Draft Notes from Site Visit at Consumers Energy’s Karn/Weadock Generating Complex on September 22, 2009

EPA conducted a site visit at Consumers Energy’s Karn/Weadock Generating Complex (Karn/Weadock) located in Essexville, MI on Tuesday, September 22, 2 009 to learn about the operations at the plant. Table 1, located at the end of this memorandum , identifies the site visit participants. The presentation that the Karn/Weadock personnel gave during the site visit is provided in Attachment 1 o f this memorand um.

This memorandum describes the information collected during the site visit.

Plant Overview

**•** The Karn/Weadock Generating Complex includes the D.E. Karn and J.C. Weadock power plants. Karn/Weadock has been in production since the 1940’s. The site cove rs approximately 2,400 acres, as well as some additional outlying property the plant has acquired. [QUESTION FOR KARN/WEADOCK : What is the size of the outlying property and where is it located?] The complex is located at the mouth of th e Saginaw River, whi ch discharges to the Saginaw Bay and ultimately combines with Lake Heron. Karn/Weadock pumps service water from the Saginaw River and discharges wastewater to Saginaw Bay via Outfall 001. A discharge flow diagram fo r Karn/Weadock is provided in A ttachment 2 of this
memorandum.

**•** Karn/Weadock employs 381 personnel, with supplemental company and contracted employees.

**•** Karn/Weadock has 12 electric generating units on site. Six of these twelve are retired Weadock units, while six are still in operation. The u nits still in operation are coal

- fired units, Karn Units 1 and 2 and Weadock Units 7 and 8, and oil/natural gas

- fired units, Karn Units 3
and 4. Karn/Weadock stated that retired Weadock Units 1

- 6 are “standard”, once

- through steam electric generating unit s that were extremely inefficient when operated. They were retired in the early 1980’s. The table below contains some general information for each operating electric generating unit.Page 2

Unit Boiler Description Installation
Date Net Rated Capacity Power ( MBTU per hour ) Fuel Blend Particulate
Control NOx
Control

Karn Unit 1 Dry

Bottom ; Tangential

fired 1959 255 MW
Baseload 2,500 75 % PRB
25 %

E astern bituminous 2 cold

- side
electrostatic precipitators (ESPs) in
series ; Sulfur
trioxide
system available to enhanc e efficiency SCR
installed in
2004 ; Year round operation of
SCR began
in 2009

Karn Unit 2 Dry

Bottom ; Wall

- fired 1961 260 MW
Baseload 2,540 75 % PRB
25 %

E astern bituminous 2 cold

- side
ESPs in
series ; Sulfur
trioxide
system available to enhance efficiency SCR
installed in
2003 ; Year round operation o f SCR began
in 2009 ; Low

- NOx
burners
installed in
1998

Karn Unit 3 Natural gas
and fuel oil

fired (dual fuel) 1975 630 MW Peaking 7,290 # 6 fuel oil
and natural

gas None Low

- NO X

Karn Unit 4 burner s

Natural gas and fuel oil

fired (dual fuel) 1977 630 MW Peaking 8,030 # 6 fuel oil,
and natural

gas None Low

- NO X

Weadock

Unit 7 burner s

Dry
Bottom ; Tangential

fired 1955 155 MW
Baseload 1,610 80 % PRB
20 %

E astern bituminous Cold

- side
ESP ; Sulfur
trioxide
system available to enhance efficiency

Weadock

Unit 8 Dry

Bottom ; Tangential

fired 1958 155 MW
Baseload 1,610 80 % PRB
20 %

E astern bituminous Cold

- side
ESP ; Sulfur
trioxide
system available to enhance efficiency [QUESTION FOR KARN/WEADOCK: Do Weadock Units 7 and 8 have any NOx controls?]

**•** Karn/Weadock stated that there is no significant difference in operation between the type of boilers (tangential versus wall) for Karn Units 1 and 2. There is no significant difference in the amount or split of ash (bottom versus fly ash) or the efficiency of the boilers.
Karn/Weadock installed a wall

- fired boiler for Karn Unit 2 mostly due to market competition
at the time.

**•** Karn Unit 1 was down for maintenance during the site visit. Karn/Weadock stated that Karn
has 30 to 60 days of outage planned for cleaning and maintenance throughout the year.Page 3

**•** Karn Units 1 and 2 and Weadock Units 7 and 8 use fuel oil for startup and supplemental co

firing for flame stabilization and mill outages.

