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 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. 


mr­ ¥.­

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 

GRE6I..RIYE8 

ENE R G Y'v 

February 9, 2010 

Lewis Dendy 

North Dakota Department of Health 

Division of A ir 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 EPA concerning 

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 or the benefit of enhanced chemical reactions provided 

by the catalyst packing. Headwaters Resources, GRE's fly 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 

of the 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 marketer for the 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 letter from 

Herbert Moeckel of Headwaters Resources. In Attachments 1 section. 

Currently there are no installations of SCR or SNCR burning North Dakota Fort Union lignite. As GRE 

does not have any data or experience with ammoniated ash we have asked our fly ash marketer, 

Headwaters Resources , to respond to Amy Platt's chemistry statement that alkaline ashes experience 

lower uptake of ammonia. 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 alkaline 
ash. The mechanism for this higher evolution of ammonia has not been identified and is currently being 

investigated. See email thread of December 29, 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 at the Electric Power Research Institute (EPRI) and 

although they have done work for other types of coal 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 and GCC of America in the Allachment 1 section. 

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 of ammonia will not 

affect the class of our fly ash but will decrease the desirability and thus the marketability of our ash if the 

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 of fly ash was predicated on the fact 

that CCS is a mine mouth plant with 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 

their feedstock . See testimonials from Headwaters Resouces, Lafarge, and GCC 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: Testimonials 

Adding 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 raw feed 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. The fly ash produced from these two units is not suitable for use in concrete. 

Unit 3 at the 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, North Dakota Business 

Development & Governmental Affairs 

1611 East Century Avenue 

Suite 200 

Bismarck, NO 58503 

AI, 

We would like to take this opportunity to express concern about ORE's potential injection of 

ammonia into the flue gas during coal burning operations as an effort to reduce NOx emissions. 

As a wholesale marketer and end-user of your fly ash from the Coal Creek facility in North 

Dakota, our concern surrounds the impact this process will have on the fly ash when used in 

concrete. 

T~e ammonia in fly ash is not present as anunonia gas. Rather, it is in the fly ash as ammonium 

sulfate. Once in the high alkaline environment of concrete the ammonia is released. This 

becomes a problem because of the odor, especially in enclosed spaces such as residential 

basements. The smell of ammonia is objectionable and would potentially impact external fly ash 

sales for OCC of America and internal use in the concrete operations owned by GCC Ready Mix .. 

Our professional experience with this situation in the past had been limited to the senses, i.e. eye 

and nose irritation and unpleasant odor. The corrective action taken was at the expense of the 

concrete producer, causing those customers to do business elsewhere. 

We value our relationship with your company and prefer to use your product because of its 

quality and performance. Please do not allow these attributes to be compromised. If you should 

have any questions, or if we may be of further assistance, please contact either of us our Denver 

offices at (303) 739-5900. 

Sincerely, 

Mark R. Lukkarila, 

Technical Services Manager 

GCC of America 

BJi~ng ogether 

Joseph E. Finnegan, 

Regional Sale Manager 

GCC of America 

CorpOfllte Ole.. r.Ie phone : 303 ·739· &900 

130 RIImpart "'y,llII111200 /'till: 303- 7311·5931 

Denve~ CO 80230 www.gee.com 
Adding Valus 10 Energy N 

January 11,2010 

Mr. Al Christianson 

Manager, North Dakota Business 

Development & Governmental Affairs 

1611 East Century Avenue 

Suite 200 

Bismarck, ND 58503 

Dear Mr. Christianson: 

The Eastlake power plant in Eastlake, Ohio had a SNCR installed over 2 years ago. Prior to 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 a noticeable at this plant. 

We started shipping the material whcn it was in the 100··200 PPM range and the customers, batch plants 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 of the truck to add air 

entraining agent and it bwned his eyes. He spent the night in the emergency room getting his eyes washed 

out not knowing it was the fly ash causing the ammonia smell. 

We quit shipping anything over 100 PPM and business started dropping off; contractors did not want fly ash 

in their mixes. Since you're only checking a small amount of ammonia 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 shut down a block plant and the customer made us take the fly ash out of his silo 

and he quit buying fly ash from us. 

Bill Newkirk 

Headwaters Resources 

Technical Sales Rep 

440-725-0088 

2761 Port Neal Circle 

Salix, IA 51052 

P: 712.943.4049 F: 712.943 .2876 
, LAFARGE 


NORTH AMERICA 

Cement 

January 26, 2010 

Mr. Al Christianson 

Manager, North Dakota Business 

Development & Governmental Affairs 

1611 East Century Avenue 

Suite 200 

Bismarck, ND 58503 

Subject: Ammonia Injection in Fly Ash 

Lafarge has used fly ash from power sources where SNCR ammonia Injection units have been installed. We 

have found that when the ammonia levels exceed 40 parts per million In the fly ash that the consumer notices 

the ammonia and find It to 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 

percentage of the fly ash that Is produced at this station and would be placed at an economic disadvantage if 

we were no longer able to market tWs high quality ash to our ready mix customers. 

This would cause our customers in turn to be at an economic disadvantage If they had to use fly ash from 

another source that is further away or use slag cement that perhaps would be more expensive than Coal 

Creek ash. 

Roy Sander/General Manager 

LAJ'AROE D.kot•• 

684 IS'" Ave. SW. PO Box 757, VoJJey City, ND 58072 

Telephone: 1701) 845-2421 Fax: 170 I) 845-1849 Toll Free: 1-800-533-8662 
Attachment 2: Email Thread Headwater to 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 2 to 10 50 to 400 

SNCR 5 to 20 200 to 600 

S03 Control 10 to 20 300 to 600 

ESP Conditioning 20 to 30 600 to 1200 

Actual ammonia concentrations will depend on ammonia injection 


rates/ coal type/ sulfur conten~ and other operating parameters. 

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