## General Electric ABMet Correspondence

ERG, technical contractor to EPA, contacted General Electric (GE) regarding input on the cost methodology for estimated costs associated with its ABMet anoxic/anaerobic biological reactor system. The following PDF includes a compilation of responses between ERG and GE regarding specific costing elements including equipment capital costs, installation costs, nutrient costs and dosages, electricity requirements, operating and maintenance labor requirements, and backwash flow rates. Elements claimed as CBI are highlighted in yellow.

## Water 

## & Process Technologies

James Harwood Industrial Sales Manager

- ABMet North America 3239 Dundas Street West Oakville ON L6M 4B2 Deborah Bartram Conada VP, Water Programs T905 465 3030 14555 Avion Parkway, Suite 200 james.harwood@ge.com Chantilly, VA, 20151 11 April, 2011

. Dear Ms. Bartram:

Note that any information contained within this letterthat is marked with

# tCBIL**-~onsidered** to be Confidential Business Information. This included both attachment graphs accompanying this letter. Thankyou for the opportunity to review the EPA costing methodology. In reviewing your memo of22 March, 2011 and the previously submitted costing information related to the use ofthe ABMet® system in FGD applications, GE has revised the costing structure and the presented formatto better fit with the methodology. This methodology is only applicable for FGD applications as ittokes into accountthe specific nature of the water and typical requirements specific tothe power generation industry. Other applications, both within and outside of the power industry, should not use these equations. 

## 1 Cost Calculations Based on the attached curves contained with this letter, GE praposes the following structure modifications to the equations within the 22 March memo: Equipment Capital Cost

# = (1)**-i~BJ)** 

### __-'-­ Where: 

### y = Equipment capital cost in USD 

### x = Design plantflow rate in gallons per minute (gpm)

Installation Capital Cost = (2) Equipment Capital Cost X Installed Cost Factor Where: Installed Cost Factor = 

## (CVil (3) 

### y 

## =Installed Cost Factor as a percentage of Equipment Capital Cost 

### x = Design plant flow rate in gallons per minute (gpm)

### Heat exchanger costs have not been included in any ofthis workup. For operational costs. GE calculates the following: Nutrient Cost

## = 14) 

### Nutrient Cost per galion X Nutrient Consumption / 1000 X FGD scrubber flow Igpm) X 60 (min/hr) X Operating hr/day X Operating days/year**~~~= ~**  

### Energy unit cost ($/kWhl X ABMet® Power Consumption / 1000 X FGD scrubberflow (gpm) X 60 (min/hr) X Operating hr/day X Operating days/year labor Cost = 16) 

### Labor rate. $X!hour-worker X # 

### ofworkers (FTE) X Operating hr/day X Operating days/year Materials Cost 

### = 0.111 X (Nutrient Cost 

### + Energy Cost 

### + Labor Cost) Where: Nutrient Consumption 

## = Nutrient consumption in gallons of nutrient per 1.000 gallons of water treated as per Section 2. Item 4ofthis letter. Nutrient cost per gallon == ( GBI..') 

### ABMet® Consumption == 

### 0.36 kWh per 

### lOOO gallons ofwater treated as per Section 2. Item 5 ofthis letter. # 

### wor,,"s (FTE) == 

### GE**recomm~nds** 

### calculation based on one (1) 

### FTE as a requirement for the ABMft® system alone based on the following requirements: Operation Frequency Duration 

### Min worker # Bulk Nutrient Refill l/month 2 hr 1 Sampling (estimated) 

### l/week 4 hr 1 Cell Backflush* varies 3 hr 1 Daily Plant Inspection daily 1 hr 1 Weekly Plant Walk down weekly 2 hr 1 Monthly Plant Maintenance (probe cleaning. etc) monthly 1day 1 Weekly Estimate - 18 hrs

## 2 System Design Basis

In response to the request from EPAfor feedback regarding the ABMet® design basis. GE offers the following responses: 1. Design Basis for 2009 ABMet® FGD Installed Cost Curve a. Ifthe previously provided cost curve is no longer up to date, please provide an updated cost curve. We would also like to convert the cost curve into an equation based on expected flow rote. If GE has already developed such an equation, please provide or comment on this approach. GE has provided an updated curveforthe GE supplied capitol equipment. Included withthis is an equation 

### to establish a GE supplied capital cost

### +/- 15% based on the design basis and theadditional information within this package. GE has also provided a curve with an associated equation forthe installation/balanceofplant portion ofan ABMet® facility. This curve will provide a percentage, which when multiplied bythe associated GE capital costwill provide a costforthe balance ofplant/installation portion afa given facility. Addition ofthe calculated GE equipmentcost plus thecalculated BOP/installation costwill yield an estimated total projectcapital cost. This combined cost is estimated to be 