**•** In 2008, Karn Units 1 and 2 and Weado ck Units 7 and 8 burned a total of 1,947,422 tons of coal to produce 3,873,186 net MWh.

**•** Karn Units 3 and 4 have identical, front

- fired boilers units with 30 burners (3 decks of 10).
Each burner on each boiler must burn the same amount of BTU for balancin g. The boilers are started with natural gas, and then typically burn a blend of natural gas and oil. Each burner is capable of burning both natural gas and oil at the same time, but Karn/Weadock does not do that. In years past, Karn/Weadock would typical ly burn about 40 percent natural gas and 60 percent oil in the boilers, but the plant has recently been burning more natural gas in these boilers because it has been so inexpensive. The plant is limited to burning 60 percent natural gas due to boiler reac tions. The radiant flame affects the way the water walls
absorb heat. Karn/Weadock controls sulfur dioxide emissions with a “ratio burn” of natural gas to oil. The burning of the medium sulfur oil, which contains more than 1 percent sulfur,
is balanced with burning of natural gas to meet the plant’s permitted sulfur dioxide limit.

**•** Karn Units 1 and 2 and Weadock Units 7 and 8 each have a sulfur trioxide injection system to enhance the performance of the ESPs. Karn/Weadock has found that the these sulfur trioxide injection systems have not been necessary and they have not been used recently due to the year round operation of the SCRs. Heat tracing and thermal insulation systems were installed to allow SCR system operation through the winter.

**•** Karn/Weadock has plans to install dry FGD systems on Karn Units 1 and 2, possibly within two years; however, these plans are currently on hold. The plant has also considered installing activated carbon injection (ACI) systems to reduce flue gas mercury emissions, but these plans depend on future mercury regulations. Fabric filter baghouses, which are currently being constructed, will replace the ESPs on Karn Unit 2 in November 2010 and Karn Unit 1 in February 2011. The primary ESPs will be retired on site and the sec ondary
ESPs will be removed.

**•** Once through cooling is used for Karn Units 1 and 2 and Weadock Units 7 and 8.

**•** Karn Units 3 and 4 use closed loop, mechani cal draft cooling towers.

Ash Generation, Handling, and Wastewater Treatment

Ash Generation

**•** Karn Units 3 and 4 are oil/natural gas

- fired units. They produce very little ash. Soot blowers exist on each unit; however, are presently never used because no precipitators are installed on these units. Without precipitators, operating the soot blowers would cause ash to exit the stack with the flue gas and air pollution control limits would be exceeded. The soot blowers on these units were last operated in the 1970’s.Page 4

Bottom Ash Handling

**•** Karn/Weadock operates a wet bottom ash handling system on Karn Uni ts 1 and 2 and
Weadock Units 7 and 8. About ten perc ent of all ash produced at the plant is bottom ash. Mill rejects are collected dry and then handled wet with the bottom ash. The Weadock bottom ash sluice is directed to the Weadock bottom ash pond throu gh a series of channels, discharged via Outfall 001H, and ultimately discharged to Saginaw Bay via Outfall 001A. An aerial view of the Weadock property, with labele d ponds, channels, and outfalls, is provided in

A ttachment 3 of this memorandum.

**•** Karn/Weado ck dredges the bottom ash pond a couple of times a year and uses the bottom ash
for roadbed. T he roads are constructed of about two feet of bottom ash, a geotech fabric, and about two feet of stone. Karn/Weadock also has plans to use bottom ash as landfil l cover
material.

**•** Karn Units 1 and 2 have a similar wet bottom ash handling system. The Karn bottom ash sluice is directed to the Karn bottom ash pond, discharged via Outfall 001B, and ultimately discharged to Saginaw Bay via Outfall 001A. An aerial view of the Karn property, with
labe led ponds, channel s, and outfalls, is provided in A ttachment 4 of this memorandum.

**•** Karn/Weadock estimates that there is about six to eight years of capacity left for the bottom ash pond. The facility will continue to develo p more options for bottom ash sluice closer to
that time.

**•** Karn/Weadock previously developed scoping

- level cost estimates for converting to a bottom ash handling system that would use dewatering bins. [ NOTE TO KARN/WEADOCK : Please provide the cost estimat e that was developed. If developed as part of a report or similar
evaluation such as vendor proposal , provide the report /proposal .] Plant personnel stated that if the bottom ash were sent to a dewatering bin, the plant would need to consider the cost for treatment of the recovered water, though reuse of the water is a possibility. The dewatered ash may need to be hauled.

