### RH 

### SIP
- Appendix C.2 document Gail Fallon to: Bachman, Tom A. 08/09/2011 01 :22 PM From: Gail Fallon/R8/USEPAIUS To: "Bachman, Tom A." <tbachman@nd.gov> 

### HiTom, Can you please tell me ifthe attached documentwhich was included with the RH SIP in Appendix C.2 is located somewhere on your regional hazewebsite? Itwas included on both the electronic disk and the hard copy you submitted in March 2010 but I do not see it on the website. 

# mr­

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.­ Ammonia in Ash ResponseNDDH (02-09-10).pdf 

### Thanks, 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

# GRE6I

..RIYE8 ENE R G Y 'v
February 9,2010 Lewis Dendy North Dakota Department ofHealth Division ofAir Quality 918 Eas' t Divide Avenue. 2nd Floor Bismarck, NO 58501-1947

Dear Lew, Great River Energy (GRE) respectfully submits our response to questions raised by US EPAconcerning ammonia in fly ash relevant to our Coal Creek Station (CCS)

.To address the issues raised by Amy Platt of US EPA in a November 30,2009 email message to Tom Bachman of NDDH,GR E provides the following responses: 1. Response to Amy Platt's email 2. Fly Ash usage and properties Response to Amy Platt's email Amy Platt's email references Dynegy's Baldwin Energy Complex and Progress Energy's Roxboro Generating Station as facilities that have post combustion NOx control and market their fly ash. Both facilities have Selective Catalytic Reduction (SCR) installed,no t Selective Non-Catalytic Reduction (SNCR) technology. It is typical for SCR technology to operate with lower ammonia injection and slippage rates than comparable SNCR technology

.With SCR technology additional mixing and chemical reaction assistance is introduced in the catalyst packing resulting in reduction in NOx emissions. SNCR technologies require additional ammonia injection to ensure contact with the NOx molecules in the flue gas, as they do not benefit from additional mixing orthe benefit of enhanced chemical reactions provided by the catalyst packing

. Headwaters Resources, GRE'sfly ash marketer, on average sees ammonia content in ash from 200-600 ppm for SNCR units and from 50-400 ppm for SCR units

. See Attachment 3 section

. Dynegy's 1,800 MW Baldwin Energy Complex has 3 units burning Powder River Basin (PRB) coal. Two ofthe units have SCR installed, the third unit has no post-combustion NOx control technology. Headwaters Resources, GRE's fly ash marketer, is also the ash marketerforthe Baldwin Energy Complex

. Headwaters only markets ash from the one pulverized coal unit that does not have either SCR or SNCR installed and therefore the ash sold does not contain ammonia

. Please see attached letterfrom Herbert Moeckel of Headwaters Resources. In Attachments 1 section

. Currently there are no installations ofSCR orSNCR burning North Dakota Fort Union lignite. As GRE does not have any data or experience with ammoniated ash we have asked ourfly ash marketer, Headwaters Resources,to respond to Amy Platt's chemistry statementthat alkaline ashes experience lower uptake ofammonia

. Headwaters has extensive experience with ammoniated ash and they have observed higher ammonia odor emissions from a plant (East Lake Plant, OH) producing a higher alkalineash. The mechanism for this higher evolution ofammonia has not been identified and is currently being investigated. See emailthreadofDecember29, 2009-in Allachment2 section. Without empirical evidence on uptake of ammonia on ash from ND lignite GRE ca nnot assume ammonia slippage rates or retention rates on fly ash. We have also presented the question about expected ammonia in ash for lignite units to Tony Facchiano, Sr

. Program Manager atthe Electric Power Research Institute (EPRI) and although they have done work for othertypes ofcoal they have not conducted research with ND lignite and would not be able to correlate the ammonia in ash with ammonia slip at this time. As there are no data from Fort Union lignite on SNCR ammonia retention in ash we have provided testimony from GRE customers. As noted by our customers, ammonia-impregnated ash would have an economic impact not only on GRE but also to our marketers who sell the ash

. See enclosures from Lafarge andGCC ofAmerica in the Allachment 1section. Fly Ash Fly ash for use in concrete is classified in 3 classes: Class N - raw or calcined natural pozzolans that comply with ASTM C618-08; Class F - typically produced from burning anthracite or bituminous coal, but lignite also;Class C - typically produced from burning lignite's, but may also be produced from burning anthracite or bituminous coal as long as the total calcium contents are higher than 10% and the ash has some cementitious properties

. CCS ash is classified as a Class F ash

. Introduction ofammonia will not affect the class of our fly ash but will decrease the desirability and thus the marketability ofour ash ifthe customer perceives a health risk or is able to procure the same material without the objectionable qualities. The original investments made in the infrastructure for the marketing offly ash was predicated on the fact that CCS is a mine mouth plantwith a consistent coal source which is producing a high quality fly ash which is very desirable in the concrete market. The introduction of undesirable characteristics into the fly ash, such as an odor or inhalation risk, will force our concrete customers to pursue alternate marketers for theirfeedstock

. See testimonials from Headwaters Resouces, Lafarge, andGCC in the Allachments 1 section

.