### +/- 25%. These costs includethe same assumptions as the December 20091 curve otherthan the geographical limitation:

• Unionized contractor labor is assumed • No special seismic criteriaare incorporated • Costs are based on executing project structureofconsortium between GE and contractor with balance ofplantengineering as a sub-contractor • Costs are based on ABMet® system being an 'island'with integration into thefull power plantsystem no being included (e.g. DCS interfaces.tie-in with existing wastewater plant. etc. omitted) • Costs areassuming integration ofABMet® system into largerwastewater facility. for example integratingABMet®following conventional physical/chemical treatmentwith ABMet® backwash waste recycled to conventional system for solids removal

1 "CBI ABMet® Cost CurveH Letter from J. Harwood GE to Sarah Holman ERG doted 17 December. 2009.-rhe general scope ofsupply (GE equipment

### + installation) and construction basis remains unchanged from the previous submittal:

• All process pumps, valves, and instruments • Process & instrument compressed air system, valves and lines • Nutrientsystem, storagetank, pumping • All process piping and supports within the ABMet® 'island' • Process equipment building with HVAC (concrete floor, block structurewith steel roof) • Concrete bioreactortankwalls and floorwith epoxy-coated rebar and epoxyflake-glass coating • Concrete backwash supply and backwash wastetankwalls and floorwith epoxy-coated rebar and epoxy flake-glass coating • Concrete process & utilitysump with pumps • Supportsteel, access stairs, walkways, grating, handrails • Engineering, commissioning and project management laborfor ABMet® 'island' • Construction equipment, materials and laborforABMet® 'island' Furthermore,the revised curve included the same omissions as the previous submittal:

• Utilityoverhead and labor • Planttie-in/integration (e.g. DCS interface, feed water, effluentwater line to discharge, etc) • Pilings, caissons, etc • Permitting • Financing charges • Otherwaste water processes such as pre or post-treatment, dewatering • Backwash waste disposal/solids handling b. Please provide a description ofthe assumed system design used as the basis forthe provided cost curve. For example. how many bioreactortrains are assumed. how many bioreactor cells are assumed pertrain. what is the design residence time through each bioreactor cell. etc.The costs are based upon thefollowing: • Feed waterquality provided by ERG2 • Numberoftrains used in this basisas well as the reactor size is variable as perthetable below given thewide range offlow rates being evaluated • Two-stage system Ii.e. 

### 2 reactors in series per train) • Retention time used in this design basis, expressed as EBCT3. is 

### 10 hoursfor thetotal system,S hours per stage • Custom project using typical component specificationsfrom existing facilities suitablefor FGD applications. ReactorDimensions (eo) FlowRate Numberof Trains (gpm) 

### Wx L x H(feet) 

### 2 50 8 x 

### 8 x 

### 24 100 11 x 11 x 

### 25 2 11x 11 x 

### 25 150 3 4 200 11x 11 x 

### 25 300 3 15 x 

### 15 x 

### 26 4 400 15x 

### 15 x 

### 26 15 x 

### 15 x 

### 26 600 6 800 8 15 x 

### 15 x 

### 26 1000 10 15 x 

### 15 x 

### 26

c. Is the system design based on standard-sized bioreactor cells that are designed to receive a maximum flow rate through each cell and where additional traihS are added to accommodate increased flow? What are the deSign and maximum flow rates for each bioreactorcell? What determines whether additional trains are needed? How do total capital costs vary between configurations? For all systems (not including the 

### 50 and 

### 100gpm systems), the designs are based on all trains operating optimally forthe design flow rate. In events such as backwashing.the piping sized so thatthe remaining bioreactors can accommodate thefull design flowoverthe briefduration ofthe backwash events or intheevent thatan individual bioreactor is to betaken off-linefor servicewhile still maintaining performance.