Fly Ash Handling Overview

**•** Karn/Weadock operates a dry fly ash handling system on Karn Units 1 and 2 and Weadock
Units 7 and 8. Thes e systems are identical in operation, but the Weadock system is smaller. There are fewer hoppers overall for the Weadock units. In both the Karn and Weadock systems, ash collected from the precipitators, air heaters, and economizers is handled dry.

For the Karn units, the air heater and economizer ash is collected in separate sets of hoppers, whereas for the Weadock units, the air heater and economizer ash is collected together in the same hoppers.

**•** The dry fly ash handling system (on Karn Units 1 a nd 2 and Weadock Units 7 and 8) is a conversion from the previously operated wet fly ash handling system. This conversion took place from 2006 to 2009, with initial operation of the dry fly ash handling system occurring in 2008. The dry fly ash handling sy stem was designed by United Conveyor (UCC) in 2006. The dry fly ash flow diagram is provided in A ttachment 1 of this memorandum.Page 5

**•** Some of the fly ash sluicing equipment is still in place at Karn/Weadock, mainly due to the
cost of removal. Karn/Weadock has no plans to use the sluicing equipment again. Plant personnel stated that there is no need because there is ample capacity and redundancy in current dry fly ash handling system (and fly ash can be diverted from the Karn to Weadock systems or vice versa). Additionally, plant personnel stated that it might not be possible to use the sluicing system as is: valves and other equipment would need to be removed/replaced.

**•** Karn/Weadock discussed why they switched from the hydroveyors, which were used with
the we t sluicing system, to mechanical exhausters to pull the fly ash by vacuum out of the hoppers. The mechanical exhausters are more reliable, and in general, the plant wants to reduce water use as much as possible. Additionally, the hydroveyor system would not have been able to pull enough vacuum to transfer the dry fly ash from the hoppers to the transfer
station/tank.

**•** New equipment additions for the dry fly ash systems include piping (some piping from the wet fly ash handling systems is still in use for t he dry fly ash handling systems), valves, the exhaust systems, the transfer station/tanks, and the loading silo.

**•** Headwaters Resources (Headwaters) markets the dry fly ash produced at the Karn/Weadock facility. The amount of fly ash sold depends on the ava ilability of projects in the Michigan area. Lafarge Company purchases about 200 tons of the Karn/Weadock fly ash per day to
manufacture cement.

**•** Long term, the facility is looking to sell about 50,000 to ns of ash per year. Karn/Weadock produces about 160 ,000 tons of fly ash per year.

**•** The mixture of coal that Karn/Weadock uses to operate their units produces a valuable ash product. It is not Class C ash, but there is still a market for it. Karn/Weadock stated that the Campbell power plant burns a 100 per cent western coal, which produces a more valuable Class C ash with a lower loss on ignition (LOI). Karn/Weadock stated that the major difference between the types/classes of ash is the final color.

Detailed Dry Fly Ash Handling System Operation

**•** The fly ash is collected dry from the bottom of the precipitator and economizer hoppers and pulled by vacuum (generated by mechanical exhausters) to the transfer tank. The Karn and Weadock dry fly ash systems each have one transfer tank. The precipitator and econ omizer hoppers are emptied based on time intervals or levels of ash. The Karn transfer tank has the capacity to hold about two to three days worth of fly ash (from Karn Units 1 and 2 combined), but the transfer tank is typically operated at about 20 percen t of its capacity. Karn/Weadock estimated that the distance from the Karn Unit 2 hoppers to the transfer tank is about 400 to 600 feet (and about an additional 200 feet from the Karn Unit 1 hoppers).

**•** Located on the side of each transfer tank is an emerge ncy loading dock and pin mixer (pug mill) that can be used to unload ash from the transfer tank in case there is a system failure or the loading silo requires maintenance. The pin mixer conditions (i.e., adds moisture to) ash in preparation for loading, ty pically to about 15 to 20 percent moisture. The emergency pin mixer can condition ash at a rate of 50 tons per hour.Page 6

**•** Dry fly ash that enters the transfer tank (from the precipitator and economizer hoppers) is transferred into filter/separators. T he filt er/separators contain bag filters and separate the fly ash from the transfer air, which is exhausted. The fly ash is then transferred into air

- lock ed transfer hoppers. As the ash is dropped into the hoppers, fugitive dust is pulled th rough the filter/separ ators and captured by bin vent filters on top of the transfer tank, ensuring that no dust exits through the stack. Operators routinely check monitors that indicate if there any
breaks in the filters.

