MEMORANDUM 

TO: Steam Electric Effluent Guideline Rulemaking Record 

FROM: Danielle Lewis, ERG 

DATE: September 30, 2015 

SUBJECT: Supplemental Costs and Loadings Documentation (DCN SE05839) 

EPA’s report “Incremental Costs and Pollutant Removals for the Proposed Effluent Limitations 

Guidelines and Standards for the Steam Electric Power Generating Point Source Category” 

(DCN SE05831) describes the methodologies used to estimate engineering compliance costs 

associated with installing and operating the various technologies and practices that make up the 

regulatory options considered by EPA. That report also presents the methodologies used to 

estimate baseline and post-compliance pollutant loadings and the corresponding pollutant 

removals for each regulatory option. 

ERG prepared this document as a complement to that report, providing additional detailed 

information and data regarding the steam electric costs and loadings. This document, consisting 

of a compilation of appendices to this cover memorandum, includes the following types of 

additional detailed information and data: 

• Spreadsheets documenting development of input tables, cost factors, chemical dosage 

rates, and other cost elements; 

• Telephone contact reports and other detailed cost information provided by vendors; 

• Equipment specifications provided by vendors; and 

• Calculations performed using the cost information, including the generation of cost 

curves. 

Table 1 lists the document appendices and describes the information and data contained in each.
Memorandum 

September 30, 2015 Page 2 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename Input Tables SE05839.A1 FGD wastewater flows Input data Development of methodology to estimate missing 

FGD wastewater flow rates for plants currently operating wet FGD scrubbers. 

CBI_FGD Input Table 

SE05839.A2 FGD wastewater flows Input data Documentation of process used to identify those 

plants discharging FGD wastewater and determination of FGD wastewater flow rate. 

CBI_FGD C&L Flow 

SE05839.A3 Ash transport water flows Input data Development of the plant-level ash transport water 

flows used to estimate pollutant loadings. This documentation includes adjustments from public comments and bottom ash complete recycle review. 

Ash Flows Documenta

SE05839.A4 Landfill leachate flows Input data Development of methodology to estimate landfill 

leachate flow rate. 

Landfill Leachate Flow 

SE05839.A5 Impoundment leachate 

flows 

Input data Development of methodology to estimate 

impoundment leachate flow rates. 

Impoundment Leachat

SE05839.A6 Ash cost inputs Input data Identification of plants that incur back-up silo and 

pugmill or redundancy compliance costs associated with fly ash handling. Also includes a comparison of O&M costs associated with dry fly ash handling and traditional wet sluicing systems. 

CBI_Fly Ash Backup 

SE05839.A7 CCR input Input data Development of the CCR Input Table using output 

from the CCR Rule and EIA tonnage data. 

CCR Rule Probabilisti

SE05839.A8 FGD high flow and recycle 

analysis 

Input data Analysis of plants with high FGD wastewater flow 

rates, greater than or equal to 1,000 gpm, to determine if recycling FGD wastewater is feasible. 

FGD High Flow Analy

General Costs SE05839.A9 Sample preservation costs Monitoring costs Development of cost factors used to estimate 

sample preservation costs. 

SamplePreservationCo

SE05839.A10 On-site landfill cost factors Transportation and disposal 

costs 

Development of methodology to estimate dollar per ton costs to transport and dispose of treatment solids to an on-site landfill. 

Loading & Hauling Co

SE05839.A11 Off-site landfill cost factors Transportation and disposal 

costs 

Development of methodology to estimate dollar per ton costs to transport and dispose of treatment solids to an off-site landfill. 

CBI_Offsite Landfill C

SE05839.A12 Plant specific MW factor 

and FGD TSS 

Pond operation costs Development of an equation to create a specific 

unitized cost value for pond operation costs based 

NonCBI_Pond Cost Fa
Memorandum 

September 30, 2015 Page 3 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename 

concentration on plant size (in MW). Development of average 

TSS concentration used to estimate pond operation costs for FGD ponds. 

FGD Costs - Chemical Precipitation Treatment System SE05839.A13 Chemical precipitation 

treatment in place 

Input data Plant-specific assessments and determinations of 

FGD wastewater treatment in place. 

