul: I arrived on site Tuesday February 

### 16, 2010 for MSHA training then began optimizing NOx on both C and 

### 0 power boilers the following day. The current NOx limit is 

### 0.7 Ibs/mBTU and the new limit that takes effect in 

### 2011 will be 

### 0.32 Ibs/mBTU. Currently the boilers are reported to operate in the 

### 0.5 to -------Q,6-llilsfmB+lJ-range-.**-+he~G!.-1il0iler2s-0riginal-design-rating-is-4QQ,QQQ-11il8fhr'---­** 

### steam flow and has 2 elevations of pulverized coal. The 

### '0' boiler's original rating is 

### 600,000 Ibs/hrsteam flow and has 

### 3 elevations ofpulverized coal. The plan was to optimize the firing to achieve the lowest NOx for both boilers. This will give Alstom a base to develop a proposal for retrofitting the boilers to achieve the new NOx limits of

### 0.32 Ibs/mBTU. The windbox dampers are controlled on an elevation basis, remote manual from the control room. There is no automatic function for either ofthe auxiliary orfuel air dampers. The OFA dampers are adjusted locally at the windbox. The SCAH's are no longer in service so the Ljungstrom air inlet temperatures are the ambient indoortemperature at the F.D. fan. The mill feed rate in tons/hr is based on the rpm ofa CE Volumetric feeder. The coal is notweighed as the scales have been out ofservice for manyyears. Except for the low load performance data the boilers were being operated attheir typical daily load demand. They operate near the design MCR on a daily basis Boiler 

### &Environmental Plant Services Division Parts &Technical Services 223266th Drive SE Phone: 425.487.0839 Department Bothell. WA 98021 cliff.oconnell@power.alstom.com

### General Chemical
- Units 'C' 

### & 

### '0' page 2 except for occasional restrictions due to process steam demand orfor equipment being out ofservice due to problems.

. For reference, the 

### 02 analyzers for both boilers are located after the generating bank about 3 feet above the centerline of the lower drum, midway between the lowerdrum and the rearwall. The 'C' analyzer is on the left side ofthe boiler. The 

### '0' boiler analyzer is located on the right side. The analyzers are 'wet' type. The LOI values on 2-18-10 was 2.5% for the 'C' boiler and 0.75% on the '0' boiler. Typically they run about 1.5 %or less on LOI. Additional LOI data has been requested. The boiler corners are referenced as 1 through 4, with corner 1 in the left/front and counting clockwise around the boiler. 'C' Boiler During the tuning the 'A' mill hot air damper was 100% open and the 'B' hot air damperwas about 45% open. The local damper drive indicators were similarfor the 'B' mill but the 'A' mill local indicator said the damperwas 'closed'. The mills were loaded the same so it may be something with the hot airdampers inside the duct as was discussed with Earl Grange. I recommend thatthe dampers and the drives be checked out and calibrations verified during the next maintenance outage. An 'as found' performance data was taken before any changes were made to the boiler. Initially I biased the mills so that the 'B' mill ran a lower coal feed than the 'A'. This was the configuration for the first 5 sets of performance data. Biasing the mills on this boiler didn't have any noticeable effect. The OFA dampers have been set at 50% open prior to testing. I opened all of the dampers to 100% except for corner#2. The corner#2 drive arm slips on the damper shaft and we could not get the damper to move. This drive arm should be repaired during the next maintenance outage. Opening the OFA dampers 100% did not significantly affect the NOx. The OFA dampers have local manual tilt drives. Unfortunately these do not move. All data was taken with the OFA tilts as shown below. Recommend repairing these during your next scheduled maintenance outage. 

### 'c" OFASETTING CORNER 1 Horizontal 2 10 dearees UP 3 Horizontal 

### 4 10 dearees UP 

### The sootblowers were not blown during the testing but the IK's and the APH blowerwere blown during lunch break each day.

### General Chemical
- Units 'C' & 

### 'D' page 

### 3

I adjusted the windbox dampers to put more airthrough the 'BB' auxiliary air (top air) elevation. Opening this up significantly lowered the NOx from a range of 

### 0,48 to 

### 0.52 Ibs/mBTU down to a range of

### 0.37 to 

### 0.41 Ibs/mBTU. When putting more air into the 'BB' elevation the windbox/furnace differential pressure decreases. In order to increase this 

### I closed down on the bottom auxiliary elevation 'AA'. This immediately resulted in a darker furnace bottom. It also prevents the operators from observing the conditions in the bottom of the furnace. Therefore the 'AA' elevation was opened up until the bottom of the furnace was visible but not as much as before the changes. Later it showed that this resulted in the f1yash getting increasingly darkerthan normal. When we went back to the original setup the NOx value increased as expected and the flyash also become lighter in color. 

### 'D' Boiler
The corner OFA dampers were found in the following settings, where the range is 

# oto 5with 5 being wide open. '0' OFA SETTING CORNER 1 3 2 31/2 3 5 4 31/2 

### Later the dampers were opened and the OFA dampers were set as shown below:-When+left-the-site-the-dampers-were-still-at-these-settingsi-o-.
------- 'D' OFASETTING CORNER 1 4 2 41/2 3 5 4 5 

### When putting in more air into the top auxiliary elevation 'CC' the effect wasn't as noticeable as observed on the 

# 'c' boiler. It is speculated that the elevations may be partially blocked and therefore opening them doesn't change the airflow very much. Later after the OFA dampers were opened and the windboxllfurnace differential pressure was increased from 3" w.g. to 4.5" w.g., no significant change here either. The best results were when the O2 

### lowered back down. The OFAtilts on this boiler as found:

### General Chemical· Units 'C' & 

### '0'

10'- OFASETTING CORNER 1 5 dearees UP 2 10 demees UP 3 10 dearees UP 4 10 dearees UP 

### Then theywere changes as follows: -'0' OFASETTING CORNER 1 10 dearees UP 2 10 dearees UP 3 15 dearees UP 4 20 dearees UP 

### page 4

It wasn't possible to change the tilts very much. And therefore no significant change in the NOx was observed. Recommend repairing the OFA tilts and dampers during the next maintenance outage. Exhaustersetup In reviewing the data the mill exhauster discharge pressures for any given mill never changed. The reading was taken from the analog pressure gauges in the control room and I was told that that those indications are dampened. They appear to be low so I inqUired how the exhauster inlet damper is setup. In order to get the maximum discharge pressure it is recommended to adjust the inlet damper as stated below. This information that is directly out of the instruction .--_.**-----manIJals-f0r-these-b0i1eFs,~.** 

### -----------------

_ It is recommended to run clean airflow tests on all pulverizers. Due to the use of ceramics and also because no clean air test has been performed in a long time. If the airflows were higher than necessary then this could result in the NOx increasing. EXHAUSTER INLET DAMPER Operation The following procedure shall be used when setting up the exhauster inlet damper. Minimum Exhauster Inlet Damper Setting (INITIAL) 1. Setthe exhauster inlet damper so that it opens 100 percent at 100 percent stroke of its drive unit. 2. Determine the clean air exhauster discharge pressure with the mili set up per the clean airflow testprocedure. 3. For tangential fired units determine the damper setting which gives a clean air exhauster discharge pressure equal to 70 percent ofthe value obtained in Step 2 above.

### General Chemical· Units 'C' 

### &'OJ page 5

4. The setting obtained in Step 3 is the temporary minimum exhauster inlet damper setting and should be established as a minimum with a temporary mechanical stop. The damper drive control unit should be temporarily stroked between this minimum and 100 percent open. 5. There should be a straight line relationship between feeder speed and exhauster inlet damper position, as feeder speed is increased from minimum to maximum and damper position moves from minimum to maximum.
Minimum Exhauster Inlet Damper Setting (FINAL) 1. Determine the exhauster discharge pressure available with the miii loaded to its design capacity and exhausterdischarge damper is 100 percent open. 2. Fortangential fired units compute 60 percent ofthe value obtained in Step 1 above. 3. Set the final exhauster inlet damper minimum to give the discharge pressure from Step 2 while operating the feederat its minimum position. Permanently fix the mechanical stop. 4. Make finai control adjustment between minimum and fuii open. This should be a straight-line reiationship between feeder speed and exhausterdamper position. This should result in 100 percent airflow at 100 percentfeeder speed and a somewhat lowerairflow at minimum feeder speed. This resuits in the Optimum Air Flow Curve. 

### Ifyou have any questions about performing a clean airflow test or setting up the exhauster inlet damper please ask. Itwas a pleasure working at your plant and everyone was extremely helpful during the testing. Sincerelyyours

----**~--------------eliff-e!eonnell---------~-­** 

### Consulting Engineer Technical Services

### Reviewer

._''-' '!:-',

_ 

### Copyto: 

## CynthiJl

_ 

## D.E.

_ File:

__15>8'

# D7 May27, 2010 GREENRIVERSODAASH OPERATIONS P.O. Box551 GREENRIVER, WYOMING 82935-0551 (307)-875-3350 

### Mr. Chad Schlichtemeier WDEQ/AQD Herschler Building 122 W. 25th 

### Street Cheyenne, Wyoming 82002 RE: Conference Call 5/12/10 BARTPermit Dear Chad: The Division and General Chemical held a conference call regarding BART Permit 6046, General Chemicalis responding tothe items addressedinthemeeting. In October2009, General Chemical established atargetlimit for C and D Boilers by artificially lowering the compliance limit alarm in the Powerhouse Control Room from 0,7 Lbs. NOx/MMBTU to 0.60 Lbs. NOx/MMBTU limit. This was done to motivatethe operators to make adjustmentsto the boilers andreducetheNOx

### as much as possible. C Boiler was operating between 0.53 and 0.60 and D Boiler was operating between 0.54 and 0.60 during this time period. In the time period ofDecember 2009 tluough mid-Febmary, General Chemical began making adjustments to air and oxygen levels to lower the NOx 

### even further, prior to contracting Alstom for boiler ttming. During this time, C Boiler was operating between 0.42 and 0.53 and D Boiler was

__ opeliting between0.50 and 0.59.-Alstombegan boilertuning onFebmary 17,2010 for a week. Numerous adjustments to a variety ofparameters were made on both boilers to minimize NOx. 

### Sincethattime, C Boilerhas operated inthe range of0.44 to 0.53 and D Boiler in the range of0.51 to 0.55. The tuning exercise demonstrated that the boilers were operating at an efficiency greaterthan Alstom expected, which ledthemto conclude that LNB would not provide a substantial improvement to NOx 

### control or reductions to meet 0.32 Lbs.lMMBTU. Alstom's correspondenceto General Chemical is attached. As we noted in the meeting, C Boiler was more responsive to tuning than D Boiler and a more significant reduction was achieved. Based upon tuning efforts and recommendations provided by Alstom, General Chemical proposes interim limits of.53 and .55 Lbs. NOx 

### per MMBTU for C and D Boilers respectively, utilizing a 30-day rolling average. In addition, we are working to get Alstom or Storm to the plant during the upcoming boiler outages to inspect, adjust and make as many repairs to the boilers notedduringtheirboilerinspection as time allows.

### Regarding permit limits, General Chemical is committed to the installation of SOPA with the option to install an equivalent technology that will meet 0.28 Lbs. NOjMMBTU based on a 3D-day rolling average. C Boilerinstallation would take place in 2014 and D Boilerin2015. Engineering workmustbe completedbythe manufacturer priorto receiving aguarantee forthe 0.28 Lb.lMMBTUNOx• 

### Ifyou have any questions regmding this response, please contact Mike Dahl at (307) 872-3445. Sincerely,

# e**~M'I** 

# r:f

# 4 i'lf RandyPitts PlantManager

-----.--

### Power Boiler & Environmental PlantServices 

### March 5, 2010 General Chemical Mr. Paul Johler P.O. Box551 Green River, WY 82935

Re: Units 'C' & 

### '0' Orignal CE 

### C/N NOx Optimization Tuning
Attention: Mr. Paul Johler
Dear Paul: I arrived on site Tuesday February 16, 2010 for MSHA training then began optimizing NOx on both C and 

### 0 power boilers the following day. The current NOx limit is 0.7 Ibs/mBTU and the new limit that takes effect in 2011 will be 0.32 Ibs/mBTU. Currently the boilers are reported to operate in the 0.5 to 0.6 Ibs/mBTU range. The 'C' boiler's original design rating is 400,000 Ibs/hr

-----**steam-f1ow-and-has-2-elevations-of-pulverized_coal._Tbe-'D-'-b.ojler~s_ori.ginaL[ating** 

### _ is 600,000 Ibs/hrsteam flow and has 3 elevations of pulverized coal. The plan was to optimize the firing to achieve the lowest NOx for both boilers. This will give Alstom a base to develop a proposal for retrofitting the boilers to achieve the new NOx limits of0.32 Ibs/mBTU. The windbox dampers are controlled on an elevation basis, remote manual from the control room. There is no automatic function for either ofthe auxiliary or fuel air dampers, The OFA dampers are adjusted locally atthe windbox. The SCAH's are no longer in service so the Ljungstrom air inlet temperatures are the ambient indoor temperature atthe F.D. fan. The mill feed rate in tons/hr is based on the rpm of a CE Volumetric feeder. The coal is notweighed as the scales have been out ofservice for many years. Exceptfor the low load performance data the boilers were being operated at their typical daily load demand. They operate near the design MCR on a daily basis Boiler & Environmental Plant Services Division Parts &Technical Services 22326 6 ffi Drive SE Phone: 425.487,0839 Department Bothell. WA 98021 c1iff,occnnell@power,alslom,com