Please contact me at 763-445-5208 regarding any questions or comments. Sincerely, GREAT RIVER ENERGY

Debra Nelson

c: Diane Stockdill File

# Attachment 1: TestimonialsAdding Value to Energy January 28, 2010

Mr. AI Christianson Manager, North Dakota Business Development & Governmental Affairs 1611 East Century Avenue Suite 200 Bismarck, ND 58503
Dear Mr. Christianson: 

### I am writing in regards to the Dynegy Midwest Generation - Baldwin Energy Complex located in Baldwin, liiinois. Headwaters Resources is the marketing company for all five Dynegy Midwest Generation plants located in Illinois. The Baldwin Energy Complex is composed of three
- 600 MW units, totaling 1800 MW. Units 1 and 2 are cyclone fired boilers and Unit 3 is a pulverized coal boiler, ali three units are burning PRB coal. Units 1 and 2 are equipped 

### I operating with an SCR and Unit 3 has neither a SCR or SNCR installed. Headwaters Resources has mainly marketed the cyclone boiler fly ash produced from Units 1 and 2 into the cement Industry as a raw feed Ingredient since 1998. Since 2000, we were able to market approximately 17,000 tons of this material Into "flowable fill" on a few mine subsidence projects in the East St. Louis, Illinois area. We have performed ammonia testing on the fly ash produced from Unit 1 and 2 utilizing the Headwaters SOP using dragger tubes. This material fluctuates between 35 and 125 ppm ammonia in the fly ash. The ammonia odor was noticeable when used on the flowable fill mixes which contained high volumes of fly ash per yard. The ammonia odor did not have an Impact on our sales agreement with Buzzl Unicem, since they were using the material as a rawfeed Ingredient in the production of cement. Starting in July 2009 new mercury regulation forced the power stations in Illinois to use activated carbon injection to reduce mercury emissions. Units 1 and 2 did begin activated carbon Injection in July 2009 at which time the material was no longer allowed to be used in the production of cement. At this time 100% of the fly ash material produced from these units is being disposed of in an on site impoundment. Dynegy is constructing SDA scrubbers which should 

### be complete by 2013, at which time the Injection point of the activated carbon will be moved allowing the use of the fly ash material in cement production. Thefly ash produced from these 

### two units is not suitablefor use in concrete. Unit 3 atthe Baldwin Energy Complex was granted a temporary variance which did not force this unit to inject activated carbon until the SDA 

### I Bag house is operational at the end of 2010. Headwaters Resources has marketed the ASTM C618 Class C fly ash produced from unit 3 Into ready mix concrete, concrete paving, and soil stabilization since 1998. Please feel free to contact me at 612-963-7093 regarding any questions or comments. Respectfully

Herbert Moeckel Technical Sales Representative Headwaters Resources P.o. Box 566 Osage Beach, MO 65065 P: 612-963-7093 F: 866-449-8130

# I 

# I 1

- January 21, 2010 Mr. AI Christianson GREnergy Manager,NorthDakotaBusiness Development

### & Governmental Affairs 

### 1611 EastCentury Avenue Suite

### 200 Bismarck,NO

### 58503 AI, We would like to take this opportunityto expressconcern aboutORE'spotential injection of ammonia intothe flue gasduring coal burningoperations asan effortto reduceNOx emissions. As a wholesalemarketer and end-userofyourfly ash from the Coal Creek facility in North Dakota, ourconcern surroundsthe impactthis processwill haveonthe fly ash when used in concrete.**T~e** 

### ammonia in fly ash is not present as anunoniagas.Rather, it is in the fly ash as ammonium sulfate. Once in thehigh alkalineenvironment ofconcrete the ammonia is released. This becomes a problem because ofthe odor, especially in enclosed spaces suchas residential basements. The smell ofammonia is objectionable and would potentially impact external fly ash sales for OCC ofAmerica and internal use in the concreteoperationsowned by GCC Ready Mix