CBI_Chem Precip TIP

SE05839.A14 Equalization Tank Cost 

Analysis 

Equalization tank costs Cost comparison of equalization tanks and pond 

operating costs for high flow FGD plants. Analysis to determine which option, equalization tanks or existing segregated ponds, is more cost effective for achieving wastewater equalization at plants with FGD wastewater flow of 1,000 gpm or greater. 

EQ Tank vs Pond Sav

SE05839.A15 Capacity factor Operation and maintenance 

costs 

Development of annual FGD wastewater treatment flows for plant operating chemical precipitation; development of capacity factor used to size FGD wastewater treatment systems 

CBI_WWT System Fl

SE05839.A16 Purchased equipment costs Pump, tank, and filter press

purchase costs 

Development of factor used to determine the flow rate of sludge generated by chemical precipitation as a function of FGD wastewater flow 

CBI_SludgeFactor.xls

SE05839.A17 Sand filter purchase costs Purchased equipment cost Sand filter freight costs and specifications provided 

by a vendor 

SandFilter Gutierrez E

SE05839.A18 Dry cargo van freight costs Purchased equipment costs Equipment freight costs by full dry cargo van 

provided by vendor 

FreightCenter Telecon

SE05839.A19 Capital and O&M costs for 

mercury analyzer 

Purchased equipment cost Recurring cost 

Development of methodology to estimate capital and O&M costs associated with installing and operating a mercury analyzer and feed-back system on the FGD wastewater treatment effluent. 

Mercury Analyzer Co

SE05839.A20 Pump purchase costs Purchased equipment costs Development of cost equations for pump purchase 

costs 

Pump Equations.xlsx 

SE05839.A21 Pump purchase costs Purchased equipment costs Online freight costs by weight for shipping pumps 

approximately 500 miles 

PumpFreight.pdf 

SE05839.A22 Pump purchase costs Purchased equipment costs FGD wastewater forwarding pump purchase costs 

provided by a vendor 

WWForwardingPropo

SE05839.A23 Pump purchase costs Purchased equipment costs Treated FGD wastewater discharge pump purchase 

costs provided by a vendor 

TreatedWWDischarge

SE05839.A24 Pump purchase costs Purchased equipment costs Sump pump purchase costs provided by a vendor SumpPumpProposal.pSE05839.A25 Tank purchase costs Purchased equipment costs Development of cost equations for carbon steel and 

fiberglass reinforced plastic (FRP) tank purchase 

TanksEqns.xlsx 
Memorandum 

September 30, 2015 Page 4 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename 

costs and development of a cost algorithm to select between these tank types 

SE05839.A26 Tank purchase costs Purchased equipment costs FRP tank purchase costs provided by a vendor Augusta Telecon_FRPSE05839.A27 Tank purchase costs Purchased equipment costs Carbon steel tank information provided by a vendor CSTank Petrucci TeleSE05839.A28 Tank purchase costs and 

clarifier purchase costs

Purchased equipment costs Carbon steel tank information and specifications 

provided by a vendor 

FisherTankEmailandB

SE05839.A29 Tank purchase costs and 

clarifier purchase costs

Purchased equipment costs Carbon steel tank purchase costs and specifications 

provided by a vendor 

Fisher Tank Budget Pr

SE05839.A30 Tank purchase costs Purchased equipment costs Development of the design basis for chemical 

precipitation storage and reaction tanks expressed by hydraulic residence time 

BAT Design Basis Ch

SE05839.A31 Tank purchase costs Purchased equipment costs Development of a cost equation for freight costs for 

shipping FRP tanks 

FRP Tank Freight Cos

SE05839.A32 Tank purchase costs Purchased equipment costs FRP tank freight costs provided by a vendor Augusta Telecon_FRPSE05839.A33 Tank purchase costs and 

clarifier purchase costs 

Purchased equipment costs Carbon steel tank purchase and freight costs 

provided by a vendor 

CSTank Petrucci emai

SE05839.A34 Tank purchase costs Purchased equipment costs Carbon steel tank information provided by a vendor CSTank Ruinen TelecSE05839.A35 Tank purchase costs and 