### General Chemical
- Units 'C' & 

### '0' page 2 exceptfor occasional restrictions due to process steam demand orfor equipment being out ofservice due to problems. For reference, the 

### 02 analyzers for both boilers are located after the generating bank about 3 feet above the centerline of the lower drum, midway between the lower drum and the rearwall. The 'C' analyzer is on the left side ofthe boiler. The 

### '0' boiler analyzer is located on the right side. The analyzers are 'wet' type. The LOI values on 2-18-10 was 2.5% for the 

## 'c' boiler and 0.75% on the 

### '0' boiler. Typically they run about 1.5 %or less on LOI. Additional LOI data has been requested. The boiler corners are referenced as 1 through 4, with corner 1 in the lefUfront and counting clockwise around the boiler. 'C' Boiler During the tuning the 'A' mill hot air damper was 100% open and the 'B' hot air damperwas about 45% open. The local damper drive indicators were similar for the 'B' mill but the 'A' mill local indicator said the damper was 'closed'. The mills were loaded the same so it may be something with the hot air dampers inside the duct as was discussed with Earl Grange. I recommend thatthe dampers and the drives be checked out and calibrations verified during the next maintenance outage. An 'as found' performance data was taken before any changes were made to the boiler. Initially I biased the mills so that the 'B' mill ran a lower coal feed than the 'A'. This was the configuration for the first 5 sets of performance data. Biasing the mills on this boilerdidn't have any noticeable effect.**--1=heGFAaampers-have-been-set-at-5Q%-open-prior-to-testing~l-opened-all-of-­** 

### the dampers to 100% except for corner#2. The corner#2 drive arm slips on the damper shaft and we could not get the damper to move. This drive arm should be repaired during the next maintenance outage. Opening the OFA dampers 100% did not significantly affectthe NOx. The OFA dampers have local manual tilt drives. Unfortunately these do not move. All data was taken with the OFA tilts as shown below. Recommend repairing these during your next scheduled maintenance outage. 

### Ie" OFA SETTING CORNER 1 Horizontal 2 10 degrees UP 3 Horizontal 4 10 degrees UP 

### The sootblowers were not blown during the testing but the IK's and the APH blowerwere blown during lunch break each day.

### General Chemical· Units 'C' & 

### 'D' page 3

I adjusted the windbox dampers to put more airthrough the 'BB' auxiliary air (top air) elevation. Opening this up significantly lowered the NOx from a range of 0.48 to 0.52 Ibs/mBTU down to a range of0.37 to 0.41 Ibs/mBTU. When putting more air into the 'BB' elevation the windboxlfurnace differential pressure decreases. In order to increase this I closed down on the bottom auxiliary elevation 'AA'. This immediately resulted in a darker furnace bottom. It also prevents the operators from observing the conditions in the bottom of the furnace. Therefore the 'AA' elevation was opened up until the bottom of the furnace was visible but not as much as before the changes. Later it showed that this resulted in the flyash getting increasingly darkerthan normal. When we went back to the original setup the NOx value increased as expected and the flyash also become lighter in color. 

### 'D' Boiler
The corner OFA dampers were found in the following settings, where the range is 

# oto 5with 5 being wide open. '0' OFASETTING CORNER 1 3 2 31/2 3 5 4 31/2 

### Later the dampers were opened and the OFA dampers were set as shown below. When I leftthe site the dampers were still at these settings.**_.~-** -**------_._---~-** '0' OFA SETTING CORNER 1 4 2 41/2 3 5 4 5 

### When putting in more air into the top auxiliary elevation 'CC' the effect wasn't as noticeable as observed on the 'C' boiler. It is speculated that the elevations may be partially blocked and therefore opening them doesn't change the airflow very much. Later after the OFA dampers were opened and the 

### windboxllfurnace differential pressure was increased from 3" w.g. to 4.5" w.g., no significant change here either. The best results were when the O2 

### lowered back down. The OFAtilts on this boiler as found:

### General Chemical
- Units 'C' & 

### '0'
lOP OFA SETTING CORNER 1 5 de!lrees UP 2 10 de!lrees UP 3 10 degrees UP 4 10 de!lrees UP 

### Then they were changes as follows: "0' OFASETTING CORNER 1 10 dearees up 2 10 dearees UP 3 15 dearees UP 4 20 degrees up 

### page 4

It wasn't possible to change the tilts very much. And therefore no significant change in the NOx was observed. Recommend repairing the OFA tilts and dampers during the next maintenance outage.
Exhaustersetup In reviewing the data the mill exhauster discharge pressures for any given mill never changed. The reading was taken from the analog pressure gauges in the control room and I was told that that those indications are dampened. They appear to be low so I inquired how the exhauster inlet damper is setup. In order to get the maximum discharge pressure it is recommended to adjust the inlet damper as stated below. This information that is directly out of the instruction manuals forthese boilers. It is recommended to run clean airflow tests on all pulverizers. Due to the use of ceramics and also because no clean air test has been performed in a long time. If the airflows were higher than necessary then this could result in the NOx increasing. EXHAUSTER INLET DAMPER Operation The following procedure shall be used when setting up the exhauster inlet damper. Minimum Exhauster Inlet DamperSetting (INITIAL) 1. Set the exhauster inlet damper so that it opens 100 percent at 100 percent stroke of its drive unit. 2. Determine the clean air exhauster discharge pressure with the mill set up per the clean airflowtest procedure. 3. For tangential fired units determine the damper setting which gives a clean air exhauster discharge pressure equal to 70 percent ofthe value obtained in Step 2 above.

### General Chemical· Units 'C' & 'D' page 5

4. The setting obtained in Step 3 is the temporary minimum exhauster inlet damper setting and should be established as a minimum with a temporary mechanical stop. The damper drive control unit should be temporarily stroked between this minimum and 100 percent open. 5. There should be a straight line relationship between feeder speed and exhauster inlet damper position, as feeder speed is increased from minimum to maximum and damper position moves from minimum to maximum.
Minimum Exhauster Inlet DamperSetting (FINAL) 1. Determine the exhauster discharge pressure available with the mill loaded to its design capacity and exhausterdischarge damper is 100 percent open. 2. Fortangential fired units compute 60 percent ofthe value obtained in Step 1 above. 3. Set the finai exhauster inlet damper minimum to give the discharge pressure from Step 2 while operating the feeder at its minimum position. Permanentiyfixthe mechanical stop. 4. Make final control adjustment between minimum and full open. This should be a straight-line relationship between feeder speed and exhauster damper position. This should result in 100 percent airflow at 100 percent feeder speed and a somewhat lowerairflow at minimum feeder speed. This results in the Optimum Air Flow Curve. 

### Ifyou have any questions about performing a clean airflow test or setting up the exhauster inlet damper please ask. It was a pleasure working at your plant and everyone was extremely helpful during the testing. Sincerely yours

CliffO'Connell Gonstllting-Engineer Technical ServicesI Date: 3-5-2010 

## I TEST As Found 1 2 I 3 4 5 6 7 8 9 10 I DATE 2/18/10 2/18/10 2/18110j 2/18/10 2/18/10 2/18/10 2/19/10 2/19/10 2/19/10 2/19/10 2/22/10 TIME 7:53AM 9:04 AM 9:55 AM 1:10 PM 2:30 PM 3:00 PM 9:35AM 10:23AM 11:19AM 2:15 PM 10:15 PM C Boiler Steam Flow k#/hr 380.027 379.288 382.219 376.238 384.881 382.037 381.112 390.212 380.012 380.344 303.321 I FWFlow% 74 74 74 73 75 74 74 76 74 74 59 FW Flow k#/hr NA NA NA INA NA NA NA NA NA NA 296.103 Drum Press psig 656 656 656 655 650 657 654 659 654 647 633 I FW Press psig 880 878 884 879 881 878 888 882 882 878 885 I SH OutTemp F 743 735 735 740 732 736 728 732 725 731 735

, FWTemp F 252 252 252 253 253 251 252 252 252 252 251 I 02 % boileroutlet 3.2 3.2 3.3 3.0 3.2 3.2 3.1 3.2 3.2 3.1 5.0 WB Press in. WG 4.2 4.0 40 4.5 3.7 3.9 4.0 4.5 3.5 3.4 2.9 I Fum Press in. WG -0.5 -0.5 -0.5 -0.5 -0.5 -0.5 -0.6 -0.4 -0.6 -0.6 -0.6 I S02 #/mBTU 1.09 1.17 1.19 1.25 1.26 1.28 1.36 1.35 1.31 1.26 1.14 S02 ppm NA NA NA INA NA NA 509.00 515.00 501.00 490.00 394.00 CO ppm 0.73 0.61 0.83 0.83 0.83 0.83 0.55 0.55 0.55 0.83 0.28 I 02 CEMS % 6.5 6.4 6.3 6.0 5.9 6.1 6.2 6.1 6.4 6.3 7.6 I NOx #/mBTU 0.52 0.52 0.50 0.41 0.42 0.42 0.48 0.46 0.40 0.43 0.47 I NOx ppm 286 251 253 202 212 215 242 240 202 207 210 

### , Opacity % 18.90 18.90 18.5ID 15.30 22.39 14.60 18.79 17.07 15.08 16.79 18.30 

# 1- Windboxdampers % OFA 50 50 * 

# - 50
-- 

# -- 50 50 50 I BB top aux air 80 80 8ID 50 60 60 60 45 55 45 55 

### , B coal 80 80 8ID 80 80 80 80 80 80 80 87 

### , AB auxair 75 75 75 75 75 75 70 70 70 90 90 

### , A coal 75 75 75 75 75 75 75 75 75 75 80 

### , AA bottom auxair 55 55 55 80 65 60 60 60 60 60 65 

## I APH In Temp F 92 93 95 96 97 96 90 90 91 98 83 I APH OutTemp F 510 516 518 520 523 524 513 513 519 525 494 I APH Gas In Temp F 620 623 625 620 626 629 625 629 631 625 593 I APH Gas OutTemp F 354 359 36ID 360 364 364 356 356 361 364 338I

### ! A Mill Disc. Press in.WG 

### 7.0 7.0 7.q 7.0 7.0 7.0 7.0 7.0 7.0 7.0 7.0 A Mill outTemp F 

### 145 140 140 141 139 139 143 143 142 139 144 A Mill Amp 

### 64 72 

### 74 73 73 74 65 67 66 74 53 A Mill feed rate 

### % 56 64 64 61 61 63 57 56 53 61 41 A Mill FlowTons/hr 

### 13.1 14.3 14.3 13.8 13.9 14.1 13.2 13.0 12.6 13.9 10.7 A Mill HotAir Damper

### % 100 100 100 100 100 100 100 100 100 100 86 I B Mill Disc. Press. In.WG 

### 6.5 6.5 6.5 6.6 6.4 6.4 6.2 6.2 6.2 6.2 6.2 I B Mill outTemp F 

### 149 149 149 149 150 149 149 149 150 150 53 BMiliAmp 

### 64 57 57[ 57 57 57 65 67 66 56 31 B Mill feed rate 

### % 49 38 36 38 38 39 52 53 51 39 9 B Mill Flow Tons/hr 

### 11.93 10.19 989 10.07 10.19 10.38 12.4 12.6 12.3 10.4 62.0 B Mill HotAir Damper

### % 50 42 49 42 46 43 42 42 42 54 54 I FD Damper 

### % 84 81 82 82 78 80 81 91 80 73 62 

## , FDfan RPM 

### 3839 3839 3839 3839 3844 3840 3842 3840 3839 3840 3839

, ID Damper

### % 63 63 64 61 61 64 61 68 65 59 44 

## , IDfan RPM 

### 3925 3925 3925 3925 3925 3925 3925 3923 3925 3925 3924
I

, FD fan disc Press in.WG 

### 9.5 9.5 9.5 9.7 9.5 9.5 9.7 9.7 9.3 8.5 7.0 

## , Ljung AH Air in inWG 

### 9.5 9.5 9.5 9.7 9.5 9.5 9.7 9.7 9.3 8.5 7.0 

## , Ljung AH Air in in.WG 

### 5.0 5.0 4.5 5.5 4.5 4.5 4.8 5.0 4.8 3.5 3.2 

## , TubularAH Airout in.WG 

### 4.1 4.1 3.9 5.0 3.8 3.8 3.7 4.1 3.2 2.8 2.2 TubularAH Gas in in.WG NA NA NA INA NA NA NA NA NA NA NA TubularAH Gas out in.WG 

### -4.3 -4.2 -4.2 -4.0 -4.0 -4.0 -4.0 -4.1 -4.2 -4.4 -3.2 Ljung AH Gas in in.WG NA NA NA INA NA NA NA NA NA NA NA Ljung AH Gas out in.WG 