.. Ourprofessional experience with this situation in the pasthad been limited to the senses, i.e. eye and nose irritation and unpleasantodor. The corrective action taken was at the expense ofthe concrete producer, causingthose customers todo businesselsewhere. We value ourrelationship with yourcompanyand preferto use your productbecauseofits quality andperformance. Please do not allowthese attributes to be compromised. Ifyou should have any questions, orifwe may be offurther assistance, pleasecontact eitherofus ourDenver officesat(303) 739-5900.
Sincerely,

Mark R. Lukkarila, Technical ServicesManager GCC ofAmerica**BJi~ng** 

### ogether Joseph E. Finnegan, Regional SaleManager GCC ofAmerica

CorpOfllte Ole

.. 

### r. Iephone: 303·739·&900 130 RIImpart"'y,llII111200 /'till: 303- 7311·5931**Denve~**CO 80230 www.gee.comAdding Valus 10 Energy N

January 11,2010

Mr. Al Christianson Manager, North Dakota Business Development & Governmental Affairs 1611 EastCentury Avenue Suite 200 Bismarck,ND 58503

Dear

### Mr. Christianson:

The Eastlake power plant in Eastlake, Ohio had a SNCR installed over 2 years ago. Priorto the installation the plant produced a high quality F-ash which was sold out every year during the construction season. The ammonia level was between 200-400 PPM after the installation which was when the problems started. Anything over 100 PPM seemed to be anoticeable at this plant. We started shippingthe material whcn it was in the 100··200 PPMrange and the customers, batchplants and several contractors started calling with complaints especially in confined spaces such as buildings and basements

. In one case a Ready Mix plant employee stuck his head in the back ofthe truck to add air entraining agent and it bwned his eyes. He spent the night 

### in the emergency room getting his eyes washed out notknowing it was the fly ash causing the ammonia smell. We quit shipping anything over 100 PPM and business started droppingoff; contractors did not want fly ash 

### in their mixes. Since you're only checking a small amount ofammonia in the load it would test for less than 100 PPM but in some cases the Ready Mix producer still had problems which indicated the entire load was not less than 100 PPM

.We shutdown ablock plant and the customermade us take the fly ash out ofhis silo andhe quitbuying fly ash from us.

Bill Newkirk HeadwatersResources TechnicalSales Rep 440-725-0088

2761 Port Neal Circle Salix, IA 51052 P: 712

.943.4049 F: 712

.943

.2876

# , LAFARGE NORTH AMERICA Cement

January26, 2010

Mr. Al Christianson Manager,NorthDakotaBusiness Development& GovernmentalAffairs 1611 EastCenturyAvenue Suite 200 Bismarck,ND 58503 Subject: AmmoniaInjection inFlyAsh Lafarge has used fly ash from power sources where SNCRammoniaInjection units have beeninstalled. We havefound thatwhenthe ammonialevels exceed 40 partspermillionIn thefly ash thattheconsumer notices the ammoniaandfind Itto be objectionable. Lafarge is concerned that if ammonia Injection units are Installed at Great River Energy's Coal Creek Station it may cause the fly ash that Is produced to be unmarketable. Lafarge currently purchases a large percentageofthe fly ash that Is produced at this station and would beplaced at an economic disadvantageif we werenolonger abletomarkettWs highquality ash to ourreadymixcustomers. This would cause our customers in turn to be at an economic disadvantage Ifthey had to use fly ash from another source that is further away or use slag cement that perhaps would be more expensive than Coal Creekash.

Roy Sander/GeneralManager

LAJ'AROED.kot•• 684 IS'" Ave

. SW. PO Box 757, VoJJey City, ND 58072 Telephone: 1701) 845-2421 Fax: 170I) 845-1849 Toll Free: 1-800-533-8662

## Attachment 2: Email Thread Headwaterto GRE From: Stockdill, Diane GRE-CC Sent: Tuesday, December 29, 2009 3:38 PM To: Nelson, Debra GRE-MG Subject: FW: Where are we at? Attachments: STI ammonia removal.pdf Let's talk tomorrow -----Original Message----­ From: Christianson, Al GRE-BI Sent: Tuesday, December 29, 2009 3:35 PM To : Stockdill, Diane GRE-CC Subject: FW: Where are we at? Fyi, they are working on it. al Al Christianson Manager, North Dakota Business Development 

## &Governmental Affairs 1611 East Century Avenue Suite 200 Bismarck, ND 58503 701-250-2164 Direct 701-442-7664 Direct 701-220-4881 Cell 701-202-8964 Car achristianson@grenergy.com www.greatriverenergy.com