2 ERG Memo to J. Harwood of GE dated 22 March. 2011. EPA DCN: SE00559.C1. 3 EBCT = Empty Bed ContactTime. This is defined as the required reactor process volumelflow rate NOT including the displacement ofthe media. To compare this with previous correspondence using the term HRT (Hydraulic Retention Time). multiply the HRT by afoetor of2to arrive at EBCT.d. EPA is evaluating wastewater flow from 50 to 1.000 gpm and 10,000to 1.000,000 gpd. GE provided a cost curve based on gallons per day capacity (between 150,000 gpd and 1.450,000 gpdl. Are there significant changes to the costs belowthe flow range represented on the cost curve (i.e., can costs be extrapolated at flow less than the minimum)? With the revised curve, the flow range covered is from 50 gpm to 1,000 gpm. Extrapolation for values less than 50 gpm using the equations appears to bias high. Extrapolation using the equations to flows beyond 1,000 gpm has not been evaluated as part ofthis submission.

e. EPA defines capital equipment as equipmentfor installation, mechanical or electrical, piping, instrumentation, spare parts, freight, taxes, and insurance. Capital installation costs including engineering costs, construction costs, and contractor's fees. Please confirm what specific cost components are included in the provided cost curve. Is the flush system (e.g., 'Aush piping, pumps, and storage design speci'ficationsl included in the provided cost curve? GE's basis is similar to the EPA's definition with a few slight changes as the process related engineering is included within the GE equipment scope. Insurance under the GE scope is only limited to insurance carried by GE for GE supplied services/liability. Insurance coverage such as builders' risk is included under installation. GE Capital Equipment Scope: • All pumps • All process valves • All process instruments • All reactor internals (media, biology, supply and collection headers) • Nutrient dosing system including tank and first-fill • Compressed air system • Motor Control Center and PLC • Process engineering • Mechanical, electrical engineering for GE supplied portions of plant • Spare parts (initial supply) • Commissioning labor (GE supplied equipment)Installation Scope: • Pretreatment System (as required, • Unloading and storageofdelivered equipment at mutuallyagreed upon FOB pOint (assuming site' • Receiving and safe storage ofequipment atsite until readyfor installation • Equipment installation • Carbon media installation • Balance ofplantengineering • Civil works as required including building. equipmentfoundation (packed and level. concrete foundation' etc. • Plant utilities including compressed airdistribution • Equipmentaccess platforms,walkways, stairs etc. • All interconnecting piping between GEW&PT supplied skids/equipment • Electrical wiring interconnections between GEW&PT supplied skids/equipment (including wiring. conduitand otherappurtenances requiredto provide power connections as needed) from MCC totheGEW&PT supplied motors orterminal boxes atthe GEW&PT supplied skid. • Equipmentanchor bolts • Waste Dewatering System (as required' • Waste disposal • Raw materials, chemicals. and utilities during equipmentstart-upand operation, unless otherwise specified. • All required permits • Supply oftelephone/fax/modem access while GE staffareon-site • Laboratory services, operating and maintenance personnel during equipment checkout. start-upand operation f. Does the capacity (in GPO) assume thatthe FGO operates 24 hours per day? What is the minimal operating period for the ABMet® system to ensure the viability ofthe bugs? Capacities assume 24 houra dayoperation. The ABMet® system is notdesignedto be operated in a batch mode,therefore, operations such as 12 hours a dayare not recommended. Equalization would be recommended to ensure as consistent operation as possible. There is no hard numberfor minimal operating period and such cases would haveto be reviewed on an individual basis. likelythrough piloting.

### 2. Geographic Location. In past correspondence with EPA (January 19. 2008 and January 30. 2009). GE indicated that geographic location will affectthe overall design and cost ofthe ABMet® system. a. Facilities with ABMet® systems in place operate either open or closed bioreactor cells. What geographic factors will determine whether a plant should install open or closed bioreactors? How does GE scale the costs between open and closed systems? Please confirm the basis (open or closed) used for the costs represented in the 2009 cost curve. 

# (' CBT")

b. GE indicated that in colder climates. the system would need to be resized to accommodate for higher residence time. Please indicate how GE would define a "colder climate" and how this would affect the costs represented in the 2009 cost curve. Intheorythis is correctos a reduction intemperature will slowthe biological kinetics resulting in a requirementforan increased retentiontime in orderto achieve the same result. Development and validotion work conducted since 2009 has verified thatthe retention time used inthis costshould be sufficientfor 99%+ ofthe potential FGD installations inthe US. Therefore, the system should not need reSizing.



### c. In the 2008 meeting with EPA, GE indicated that geographic location will affect the installation costs ofthe system. Howwill location impactthe installation costs represented in equation (2) above? Individual State regulations and policies may have an impactonthe installation costs. Some states/utilities do not require unionized laborfor example which could lowerthe installation portion. Others. like Pennsylvania, require the exclusive use ofsteel sourced in the US, which can be a premium depending onthetiming and the market. Given the numberofvoriables, it is difficultto quantify any speCific impacts.

