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Final Notes from Site Visit 

at Fayette Power Project/Sam Seymour Power Station 

on October 30, 2008 

EPA conducted a site visit at the Fayette Power Project/Sam Seymour Power Station (Sam 

Seymour) located near La Grange, TX on Thursday, October 30, 2008 to learn about the 

operations at the plant, specifically the FGD wastewater handling system. The plant is operated 

by the Lower Colorado River Authority (LCRA). Table 1, located at the end of this 

memorandum, identifies the site visit participants. The plant process flow diagram and a 

simplified process flow diagram for the Unit 3 FGD systems are included as attachments to this 

memorandum. 

This memorandum describes the information collected during the site visit and the pre-site visit 

phone call, which was held on September 25, 2008. 

Background on Steam Electric Detailed Study and Introductory Remarks 

EPA provided background on the steam electric detailed study, highlighting the current focus on 

wastewaters from coal-fired facilities, specifically ash handling, FGD wastewaters, and coal pile 

runoff. EPA stated that the purpose of the study is to determine whether revisions to the current 

effluent guidelines for the industry are warranted. 

EPA stated that the purpose of the visit is to learn more about the plant’s operations, specifically 

the operation of the FGD scrubber systems and the FGD wastewater handling systems. 

LCRA provided an overview of safety concerns for the plant in preparation for the tour. LCRA 

personnel then presented a video presenting a brief overview of the Fayette Power Project (FPP). 

Plant Overview 

• Sam Seymour has three coal-fired generating units. The boilers are manufactured 

by Combustion Engineering and are tangentially fired. The table below contains 

some general information for each generating unit. 

Unit 

Installation 

Date 

Net 

Capacity 

(MW) 

Particulate 

Control NOx Control SO2 Control 

1 1979 615 ESP Low NOx 

burner; no 

SCR 

Wet FGD currently 

being installed 

(Fall 2010) 

2 1980 615 ESP Low NOx 

burner; no 

SCR 

Wet FGD currently 

being installed 

(Fall 2010) 

3 1988 480 ESP Low NOx 

burner; no 

SCR 

Wet FGD in original 

design (1988) 
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• Units 1 and 2 are co-owned by Austin Energy, but operated by LCRA. Unit 3 is 

owned and operated by LCRA. FPP’s permit with the state of Texas requires the 

installation of scrubbers by October 2012. 

• Sam Seymour does not have SCR systems in place. The plant is monitoring the 

regulations to determine if they will be needed in the future. In 2005, they 

installed low NOx technologies to meet the State’s regional NOx reduction 

requirements and emission caps in the FPP Flexible Air Quality Permit. The 

plant’s average NOx emission rate is currently approximately 0.1 lbs/MMBTU. 

• All units burn Powder River Basin (PRB) coal which is delivered by rail. The 

coal is low sulfur (ranges from 0.6-0.8 lb/MMBTU sulfur, or around 0.35% S). 

LCRA stated that the average chlorides content of the coal for the last four 

months was 95 ppm. The range was from 71 ppm to 166 ppm for June to 

September 2008. 

• Unit 3 was originally designed to burn lignite coal, which has a high ash content; 

therefore, the ESP for this unit is over designed for burning PRB coal. 

• Oil is used for startup operations. LCRA is looking at using natural gas for this 

purpose in the future. 

• Sam Seymour receives about 18,000 tons of coal per day via rail. Sam Seymour 

typically has a 2 month supply of coal on site at any given time. Sam Seymour 

uses “reclaim” pond water for dust suppression on the coal pile. 

• Runoff from the coal pile is stored in the coal pile runoff pond, but is first 

diverted through a settling basin, which is in the front section of the pond. LCRA 

indicated this configuration helps to keep the main runoff pond clean of solids. 

The settling basin is excavated periodically to remove the solids. Effluent from 

the coal pile runoff pond is permitted to be discharged to the lake, to Cedar Creek, 

or to the Reclaim pond. Most discharges from the coal pile runoff pond are to the 

lake for the purpose of water reuse. Discharges to the lake and Cedar Creek are 

monitored for TSS, oil and grease, pH, and chlorides. The pH of the pond 

typically ranges from 8.0 to 8.5. 

• Sam Seymour uses water from Lake Fayette for cooling water. Lake Fayette is 

2,400 acres. 