--- --Original Message----­ From: Jerry Smith [mailto:jsmith@headwaters.com] Sent: Tuesday, December 29, 2009 3:34 PM To: Christianson, Al GRE-BI Subject: FW: Where are we at? AI: Attached is Bruce's response to your latest inquiry. It appears that we are still waiting on Mr. O'Conner (EPRI) to review our data on Sammis and East Lake ash. The attached brochure from STI may be helpful in the comparison of SNCRs and SCRs in regard to ammonia being introduced into the ash. I don't know if this is sufficient for your needs. If not, I suggest that we (Diane, you, and I) get on a conference call with Bruce to discuss what else we may be able to provide

. Just let me know. Thanks. From: Bruce Boggs Sent: Tuesday, December 29, 2009 2:35 PM To: Jerry Smith Subject: RE: Where are we at? Jerry,

### There was no official document generated by EPRI to circulate on this issue. The curious finding that the more alkaline ashes had higher ammonia odor emissions was reported to EPRI but the reason for the finding was never identified. Dave O'Connor at EPRI will review our data showing the data on Sammis and East Lake comparisons. The data from our East Lake plant with SNCR and higher alkaline ash should be available shortly to compare with the much lower levels of ammonia from an SNCR associated with low alkalinity ash at Sammis. STI found it necessary to develop an ammonia removal/treatment system in addition to the carbon removal system they operate at several locations. I do not know if the Roxboro plant uses this system but I would point out that with the storage dome at Coal Creek, the ammonia levels that could accumulate would be extremely hazardous. A little know fact is that ammonia is an explosive gas at certain levels when it accumulates with air present. See attached STI brochure on ammonia removal. In that brochure they support the fact that SNCR units will introduce much more ammonia to the ash than SCRs but both can prevent ash from being used in the market. Bruce

From: Jerry Smith Sent: Tuesday, December 29, 2009 2:46 PM To: Bruce Boggs Subject: FW: Where are we at? Bruce: Please see AI's and Diane's comments below. Have we heard anything from EPRI on this issue? Thanks. From: Christianson, Al GRE-BI [AChristianson@GREnergy.com] Sent: Tuesday, December 29, 2009 1:22 PM To: Jerry Smith Subject: FW: Where are we at? Anything new, people want to know? Al Christianson Manager, North Dakota Business Development 

## &Governmental Affairs 1611 East Century Avenue Suite 200 Bismarck, ND 58503 701-250-2164 Direct 701-442-7664 Direct 701-220-4881 Cell 701-202-8964 Car achristianson@grenergy.com<mailto:achristianson@grenergy.com> www.greatriverenergy.com<http://www.greatriverenergy.com> From: Stockdill, Diane GRE-CC Sent: Tuesday, December 29, 2009 1:15 PM To: Christianson, Al GRE-BI

### Subject: Where are we at? Where is Headwaters at on the SNCR justification documentation? I saw the waiting for EPRI response but when do they plan on having something to us? 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 3: Headwaters information on SCR VS. 

## SNCR

# Ammonia Contamination Levels

Air Pollution 

# NH3 "Slip" 

# NH3 in Ash Control Process ppmv mg/kg 

# SCR 2to 10 50 to 400 SNCR 5to 20 200 to 600 S03Control 10to 20 300 to 600 ESP Conditioning 20 to 30 600 to 1200
Actualammonia concentrations willdependon ammonia injection rates/ coaltype/ sulfur**conten~** 

# andotheroperatingparameters.

### RE: RH SIP
- Appendix C.2 document Bachman, Tom A. to: Gail Fallon 08/09/2011 01 :30 PM 

### From: "Bachman, Tom A." <tbachman@nd.gov> To: Gail Fallon/R8/USEPAlUS@EPA History: This message has been replied to.


### Gail: I did not find it on our website. I should have been in the**Supplemen~al** 

### Information folder for Coal Creek. I will have it added

- Thanks. Tom Bachman, P.E. Sr. Env. Engr. ND Dept. of Health (701) 328-5188 -----Original Message----­ From: Fallon.Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] Sent: Tuesday, August 09, 2011 2:22 PM To: Bachman, Tom A. Subject: RH SIP

- Appendix C.2 document

Hi Tom, Can you please tell me if the attached document which was included with the RH SIP in Appendix C.2 is located somewhere on your regional haze website? It was included on both the electronic disk and the hard copy you submitted in March 2010 but I do not see it on the website. (See attached file: Ammonia in Ash ResponseNDDH (02-09-10) .pdf) Thanks, 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