### -10.0 -10.0 -10.G -9.5 -9.7 -9.7 -9.5 -10.0 -10.0 -10.0 -7.5 

### ! ID fan disc. Press. in.WG 

### -0.15 -0.15 -0.15 -0.15 -0.15 -0.15 -0.15 -0.15 -0.15 -0.15 -0.15 Barometric Press. mm Hg na na na 

## I na na na 

### 607.9 607.9 607.9 607.9 608.0
• Corner 

### 1 is 

### 100% open whiie other

### 3 corners are 

### 50% open. /\A Corner

### 2 is

### 50% open while other

### 3 corners are 

### 100%

### o~en

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### 2 is

### 50% open whiie other

### 3 corners are 

### 100% closed I

# AECOM AECOM Environment 1601 Prospect Parkway, Fort Collins, Colorado 80525 T970.493.8878 F970.493.0213 www.aecom.com

December 12, 2008

Mr. Cole Anderson Air Quality Engineer Wyoming Department of Environmental Quality Air Quality Divison Herschler Building 122 West 25th Street Cheyenne, WY 82002· RE: Revised BART Analysis forthe Green RiverWorks (AP-6046) Dear Mr. Schlichtemeler: On the behalf of our client, General Chemical, and in response to your letterof November 4,2008, AECOM is submitting the enclosed Revised BestAvailable Retrofit Technology (BART) Analysis Report for the Green RiverWorks. This revision incorporates your requested evaluation of Low NO, Burners with Separated Overfire Air, which reduces emissions to the levels specified in the Division's BART analysis. If you have any questions regarding this submittal, please contact Dr. Bruce Macdonald at (970) 530-3500. Regards,

# "1:(t<:~t{

# Mi6naelze5ell~~----- .. \.-

. Senior Program Manager Air Resources michael.zebell@aecom.com

AECOM Environment

# J)~~~~_._. ----'·Bruce C. Macdonald, Ph.D. Vice President Regional Air Quality Practice Leader bruce.macdonald@aecom.comPrepared for: General Chemical Soda Ash Partners Green River, Wyoming



# Responseto Comments fortheBART Analysis - General Chemical Green RiverWorks

AECOM Environment December2008 Document No.: 02999-022 

# AECOMPrepared for: General Chemical Soda Ash Partners Green River, Wyoming



# Responseto Comments fortheBART Analysis - General Chemical Green RiverWorks

Prepared By:

### Micha~1 Zebell, PE "

Reviewed By: Bruce MacDonald

AECOM Environment December 2008 Document No,: 02999·022 

# AECOM

## Contents

1.0 Introduction 1·1
2.0 Summary of Previous BART Work 2·1
3.0 Consideration of Emission Control Alternatives 3·1 3,1 NOxCombustion Controls """ " ",

..",,,

.., ,,,,,,,, ,,.,, ,..',, ,,,., ,,,,,,..",,,,,,.,3·1 3,1 ,1 NOx Control Technical Feasibility"",,,," ""

.." , " '""""" '

...",,,,,,,",,"

.." "",".3-1
4.0 Emission Reductions for BART Cost Evaluation 4·1 4.1 Actual Annual Emissions Baseline , ,.." "

.., ",,,,,,

..,,,,,,,, ,,,,,..,'

..,,..,,, 4·1 4.2 Effectiveness and Economic Analysis of NOx Emission Control Alternatives """" ,,,..,,,, ,..,...4·1 4,2.1 Costs for Boiler C NOx,,,...,, , ,, ,,,,, ,,,..,,,..,'

......,,,..,,,.,,........,,,' "" ,,, ,,4·2 4,2.2 Boiler D NO, ,,, , ,,,,,,'

..,,,.,, ,,,,,,, ,,.,,,," ,,.,, ,,.,,, ,,,..,,,,,."."."." " 4-2
5.0 Selection of Control Scenarios 5·3 5,1 Control Options Modeling Emission Rates" , ""

..,.." "" ",

..",,, ,,, ,,, " 5-3 5,2 Control Scenario Options for Evaluation "

.."" """ "."

.." , , , ,

.., " ,

..5-5
6.0 Selection ofthe Best Alternativefor BART Control 6·1 6,1 Summary of Results"",

..,,,....,,,.........,.......,...."

...., ,,, , ,,,,,,,'

..,, ,,,..,'"' ,.."." ,,.,6-1 6,2 Annualized Costfor Implementing Control versus Decrease in Visibility ImpairmenL

.." , ,6·1



## List of Appendices AppendixA Cost Analyses for BART Control Options Appendix B Cost Quote from Aistom Power

J:\200012999-022-Gen_Chem-BART\Final BART Reporl\Gen Chem BART Response Dec-12,doc December2008

## List of Tabtes
Table 4-1 Table 4-2

. Table 4-3 Table 5-1 Table 5-2 Table 

### 6-1 Baseline Annual Average Emissions for 2001-2003 .4-1 Cost Evaluation of NO

### xcontrols for Boiler C 4-2 Cost Evaluation of NO

### xcontrols for Boiler D .4-2 Emission Rates for Visibility Evaluation for LNB and LNB+SPFA 5-3 Visibility Modeling Results 5-4 Tabulation of Visibility ImprovementatJim BridgerWilderness Area and Annual Costs for Each Control Option 

### 6-1

J:\2000\2999-022-Gen_Cllem-BART\Final BART Report\Gen Chern BART Response Dec-12.doc ii December2008

## 1.0 Introduction

Federal regulations under40 Code of Federal Regulations (CFR) 51 Appendix Yprovide guidance and regulatoryauthorityforconducting avisibility impairment analysis for designated eligible sources. The regulations are provided in Wyoming AirQuaiity Standards and Regulations, Chapter6, Section 9. The program requires the application of Best Available RetrofitTechnology (BART) to those existing eligible sources in orderto help meetthe targets forvisibility improvement at designated Class Iareas. The Wyoming Department of Environmental Quality (WDEQ) identified two coal-fired boilers, Boilers Cand D, atthe General Chemical facility in Green River, Wyoming, (General Chemical- Green River) as two BART-eligible emission units. TheWyoming BART program requires that BART-eligible sources perform asite-specific BART analysis including acontrol technology review and CALPUFF modeling to assess the visibility impact ofthe emission units. General Chemical- Green Riverconducted a BART review and provided a reportto WDEQ (BART Analysis forthe General Chemical Green RiverWorks, March 2007). The conclusion ofthat report is that installation of Low NO, Burners (LNB) represents BARTfor Boilers Cand D. WDEQ made adraft determination for public review based on the information submitted byGeneral Chemical- Green River, and received comments on the draft determination. In response to those comments, WDEQ requests that General Chemical evaluate additional state-of-the-art control levels achievablethrough application of LNB with separated over-fire air (LNB+SOFA) to reduce emissions below the levels specified in the original BART determination. This report documents the application of LNB and LNB+SOFA as representing BART for Boilers Cand Dat General Chemical- Green River using updated additional information from the March 2007 analysis. The NO, control technologies evaluated in the original BART determination included both post-combustion controls and combustion controls as follows:

• Post-Combustion Controls Selective catalytic reduction (SCR); Selective non-catalytic reduction (SNCR);

• Combustion Controls: LNB; and LNB+SOFA. In the March 2007 reportthe post-combustion controls were determined to be too costly relative tothe amount of emission control and visibility impact improvement gained (benefits) through application of those technologies. Ofthe two combustion control techniques evaluated in the original BART determination, LNB +SOFAwas shown to be too costly relative tothe benefits; however, this conclusion was not clearly communicated and this response to comments is designed to ciarifythat conclusion. In addition, the costs of LNB and LNB+SOFA have been revised from the originai report based on additional information from Alstom Power Systems.

1-1 December 200B

## 2.0 Summary of Previous BART Work

The follow'lng is a brief summary of the March 2007 BART report submitted by General Chemical- Green River and subsequentWDEQ review and draft BART determination. There are no near-term limitations on the useful life of BoilerC and D. These units, along with the other non-BART eligible gas-fired boiler provide on-site steam and electric powerfor mining and ore processing operations. The boilerhouse containing all three boilers is located within a compact area atthe facility. Boilers Cand Daretangentiallyfired using low sulfur bituminous coal. Boiler Chas atotai heat rate inputof 534 million British Thermal Units per hour (MMBtu/hr) and Boiler Dis rated at 880 MMBtu/hr. Given the limited area at the site, coal is received readyfor firing, without on site long-term storage, pre-sizing, orcoal biending. Both boilers are equipped with in-line pulverizers that preparethe coal fordirect introduction into the combustion zone. Particulate emissions from both boilers are controlled byseparate hot-side electrostatic precipitators (ESP) which vent through independent stacks that penetrate and extend above the boiler house roof. The facility is currentlyoperating underan operating permit number30-123-1 issued bythe WDEQ. The emission limits forthe units are as follows: Particulate Matter (PM) Oxides of Nitrogen (NOxl Sulfur Dioxide (S02) 0.10 Ib/MMBtu 0.7Ib/MMBtu 1.2 Ib/MMBtu Both units are subjectto Wyoming Air QualityStandards and Regulations (WAQSR) Chapter 5, Section 2 and 40 CFR Part 60 Subpart D - Standards of Performance for Fossil-Fuel Fired Steam Generators. Both units are eqUipped with continuous emission monitoring systems (CEMS) for NOxand S02 emissions, and data are maintained in pounds-per-MMBtu (lb/MMBtu) for each hourrecorded. Periodic monitoring via Method 5 (40 CFR 60 AppendixA) source testing is conducted to demonstrate compliance with the PM limits, and a Compliance Assurance Monitoring (CAM) plan has been proposed for demonstrating continuous compliance with the PM limits. The BART Air Modeling Protocol issued byWDEQ in September, 2006 defines visibility impairing baseline emissions as the maximum-24'hour aellfaleni'lssi6n rates-foftfieyears20Ql through2003.-T-heseemissTons represent a realistic depiction of anticipated annual emissions forthe source. These baseline emissions were used in the original report as the basis for estimating annual emission reductions forthe various control technologies evaluated and determining the annualized costs to achieve those reductions. The baseiine analysis showed that the permit limits were representative of the maximum 24-hour actual emissions forthe purposes of the BART analysis. The facility used the permit limits as representative of maximum emissions for the per'lod from 2001-2003 and as the basis for determining baseline (pre-BART) em'lssion rates. The original BART determination concluded that BART for General Chemical- Green River is controlling NO, emissions from the baseline emission rate of 0.7 to 0.49 Ib/MMBtu.

2-1 December 2008

## 3.0 Consideration of Emission Control Alternatives

The following is adescription of the LNB and LNB+SOFA NO, control systems under consideration. The level of boilerwork required to install each of these systems varies significantly. Installation of LNB is a matter of changing the existing burners and replacing them with burners with adifferent configuration in the same space. Installation of LNB+SOFA requires extensive modification ofthe boilerwindbox where new air ports are installed, air supplyprovided, and operator interface control provided. 

### 3.1 NOx 

### Combustion Controls Based on review ofthe literature and discussions with vendors, two levels of combustion modifications and low NO,burners have been identified as available for retrofit of tangentiallyfired boilers equipped like those at General Chemical- Green River. The combustion controls and the level of control provided are asfollows:

• LNB for an additional 10to 30 percent control; and

• LNB+SOFAfor an additional 25 to 45 percentcontrol. Dueto the small size, age, and design of the Combustion Engineering boilers at General Chemical- Green River, as well as the NOxcontrols already in place, the retrofit of low NOxcombustion control options is practically limited to the two options noted above and described below. The low NOxburner market is amature and cost-competitive business. Avarietyof manufacturers have developed competitive LNB and LNB+SOFA systems. In a retrofit application, the applicabilityof various product offerings and site-specific costfactors varyfrom boilerto boiler. Forthe purpose of this analysis, the analysis included obtaining datafrom Alstom Power Systems. Adesktop studywas conducted to evaluate the alternative levels of control, feasibility, emission reduction potential, and costs associated with installing NOxcontrols of Boilers Cand D. Alstom's LNCFSTM_P2 system (LNB) represents advancement in coal combustion technologyfortangentiailyfired units. The system was developed to offerthe advantages of significant NOxreduction through simple nozzle tip replacement. There are three main components tothe LNCFSTM_P2 system; the P2 coal nozzle tip and vaned close coupled overfire air, and concElntricfiring system"i! nozzle tips. Alstom's LNCFSTM Level II (LNB+SOFA) is amore aggressive NOxreduction firing system which also could be retrofitted to the General Chemical- Green River boilers. The system utilizesthe same general components described for LNCFSTM P2 system above, with the addition of a new SOFA System. The SOFA system employs astaged combustion process that diverts secondary airfrom the main windbox and injects it into the furnace above the main firing zone. This staged combustion process is one ofthe first principles of aggressive NOx reduction. The air is introduced intothe furnace through adedicated SOFAwindbox mounted above the main wlndbox. Typically, the SOFA windboxes are corner-mounted, butthis can vary based upon the particular geometryof the boiler and local interferences. 3.1.1 NOxControl Technical Feasibility Both of the two NOxcontrol technolog'les described above aretechnicallyfeasible and are evaluated further in the following sections.

3-1 December2008

## 4.0 Emission Reductions for BART Cost Evaluation

4.1 Actual Annual Emissions Baseline The estimated reduction in emissions from the annual baseline is used to evaluate the potential costs and benefits of each technicallyfeasible retrofit technology. While the visibility analysis usesthe potential 24-hour allowable emissions for NOx,the BART cost evaluation is based on actual annual emissions for 2001 through 2003. The annual NOxemissions are used as reported forthe three years and is shown in Table 4·1.