**•** As the top of transfer hopper closes, separating the a sh from the vacuum pressure, the bottom of the hopper opens, introducing the ash to a positive air pressure system. The ash is blown by compressed air to the 2,700 ton storage silo, which is 2, 300 ft away from the Karn transfer tank and over 4,000 ft away from the Weadock transfer tank. NUVA pressure feeders are used to introduce the ash to the positive pressure system. Relief valves were installed on the transfer hopper to ensure that they don’t contract as the change in air pressure occurs.

**•** From the sto rage silo, dry fly ash is either loaded pneumatically into trucks for sale or moisture conditioned, loaded into trucks and landfilled. Currently, Karn/Weadock unloads ash, either for landfill or sale, five days per week during daylight hours only. It is co st prohibitive for Karn/Weadock to install lights on the roads to the silo at this time.

**•** Dry fly ash for sale is transferred to the trucks pneumatically, under negative pressure, with a double annular spout. A vacuum is pulled through the outer annulus o f the spout, creating a tight seal with the truck. Ash is delivered through the inner annulus of the spout into the truck. The vacuum captures any fugitive dust and pulls it back into the silo. Karn/Weadock stated that with this system, the ash flows easi ly into the trucks, “like a liquid”. Trucks are each loaded with approximately 50 tons of dry fly ash. Plant personnel stated that the moisture content of the dry fly ash stored in the silo is very low. Any significant amount of
moisture would cause sedim entation in the silo.

**•** Bagfilters are located at the top of the silo. There is a transmitter analog gauge to monitor the quality of the bags. Visual checks are also performed and logged periodically by operators. The conveying piping is also visually check ed for any leaks.

**•** Dry fly ash that is not sold is moisture

- conditioned in pin mixers and then loaded into one of two trucks. The pin mixers at the storage silo are much larger than the emergency pin mixer near the transfer tank. The pin mixers at the stor age silo moisture

- condition the ash to about 17 to 18 percent. The inside of the pin mixer contains large bars (till bars) made out of nylon
anti

- stick material that mix the ash with the water, which is sprayed into the mixer. The pin mixers are also oper ated under vacuum to control fugitive dust.

**•** One truc k holds 42 to ns of ash that has been conditioned to a moisture content of about 17 to 18 percent (about 37 tons of dry fly ash and 5 to 6 tons of water). A 6,500

- gallon service water truck regularly driv es around the perimeter of the silo area wetting the ground to control fugitive dust.

**•** The trucks that load the moisture

- conditioned ash place it in the landfill/ash pond area. A bulldozer spreads the ash and compacts it to the desired density. The bulldoz er operator uses a compaction hammer to test the density of the surrounding area once every 104 truckloadsPage 7

or 4 ft of ash displaced. Lab tests are done to determine the exact density and moisture content of the ash placed. In order to obtain an accurate re ading for the elevation, surveying
would have to done.

**•** After trucks have loaded moisture

- conditioned ash, some water is released to the silo area through a drain hose. Sumps around the area drain to a collection ditch and small sediment pond where sedimen t and ash are dredged and stacked.

Dry Fly Ash Handling Conversion Timeline and Costs

**•** Butch Braun, the System Engineer for the dry fly ash handling system, presented Karn/Weadock’s conversion plan and the related costs during the site visit. The presen tation given by Mr. Braun is provided in A ttachment 5 o f this memorandum.

**•** The scope of the project was to convert the wet fly ash handling systems on Karn Units 1 and 2 and Weadock Units 7 and 8 to dry fly ash handling systems that pneumatically convey fl y ash from the precipitator, economizer, and air heater hoppers to the storage silo for landfill
and/or sale.

**•** The project was started in 2005 with the development of a dry fly ash handling study, which updated a previous study performed in 2002. Mr. Braun mentioned that a report was generated that documents the 2005 study. [ NOTE TO KARN/WEADOCK: Please provide this report] The foundations for the new dry fly ash handling system were laid in 2006. The year 2007 focused on the engineering and mechanical/elec trical designs. Activities in 2008 included the construction, start

- up, and testing of the final design. Karn/Weadock is closing out the project during the year 2009.

**•** UC Services developed the overall system design and provided the major equipment (compr essors, blowers, tanks, piping, etc) as well as the redundant equipment used throughout the system. UCC designed and provided the ash storage silo.

