### RE: Coal Creekfly ash cost documentation Dendy, Lewis H. 

### to: Gail Fallon 06/20/2011 06:55 AM Cc: "Semerad, Jim L.", "Bachman, Tom A." From: "Dendy, Lewis H." <Idendy@nd.gov> To: Gail Fallon/R8/USEPAlUS@EPA Cc: "Semerad, Jim L." <jsemerad@nd.gov>, "Bachman, Tom A." <tbachman@nd.gov> History: This message has been replied to. Gail, GRE's response to your question below is at the beginning of the attached message string. Lew Dendy Environmental Scientist ND Division of Air Quality 918 E. Divide Ave., Bismarck, ND 58501-1947 Ph 701.328.5188, Fax 701.328.5185 http://www.ndhealth.gov/AQ/Airhomepage.htm -----Original Message----­ From: Fallon.Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] Sent: Thursday, June 16, 2011 11:30 AM To: Dendy, Lewis H. Cc: Semerad, Jim L.; Bachman, Tom A. Subject: RE: Coal Creek fly ash cost documentation Hi Lew, Did GRE provide any explanation of why their original sales price of $36/ton was so far off? Thanks for coordinating this. Gail Gail Fallon Regional Haze Program Manager Air Quality Planning Unit (8P-AR) US EPA Region 8 1595 Wynkoop Street Denver, CO 80202-1129 Phone: 303-312-6281 Fax: 303-312-6064 Email: Fallon.Gail@epa.gov

From: "Dendy, Lewis H." <ldendy®nd.gov> To: Gail Fallon/R8/USEPA/US@EPA Cc: "Bachman, Tom A." <tbachman@nd.gov>, "Semerad, Jim L." <jsemerad@nd.gov> Date: 06/16/2011 05:51 AM Subject: RE: Coal Creek fly ash cost documentationGail, The attached documents are provided in response to your request below
. The two GRE emails you requested below were mentioned in the 12/2/09 NDDoH response to Department of the Interior (DOI) comments on the Coal Creek BART determination which said: "GRE emails dated 8/8/08 and 8/17/08 provide additional information on this issue (ash sales), as does a summary of a University of Kentucky study on the matter." The first attachment above is the 8/8/08 GRE email. The second attachment is the 9/17/08 GRE email which was mistakenly referred to as dated 8/17/08. This email contains the abstract of the University of Kentucky study. A review of our response to DOI comments indicates we addressed the sale of fly ash and not the mitigation of ammonia in fly ash. The third attachment is the document from our Coal Creek BART file that I was recalling which mentioned the mitigation of ammonia from fly ash. The last attachment is the email we received from GRE responding to your request. Please let me know if we can be of further assistance. Thanks, Lew Dendy Environmental Scientist ND Division of Air Quality 918 E. Divide Ave., Bismarck, ND 58501-1947 ph 701
.328.5188, Fax 701.328.5185 http://www.ndhealth.gov/AQ/Airhomepage.htm -----Original Message----­ From: Fallon
.Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] Sent: Wednesday, June 01, 2011 1:31 PM To: Bachman, Tom A.; Dendy, Lewis H. Subject: Coal Creek fly ash cost documentation
Tom and Lew, Per our phone conversation yesterday, we are looking for additional documentation to support your NOx BART determination for Coal Creek. Specifically, we are interested in the following cost information pertaining to lost fly ash sales which is a large component of the cost for SCR and SNCR: 1. Supporting documentation (such as invoices/bills of sale) for fly ash pricing and tonnage

- Several years of data would be helpful to show any price andtonnage fluctuations 2. Supporting documentation regarding landfill costs 3
. Cost to remediate the ammonia in the ash

- Headwaters Resources' web literature indicates that it can add a chemical reagent to the ash to convert the ammonia

### to harmless compounds
. The cost of this process would seem to be relevant to the BART analysis
. Perhaps some of this information has already been provided somewhere in the SIP. Lew mentioned you 

### may have provided something in response to FLM comments on ammonia mitigation. In Appendix J.l.2 of the SIP, I found where ND references a couple of Great River Energy emails and a Univ. of Kentucky study regarding ammonia in fly ash that are supposed to be attached but are not. Maybe there is something relevant there. Please provide these attachments as well
. Thanks for any assistance you 

### can offer. Gail
Gail Fallon Regional Haze Program Manager Air Quality Planni"ng Unit (8P-AR) US EPA Region 8 1595 Wynkoop Street Denver, CO 80202-1129 Phone: 303-312-6281 Fax: 303-312-6064 Email: Fallon.Gail@epa.gov [attachment "GRE 8 8 08 Email.pdf" deleted by Gail Fallon/R8/USEPA/US) [attachment "GRE**9-1~** 