Table 4-1 Baseline Annual Average Emissions for 2001-2003 Data provided in ton/year Pollutant Year C Boiler D Boiler NO, 2001 1015.9 1436.2 2002 1147.2 1441.9 2003 1009.2 1527.1 Average 1057.4 1468.4


### 4.2 Effectiveness and Economic Analysis of NOxEmission Control Alternatives Detailed cost datafor NOxcontrol are included in Appendix A. Acost quotation form Alstom PowerSystems is included in Appendix 

### B. The data include assumed components of capital and operating costs, as shown in each table. Aside from the standard capital and operating costs, there are addWonal costs associated with modifications to existing units atthis site. These are the costs for replacement energyto provide steam and electricitywhen the existing units are being modified, the costs of lost production (fractional revenue stream) and the costs for demolition of existing structures and reconstruction within or nearthe existing units. This analysis assumes that lost production revenue would not be included in the cost of installation. The lost revenue wouid be based on the marg'lnal return (sales minus costs) for product, but market conditions dictate the magnitUde ofthis cost, and with this uncertaintyit is notincludedhere. Foroperating while one ofthe units is down for instailation of a new control device, the faciiitywould use the natural gasfired E-boiler. The E-boiiercan generate up to 350,000 Ibs/hour of steam, while the Cand D boiiers generate upto 400,000 and 660,000 Ibs/hourof stearn, respect'lvely. The E-boiier has a heat input rating of490 MMBtu/hour, the C boiler has a heat input rating of 534 MMBtu/hour and the D boiler has a heat input rating of 880 MMBtu/hour. The E-boilercan therefore replace onlya portion of the 

### Cand D boiler steam demand. Replacement energycosts during downt'lme are accounted for byassuming that retrofits would be made for each boilerat differenttimes. The cost analyses assume natural gas costs of $10/MMBtu for operation of the natural gas fired boiler (Boiler E) and coal costs of$2/MMBtu for acost differential of $8/MMBtu. Therefore the cost of the replacement steam is $94,000 per day (490 MMBtu/hrX$8/MMBtu X24 hr/day) for either unit. The downtime associated with Installation of each system is assumed to be 1-weekbeyond the normal turnaround t'lmefor LNB and 5-weeks beyond the normal turnaround t'lme for LNB 

### + SOFA. The replaced energycost forthese periods would apply to each of the Installed systems. At $94,000 per day, the cost is approXimately$658,000 forthe LNB options and $3,290,000 forthe LNB 

### + SOFA option. The estimate is based on a20 year period at 7 percent interest.

4-1 December2008Alstom's review of the current design and operation indicates that a substantial level of boiler refurbishing and tun'lng could lead to improved pre-controi NOxemissions above those tabulated for the 2001-2003 time period. Based on an engineering review, Alstom estimates that the pre-control NO

### xlevels could be brought down to 0040 Ib/MMBtu ahead of the installation ofthe revised burnerdesign. This value is used to determine the expected emission limits associated wHh each ofthe optional designs. 

### 4.2.1 Costs for BoilerC NOx The Alstom LNCFS P2 (LNB) option is expected to reduce NO

### xemissions by about 20 percent to 0.32Ib/MMBtu. This equates to an annual reduction from baseline emissions of about 419 tons peryear (tpy), at an estimated cost of $480 perton (AppendixA). The Alstom LNCFS Level 2 (LNB+SOFA) option is expected to reduce NO

### xemissions to about 0.28 Ib/MMBtu. This equates to an annual reduction from baseline emissions of 512 tpy, at an estimated annualized cost of $1,640 perton (Appendix A). Table 4-2 summarizes the total cost, annualized costs and incremental cost perton of each evaluated NOx combustion control technology. Table 4-2 Cost Evaluation of NO

### xcontrols for Boiler C Control NO, Controlled Cost Effectiveness Incremental Technology (tpy) Annualized Cost ($) ($/ton) Cost ($/ton) LNB 419 $202,000 $480 LNB+ SOFA 512 $838,000 $1,640 $6,800



### 4.2.2 Boiler D NO, The Alstom LNCFS P2 (LNB) option is expected to reduce NO

### xemissions to about 0.32 Ib/MMBtu. This equates to an annual reduction from baseline emissions of about 582 tpy, at an estimated cost of $360 perton (Appendix A). The Aistom LNCFS Level 2 (LNB+SOFA) option is expected to reduce NO

### xemissions to about 0.28Ib/MMBtu. This equates to an annual reduction from baseline emissions of 737 tpy, at an estimated annualized cost of $1,420 perton (Appendix A). Table 4-3 summarizes the total cost, annuali<:ed costs and Incrementaicostperton ofeach evaluated NO

### x combustion control technology. Table 4-3 Cost Evaluation of NO

### xcontrols for Boiler D Control NO, Controlled Cost Effectiveness Incremental Technology (tpy) Annualized Cost ($) ($/ton) Cost ($/ton) LNB 582 $211,000 $360 LNB + SOFA 737 $1,047,000 $1,420 5,420

4-2 December 2008

## 5.0 Selection of Control Scenarios

5.1 Control Options Modeling Emission Rates Visibility impacts were evaluated with modeling based on the maximum 24-hour NOxemission rate. For evaluating visibility improvement as a result of installing the BART options, the first step is to identifythe level of improvement in the 24-hour maximum emissions, from the baseline to the proposed new limits. Table 5-1 lists each control option, as applied to each unitfor separate NOxcontrols. The controlled emission rate used for modeling are also listed and are based on achieving an emission rate of 0.32 Ib/MMBtu for LNB and 0.28 Ib/MMBtu for LNB+SOFA and the maximum rated heat inputcapacityof the boilers. Table 5-1 Emission Ratesfor Visibility Evaluation for LNB and LNB+SPFA Baseline Peak24·hour Future Peak24-hour Unit Control Option Emission (Ib/hour) Emission (Ib/hour)

C LNB 376 171 C LNB + SOFA 376 150 D LNB 616 282 D LNB +SOFA 616 246

The baseline modeling visibility impact was determined for each modeling yearfor each of the above control option installed on both boilers. In accord with BART gUidance, the CALPUFF Method 6modeling setup was used to evaluate results of impacts on v'lsibilityat the nearbyClass I areas. Impacts were assessed atthe Jim BridgerWilderness Area and atthe FitzpatrickWilderness Area. In all cases, the maximum impacts are atthe Jim BridgerWilderness Area. Results of the modeling for each ofthese scenarios are provided in Table 5-2, showing the maximum impact for each yearforthe baseline analysis and the impactfor each scenario forthe worst case year (2001). The table liststhe results forthe Base Case for each ofthe three modeling years, using the percentchange based on the 20 percent cleanest days at each of the Class I areas;-- Results forthe Base Case show the maximum impacts BART impacts are evaluated on the reported 8th highest impactfor each of the 3years. The results showed thatthe maximum numberofdays with impacts above 5percent and 10 percent atthe Jim BridgerWilderness Area occurred in 2001. The impacts for that year haveformed the basis for evaluating each ofthe options.

5-3
December2008Table 5-2 Visibility Modeling Results .::.:., L, ,

2001 2002 2003 Days> than Days> than Days> than Class I 0.5 dv 1.0 dv MAXdv 8th Highest dv 0.5 dv 1.0 dv MAXdv 8th Highest dv 0.5 dv 1.0 dv MAXdv 8th Highest dv

Area D Sext D Bext D Bext D 

### Bert 

## o Sext D 

### Bert D Sext D 

### Bert D 

### Bert DBert Sext D Sext Method6, 20% BestDays Background, Base Case Emissions BridgerWilderness 21 6 2.19 0.841 16 2 1.70 0.72 16 5 2.46 0.967 Fitzpatrick Wilderness 8 2 1.77 0.502 7 2 1.81 0.469 10 0 0.79 0.591 Method6, 20% BestDays Background, LNB+SOFA BridgerWilderness 10 3 1.53 0.60

-- 

## -- -- 

## -- -- -- -- 

## -- Fitzpatrick Wilderness 5 1 1.25 0.37

-- -- 

## -- -- -- 

## -- -- -- Method6, 20% BestDays Background, LNB

• BridgerWilderness 10 3 1.60 0.62 

## -- -- 

## -- -- 

## -- -- -- -- Fitzpatrick Wilderness 5 1 1.30 0.39 ,

-- 

## -- -- -- -- 

## -- -- --

5-4 December2008

### 5.2 Control Scenario Options for Evaluation The Control Scenario options forvisibility impact modeling and economic analysis must consider a reasonable combination of equipment and control options. The evaluation of the visibility improvement due tothe BART options was conducted by grouping the choices in order of increasing controls for individual pollutants and for combinations of control technologies as follows: Base Case: No additional controls; Option 1: LNB; and Option 2: LNB+SOFA Forthis consideration, the optional controls were applied to each boilerforeach option. The combination of the modeling results and the economic analyses are provided in Chapter6.

5-5 December 2008

## 6.0 Selection of the Best Alternative for BART Control
6,1 Summary of Results The selection of BART controls Is based on the annualized costs for controis and the extent of improvement in visibil'ityat Class I areas, Forthis analysis the improvement is based on impacts at the Jim BridgerWilderness Area only, and is based on the 98th percentile impact at that area, Table 6-1 provides the calculated improvement in visibilityfor each control option, taken from the results in Table 5-2, The improvement is based on the added cost and increased control for the next option (Case 1 over the Base Case, and Case 2 over Case 1, respectively). The cost associated with each ofthe controls is also provided in Table 5-2, summarized from the data provided in Appendix A cost analyses. Table 6-1 Tabulation of Visibility Improvement at Jim BridgerWilderness Area and Annual Costs for Each Control Option Modeled dV Delta dV Annualized CQst ($1,000) Case Max Impact 8th-highest Max 8th Highest NO, PerdV Base 2.19 0.84 1 - LNB 1.60 0.62 0,59 0.22 $413,000 $1,877 2-LNB+SOFA 1.53 0,60 

## om 0,02 $1,885,000 $94,250

The caicuiated annualized cost for visibility improvementfor each ofthe control options is also provided in that table, based on the combined data for2001. The results are given in thousands of doliars for a delta deciview (threshold of perceptibility) improvement. The results of modeling for other years for the baseline and BART options are provided separateiy in the computer modeling archive, 

### 6.2 Annualized Costfor Implementing Control versus Decrease in Visibility Impairment BART Controls are selected based on the estimated cost for applying those controis and on the expected visibility improvement that would result from both LNB and LNB+SOFA, The retrofit of LNB is determined to represent BARTfor Boilers C and 

### Dat the General Chemical- Green River, This conclusion is based on technical Viability, degree of deciview improvementthat can be achieved, and the cost effectiveness in dollars per deciview improvement of the Control Scenario options evaluated.

6-1 December2008

## Appendix A Cost Analyses for BART Control Options

December 2008

## Table A-1 Boiler Data Sheet General Chemical
- Green River, WY --Control of Peak LNB LNB+SOFA Ib/hr @ 

### 0.32 ib/hr @ 

### 0.32 Unillnformation Ib/MMBtu Ib/MMBtu Boiler C Year Built 

### 1973 Manufacturer Combustion Engineering Rating 

### 534 MMBtu/hr 

### 400 klb/hr Steam Fuel Low-Sulfur Bitum'lnous Coal Firing Tangentially Fired Air Pollution Control Hot-Side ESP Soda Ash Coal Conditioning NOx Emissions 

### 376 Ib/hr Maximum 

### 171 150 0,50 Ib/MMBtu Average 

### 267 Ib/hr Average 

### 1057 TPY Average 

### 1147 TPY Max 

### (2001-2003) Exhaust Temperature 

### 320 of Boiler D Year Built 

### 1975 Manufacturer Combustion Engineering Rating 

### 880 MMBtu/hr 

### 660 klb/hr Steam Fuei Low-Sulfur Bituminous Coal Firing Tangentially Fired Air Pollution Control Hot-Side ESP Soda Ash Coal Conditioning NOx Emissions 

### 616 Ib/hr Mf!)<imunL 

### 282. I 

### 246 0,47 Ib/MMBtu Average 

### • 415 Ib/hr Average 

### 1468 TPY Average 

### 1527 TPY Max 

### (2001-2003) Exhaust Temperature 

### 320 of

## Table A-2 Combustion Modifications and Low NOx Burners 

## Boiler C

1 BasIc equipment for Aistom options are from Aistom Power budgetary costs of S170,000 for LNCFS P2 and $1,800/MMBtulhr for

LNCFS Level 2. 2 Total installed costs for Aistom options are based on low NOx burner factors from "Best Available Retrofit Technology Engineering

Analysis", Midwest RPO, March 30, 2005lhat ind'icaies total costs are 2.65 times basic equ'lpment. Alstom Alstom LNCFS LNCFS P2 Level 2 Basis (LNB) (LNB+SOFA) Capital Cost Basic Equipment 

### $ 175,000 

### $ 961,200 Note 1 Total Installed Cost not 

### $ 463,750 

### $ 2,547,180 Note 2 Includin[J Lost Revenue Lost Revenue 

### $ 658,000 

### $ 3,290,000 Total Installed Cost 

### $ 1,121,750 

### $ 5,837,180 Includinq Lost Revenue Annual Costs, 

### S/yr Increased Carbon Loss 

### $ $ 40,000 Possible 50% increase for LNCFS Level 2 IfLoss on lonition) . Operatlnq Labor 

### $ 32,850 

### $ 32,850 1 hrlshift at $30/hr Supervisor 

### $ 4,928 

### $ 4,928 15% of ooeratin[J labor· Note 3 Maintenance Labor 

### $ 8,974 

### $ 46,697 0.8% of total installed cost· Note 4 Maintenance Materials 

### $ 13,461 

### $ 70,046 1.2% of total installed cost Note 4 Overhead 

### $ 36,128 

### $ 92,713 60% of oper, maint. &supv labor + maint. mtl costs· Note 3 ProoertvTax 

### $ · 

### $

· 1% of total installed costs· Note 3 Insurance 

### $ · 

### $ · 2% of total installed costs· Note 3 Administration 

### $ · 

### $ · 2% of total installed costs· Note 3 Cap'ital Recoverv 

### $ 105,893 

### $ 551,030 7%, 20 years· Note 3 Total Annual Cost 

### $ 202,000 $ 838,000 Cost Effectiveness NOx Emissions before Base on historic average emission rate for 1,167 1,167 2001,2002, and 2003 and maximum rated Control, ton/yr heatTripLit 

### cifb6rrer. - -_
.. - After Control Emissions, 748 655 Based on information from Alstom ton/vr Emission Reduction, ton/yr 419 512 Cost Effectiveness, 

### $/ton 480 1,640 Incremental Cost 

### $ 636,000 Incremental NOx Reduction, ton/Yr 94 Incremental Cost Effectiveness, $/ton 6,800



### .

3 "8est Available Retrofit Technology Engineering Analysis", Midwest RPO, March 30, 2005, 4 8ased on EPA's CUECQST program. 5 EPA Air pollution Control Cosl Manual, Sixth Edition, Section 4, Pages 1·3 and 1-25. EPAJ452/8-002-001. January 2002.

