## Mercury Analyzer Costs

This Excel file contains the following worksheets:

Telecon Notes

FRP Piping Costs

Distance Calc This Excel workbook documents the methodology developed to estimate the costs associated with the mercury analyzer.

EPA included costs for a mercury analyzer and feedback pump and piping for all FGD and leachate wastewater treatment systems. ERG, on behalf of EPA, contacted a vendor of the mercury analyzer, Milestone, Inc, to gather specific details on the analyzer and it's operation to best estimate the capital costs and O&M costs associated with including this feature as part of the treatment system.

Notes from the telecon ERG had with Milestone, Inc to discuss details of the mercury analyzer. Included in these notes are the capital cost of the analyzer, the O&M costs associated with replacement chemicals and materials, and details on the recurring cost associated with replacing the analyzer at a standard interval. Calculations to determine the percentage of purchased cost associated with freight costs. ERG gathered information on the cost of fiberglass reinforced piping (FRP). Assuming this piping would be transported by truck, ERG also estimated the freight cost for each size pipe to estimate what percentage of the capital cost should be allocated for freight costs. Freight percentage is highlighted in yellow. Survey data on FGD wastewater treatment systems. This data includes information on the size, or footprint, of the system. This data was used to estimate the distance of piping needed to route wastewater from the effluent tank back to the equalization tank when the mercury analyzer indicates that the treated effluent is off specification.Project No.: 0172.09.029.043

DISTRIBUTION Page _1_ of __1_ Project Name: Steam Electric Rulemaking TELEPHONE CALL RECORD Outgoing Call Date: 03/27/12 Time: 11:30 am PDT Company Name: Milestone Inc. Contact Name: Tim Michel Phone No.:(203) 925-4240 Name: Kavya Kasturi Eastern Research Group GENERAL SUBJECT : Milestone’s Direct Mercury Analyzers TOPICS DISCUSSED AND ACTION TAKEN On Tuesday, March 27, 2012 at 11:30 am I spoke with Mr. Tim Michel. I explained that I was calling to learn more about Milestone’s direct mercury analyzers for use by the steam electric power industry. Mr. Michel stated that they offered two analyzers: the DMA-80, which is their standard dual-cell analyzer, and the DMA-80.3, which is their tri-cell analyzer for increased sensitivity. Both instruments follow EPA Method 7473 for thermal decomposition (in which the DMA is referenced). The concentration of mercury is determined by calculating the total mercury weight and dividing it by the weight of the sample. The dual-cell can typically measure concentrations to the single ppb range while the tri-cell can measure concentrations to the mid-ppt range. Mr. Michel stated no sample preparation is required beyond standard methods of acidifying the sample to preserve mercury. To analyze the sample, for liquid samples, the sample is pipetted into a quartz sample boat which takes less than one minute. The analyzer can hold up to 40 sample boats in an auto sampler tray. After the tray is inserted into the machine, the user hits start to begin the analysis. Analysis takes approximately 6 minutes per sample. Any number of samples between 1 and 40 can be run at a time. Mr. Michel stated the operation of the equipment is simple and while professional laboratories use the equipment, high schools also use the equipment. Mr. Michel stated that the analyzers have been used for more than 10 years and there are approximately 300 systems in use in the United States. Mr. Michel stated that the following power companies used the analyzer: WE Energies, Duke Power, York, Detroit Edison, Com Edison, Great River Energy, and Grand Rivers Dam Authority. The cost of the DMA-80 is approximately $36,000 which includes installation and training as well as a consumables kit. The DMA-80.3 costs approximately $41,000. The lifespan of the equipment is approximately 5-7 years but companies may choose to upgrade if Milestone releases a new analyzer. The analyzers use the following consumables: a catalyst tube and an amalgamator. The lifetime depends on the concentration of mercury in the samples. Mr. Michel stated if approximately 200 samples were analyzed per week, the consumables would need to be replaced approximately once every quarter. The consumables cost $600 to replace. Mr. Michel stated that the captured mercury could be exhausted to a fume hood or captured by an activated carbon trap. If activated carbon is used, he recommended replacing the activated carbon every other time the consumables are replaced. A cost comparison of the DMA-80 to cold vapor atomic absorption is provided on Milestone’s website: http://www.milestonesci.com/images/assests/dma-80.pdf Mr. Michel said the costs were up to date and while the cost estimates were based on soil samples, he expected the results would be similar for wastewater samples. Mr. Michel stated that calibration is not required every day. He recommended quality control checks using samples of known mercury concentration bracketing expected sample concentrations be performed. If thequality control checks are passed there is no need to recalibrate. If calibration is required, he recommended a 10