**•** Karn installed isolation valves during a forced outage for Karn Unit 1 in 2006. Karn Unit 2
was installed during a planned outage in 2007. Weadock Units 7 and 8 isolation valves were installed during a forced outage in 2006. With these isolation valves, the facility was able to isolate the wet system from the new dry system and perform tie in work while the ge nerating units were still in operation.

**•** The total budget for the conversion was $50 million. This is nearly double the cost estimated in the 2005 plan.

**•** When asked about specific costs, Mr. Braun used the conversion for Karn Units 1 and 2 as an example. Mr. Braun estimated that the Karn installation was about $19 million (and the Weadock installation was about $24 million and the silo was about $7 million). He provided the following rough, breakout for the Karn materials/installation cost (Note: the atta ched “Project Construction Cost Breakdown” presentation includes another version of this breakout):

**•** U C Services maj or equipment: $4 million;

**•** Buildings: $2 million;Page 8

**•** Piping to the silo: $2 million;

**•** Electrical: $2 million;

**•** Mechanical installation: $3 million ; and

**•** Cement foundation for silo: $1.5 million

**•** The conversion for Weadock was more expensive than Karn due to challenges the facility encountered with spacing and location. The Weadock system required more piping to reach the transfer tank and storage si lo. Some system equipment (e.g., compressors and filter/separators) also had to be split between two buildings for spacing issues. Additionally, the compressor pumps needed to be placed on the roof to save space, which resulted in the
added construction of a platform for support.

**•** Challenges that Karn/Weadock encountered during the conversion included equipment and underground work interferences, manpower availability, weather, and the availability of the
contractor to install the silo. Karn/Weadock was ab le to use regular scheduled outages to complete the conversion over the four

- year period.

**•** Karn/Weadock stated that the silo started operating on December 9, 2008 and started landfilling ash on December 18, 2008. Both dry fly ash handling systems were in f ull operation on February 21, 2009.

**•** Karn/Weadock stated that the annual O&M cost, including labor, for the silo is $225,000. This includes the O&M costs for two pickup trucks, the bulldozer, and the service water
truck. [QUESTION FOR KARN/WEADOCK: What i s the total operator time included in the annual O&M costs? Specifically, please include the number of persons, hours per day, and days per week.]

**•** Karn/Weadock stated that there has been only a minimal increase in O&M costs for the dry system from the wet system thus far. Karn/Weadock estimated that start up time for the dry system is about one hour, compared to the 20 minutes for the wet system. The difference in start up time could be partly related to learning how to operate the new dry system.
Karn/Wea dock stated that maintenance costs have been low so far, but predicted that they will rise due to the complexity of the new system (e.g., additional valves).

**•** The design of the Karn/Weadock dry fly ash handling system is similar to the Campbell power plan t system. Karn/Weadock looked to the Campbell system design for lessons learned during the conversion. The one major difference between the two systems is that the Campbell system has two loading silos: one for dry fly ash sale and one for moisture

conditi oned landfilling.

**•** Karn/Weadock discussed that they would like to modify the ash loading area for separate loading areas for dry fly ash sale and moisture

- conditioned landfilling. With two separate loading areas, moisture

- conditioned ash and dry ash could be loaded at the same time. This would eliminate the timely process necessary to switch from the moisture

- conditioned loading equipment and the dry spout between truck loads. Two loading bays versus two loading silos were also discussed.Page 9

Karn/Weadock As h Ponds and Landfills

**•** Karn/Weadock operates a network of ash ponds. This network includes a series of ponds and
channels that was created (and most useful when) fly ash was sluiced . The network of
channels was created to increase retention capacity

. The earliest ponds that were constructed
on the plant property were filled prior to 1969.

**•** The Karn ash field (landfill) is about 170 acres and the Weadock ash field is 292 acres

. There are no leachate collection systems for these landfills

.

**•** The Karn fly a sh ponds /landfill are currently full. A ll Karn ash that is not being sold is being
used to fill in the Weadock ash ponds or landfill

. In Michigan, ash impoundments must be closed as landfills are with a cover. Karn/Weadock plans to use dredged bottom ash for this
cover material.

**•** Karn/Weadock built a slurry wall along the entire pond system as part of the plan for vertical expansion of the ash pond/landfill area

.

**•** As the Karn fly ash ponds were running out of capacity, Karn/Weadock could no longer meet
th eir TSS limits on the ash pond discharge. Because of this and Karn/Weadock’s overall goal to use and discharge less water (partly due to trends of tighter regulations on discharges), Karn/Weadock converted to a dry fly ash handling system.