## Table A-3 Combustion Modifications and Low NOx Burners 

## Boiler D

1 BaSIC equipment for Aistom options are from AIs10m PO'ller budgetary costs of $200,000 for LNCFS P2 and $1 ,aOOfMMBtu/hr lor

LNCFS Level 2. 2 Total installed costs for A!stom options are based on low NOx burner factors from "Best Available Retrofit Technology Engineering

Analysis", Midwest RPO, March '30, 2005 that 'Indicates total costs are 2.65 times basic equipment. This factor accounts for e Alstom Alstom LNCFS LNCFS P2 Level 2 Basis (LNB) (LNB+SOFA) Capital Cost Basic Equipment 

### $ 200,000 $ 1,584,000 Note 1 Total Installed Cost not Note 2 Includinq Lost Revenue $ 530,000 $ 4,197,600 Lost Revenue $ 658,000 $ 3,290,000 Total Installed Cost $ 1,188,000 $ 7,487,600 Includinq Lost Revenue Annual Costs, $/vr Increased Carbon Loss $ $ 40,000 Possible 50% increase for LNCFS Level 2 Loss on Iqnition) Operat'lnq Labor $ 32,850 $ 32,850 1 hr/shift at $30/hr Supervisor $ 4,928 $ 4,928 15% of ooeratina labor
- Note 3 Maintenance Labor $ 9,504 $ 59,901 0,8% of total installed cost - Note 4 Maintenance Materials $ 14,256 $ 89,851 1.2% of total Installed cost Note 4 Overhead $ 36,923 $ 112,518 60% of oper, maint. &supv labor + maint. mtl costs - Note 3 PropertvTax $ 

### - $

- 1% of total installed costs - Note 3 Insurance $ 

### - $ 

### - 2% of total installed costs - Note 3 Administration $ 

### - $ 

### - 2% of total installed costs - Note 3 Capital Recoverv $ 112,147 

### $ 706,829 7%, 20 vears - Note 3 Total Annual Cost $ 211,000 $ 1,047,000 Cost Effectiveness NOx Emissions before Base on historic average em'lssion rate for

. Control, ton/yr 1,816 1,BJI3.**200L~Q02,** and 

### 21tOa and maximum rated heat innut of boiler. After Control Emiss'lons, 1,233 1,079 Based on information from Alstom ton/vr Emission Reduction, ton/vr 582 737 Cost Effectiveness, $/ton 360 1,420 Incremental Cost $ 836,000 Incremental NOx Reduction, ton/vr 154 Incremental Cost Effectiveness, $/ton 5,420

, ,

3 "Best Available Retrofit Technology Engineering Analysis", Midwest RPO, March 30, 2005. 4 Based on EPA's CUECOST program. 5 EPA Air Pollution Control Cost Manual. Sixth Edition, Section 4, Pages 1-3 and 1-25. EPA/4521B-002-001. January 2002.

## Appendix B Cost Quote from Alstom Power**D~cerr.ber** 2008

# IPOWER SYSTEMS ENERGYAND ENVIRONMENTSYSTEMS Boiter f<etrofits, Willdsor Operations ALSTOM Powel h:. 2000 Day HIli Road Vv'indsol; CT 060'35 ':"1;'1 (B50) 2BS-90S2 Fax: (aw) 285./.301 , 

### October3, 2008

Mr. Mike Dahl General ChemicalCorporation GreenRiverWorks PO Box 551 GreenRiver, WY 82935 Subject: General Chemical- GreenRiverWorks, Boilers C & 

### D LowNOx ConcentricFiring System (LNCFSTM) P2Modification AlstomContractNumbers 22072 & 

### 21173 /Alstom SubmittalNo. 43033880 DearMr. Dahl: Alstom's Boiler Retrofits Windsor, CT Operations (the Company) is pleased to present General Chemical Corporation (the Purchaser) the attached budget submittal and budgetary estimate for an Low NOx Concentric Firing System (LNCFSTM) P2 Low NOx modification. The proposed materials are intended for use at the Purchaser's Green River Works, boilers C and D. The boilers arefurther identified as the Company's Original ContractNo. 22072 and 21173. The LNCFSTM P2 system utilizes a VCCOFATM nozzle tip to maximize close-coupled overfire air capacity. This offerdoes notrequire any coalptpemodifications:

--- - - - The Company's budgetalY estimate for the combustion system modifications is listed on the attachedpage. This estimate includes engineering services to design all requiredmaterials, material fabrication, equipmentarrangement drawings, instructionmanuals, and material delivery to the site. Budgetarypricing for Technical Services Supervisioncanbe includeduponyourrequest. Ifyou should have any questions or need additional inf0l11lation, please feel free to call me at (860) 285-9989. Sincerely,

Michael Taber Business Development BoilerRetrofits WindsorOperations

cc: Michael Zebell JeffEdwards

### Mr. MikeDahl October3, 2008 ATTACHMENT

BUDGETARYPRICING LNCFSTM

### P2 System BOILERC The Company's budgetary estimate for the proposed LNCFSTM P2 system, as described in the submittal document, is:OneHundred Seventy-FiveThousand Dollars $175,000.00

BOILERD The Company's budgetary estimate for the proposed LNCFSTM P2 system, as described in the submittal document, is: Two HundredThousand Dollars $200,000.00

The abovc estimate 

### does not include installation, technical services, or additional burner nozzle tip weld overlaymaterial.

Note: 

### This budget submittal gives apreliminmy indication ofthe basis ofwhich the scope ofwork describedherein can beprovided, anddoes notconstitute afirmprice, offerorcommitmentas to such scope. In particular, anyprices, delivery times orperformancefigures provided in this budget submittal are given without commitment and without regard to terms and conditions. This budgetprice has beenpreparedwith only the minimum technical investigation to determine thefeasibility ofthe requirements, ifany, thatyourorganizationprovidedto ours. To this end, we lookforward to disclissing the content ofthis submittal and, when appropriate, providing a moreformal offer. At that time, we can review andcomment to YOlir organization's terms and conditions or we will reference Olirstandardterms andconditions or apreviolisly agreed upon setofterms withyourorganization thatmay be appropriatefor thisproject. This letterforms an integralpartof this submittal.

## /J BudgetSubmit/a! To:


# General Chemical Corporation Green River Works Unit C and D

For: 

# Advanced Combustion System Changes

October3, 

## 2008 SubmittalNumber43033880 Copyright 2008 ALSTOM Power Inc. Al! Rights Reserved

### The information contained 

### in this Submittal is considered to be ofa confidential and proprietary nature, the rights to which belong to ALSTOM Power Inc. (Alstom/the Company), and are protected under the copyright and trade secret laws. This information is being furnished to the Purchaser to enable the Purchaser to evaluate the Company's Submittal. Ifa Contract is awarded to the Company based on this Submittal, then the information is to be included in whole or

### inpart in the Contract. Neither this Submittal nor any information contained therein, nor any proprietary inf01111ation furnished pursuant thereto, shall be disclosed to others, or used for any pUlpose other than that set forth above, without the prior written approval ofthe Company. The Company may seekto obtainpatent coverage on aspects ofthe Company's offering as described inthis Submittal.

### SubmittalNumber43033880



### TABLE OF CmHENTS
I.! INTENT 1 1.2 UNIT DESCRIPTION I 2.1 MATER1ALS AND SERVICES LISTING 1 

### 2.1.1 Low NOx Concentric Firing System (LNCFSTM) P2 I 3.1 TECHNICALDISCUSSION 2 3.1.1 LNCFSTM P2 Modification 2 3.1.2 Windbox Technical Details 3 3.2 F1ELD SERVICE SUPPORT 5 3.3 ITEMS/WORKNOT 1NCLUDED 

### 8 3.4 TERM1NATIONP01NTS · 

### 8 4.1 PERFORMANCEPREDICTIONS FORUNITS CANDD 9 4.2 SCHEDULE 9 

### 4.3 SHIPMENT 9 4.4 TAXES 10 4.5 CONDITIONS OF SALE 10 APPENDIX A.l 

### ORGAN1ZATIONAL CHARTOF PROPOSED PERSONNEL 1 A.2 QUALITYASSURANCE "."' , 2 A.3 TOTAL PROJECTMANAGEMENT.. 

### .4



### General Cltemical COIporalion Gadsden Sleam PlanI, 

### UnilNo.1 Table ofCon/enls

### SubmittalNumber43033880



### l.l INTENT Alstom's Boiler Retrofits Windsor, CT Operations (Alstom/the Company) proposes to furnish General Chemical Corporation (Jthe Purchaser) the material and services outlined in this Budget Submittal to provide a Low NOx Firing System. This submittal includes an offer for an LNCFSTM P2 modification. The materials are intended for the Purchaser's Green River Works, Units C and D. The boilers are further identified as the Company's ContractNumbers 22072 & 

### 21173. The Company has been asked to quote an LNCFSTM P2 modification for NOx reduction. PeakNOx is listed as 0.68 and0.83 IbIMBhl, respectively for eachunit. Giventhe western coal and vintage ofthese units, the NOx would be expected to be significantly lower than these rates. Discussions with ENSR indicate NOx may achmlly be closer to 0.5 ib/MBhl, but this has not been confirnled. The stated target for the NOx reduction system is 0.49 ib/MBh!.


### 1.2 UNIT DESCRIPTION There are two units at Green RiverWorks to be modified. Boiler C is rated for 400 klb/hr steamflow, and Boiler D is rated for 600 klb/hr. Both are fixed-T VU-40 units, boiler C with two (2) elevations ofcoal, andboilerD with three (3) elevations ofcoal. Intennediate aux compartments contain two (2) flame scanners. There is a single manual tilting CCOFA above the top end air compartmentonboth units.
2.1 '\1

### ATERIALS AND SERVICES LISTING 2.1.1 Low NOx Concentric Firing System (LNCFSD') P2 The following is a listing ofthe major equipment included within the scope ofthe LowNOx Concentric Firing System(LNCFSTM) P2 Modification. BOILERC Item Quantitv 

### 1. Eight (8)
2. Four (4)
3. Eight (8)



### GenemlChemical COl1Jomtion Green Ri,'er 'Yorks, Boiler CandD Description Coal nozzles with round-to-square transition P2 nozzle exit, fabricated from 309 stainless steel Fixed CFSTM nozzle tips, fabricated from 309 stainless steel VCCOFA nozzlc tips, fabricated ll'om 309 stainless steel



### Page 1

### SubmittalNumber 43033880



### 4. As Required Drawings and instruction manuals to incorporate the abovecquipment BOILERD 1.
2.


### 3. 

### 4. Twelve (12) Eight(8) Eight(8) As Required Coal nozzles with round-to-square transition P2 nozzle exit, fabricated from 309 stainless steel Fixed CFSTM nozzle tip fabricated from 309 stainless steel VCCOFA nozzletips fabricated from 309 stainless steel Drawings and instruction manuals to incorporate the above equipment
3.1 TECHNICALDISCUSSION 3.1.1 LNCFST>' P2 Modification Alstom proposes a Low NOx Concentric Firing System (LNCFSTM) P2 modification for General Chemical's Green River Works, Boilers C and D. The advanced design of the P2 Low NOx system was derived through tcsting comprehensive full-scale combustion inAlstom's PowerPlantLaboratories. The P2 Low NOx system, developed by Alstom, represents advancement in coal combustion for tangential firing. The system was developed to offer the advantages ofNOx emissions reduetion-through-modifiednozzle-tips. The P2 coal nozzle tip is part ofan advanced in-windbox low NOx firing system that includes Vaned Close-Coupled Overfire Air (VCCOFAfM), as well as optimized intermediate air compartments. (See Figure 1.) The system requires modifications that includc replacement ofintermediate airtips andtop end airnozzle tips. The Company predicts that a 10