### 08 Email.pdf" deleted by Gail Fallon/R8/USEPA/US) [attachment "Removing NH3 From Fly Ash.pdf" deleted by Gail Fallon/R8/USEPA/US)

----- Message from "Nelson, Debra GRE-MG" <dnelson@grenergy.com> on Wed, 15 Jun 2011 16:09:56 -0500

----­ To: "Dendy, Lewis H." <ldendy@nd
.gov>
cc: "Bachman, Tom A." <tbachman@nd.gov>, "Semerad, Jim L." <jsemerad@nd.gov> Subject: RE: Coal Creek fly ash cost documentation Lew, We respectfully submit our response to the questions raised by US EPA Region 8. 1. Fly ash Pricing and tonnage: Fly ash sales at Coal Creek Station are paid from the weigh tickets obtained from the fly ash loaded trucks. The marketer of the fly ash will pay GRE directly from the accumulated truck weigh tickets on a monthly basis. GRE does not invoice the marketer for the ash. The existing records for sales are the individual truck weigh tickets. The attached document, FlyashSales2006-2010.pdf, contains the total fly ash sales in tonnage and in dollars received, and a calculated $/ton. This data was compiled from the thousands of individual weigh tickets obtained from the ash haulers. If there is still a need for the supporting documentation for these years we can provide copies of all the weigh tickets. This process will take some time to complete and some resources dedicated to completing. Please let me know if further documentation is required. 2. Landfill disposal costs: During the development of the CoalCreek Station BART analysis, CCS was also re-evaluating the model for landfill disposal costs. When the revised BART analysis was submitted to NDDH the Landfill model was predicting a $6/ton disposal cost
- the model was not finalized at that time
. The value used in the BART analysis was $6/ton based upon an email message from the plant to the engineering firm contracted to conduct the analysis
. Upon refinement and finalization of the model, the final value contained within the model puts our landfill disposal costs at $7.19/ton (in 2007 dollars). The attached document, LandfillDisposal.pdf, is a presentation of the final model values. 3
. Inclusion of ammonia mitigation in BART analysis: A quick evaluation of the BART Analysis data reveals that the inclusion of ammonia mitigation technology has the same effect on the BART analysis as land filling the ash. The estimated installed cost for ammonia mitigation was roughly estimated by Headwaters at $5-$10 per ton of ash. Landfill costs are estimated by the final landfill model at around $7.19 (in 2007 dollars) per ton of ash. The attached tables (NH4MitigationCosts.pdf) include the ammonia mitigation technology in the SCR and SNCR economic analysis. The final cost summary table has remained virtually the same. Whether the analysis utilizes landfill costs or ammonia mitigation costs, it does not change the conclusions of the BART analysis that SCR and SNCR technologies are not cost effective. If there are further questions please feel free to contact me. I will be unavailable June 16 

### & 17th but will be available to address further questions starting June 20th. Deb Nelson Environmental Services Great River Energy (763)445-5208 dnelson@ grenergy.com

- - ---Original Message----­ From: Dendy, Lewis H. [mailto:ldendy@nd.gov] Sent: Wednesday, June 01, 2011 2:23 PM To: Nelson, Debra GRE-MG Cc: Bachman, Tom A.; Semerad, Jim L. Subject: FW: Coal Creek fly ash cost documentation Hello Deb, Please see the EPA/R8 email below for an additional request for supporting information to assist them with their decision on BART for Coal Creek Station. We request that GRE provide any available information in response to the questions. I'll review our file for anything that we might have. Please let Tom or I know if we can be of assistance. Thanks, Lew Dendy Environmental Scientist ND Division of Air Quality 918 E. Divide Ave., Bismarck, ND 58501-1947 Ph 701.328.5188, Fax 701.328.5185 http://www.ndhealth.gov/AQ/Airhomepage.htm

### -----Original Message----­ From: Fallon
.Gail@ epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] Sent: Wednesday, June 01, 2011 1:31 PM To: Bachman, Tom A.; Dendy, Lewis H. Subject: Coal Creek fly ash cost documentation
Tom and Lew, Per our phone conversation yesterday, we are looking for additional documentation to support your NOx BART determination for Coal Creek
. Specifically, we are interested in the following cost information pertaining to lost fly ash sales which is a large component of the cost for SCR and SNCR: 1. Supporting documentation (such as invoices/bills of sale) for fly ash pricing and tonnage

- Several years of data would be helpful to show any price and tonnage fluctuations 2. Supporting documentation regarding landfill costs 3. Cost to remediate the ammonia in the ash