point calibration which may take up to an hour. Additional documentation is available on Milestone’s website: http://www.milestonesci.com/index.php/productmenu/ mercury/dma80-overview.htmlcalling to learn more about Milestone’s direct mercury analyzers for use by the steam electric power industry. Mr. Michel stated that they offered two analyzers: the DMA-80, which is their standard dual-cell analyzer, and the DMA-80.3, which is their tri-cell analyzer for increased sensitivity. Both instruments follow EPA Method 7473 for thermal decomposition (in which the DMA is referenced). The concentration of mercury is determined by calculating the total mercury weight and dividing it by the weight of the sample. The dual-cell can typically measure concentrations to the single ppb range while the tri-cell can measure concentrations to the mid-ppt

Mr. Michel stated no sample preparation is required beyond standard methods of acidifying the sample to preserve mercury. To analyze the sample, for liquid samples, the sample is pipetted into a quartz sample boat which takes less than one minute. The analyzer can hold up to 40 sample boats in an auto sampler tray. After the tray is inserted into the machine, the user hits start to begin the analysis. Analysis takes approximately 6 minutes per sample. Any number of samples between 1 and 40 can be run at a time. Mr. Michel stated the operation of the equipment is simple and while professional laboratories use the equipment, high schools also use the equipment. Mr. Michel stated that the analyzers have been used for more than 10 years and there are

Mr. Michel stated that the following power companies used the analyzer: WE Energies, Duke Power, York,

consumables kit. The DMA-80.3 costs approximately $41,000. The lifespan of the equipment is approximately

The analyzers use the following consumables: a catalyst tube and an amalgamator. The lifetime depends on the concentration of mercury in the samples. Mr. Michel stated if approximately 200 samples were analyzed per week, the consumables would need to be replaced approximately once every quarter. The consumables cost $600 to replace. Mr. Michel stated that the captured mercury could be exhausted to a fume hood or captured by an activated carbon trap. If activated carbon is used, he recommended replacing the activated carbon every other time the consumables are replaced. A cost comparison of the DMA-80 to cold vapor atomic absorption is

Mr. Michel said the costs were up to date and while the cost estimates were based on soil samples, he expected

Mr. Michel stated that calibration is not required every day. He recommended quality control checks using samples of known mercury concentration bracketing expected sample concentrations be performed. If thequality control checks are passed there is no need to recalibrate. If calibration is required, he recommended a 10

Additional documentation is available on Milestone’s website: http://www.milestonesci.com/index.php/productmenu/http://www.frppiping.com/frp_filament_wound_pipe?b=1

Pipe Size Cost 1 $/ft gpm gpd # pieces on truck (48' x 8' x 8')

2 10.12 125 180000 384 3 14 250 360000 256 4 17.89 450 648000 192 6 21.83 1050 1512000 128 8 28.36 1850 2664000 96 10 37.27 2900 4176000 72 12 47.1 4150 5976000 64

Note: Assume FRP Filament Wound Pipe Note: Assume 20 foot sections of pipe Note: Costs from FRP Piping Note: For shipping by truck. Assume 4 rows of pipe high and two lengths of pipe are loaded on the truck. Number of pipes across depends on piping diameter (total length / pipe diameter)Total length of pipe (ft) Freight ($/ft) Freight to pipe ratio

8064 0.173611111 0.017155248 5376 0.260416667 0.01860119 4032 0.347222222 0.019408732 2688 0.520833333 0.023858604 2016 0.694444444 0.024486758 1512 0.925925926 0.024843733 1344 1.041666667 0.022116065