- 30% NOx reduction can be achieved with the LNCFsn, P2 modification. This NOx reductionrange is afunction ofhowtheunit is currently operated to control NOx. Additional NOx reductions of50% or greater can be achieved with aseparated overfire air (SOFA) system. The Company plans to re-tip the main windbox with its patented LNCFST>I P2 modification. Since this is afixed-T windbox, the coal nozzle will be replaced with a new coal nozzle. This includes the !lange connection to the coal pipe and a

General Chemical C01])()/'{/tion GrecnRil'er Works, Boiler

### CandD Page 2

# t\l SubmittalNumber43033880

Figure I

- P2 CoalNozzle Tip modified nozzle exit. The nozzle exit will go from a round-to-square design and incorporate the center bluffwedges ofthe P2 coal tip. (Refer to Figure 1 for a Wide Range CoalNozzle (WRCN) tip design.) The intenllediate aux air elevations will contain a new fixed CFSTM nozzle tip with scanner ports. Both the top end air and CCOFATM air compartments will be modified with the VCCOFATM nozzle tip. The VCCOFA

### TM nozzle tip has a tlxed position, which eliminates the use ofthe manual tilt drive. No changes will be made to the bottom end airnozzle tip. An additional review ofthe damper box in each compartmcnt will be made, to determine ifthe damperarea-needs-to be resi2edto-maintain a-reasonable control range. Downsizing the damper box will simply require welding one or more ofthe existing blades closed. All nozzle tips will be manufactured from 309 stainless steel. 3.1.2 Windbox Technical Details Coal Compartments The coal compartments will be equipped with P2 coal nozzle tips and new support plates. A total ofeight (8) coal nozzles will be supplied for Boiler C and twelve (12) coal nozzles for Boiler D. The P2 coal nozzle tips have been designed to improve coal combustion occurring in the near-nozzle region ofthe boiler, which helps in NOx reduction.



### General Chemical Corporation Green River lVorks, BoilerCandD Page 

### 3

# t\ SubmittalNumber43033880



### Optional P2 Coal NozzleTip Weld Overlay Alstom's optional weld overlay includes coverage of the leading edges of the splitter plates, including the notched areas ofthe splitter plates, with overlay. The optional weld overlay design was incorporated to extend the life ofthe coal nozzle. Many Western coals have high silica and alumina content in their ash and exhibit higher erosion potential. Sub-bituminous coals require higher coal throughput and increasetheirerosionpotential. This optioncanbe priceduponrequest. Vaned Close-Coupled Overfire Air The VCCOFATM system is installed in the top most air compartment ofthe main windbox

- top end aircompartment. (See Figure 2 and 3.) The existing air nozzle tip plates are removed, and a set offixed vanes is installed into this compartmentto optimize the amountand injection angle ofthe close-coupled air.

Figure 2 - 

### VCCOFA 10" 

### Compartment Figure 3

- 

### VCCOFA 12" 

### COll1partl11ellt 

### Concentric Firing System (CFST") Redistribution ofthe secondary air to achieve maximum NOx reduction is critical. This is accomplished by replacing the existing auxiliary air tips with the Company's Concentric Firing System (CFSTM) offset air tips. A typical CFSTM nozzle tip is illustrated in Figure 4. The CFSTM offset airtip directs apOliion ofthe secondary air closer to the furnace walls relative to the firing angle of the fuel nozzles. Under Low NOx firing conditions with staged air, a rcducing atmosphere can exist near the furnace walls. An increase in furnace slagging can be the result ofthis rcducing atmosphere. CFSHt aids in the control of slagging by promoting an oxidizing atmosphere in these areas. The CFSTM offset air tip directs a portion of

General Chemical Corporation Green Rh'er Works, Boiler

### CandD Page 

### 4

### SubmittalNumber43033880

Figure 

### 4 - CFsn, AirNozzle Tip the secondary air closer to the furnace walls relative to the firing angle ofthe fuel nozzles. The CFSTM angle is detern1ined for each boiler based on fuels fired and fi.lrnace geometry. An additional benefit of reducing NOx may be realized with CFSTM air. The auxiliary air that is directed away from the [,leI stream prevents the fuel jet from entraining this air; thereby, reducing the combustion stoichiometry during volatilization and the initial stages ofchar combustion. This results in a very fuel rich primary flame, while maintaining-oxidizing eonditions-alongthe furnace walls and enhancing overall mixing in the fireball. All new adjustable yaw CFSTM air nozzle tips will be a one-piece design, fabricated using 309 stainless steel.



### 3.2 FIELD SERVICE SUPPORT It is recommended that the above modifications (installation, set-up, and initial start-up) be supervisedby the Company's representative to ensure a successful and trouble free retrofit. The Company can provide a Service Engineer (SE) to offer field technical support to the Purchaser as requested during the project. The SE can perform an array ofactivities prior to, during, and following the outage, as an advisor to the Purchaser. These services can bc provided on a per diem basis, at the rate prevailing at the time ofservicc, as requested by thc Purchaser.



### General Chemical CO/1)()ration Green River Works, Boiler C 

### andD PageS

### SubmittalNumber43033880

The following are typical activities that couldbe perfonned: Pre-Outage Activities The designated lead service engineer could begin project activities, which include but are not limitedto the following:

• Travel to site

• Inspect "as-received" burner equipment to review for potential problems and equipment shortages

• Perfonn pre-outage walkdowns to identify overlooked interference's and unit peculiarities

• Attend pre-outage meeting with the Purchaser and Constmetion for introductory and technical support/consultation reasons Ontage Activities During the outagethe lead engineerwould:

• Perform detailed windbox and burner inspections to identify areas, which could necessitate additional unanticipated work.

• Provide detailed inspection and checkout ofwindbox, nozzles, tips, linkages and pins during and upon completion ofinstallation.

• StrokemainbUl11ertilts to ensure full travel is achieved withoutundue strain.

• Check out MainWindbox dampers and stroke.

• Checkout and startup ignitors and scanners (ifapplicable)

• Provide general boiler outage supportandinspectiOlLas time avails._

• Provide technical service and direction to the Purchaser during the installation and cold commissionphases ofthe project.

• Performdetailed inspection and checkout ofall other material and equipmentprovided by the Company underthis scope offering. 

### Note: Boiler and Environmental Plant Services division ofALSTOM Power Inc. Technical Services Engineer ("Representative") shall act in an advisory capacity to Purchaser's personnel during the scheduled time period. Such Representative is not authorized to supervise operations or other business activities nor is the Representative authorized to operate any machinery or equipment. The responsibilities of the Representative are limited to advising and consulting in accordance with the provisions of the Submittal/contract. Nothing herein shall relieve the Purchaser or its othercontractors from the rcsponsibility for dimensional accuracy, quality or worlQ11anship, or asscmbly, erection and operation ofequipment. The Representativc shall have no rcsponsibility for inspection



### General Chemical C0I1}()ration Green River Works, Boiler 

### C{/lIdD Page 6

### SubmittalNumber43033880

services which may be requiredby local, state, federal, or independentregulatory agencies orboards. Post-Outage Activities 

### Post-outage activities consist of start-up support, and tuning support. Staffed with one qualified Service Engineer, the Company would:
o During initial fires conduct clean airflow checks on all mills looking for system resistance and ensuring propermill airflow.

o 

### Assist the purchaser with testing and setting coal fineness on the pulverizers. Fineness mustbe set in orderto tune the units.

o 

### Burner equipmentunittuning to meet contractobjectives athigh, mid and low load. o Once the unittuning bas been completed, the Lead Service Engineerwould prepare "as marked up" prints and close outreports. Alstom has not included any temporary test equipment for measuring NOx and CO and assumes the customerwillprovidethis datathroughpennanentinstmments orCEM. 

### Note: Safe operation of tbe unit is the responsibility of the Purchaser, under all circumstances. TUNING CRITERIA The following criteria are recommendedto bc providedbythe Purchaserto support tuning:

o 

### A consistent specified coal supply is required for the duration ofthe observation and tuning period.

o 

### Fly ash sampling is required for the tuning phase during each test.

o 

### Fineness tests are required prior to tuning. Additionally, recent clean airflow test data should be available. Fineness test equipment and ports are assumed to be available fr0111 the purchascr.

o 

### Existing plantO2

### monitors are calibratedand accurate.
o 

### Existing plant stack monitor for NOx and CO is available, calibrated and accurate.

• Main burnertilts are to be operable within the full tilt range.

• Secondary airdamper drives are to be operablc with afull one hundred percent (100%) stroke.

• Plant personnel support will be rcquircd to work with the control system in reconfiguration ofparameters, as required. Unit "scasoning" will bc required to determine accurate unit perfol1nance. One (l) week is estimatedbut is dependent on fuel characteristics.



### General Chemical COl1Joration Page 7 Green River Works, BoilerC

### andD

### SubmittalNumber43033880



### 3.3 ITEMS/WORKNOT INCLUDED The following items are not included in the scope ofthis Submittal and are to be supplied by the Purchaser:

• Installation ofEquipment

• Casing and insulation removal, and installation. Asbestos abatement, ifrequired.

• All control system modifications

• Performance Testing

• Electrical wiring andconduit

• Stmctural steel or modifications to the existing structural steel is not included in this offering, except for new suppOli steel required to support Company supplied equipment.

• Relocation ofexisting piping, cable trays, ducts, sootblowers and observation doors, if required.

• New ductwork systems and modifications to the existing ductwork systems, except for windboxes

• Pulverizer modifications

• Ignitors or scanners and any associatcd repairs orupgrades (ifapplicable)

• Coal piping modifications required to restore systembackto original design



### 3.4 TERMINATION POINTS The terminationpoints for this offering are as follows: Windbox Modification Components Materials to replace existing windbox, as shown in the materials list. Control Svstem SAMA logic drawing willbe supplied. All control system modifications are to be by the Purchaser or their control vendor. This includes system hardware, engineering, and programming. The Company will provide control system logic design for secondary air control.

General Chemical COl1JOra!ion Green River Works, BoilerC

### andD Page 8

### SubmittalNumber43033880

4.1 

### PERFORNIANCE PREDICTIONS FOR UNITS CAND D 

### Following the completion ofthe installation ofthe proposed equipment, the Company is predicting the following at 100% MCR: Emissions Prediction 

### LNCFST>IP2 System: Nitrogen Oxides, 

### Ib/MBtu: 10

- 30% reduction from baseline



### 4.2 SCHEDULE Based upon current engineering and production schedules, the Company anticipates that the material andlor equipment described in this Submittal could be shipped out to the jobsite thirty (30) weeks afterthe receipt ofan acceptable purchase order. This lead-time for material delivery does not include actual shipping time ·from the manufacturing point to the specified destination, or additional time which may be required for approval ofdrawings, plans, and specifications by the Purchaser. AlTangement drawings for the main windbox modifications will be submitted to the Purchaser approximately sixteen (16) weeks after the receipt of an acceptable purchase order. Preliminary installation drawings may be available for review upon Purchaser's request.


### 4.3 SHIPMENT The material andlor equipment described in this Submittal are quoted FOB. destination with freight prepaid and included to thejobsitc ornearest rail unloading facility. The prepaid freight charges included in the Submittal price are based on standard rail or truck transportation and routing as designated by the Company. Should the Purchaser request expeditious or special shipping, all additional charges resulting therefrom will be addedto the Purchaser's account. Switching, unloading and extra handling chargcs are not included In 

### the Company's quotcd price and, ifincurred, will be added to the Purchaser's account.



### General Chemical CO/poratio/l Page 9 Green River Works, Boiler C

### andD

### SubmittalNumber 43033880



### 4.4 TAXES 

### The Purchaser will pay all sales, use, value added, excise and other taxes which may bc levied or assessed in connectionwith the transferofthe material orequipmentfurnished by the Company (including such taxes which are levied or assessed in connection with such material or equipment which the Company obtains for use inperforming the services), or in connection with the perfonnance ofthe services, orin cOlmection with this Submittal or any resultant Contractorthe Company's performance underthis Submittal or anyresultant Contract. The Company's price does not include any suchtaxes. lfthe Company pays any suchtaxes, the Purchaserwill reimburse the Companypromptly upon receipt ofthe billing invoice. The Purchaser will provide the Company with any exemption certificates and otherrelevantdocuments in sufficienttime to claimanytax exemptions in association with this Submittal or any resultant Contractbutin all events will be suppliedpriorto shipment of material. This article shall prevail over any conflicting or inconsistent provisions containedelsewhere inthe documents comprising the Contractregarding taxes.
4.5 CONDITIONS OF SALE 

### The Standard Tenns and Conditions ofSale

- Domestic, located in the Appendix ofthis Submittal, shall govern this Submittal andany orderresultingtherefrom.