### 3. Heat Exchangers. Has GE evaluated the use ofheat exchanges with the ABMet® technology to achieve on optimal operating temperature for the influent prior to entering the bioreactors? GE has utilized heat exchangers within the twa facilities at Duke Energy. In these cases, the heatexchanges were used as an insurance policy to ensure thatthe feed water temperature remained belowthe maximum operating temperature during the hottest months of the summer. They were used as a means ofmaintaining a consistent feed water temperaturethroughouttheyear. Itis possible thatthey could be utilized to control to a constantfeed temperatureyear-round. butthis function has not been evaluated atthis time.



### a. Does GE offer the heat exchangers as part ofa package? How do the costs relate to the overall capital costs ofthe ABMet® system? Are the costs of heat exchangers included in the 2009 cost curve? GE has not supplied this eqUipment to date. Heat exchangers are not included within this cost curve. 

### b. What materials ofconstruction would be needed to conduct the heat transfer for FGD wastewaterwithout scaling the equipment? The units used previously were oftitanium construction. It may be possible for an alternative material thatwill offer similar performance ata reduced cost. Aheat exchanger vendorwould be able to offer the most comprehensive analysis ofthe options. 

### 4. Nutrient Costs. Does GE recommend that nutrients be continuously fed into the bioreactors to maintain bacteria regardless afwhether the FGD scrubberwastewater is fed? Ifso, how does GE determine the minimal nutrientfeed rates during instances where FGD scrubber purge is not being fed into the system? Does GE have nutrient cost data in 

### $ per gallon of FGD scrubber wastewatertreated and/or in 

### $ per unit of nutrient added? GE recommends that nutrient is fed continuously during operation. During cases where the system is in stand-by without receiving feed water. nutrientwould only be dosed periodically every few days as partofa maintenance mode. 

# ( eBl.') /.5. Energy Consumption. The energy costs are assumed primarily from the cast of pumping. EPA plans to include energy costs for heat exchanger operations. Can GE provide energy consumption data for operoting the ABMet® system? Energy consumptions over the ronge offlows do vary somewhat due to some constants such as PLC power. Estimated power consumption for the process including ABMet® pumps, instruments, compressor and controls (not including balonce of plant components such as HVAC, lighting. etc) ranges from 0.32 kWh/l,OOO gal to 0.40 kWh/l,OOO gal.

Best Regards,

James Harwood Industrial Sales Manager

- ABMet

enc. GRAPH

- ABMet® FGD GE Equipment Cost $US per Gallons per Minute Capacity GRAPH

- ABMet® FGD Installation Cost Component as a % of GE Equipment

# e**~ater** &Process Technologies 

### ABMet FGD GE Equipment Cost $US per Gallons per Minute Capacity

# Cf,\

ABMet FGD Installation Cost Component

_ Water

# &p:OC~~s Technologies 

### as a % 

### ofGE Equipment

# • G EPower & 

### Water 

## Water 

## &Process Technologies

James Horwood Industrial Sales Manager

- ABMet North Americq

. 3239 Dundos Street West Ookville ON L6M 4B2 

### Deborah Bartram Canodo 

### VP. Water Programs T905 465 3030 

### 14555 Avion Parkway. Suite 200 jomes.horwood@ge.com 

### Chantilly. VA 20151 6 May. 2011 Dear Ms. Bartram: Note that any information contained within this letter that is marked with a

# .. § is considered to

# -~ be Confidential Business Information. Furtherto our call of 19 April 2011. GE has estimated sludge and solids yields for the ABMet systems proposed in our 11 March 2011 letter to you. The information below is a modeled estimate and may not reflect actual volumes in operating conditions. The modeling is based on the feed watercriteria utilized for the estimates provided on 19 April. Forthis estimate. it is assumed thatthe entire system will be backwashed once per month with a recommended operating protocol that dictates that the backwashing ofthe system is spread out over that month to ease handling and minimize instantaneousvolumes. For example. a system with 4 reactor trains (8 reactors totall would backwash 2 reactors per week. Estimated backwash water volumes: 

### Volume per Volume per FlowRate Number

### of Number

### of 

### backwashper backwash total Trains Reactors reactor tgpmJ tusgalJ

50 2 4 

### 100 2 4 

### 150 3 6 

### 200 4 8 

### 300 3 6 

### 400 4 8 

### 600 6 

### 12 800 8 

### 16 1.000 10 20

### ABMet solids are generally co-Iandfilled with upstream clarifier solids. Given thatthey would amount to a minute fraction ofthe clarifier solids. the ABMet solids do not change the classification ofthe overall product. The ABMet solids can also be dewatered and handled separate and pass the TCLP test. Best Regards.

James Harwood Industrial Sales Manager ABMet