0.017155248 Min 0.024843733 Max 0.021495762 Average 0.022116065 Median

Note: For shipping by truck. Assume 4 rows of pipe high and two lengths of pipe are loaded on the truck. Number of pipes across depends on piping diameter (total length / pipe diameter)plant_id cbi_WWT_ID System_ID 4861 FALSEWWT-1 9504 FALSEWWT-1 9671 FALSEWWT-2 7382 FALSEWWT-1 6671 FALSEWWT-1 6689 FALSEWWT-1 8353 FALSEWWT-1 771 FALSEWWT-A 2079 FALSEWWT-A 4978 FALSEWWT-1 5570 FALSEWWT-1 9391 FALSEWWT-1 210 FALSEWWT-1 450 FALSEWWT-1 7728 FALSEWWT-1 103 FALSEWWT-1 7884 FALSEWWT-1 5355 FALSEWWT-2 1731 FALSEWWT-1 4237 FALSEWWT-2 4679 FALSEWWT-1 6283 FALSEWWT-2 3015 FALSEWWT-1 3597 FALSEWWT-1 2297 FALSEWWT-1 7434 FALSEWWT-1 8308 FALSEWWT-1 9059 FALSEWWT-1 6377 FALSEWWT-1 7301 FALSEWWT-1 9805 TRUE [REDACTED] 9805 TRUE [REDACTED] 9948 FALSEWWT-A 5126 FALSEWWT-2 2268 TRUE [REDACTED] 904 FALSEWWT-1 1219 FALSEWWT-1 66 FALSEWWT-2 3831 FALSEWWT-1 4122 TRUE [REDACTED] 4122 TRUE [REDACTED] 2033 FALSEWWT-1 3843 FALSEWWT-1 1381 FALSEWWT-1 3709 FALSEWWT-2 7135 FALSEWWT-19768 FALSEWWT-1 2550 FALSEWWT-1 4624 FALSEWWT-1 5477 FALSEWWT-1 8753 FALSEWWT-1 9166 FALSEWWT-1 14 FALSEWWT-1 3146 FALSEWWT-1 4543 TRUE [REDACTED] 3095 FALSEWWT-A 6616 FALSEWWT-1 3373 FALSEWWT-1 7785 FALSEWWT-2 7785 FALSEWWT-3 5318 FALSEWWT-A 8661 FALSEWWT-1 5015 FALSEWWT-1 4533 FALSEWWT-1 3719 FALSEWWT-1 6933 FALSEWWT-1 7727 FALSEWWT-1 3265 FALSEWWT-1 6939 FALSEWWT-1 3196 TRUE [REDACTED]

Count 68 Aveage Footprint 113039.9265 ft2

If we assume the FGD area is a rectangle with one side of x and the other of 2x.

Length of the short side of the treatment system 237.7392758 feet

To conservatively estimate the distance of piping needed to route the FGD treatment system effluent from the treated effluent tanks back to the EQ tanks assume it's routed from one corner to opposite corner. A distance of 3x.

Total pipe length 713.2178274feetPlant_Desig Footprint_ft2

WWT Clarifier & Multimedia Filters 576 Wastewater Treatment System 126000 FGD Wasterwater Treatment System 6272 Wastewater Treatment Plant 59500 WW Treatment 80000 FGD Treatment sys. 2600 FGD Blowdown Treatment System 10858 FGD WWTP 90000 FGD WWTS 80000 Wastewater treatment 46636 FGD Treatment 549553 FGD Bioreactor sys. 1829520 Waste Water Treatment Plant 62400 WWT-1 52000 LAMELLA 1247 FGD WWT 750000 FGD WWT 19587 Polymer Addition 25 FGD Wastewater Treatment 53600 FGD WWT 100000 FGD WWT Plant 15000 FGD WWTS 5929 Waste Water Treatment System 3100 FGD WWSRS and CWTS 713400 FGD WWTP 100000 Scrubber Evaporation Pond 8432 FGD Wastewater Treatment 15000 WWTS 30000 FGD Wastewater Treatment System 30000 Wastewater Treatment 55300 [REDACTED] [REDACTED] [REDACTED] [REDACTED] FGD Wastewater Treatment 16800 Clarifier 12000 [REDACTED] [REDACTED] Waste Water Treatment 5000 WasteWater Treatment 34376 Densadeg WWT 9030 FGD WWT 25814 [REDACTED] [REDACTED] [REDACTED] [REDACTED] WASTEWATER 2 705980 WWTS 102000 WWT 40000 ERGS FGD WWTS 25440 WWT-1 360000Wastewater treatment plant 62400

FGD WWTS 40000 wwtp 25000 WWTP 20000 FGD system treatment 343000 Wastewater treatment 12480 WWT 20000 Scrubber System 3600 [REDACTED] [REDACTED] FGD Wastewater Treatment System 13800 FGD WWTP 100000 Waste Water Treatment 27500 Purgewaer Treatment 135000 Wastewater Treatment 89915 FGD WWTP 90000 FGD WWTS 108900 FGD WWTP 10000 FGD WWT 20000 WWTP -999 Wastewater treatment plant 3172 Waste Water Treatment Plant 41633 FGD CPS WWTP 67700 Waste Water Treatment 5000 [REDACTED] [REDACTED]

To conservatively estimate the distance of piping needed to route the FGD treatment system effluent from the treated effluent tanks back to the EQ tanks assume it's routed from one corner to opposite corner. A distance