General Chemical CO/poration Green RiperfVorks, Boilcr C

### alldD Page 1()

### APPENDIX

### SubmittalNumber43033880

A.I ORGANIZATIONAL CHART OF PROPOSED PERSONNEL



# 1- Paul**Greni~**

ProjectMWlager

Windsor, CT

-'-""'1 Rich LaFJesh i Design Engi1leer !**--~--'** TimGr Desigll G BarbaraLane Planl1er/Seller/uler Charlie Hart Fie{(JServiceSupport
'"_'_··'·_,."••• '··'e •

__,_••,••



### General Chemical Corporation GreenRiver Works, Boiler C

### amI f) 

### App-l

### SubmittalNumber43033880

A.2 

### QUALITY ASSURANCE ALSTOM was ISO 9001 certified by the American Society of Mechanical Engineers (ASME) in November 1994 and later recertified by Hartford Steam Boiler Registration Services in July 2000 and June 2003. Our current ISO 900I certificate is with Lloyds Register Quality Assurance (LRQA) based upon their review ofALSTOM in November 2005. It 

### is valid until November 30, 2008. ALSTOM's ISO 9001 Quality System is documented in a Quality Systems Manual, which is supported by common quality procedures and departmental work instructions. A copy ofthis Quality System Manual and ourcUtTentISO Certificate canbeprovidedupon request. It 

### is the Company's policy to have and maintain manuals ofprocedures and operations which will be followed to assure that a productwithin the Company's scope ofsupply will be engineered, designed, and fabricated to meet or exceed the applicable Codes, Purchaser specifications and relevant Company standards. The following is a synopsis ofthe overall quality program.

• The Company's Quality Assurance Department reviews the Submittal and Contract requirements upon request and advises the appropriate department of any special requirements. Concerned departments will initiate the appropriate steps to assure the capacity and capability ofthe Company to comply with all contractual obligations. This review wiIl determine the nature andextent ofthe involvement ofthe Company's Quality Assurance Depmiment.

• It is the responsibility ofthe Company's Quality Assurance Department to audit the Product Design and Design Graphics Departments to assure that the unit design is completed in accordance with established procedures, using current, applicable Standards and Codes.

• All items are ordcred from qualified suppliers. Suppliers are approved by the Company's Quality Assurance and Supply Management Department. This qualifying procedure is delineated in aCompanyprocedure.

• The Company's procurement order system is the official medium for authorizing material to be purchased and work to be performed in its shops and its suppliers' shops. Appropriate tests, checks, and inspections are spccified to assure the quality of purchased and manufactured items.

• When deemcd appropriate, manufacturing processes cmployed by the Company and suppliers' shops, follow travelers, or similarshop documents that accompany the work and indicate applicable specifications, procedures, and techniques. This traveler is also the established documentto be signed-offon by the operator, foreman, inspector, and Non-Dcstructive Examination (NDE) pcrsonnel when appropriate. All work is performcd by welders, NDE persollnel, and inspcetors qualified in accordance with applicable Codcs and procedures.



### General Chemical Corporatioll Green Ri1'er Works, Boiler 

### CalldD App-2

# 9
""" Submit/alNumber43033880

• Fabrication of all items is accomplished to provide equipment confom1ing to the engineering drawings and specifications, and to present a quality workmanship appearance. All NOE required by the applicable ASME Code is performed, and the results are made available to the Authorized Inspector. Additional NDE for Company or supplier quality control purposes is perfol111ed on some product fom1s and on specific weldments, in accordance with Company standards or by contractual agreement.

• Inspection ofthe manufacturing operations is the responsibility ofthe individual plant Quality Assurance Department. Surveillance over the suppliers' work is the responsibility ofthe Company's Quality Assurance Department.

• The details ofthe quality program utilized (including references to test procedures, techniques, and associated Company standards) are contained in the Company's QualityAssuranceManual, the Fossil Engineering Quality Assurance Manual, and the Quality Assurance Manuals ofthe Company's manufacturing facilities and suppliers' facilities. The test procedures, instmctions, and associated Company standards are considered proprietary and are available for the Purchaser's review at the Company's and its snppliers' facilities.



### Gelleral ChemicalC011J01'lIIioll Greell River Works, Boiler C

### alldD App·3

### SubmittalNumber43033880



### AJ TOTAL PROJECT MANAGEMENT An individual Project Manager coordinates and directs the project effort throughout engineering, procurement, fabrication, delivery, installation, commissioning, start-up, performance testing and final close-out. The Company works on a team basis with the Purchaser. Focused, integrated teams, comprised ofboth Purchaser and Company personnel, are formed. Each Project Team includes aPurchaser Project Manager, a Company Project Manager, and Specialists in the areas ofengineering, procurement, installation, and commissioning. This winning team ensures thatthe high standards ofboth the Company and the Purchaser are maintained and that all available resources are utilized to the Purchaser's best advantage. The Project Team has a mutual goal- the successful completionofthe project. Figure 5 illustrates the Project Team, whileFigure 6depicts the major events demonstrating the integration ofthe ProjectTeam into aproject-focusedentity. 

### INTEGRATEDPROJECTTEAM
Purchaser'.s 

# IL- Purchasor Company 

# - PlannertScheduler ProJGctToom Project Projecl Manager Manager
f- Prolect Englnoor

,- - Purchasing Man-egGr



## - Inslallallon SQrvlCQS

Power Plant field Service laboratorIal Support

Balance of Plant "- Designer 

### Figure 

### 5 - Il1tegratedProjeet Team

General Cllelllica! Corporation Green River Works, Boiler C

### andD App-4

### SubmittalNumber43033880

PROJECTEXECUTION 

# ®**MonulOcfI.J'~** 

## I (lndol,fpplno

### I



## ,



## , Shop 

# I'r•. 

# ,,-**"~~9'l ~.'Il'"I'**  AP\'llQvlli PIO,<IiIC'1 cllvllfes A(etp.lonc' 1--+ nn,jlnl,,1"'>01**(le~'J1!** / 

# I Orde,

A.,..<Ird

# '"
Acllvltles Ptl1!lId I-**(jC~\l1r** Purchas40H CompanyA

Pmi",d**D.~tjoP""ffl** .--)0- 

# .-**®~_. OI;~**  .. 1'1IY,llOU Rl>vl.w**"'n~1Il,l1** 

### Figure 

### 6 - ProjectExecution The Integrated Project Team is focused on the end product. This allows all team members to interact and promote the success ofthejJroject. InlloyatiQl) is_CllCQUragedto support the project goaL Innovation in one function, such as design, may greatly enhance manufacruring ofa project. Under the Project Team concept, each function or piece ofa project is designedto enhancethe project goaL Utilizing the Total Project Management approach allows both the Purchaser and the Company to optimize resources to meet the shared commitment. Eliminating duplication ofefforis within both organizations can reduce use ofresources, The participants become partners in an effortto produce the desircd end result. The Project Manager provides single point contact for both the Purchaser and the Company, Thc single point contact affords resolution of all issues both internally and externally. Questions of a legal, technical, contractual, schcduling, financial, quality control, design, performance, installation, or commissioning nature arc properly directcd and addressed. Project Team members are provided with timely, accurate and coherent feedback and responses to questions and concerns.



### General Cllelllical Corporation Green Ril'er Works, Boiler C

### alldD App-5

### SubmittalNumber43033880

All team members receive accurate feedback on how their performance is affecting the overall project. The Project Manager cultivates team spirit. The Project Team members understand the requirements ofthe desircd result and are encouraged to fulfill the overall projectrequirements, The Project Manager is supported by a strong organization providing experienced assistance and support for scheduling, legal, financial and technical advice, 

### If required, additional Project Management personnel can offer direction and support to a project. Total Project Management does notrely solely upon the experience, skills, and availability ofone person withinthe Company, The Company and the Purchaser share a clear and common goal

- supplied equipment, in operation, performing as required, by the agreed upon date, When numerous contractors carry out a project, the only entity that retains ownership or accountability for the final product is the Purchaser. Individual contractors will have met their commitment when their part ofthe project is complete, Although "Engineering Complete" is an important milestone in any project, ifthe individual contractor's engineering effort has not supported and been integrated into the fabrication, installation, start-up or performance ofthe final product, the endresultmay notmeetthe Purchaser's requirements and expectations, The overall quality ofthe final product is within the control ofthe integrated ProjectTeam, Quality control and quality assurance of the many components and functions of the project's scope are enhanced when commitmentto the successful completion ofthe project is the goal ofthe Project Team, Decisions are based on what is best for the entire project, not on what may be enough to meetthe contractual requirements ofindividual components orfunctions,



### Gel1eral Chemical C0I1JOratiol1 Greel1 River Works, Boiler C

### al1dD App- 6

### SubmittalNumber43033880

(Goods and Services)

- Domestic/Rev: OSi!2'()5 ALSTOM Power Inc. STANDARD TERMS AND CO:'<DITlO:-;S OF SALE ARTICLE 1. Oefinitinns. 1.1 The words '",ve", "our", "ours", and "us" mean the Seller. 1.2 The words "you", "your", and yours" mC'dn the Purchaser. 1.3 The word "Agreement" means the agreement under which we provide you \vtlh goods, equipment and/orservices, and includes these Standard Terms andConditions ofSale andall documents expressly incorporatedbyreference und all attachments. 1AThe word "Goods" means thegoods oreqllipmentwhichwe will provide toyou under the Agreement. 1.5 The word "Services" means installation, simi-up, training, supervision, engineering. andlor other services which we will provide to you under the Agreement. 1.6 The word "Affiliate" means any entitywhich controls oris controlled by or is undercoml11oncontrol withus. ARTICLE 2, Duration ofSubmittalj Effect. 2, I We may withdraw any Submittal at anytime until we receiveyomwrittenacceptance, 2,2 Ifwe do not receive your written acceptance within 60 days ofthe date ofany Submittal, that Submittal will expire and be void, unless otherwise stated in the Submittal, 2,3 Anychanges whichyou wish to make to any Submittal must be expressly acceptedbyus inwriting; othenvise thosechanges will be void, 2.4 We expresslyrejectanyprovisions elsewhere in the Agreementwhich conflictwith these StandardTen1lS and Conditions ofSale, ARTICLE 3, Shipmentand Deliverv. 3.1 We will deliver the Goods F,O,B. points ofshipment or as stated in the Agreement. This will be the only delivery which we are required to make to you. Title andrisk ofloss will pass to you when we makethis delivety, ARTICLE4. Termination and Caucellation. 4,1 You maynot terminate orcancel theAgreementexceptby givingus written notice. 4,2 Ifyou te1111inate or cancel, you must pay us for ourcosts oflabor, material, engineering, administration, and overhead incuned up to the date we receive your notice, and demobilization costs, together with a reasonable profit on these costs. These costs include any tel111ination or cancellation charges from ourvendors, Ifyourequest, wewill provide you with documentation in supportofthese costs, 4.3 IfyoLl fail to make any paymentto us when due, and ifyolldo not make such paymentwithin seven days ofourgiving you notice thatyou are in default ofyoUl' obligation to make such payment, we sha11 have the right to cancel the Agreement. ARTICLE 5. Dehw, 5, I We will not be in default and we \vill not be liable to you for loss or d:ll11age Wl1ich results from delay or failure to perfonn any ofou)' obligations, ifthis delay or failure is caused by one or more cirCLImstances beyond our reasonable control ('Torce Majeure"), \vhether or not existing orforeseeable on the date ofthe Agreement. 5,2 Force tVlajeure includes, without limitation, acts ofGod, war, acts ofthe public enemy, civil disorder. riot, sabotage, governmental action or law or regulation, strikes, work slowdowns, or labor shortage or other labor problems, fire, nood, emthquake, severe weather, health and safety considerations, embargoes, transportation sh0l1age or delay, fuel or material sh0l1age, failure of petfonnance by a vendor or subcontractor, and your failure to give timely approval and comment to documents orotherwise perf011l1 YOllrobligations, 5.3 Our time ofperfonnance will be extended by the length ofany delay caused by Force Majeure plus a reasonable time to reSume our nOnllal operations. 5.4 Ifa delayresults from Force Majeure, we will cxcrcisereasonable efforts to minimize the delay; provided; thatwe will have no obligation to subcontractwork orto work atover-time rates orotherwise incuradditional costs and expenses, 5.5 Ifwe are ready to ship, but shipment is delayed through no fault ofaliI'S, then the date on which we are ready to ship will be regarded as the date ofshipment and delivery for all plllvoses, includingpayment. You will be responsible for the costs \Ind risks ofstorage und handling and risk ofloss commencingwith thatdate, 5.6 You will reimburse us for all extra costs and expenses which we incnr (i) as a result of:mydelay which you cause, and (ii) for omreasonable efforts to mitigate any delay causedbyForce Majeure. ARTICLE 6. Limited WlIrranh'. 6,1 We warrunt to you tll:1tthe Goods will be delivered free from defects in material and workmanship, 6.2 Ifyou discover a defect in material orworkmanship during the WarrantyPeriod (set forth below), yOLl must give us written notice within 10 (bys. We will, Elt our option, eithcr deliver to you a**l'eplae~11lent** part, F.O,B, point of**~hipment,** and installation**ther~of** shall be your t'csponsibility. or repair the defect in place or elsewhere on a straight-time basis, You will provide work area, utilities, access and egress to enable us to perforll1otll' obligations underthis Section 6.2, 6.3 We warrant to you that the Services, ifany. will be perf0l111ed in agood and wOI'kmanlike manner. Ifwithinthe Wammty Period you discov'er thElt any p0l1ion ofthe Services was not performcd in a good and workmanlike l1l[lnncr, yOll must give us notice within 10 days ofyour discovery and we will pelformagain that P0l1iotlofthe Services, 6A The WalTilnty Period as to Goods will expirc 12 months from the date ofdelivery, The WillTanty Period as to Services will expire 12 months from the date ofcompletion ofthe Services.