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

### chemical reagent to the ash to convert the ammonia to harmless compounds. The cost of this process would seem to be relevant to the BART analysis. Perhaps some of this information has already been provided somewhere in the SIP. Lew mentioned you may have provided something in response to FLM comments on ammonia mitigation
. In Appendix J.1
.2 of the SIP, I found where ND references a couple of Great River Energy emails and a Univ. of Kentucky study regarding ammonia in fly ash that are supposed to be attached but are not. Maybe there is something relevant there. Please provide these attachments as well. Thanks for any assistance you can offer
. Gail
Gail Fallon Regional Haze Program Manager Air Quality Planning Unit (8P-AR) US EPA Region 8 1595 Wynkoop Street Denver, CO 80202-1129 Phone: 303-312-6281 Fax: 303-312-6064 Email: Fallon.Gail@ epa.gov

NOTICE TO RECIPIENT: The information contained in this message from Great River Energy and any attachments are confidential and intended only for the named recipient(s). If you have received this message in error, you are prohibited from copying, distributing or using the information. Please contact the sender immediately by return email and delete the original message.[attachment "NH4MitigationCosts.pdf" deleted by Gail Fallon/R8/USEPA/USl [attachment "FlyashSales2006-2010.pdf" deleted by Gail Fallon/R8/USEPA/USl [attachment "NDDH- Landfill.pdf" deleted by Gail Fallon/R8/USEPA/USl

----- Message from "Nelson, Debra GRE-MG" <dnelson@grenergy.com> on Thu, 16 Jun 2011 15:24:24 -0500 ----­ To: "Semerad, Jim L." <jsemerad@nd.gov> cc: "Bachman, Tom A." <tbachman@nd.gov>, "Dendy, Lewis H." <Idendy@nd.gov>

### SUbjec~ RE: Coal Creekfly ash costdocumentation Jim, The $36/ton was a error propagated with our2nd "original" submittal in 2007. I looked into ouroriginal 2006 submittal (which we had recalled) and the $/ton was $5. So in reconfiguring the spreadsheets the value was mistyped and GRE submitted the improper number. Deb Nelson Environmental Services Great River Energy (763)445-5208 dnelson@grenergy.com -----Original Message----­ From: Semerad, Jim L. [mailto:jsemerad@nd.gov] Sent: Thursday, June 16, 2011 11 :42 AM To: Nelson, Debra GRE-MG Cc: Bachman, Tom A.; Dendy, Lewis H. Subject: RE: Coal Creekfly ash costdocumentation
Deb: Iam attaching an email from EPAthat poses a follow-up question to the submittal referenced below. Please reply so thatwe can respond to EPA. Note that Lew is out until nextweek. Thanks.
Jim Semerad Division ofAir Quality State Dept. of Health (701) 328-5188 jsemerad@nd.gov Division Website: http://www.health.state.nd.us/AQ/Airhomepage.htm-----Original Message----­ From: Dendy, Lewis H. Sent: Thursday, June 16, 2011 6:53 AM To: Nelson, Debra GRE-MG Cc:Semerad,Jim L.; Bachman,Tom 

### A. Subject: RE: Coal Creekfly ash cost documentation Deb, Iappreciateyour effort and GRE's quick response. Thankyou very much, Lew Dendy Environmental Scientist NO Division ofAir Quality 918 E

. Divide Ave., Bismarck, NO 58501-1947 Ph 701.328

.5188, Fax 701

.328.5185 http://www.ndhealth

.gov/AQ/Airhomepage.htm -----Original Message----­ From: Nelson, Debra GRE-MG [mailto:dnelson@grenergy.comj Sent: Wednesday, June 15, 2011 4:10PM To: Dendy, Lewis H. Cc: Bachman, Tom 

### A.; Semerad, Jim L. Subject: RE: Coal Creekfly ash cost documentation Lew, We respectfully submit our response to the questions raised by US EPA Region 8

. 1. Fly ash Pricing and tonnage: Fly ash sales at Coal Creek Station are paid from the weigh tickets obtained from the fly ash loaded trucks. The marketerofthe fly ash will pay GRE directlyfrom the accumulated truck weigh tickets on a monthly basis. GRE does not invoice the marketerfor the ash

.The existing records for sales are the individual truck weigh tickets. The attached document, FlyashSales2006-201O.pdf, contains the total fly ash sales in tonnage and in dollars received, and a calculated $/ton

.This data was compiled from the thousands ofindividual weigh tickets obtained from the ash haulers. Ifthere is still a need for the supporting documentation for these years we can provide copies ofall theweigh tickets. This process will take some time to complete and some resources dedicated to completing