• Sam Seymour operates a reclaim pond which can receive wastewater from the 

following sources: treated sewage, FGD dewatering (thickener overflow and 

filtrate from vacuum filter drum), pump seal water, bottom ash pond effluent, and 

demineralizer regeneration wastes. The reclaim pond is permitted as a “no 

discharge” pond. Pond water is used primarily as makeup water for the Unit 3 

FGD scrubber. In addition, pond water is used for the Unit 3 bottom ash 

submerged scraper conveyor, and is applied to the coal pile or roads for dust 

suppression. Dependant on weather conditions, the amount of dust suppression 

water used can exceed one million gallons per month. Sam Seymour has the 
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capability for pumping water between the bottom ash pond and reclaim pond (in 

either direction) as needed to manage wastewater volumes, but the plant will 

typically transfer water from the bottom ash pond to the reclaim pond. The 

reclaim pond is equipped with evaporative sprays, which are used when needed to 

reduce the water volumes. 

Ash Handling and Wastewater Treatment 

• Sam Seymour operates a dry fly ash handling system on all three units, with the 

exception that the air pre-heater and economizer ash from Units 1 and 2 are wet 

sluiced to the ash pond along with the bottom ash. The dry fly ash is captured and 

sold for use in road construction. LCRA stated that this option will be eliminated 

at the plant. Units 1 and 2 are also capable of processing fly ash wet; however, 

this option would only be used if the dry system were down for a prolonged 

period of time. The fly ash would not be marketable if it was wet. 

• Sam Seymour operates a submerged scraper conveyer (SSC) bottom ash handling 

system on Unit 3. The bottom ash is collected in a water bath collection trough at 

the bottom of the boiler and a drag chain moves along the trough pulling the 

bottom ash out of the boiler. The bottom ash is dumped onto a conveyor and 

stacked in piles for reuse. The water bath uses reclaim pond water. 

• Sam Seymour operates wet bottom ash handling systems on Units 1 and 2. Ash 

pond water is used to sluice the ash. The sluice water is dewatered in one of two 

bunkers where it overflows to an internal “creek” that winds around the ash pond 

site to help drop out more solids prior to entering the ash pond. The pond is 

equipped with evaporative sprays, which are used when needed to manage the 

water volume. There is no discharge from the ash pond, although water can be 

transferred to the reclaim pond. The plant is planning to convert Units 1 and 2 to 

SSC bottom ash handling because the ash pond is becoming full. In addition, the 

ash handling equipment is nearing the end of its lifespan, and the plant feels this 

would be a good time to make the switch. LCRA expects the transition to occur 

during an outage in the near future. [CBI information has been removed from this 

document.] The transition will include removing the existing hoppers, installing a 

water trough, a conveying belt system, and other ash handling equipment. A 

maintenance cost comparison, averaged over an eight-year period, shows that it 

costs about 30% more annually to maintain the dry (SSC) system. The reclaim 

pond will be the makeup water source for the new SSC systems. 

Coal Combustion By-Products Landfill Operations 

• LCRA has a registered landfill of a hundred and twenty two acres, of which, 

approximately twenty-five aces is active for the handling of coal combustion byproducts. 

• Sam Seymour operates a landfill runoff pond that is permitted for discharge; 

however, LCRA stated that the water is typically used as makeup to the reclaim 

pond. The pond only receives runoff from the active portion of the landfill. 
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Discharge from the runoff pond is limited for TSS, oil and grease, selenium, and 

pH. The selenium limit is 0.1 ppm and the plant normally achieves 0.05 ppm. 

FGD System and Wastewater Handling 

• Sam Seymour operates a limestone, forced oxidation FGD scrubber system on 

Unit 3. Unit 3 has three individual absorber vessels, two that are in operation at 

any one time and one spare. 

• Limestone is received via truck and stored indoors. 

• No additives are used in the scrubber system. About 5 years ago, the plant tested 

the use of petroleum coke by blending it with the PRB fuel. During that test, the 

addition of dibasic acid to the scrubber was needed to assist in sulfur removal to 

ensure air permit compliance. In addition to mechanical handling problems, it 

was determined that Petroleum coke could not be used because the sulfur content 

was too high. However, normally no additives are used. The study that was 

performed using Petroleum coke was a fuel study only. LCRA did not document 

the amount of DBA used throughout the tests to maintain the required SO2

removal efficiency for permit compliance. 

• LCRA estimated that the solids concentration in the scrubbers is approximately 

12.1% (by weight) and the pH ranges from 5.95 to 6.05. 

• LCRA indicated the chlorides range from 5,000 ppm to 10,000 ppm in the 

reaction tank. 