**•** Karn/Weadock mentioned that they are considering building a new electric generating unit with cooling towers on top of the old Karn ponds.

**•** Karn/Weadock recently conducted a potential failure mode analysis of their ponds with the company, AECOM, and report(s) of the analysis are being drafted. Prior to that, Karn/Weadock conducted inspections of their ponds; these were not formal geotechnical inspections, but what Karn/Weadock described as general inspections.

**•** Karn/Weadock has conducted groundwater monitoring around the ash pond/landfill area since 1982, with a particular focus on boron and arsenic. Typically, the leachate in the area contains about 2 ppb of boron, but closer to 100 ppb is measured during groundwater testing.

Metal Cleaning Was tes

**•** The plant determines when boiler cleaning is necessary for Karn Units 3 and 4 based on gallons of oil burned. When cleaning is required, the boiler is shutdown and cleaned via water wash. The water used is plant service water (Saginaw river water). There are no
che micals added to the boiler water wash. Used boiler water wash is transferred to the Karn ash ponds.

**•** Karn Units 3 and 4 boilers are usually cleaned twice a year. Karn has to balance cleaning the boilers with the efficiency of the units. Time and money are lost when the boiler is shut down for cleaning; however, when the boiler is not clean, the ash that has coated the reheater, superheater, and economizer tubes/surfaces decreases the efficiency of the boiler.
Karn/Weadock stated that when the Karn Units 3 and 4 boilers are not clean, they are typically about 10 percent less efficient than when clean.Page 10

**•** Unlike Karn Units 3 and 4, the coal

- fired units on site produce so much ash that soot blower operation is necessary to maintain efficiency. The coal ash tha t collects on the water wall and steam tubes affects the heat absorption rate. The soot blowers, which consist of rotating lances that eject compressed air, run frequently while the unit is operating to remove the ash off the wall and tubes. Air pollution control is not an issue, as would be with Karn Units 3 and 4, because the coal

- fired units are equipped with ESPs. Water lances are also used while the unit is operating, but less frequently, to clean the water wall/tubes of the coal

- fired
boilers. Water f rom this operation immediately evaporates.

**•** Karn/Weadock stated that the Karn Units 1 and 2 boilers are chemically cleaned every seven years. Thermal evaporation of the metal cleaning waste is preferred by the plant, but the
waste can be treated for disc harge.

**•** Karn/Weadock operates two chemical treatment ponds systems on site, one for Karn and one for Weadock. The metal cleaning wastes are treated, transferred to the respective ash ponds, and ultimately discharged via Outfall 001A.

**•** Plant personnel sta ted that treatment depends on the type of waste entering the chemical treatment site. Typically the process focuses on settling out iron and copper so that limits are met prior to transfer to the ash ponds. [QUESTION FOR KARN/WEADOCK : What types
of metal cleaning wastes are treated in the “chemical treatment facilities”, how often are they generated/transferred, and how much is generated/transferred?]Table 1. Site Visit Attendees

Name Organization (Representing) Telephone E

- mail

Rick Hall CECO KW En vironmental (989) 891

- 3464 rghall@cmsenergy.com

Gary Dawson CECO KW Corp (517) 788

- 2432 gadawson@cmsenergy.com

JR Register CECO LWM Corp Not provided Not provided

J enny Crawford CECO LWM Corp (517) 788

- 1469 jacrawford@cmsenergy.com

Dave Marshall CECO, Site Ash Handling Supervisor Not provided Not provided

Dave Walter CECO, Karn 1&2 Production Lead Not provided Not pro vided

Butch Braun CECO KW Dry Fly Ash System Engineer Not provided Not provided

Jim Lalonde CECO, Karn 1&2 Production Engineer Not provided Not provided

Roberto Falco CECO, Results Supervisor Not provided Not provided

Dennis Dobbs CECO, Site Business Manager Not provided Not provided

Larry Dewitt CECO, Site Production Manager Not provided Not provided

Donna Hill UWAG/Southern Co. (205) 257

- 5234 dbhill@southernco.com

Ron Jordan EPA/Office of Water (202) 56 6

- 1003 jordan.ronald@epa.gov

Jezebele Alicea

Virella EPA/Office of Water (202) 566

- 1755 alicea.jezebele@epa.gov

Sarah Holman ERG (Contractor to EPA) (703) 633

- 1661 sarah.holman@erg.com

Elizabeth Sabol ERG (Contractor to EPA) (703) 633

- 1659 elizabeth.sa bol@erg.com