. Please let me know iffurther documentation is required

. 2

. Landfill disposal costs: During the developmentofthe Coal Creek Station BART analysis, CCS was also re-evaluating the model for landfill disposal costs
.When the revised BART analysiswas submitted to NDDH the Landfill model was predicting a $6/ton disposal cost - the model was notfinalized atthat time

. The value used in the BART analysiswas $6/ton based upon an email messagefrom the plantto the engineering firm contracted to conductthe analysis. Upon refinement and finalization ofthe model, the final value contained within the model puts our landfill disposal costs at $7.19/ton (in 2007 dollars). The attached document, LandfiliDisposal.pdf, is a presentation ofthe final model values

. 3

. Inclusion ofammonia mitigation in BART analysis: A quickevaluation ofthe BART Analysis data reveals that the inclusion ofammonia mitigation technology has the same effect on the BART analysis as land filling the ash

.The estimated installed costfor ammonia mitigation was roughly estimated by Headwaters at $5-$10 per ton ofash

. Landfill costs are estimated by the final landfill model ataround $7.19 (in2007 dollars) per ton ofash. The attached tables (NH4MitigationCosts

.pdf) include the ammonia mitigation technology in the SCR and SNCR economic analysis. The final cost summarytable has remained virtually the same.Whetherthe analysis utilizes landfill costs or ammonia mitigation costs, it does not change the conclusions ofthe BART analysis that SCR and SNCR technologies are not cost effective

.Ifthere are further questions please feel free to contact me. Iwill be unavailable June 16 & 17th butwill be available to addressfurther questions starting June 20th. Deb Nelson Environmental Services Great River Energy (763)445-5208 dnelson@grenergy

.com -----Original Message----­ From: Dendy, Lewis H. [mailto:ldendy@nd.gov] Sent: Wednesday, June 01, 2011 2:23 PM To: Nelson, Debra GRE-MG Cc: Bachman, Tom 

### A.; Semerad, Jim 

### L. Subject: FW: Coal Creekfly ash costdocumentation Hello Deb, Please see the EPAJR8 email belowfor an additional requestfor supporting information to assistthem with theirdecision on BARTfor Coal Creek Station. We request that GRE provide any available information in response to the questions. I'll review ourfile for anything thatwe might have

. Please letTom or I know ifwe can be ofassistance

. Thanks, Lew Dendy Environmental Scientist ND Division ofAir Quality 918 E

. DivideAve., Bismarck, ND 58501-1947 Ph 701.328.5188, Fax 701

.328.5185 http://www

.ndhealth.gov/AQ/Airhomepage

.htm

-----Original Message----­ From: Fallon

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

.gov] Sent: Wednesday, June 01,20111:31 PM To: Bachman, Tom 

### A.; Dendy, Lewis H

. Subject: Coal Creekfly ash cost documentation
Tom and Lew, Perour phone conversation yesterday,we are looking for additional documentation to supportyour NOx BART determination for Coal Creek

. Specifically, we are interested in the following cost information pertaining to lostfly ash saleswhich is a large component ofthe costfor SCR and SNCR:

1

. Supporting documentation (such as invoices/billsofsale)forfly ash pricing and tonnage

- Several years ofdata would be helpful to show any price and tonnage fluctuations 2. Supporting documentation regarding landfill costs 3. Cost to remediate the ammonia in the ash

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

## •

chemical reagent to the ash to convertthe ammonia to harmless compounds

. The cost ofthis processwould seem to be relevantto the BARTanalysis

. Perhaps some ofthis information has already been provided somewhere in the SIP

. Lew mentioned you may have provided something in response to FLM comments on ammonia mitigation

. In AppendixJ

.1

.2 of the SIP, Ifound where ND references a couple ofGreat River Energyemails and a Univ

.of Kentucky study regarding ammonia in fly ash that are supposed to be attached butare not. Maybe there is something relevant there

. Please provide these attachmentsaswell. Thanks for any assistance you can offer. Gail
Gail Fallon Regional Haze Program Manager Air Quality Planning Unit (8P-AR) US EPA Region 8 1595Wynkoop Street Denver, CO 80202-1129 Phone: 303-312-6281 Fax: 303-312-6064 Email: Fallon.Gail@epa

.gov

NOTICETO RECIPIENT:The information contained in this message from Great River Energy and any attachments are confidential and intended onlyfor the named recipient(s). Ifyou have received this message in error, you are prohibited from copying, distributing or using the information

. Please contactthe sender immediately by return email and delete the original message.

NOTICETO RECIPIENT:The information contained in this messagefrom Great River Energy and any attachments are confidential and intended onlyfor the named recipient(s). Ifyou have received this message in error, you are prohibited from copying, distributing or using the information. Please contactthe sender immediately by return email and delete the original message.