• The unit 3 mist eliminator uses water from the reclaim pond. Mist eliminators for 

Units 1 and 2 will use 100 percent lake water. 

• Sam Seymour operates a closed circuit system, using reclaimed pond water for 

the scrubber. LCRA stated that the flow rate to the reclaim pond is 121 gpm. For 

makeup water, Sam Seymour adds cooling water flow to the reclaim pond, and 

the reclaim pond receives a limited volume of rain water runoff from a portion of 

the plant. 

• Gypsum created in the system is not washed. The chlorides content is too high 

for use as wallboard; however, the plant sells the gypsum to a third party who 

sells it for use in cement manufacturing and as a soil conditioner. FPP produces 

35,000 to 50,000 tons of gypsum per year. Each truck hauling gypsum from the 

plant will carry approximately 25 tons. 

• LCRA stated that the blowdown from the scrubbers is typically continuous. The 

blowdown is transferred to the thickener feed tanks, where polymer is added, and 

then to the thickeners for solids dewatering. 

• LCRA stated that the overflow from the thickeners is either transferred to the 

FGD system or to the reclaim pond. 
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• LCRA stated that the underflow from the thickeners is transferred to the filter 

feed hold tank. The tank feeds one of two vacuum drum filters, which are 

operated once a day for about 4 to 5 hours to dewater the gypsum. The final filter 

cake is about 88% solids. The filtrate from the vacuum drum filter is transferred 

to the reclaim pond. LCRA expects the filters will need to operate about 20 hours 

per day once all three units are equipped with scrubbers. 

• Sam Seymour is considered a zero discharge FGD system because they do not 

discharge any FGD wastewater directly to surface waters.

• Sam Seymour plans to use hydroclones with the new scrubbers on Units 1 and 2. 

The likely configuration will transfer the hydroclone overflow to the scrubbers 

and the underflow to the filter feed tank. 

Demonstration Projects 

• Sam Seymour has an ongoing demonstration project for reducing mercury 

emissions. The project uses a catalyst to oxidize mercury for capture in the wet 

scrubber, and has been operating for about six months (of a two year test period) 

on Unit 3. URS, the contractor supporting the demonstration project, provided a 

presentation which is attached to these notes. 

• The demonstration-scale project operates on a little less than 50 percent of the 

flue gas from Unit 3 (approximately 200 MW equivalent). 

• The oxidation catalyst, which consists of 36 catalyst modules, is located 

downstream of the ESP, where the air flow is relatively particulate free. On a full 

scale system, the catalyst would probably be added to the ESP outlet. 

• Sam Seymour is looking for a 70% reduction of mercury across the system. 

• During the test, the scrubber absorber liquid is tested for mercury. URS has found 

that most (99%) of the mercury ends up in the gypsum (at about 3 ppm). Mercury 

levels in the liquid fraction are typically less than 10 ppb. There has been no 

effect on the ability to reuse gypsum. 

• Sam Seymour previously looked at activated carbon injection for the reduction of 

mercury in the flue gas. They found the technology is very effective at capturing 

mercury but it increases the carbon content of the fly ash. Increasing the carbon 

content of the fly ash changes it into a product that does not meet the ASTM 

specifications for Redi-mix concrete production. However, the material is 

suitable for road construction. 
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Table 1. Site Visit Attendees 

Name Organization (Representing) Telephone E-mail Ted Borgstedte LCRA (979) 249-8569 Ted.Borgstedte@lcra.oMonte Gottier LCRA (979) 249-8340 Monte.gottier@lcra.org Beckie Loeve LCRA (979) 249-8774 Beckie.loeve@lcra.org Johnny Madrid LCRA (512) 473-3333 Johnny.madrid@lcra.oJennifer Thompson LCRA (979) 249-8705 Jennifer.thompson@lcrGary Blythe URS Corporation (512) 454-4797 Gary_blythe@urscorp.Ron Jordan EPA/Office of Water (202) 566-1003 jordan.ronald@epa.gov Deb Bartram ERG (Contractor to EPA) (703) 633-1669 deborah.bartram@erg.c
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Attachment 

FAYETTE POWER PROJECT/SAM SEYMOUR 

PROCESS FLOW DIAGRAMS 

Simplified Process Flow Diagram: 

Fayette Power Project/Sam Seymour Power Station 

Unit 3 FGD Wastewater Treatment System 
Attachment 

URS PRESENTATION 

FULL-SCALE DEMONSTRATION OF A MERCURY OXIDATION CATALYST 

UPSTREAM OF A WET FGD SYSTEM