SI<lIIdardTerms & emu/iliu!lS

-**D(!me.~lic**


### Celleral Chemical C0'1JOratioll Creell River Works, Boiler CandD Page j d3
App- 7

### SubmittalNumber43033880

6.5 We\vill have no obligations to you under Sections 6.1,6.2 and 6.3 if: [i) you fail to operate or maintain the Goods in accordance with generally appro\'ed induslly practice: or IIi) you fail to operate or maintain the Goods in accordancewith instnlctions from LIS; or (iii) you fail to give us written notice within 10 days ofyour**discon~ry** ofadefect; or (iv) the Goods have been altered orrepaired by someone otherthan us; or IV) the Goods havebeen in:imlled by someone otherthan us, and the installation is notdone inaccordance with our inSlnlctions. 6.6 We warrant to yOll that <It delivery, the Goods will be free ofany liens or encLlmbrances. Ifthere are any such liens or encumbrances, we will cause them to be discharged promptly afteryouhavenotified us oftheirexistence. 6.7 We make no guaranty or \valTanty of the perfonnance of the Goous except as may be expressly identified as a Performance Guarantee elsewhere in the Agreement. Any other data and infon1lation pertaining to perf0l111anCe ofthe Goods, wllether stated in the Agreement or elscwbere, are for purposes ofillustration orestimate only, and are notguaranteed. 6.8 THE EXPRESS WARRANTIES WE MAKE TO YOU IN THIS ARTICLE 6 AND THE PERFORMANCE GUARANTEE, IF ANY, REFERRED TO IN SECTION6.7 ARE THE ONLY WARRANTIES AND GUARANTEES WE WILL MAKE. THERE ARE NO OTHER WARRANTIES OR GGARANTEES. WHETHER STATUTORY, ORAL, WRITTEN, EXPRESS, OR IMPLIED. IN PARTICULAR, THERE ARE NO IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. THERE ARE NO STATUTORY, ORAL. OR IMPLIED CONDITIONS. THERE ARE NO IMPLIED WARRANTIES AGAINST REDHIBITORY DEFECTS, VICES, OR DEFECTS, HIDDEN OROTHERWISE. 6.9 The remedies we provide to you in Sections 6,2, 6.3, and 6,6 and the remedies we expressly provide in connection with the Perfonnance Guanmtee, ifany, as referred to in Section 6.7 are, the only remedies you will have in th: event ofa breach ofwarranty or Perfommnce Guarantee. ARTICLE 7. Limitation ofLillbilih·. 7.1 For purposes of thIS Alticle 7, the \vords "we", "our", "ours", and "us" mean the Seller and its Affiliates, and their employees, agents, subcontractors, and suppliers, 7,2 Our liability to you under the Agreement or under any cause ofaction relating to the subject matter ofthe Agreement, whether based on contract, ,valTanty (including warranty against redhibitory defects or vices). tort (including negligence), strict liability, profeSSional liability, indemnity, contribution, orothenvise, will notexceed thebase price ofthe Goods andServices. 7.3 We will not be liable to you under the Agreement or underany cause ofaction relating to the snbject matter ofthe Agreement whetherbased on contract, walTanty (including warranty against redhibitory defects or vices), tOli (including negligence), strict liability. professional liability, indemnity, contributIon, or othenvise, for loss ofprofits or revenue or business opportunity, loss by reason ofshutdown ofYOllT facilities or inability to operate your facilities at full capacity, cost ofobtaining other means for performing the function of the Goods, increased cost of Goods or Services outside of our scope ofwork, costs ofreplacement power or capital, claims ofyour customers, or incidental orconsequential damages ofany nature. 7.4 \Ve will not be liable to you for any loss ordamage relating to anypOltion orcomponent ofthe Goods or Services which you sustain afterthe expiration ofthe WalTallty Periodpertaining to suchportion orcomponent ofthe Goods orServices. 7.5 You will have waived your right to sue liS at lrl\v or in equity underthe Agreement orunderflny caUse ofaction relating to the subject matter of**th~ Agreem~nl**  unless you commcnce your suit within one year from the date on which you sustain the loss ordamage which is the subject ofvoursuit. 7.6**Th~** provisions ofthis Attic1e 7shall prevail overany inconsistent provisions elsewhere in the Agreement. ARTICLE 8. Permits: Environmental and SafL'tv Responsibilities. 8.1 YOll wil1 (at yourexpense) obtain and maintain in force all permits and approvals necessary for the installntion and operation ofthe Goods and the pcliormance ofthe Services,-and the disposal of\vaste products. 8.2 lfyoll fail to perf0n11 yourobligations undcrSection 8, 1 orifyoll fail to do the following: (i)**oper~ltc** the Goods in complIance with <Ill applicable Irl\vs, mles, regulations, permits, and approvals, and with llperating instmctions (including safety-related instmctions) which we issue from time to time: (ii) dispose ofany wasteproducts in compliance with ajl rlpplicable laws, 11l1es. regulations. pemlits and approvals; (iii) in operating the Goods and disposing ofthe waste products, avoid contribu(mg to air or water pollution or any condition which is haZell'dolls to health; then you will indemnify us and hold us harmless and defend us at your expense from any claim. suit, or liability or penalty which may result from stIch failure, and yOIl \vaive any immunity from this indemnity obligation which Illcty be conferred by workers compensation laws. ,\RTICLE 9. Taxes. 9.l The Agreementprice shall include, andwe shall pay. all taxes and assessments for unemployment insurance, workers' compensation, social sccmity ctnd disability benefits, and othertaxcs which are based upon Ihecompens:llion pCliJ to persons employed by us oroursubcontractors for the performance ofany Sen'ices underthe Agreement. 9.2 The Agreement price shall include all applicable foreign, kderal, state and local income, duties, cxcise, and similartaxes payablewith respect to this Agreement pursll<lnt to laws or regulations in effect on the fiJ"st day of our Sttblllittalo The price excludes all Dlher dllttes, cxcise. or simibr t<\xes assessed by allY govelllmental body or agency with respect to the Goods and ServiceS, induding increases in the ctl1lount ofany tax or duty due to changes in laws or rcgulations. which become cft"\:ctive after the first date ofom Submittctl. lfwe aJ"c required to pay. or if you are required to withhold any tax orduty not included in the price ofthe Goods and**Sen'ic~,** then the amount ofstich tax shall be paid to tiS by you in addition to the prices provi{led herein.

S(aJld,wd Ter/1/s & Condilirms

- Domestic



### Genera! Chemica! Corporation Green River Works, Boiler C

### andD Poge 2 of3


### App- 8

### SubmittalNumber43033880

9.3 YOll will payor reimburse us all sales. use, and other similar taxes. which may be levied or assessed in connection \vitll the transfer ofthe Goods and Services furnished by us. Our price does not indude any such tax.es. You will provide us with any exemption cel1ificates and otherrelevant documents in stlfficicnt time to claim any lax exemptions associated with this Agreement, but in all events will be supplied prior to shipment ofll1utefial. Additional taxes along with associated interest find penalties assessed to liS by govemment authorities for denied exemption shall be your responsibility. 9.4 The tirm price shall include or, ifpricing is non-firm, we \vill invoice you for, and we shall pay, all sales, use, and other similar taxes, associated with lools. rentals, and cotlsumables utilized dming erection or installation, orfor the perfolmance ofany other Services under the Agreement. ARTICLE 10. Patents. 10.1 \Ve will defend you !lgainst any suit whichclaims that the Goods infringe any united States orCanadian patent. We will satisfy anyjudgment for damages entered against you in such suit. [I' sllchjudgmentenjoins yOll from using the Goods. then \ve shall at ouroption: (i) obtain foryou the right to continueusing the Goods; or (ii) eliminate the infringement by replacing or modifying all orpart ofthe Goods; or (iii) take back the Goods and refund 10 you all payments on the price which wehave received. In this event, neitheryou nor\ve will have any claim againstthe otherunderthe Agreement oradsing out ofthe subjectmatterofthe Agreement. 10.2 We \vill have no obligation under this Article 10 ifyou fail to notify us promptly ofany claim or suit for infringement or ifyOll fail to cooperate with lIS in conductingthe defense, or ifinfringementresults from: (i) liseofthe Goods exceptin accordance withour instlUctiollsto**YOll~** or (ii) anychange made to the Goods afterwe makedelivery ormade at yOul'**request~** or (iii) any portion ofthe Goods madepursuantto yourdesign. 10.3 Theremedies which weprovide to you in this Article 10 arethe only remedies yollwill have in the event ofany infringement claim. ARTICLE t I. Changes. 11.1 We will not make changes in the Goods orServices unless yOll andwehave executedawritten Change Order for suchchange. 11.2 TheChange Order will includeaprice adjustmentforany added costs orthe change plus areasonable profit. 11.3 Ifthe change impairs our ability to satisfy OLlr obligations to you, including meeting delivery schedules and any Pelformance Guarantees, the Change Orderwill includeappropriate modifications to the Agreement. 11.4 Ifafter the earlier ofeither (i) the date ofthe Submittal on which the Agreement is based or (ii) the date ofthe Agreement, new or revised governmental orcode requirements shall require achange in the Goods or Services, the**chan~e** \vill be the subjectofaChange Orderpursuant to this Article II. ARTICLE 12. Confidentiality; Use ofDrawings. 12.1 You acknowledge that the infonnation which we submit to you in connection with any Submittal or this Agreement includes our confidential andproprietmy infonmltion, both ofatechnical and commercial nature. 12.2 Youwill notdisclose ourconfidential andproprietary infommtionto thirdparties without ourpriorwrittenconsent. 12.3 You will not pennit anythil·d pal1y to fabricate components oflhe Goods from our druwings. YOll will indemnifyus and hold us harmless and defend us from any claim. suit, or liability based on personal injury (inclnding death) or property damage related to any component ofthe Goods \vhich is fabricated by athird pattywithoutour prior\vdttcnconsent. 12.4 The Goods may contain software and related instl1lctions lind other materials which we and our suppliers have provided. Your use thereof shall be subject to license conditions andotherrestrictions which we orour suppliers may impose as required to maintainconfidentiality. J2.5 You representto LIS that you have the rightto disclose to us any drawings orother infon11atiol1 which you provide to us under the Agreement, without condition. ART[CLE-13;,gEO Compliance. 13.1 We shall at all times comply with the requirements ofExecutiye Order 11246. ARTICLE 14. End User, 1.:1-.1 Ifyou are not the End l)ser ofthe Goods or Services. then you will use yourbest efforts to obwin the End L.:ser's conse-nt to be bOllnd to us by the provisions ofArticle 6, Article 7, and Article 8("End UserConsent"). 14.2 IfyoLl do not obtain such End User Consent, then you shall indemnify tIS and our Affiliates and our**a~ents,** employees, subcontractors, and suppliers tl'om any liability, cost, loss orexpense for which we would not ha\·e been liable orfrom which wc wonld have been indemnified if you had obtained the End UserConsent. ARTICLE 15. Entire ,-\ lfrcement. 15,1 The Agreement contains thc entire understanding between yOll Hnd us, und supersedes any prior oral and written understAndings between you and us concerning the Goods and Services, including any document which is not expressly incOlvorated by reference into this Agreement. YOli ackno\vledgethatyou are not relying on any representation notexpresslycontained ill the Agreement. 15.2 No modification to the Agreementwill be effective unless in wl"iting duly executedbyyou and us. 15.3 The Agreement is binding on the parties aml their respective successors and assigns. ARTiCLE 16, Invnlidit\'. 16.1 Ifa final decision ofa COl\lt ofcompetentjurisdiction holds invalid aportion ofany sentence ofthis Agreement, or asentence ofany section ofthis Agn.::el11ent, or asection oflIny Article, or any At·tiele ofthis Agreemcnt, the remainder ofsuch sclltence or section or Article or this Agreement, as thecase Illay be,shall be valid. ARTICLE 17. Governing Law. 17.1 The Agreementwill be governed by and construed aecording to the laws ofthe State ofConnecticut. L'.S.A.

S/ilI/d,ml Terms & COi/ditirJl/s- Domestic


### General Chemical Corporation Green River Works, Boiler C

### andD Page 3

## on
App- 9AECOM Env'lfonment

www.aecom.com About AECOM Environment Evolving to better serve global clients, AECOM has formed AECOM Environment-a new global business line that utilizes the environmental management resources of ENSR, Earth Tech, STS and Metcalf & Eddy. With over 4200 staff worldwide in 20 countries, AECOM Environment is one of five new giobally integrated business lines of AECOM (AECOM Water, AECOM Transportation, AECOM Design, AECOM Energy and Power). As AECOM Environment, we can offer clients broader and deeper environmental health and safety services with greater technicai expertise across greater geographies-closer to sites and facilities. Plus, we can deliver more value by leveraging the full resources of AECOM's worldwide staff of 41,000 people in 450 offices. Our commitment to the success of your projects and your organization is our top priority, as we harness the global capabilities of AECOM.



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