clarifier purchase costs

Purchased equipment costs Carbon steel tank liner purchase costs and 

specifications provided by a vendor 

TankLiner Anderson e

SE05839.A36 Tank purchase costs and 

clarifier purchase costs

Purchased equipment costs Carbon steel tank liner specifications provided by a 

vendor 

LinerSpecs.pdf 

SE05839.A37 Tank purchase costs Purchased equipment costs Assessment of materials of construction for 

wastewater treatment tanks 

CBI_TIP WWTU Det

SE05839.A38 Tank purchase costs Purchased equipment costs Development of the design basis for the biological 

and evaporation treatment system feed tank expressed by hydraulic residence time 

BAT Design Basis Bio

SE05839.A39 Chemical storage tank 

purchase costs 

Purchased equipment costs Development of an algorithm to determine whether 

chemical storage tanks are required (as opposed to onsite storage in chemical totes), and if so, the tank size requirements 

CBI_Chemical tank si

SE05839.A40 Tank purchase costs Purchased equipment costs Totes information and costs provided by a vendor Totes Information and SE05839.A41 Chemical feed system 

purchase costs 

Purchased equipment costs Chemical feed system information and purchase 

costs provided by a vendor 

EnproTech Telecon_C

SE05839.A42 Chemical feed system 

purchase costs 

Purchased equipment costs Chemical feed system information and purchase 

costs provided by a vendor 

ChemFeed Litherland 

SE05839.A43 Chemical feed system 

purchase costs 

Purchased equipment costs Chemical feed system specifications provided by a 

vendor 

LiquidFeedSpecs.pdf 

SE05839.A44 Chemical feed system Purchased equipment costs Development of an algorithm to estimate lime CBI_Lime Feed Syste
Memorandum 

September 30, 2015 Page 5 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename 

purchase costs storage requirements and lime storage silo size. 

Development of a cost equation for lime feed system purchase costs 

SE05839.A45 Chemical feed system 

purchase costs 

Purchased equipment costs Chemical feed system specifications provided by a 

vendor 

CBI_LimeFeedSpecs.

SE05839.A46 Mixer purchase costs Purchased equipment costs Mixer information and purchase costs provided by 

a vendor 

Phila Mixers Telecon_

SE05839.A47 Mixer purchase costs Purchased equipment costs Mixer freight costs provided by a vendor Hibshman Email.docxSE05839.A48 Mixer purchase costs Purchased equipment costs Mixer specifications provided by a vendor MixerSpecs.pdf SE05839.A49 Mixer purchase costs Purchased equipment costs Development of cost factors used to estimate mixer 

purchase costs as a function of tank volume and mixer torque 

MixerRatios.xlsx 

SE05839.A50 Mixer purchase costs Purchased equipment costs Development of a filtrate sump sizing factor used 

to calculate the filtrate sump mixer cost 

Sump_HRT.pdf 

SE05839.A51 Clarifier purchase costs Purchased equipment costs Solids contact clarifier costs and specifications 

provided by a vendor 

Siemens Telecon SC C

SE05839.A52 Clarifier purchase costs Purchased equipment costs Clarifier freight costs provided by a vendor Clarifier Rasmussen ESE05839.A53 Clarifier purchase costs Purchased equipment costs Solids contact clarifier costs and specifications 

provided by a vendor 

Clarifier Sute Email.d

SE05839.A54 Clarifier purchase costs Purchased equipment costs Development of the design basis and treatment in 

place methodology for clarifiers 

CBI_Evaluation of cla

SE05839.A55 Clarifier purchase costs Purchased equipment costs Development of an equation to estimate clarifier 

tank volume as a function of FGD wastewater flow 

ClarifierTankSize.xlsx 

SE05839.A56 Filter press purchase costs Purchased equipment costs Filter press information and purchase costs 

provided by a vendor 

CBI_Filter Press Yazd

SE05839.A57 Filter press purchase costs Purchased equipment costs Filter press information and purchase costs 

provided by a vendor 

Andritz Telecon_Filte

SE05839.A58 Filter press purchase costs Purchased equipment costs Filter press specifications provided by a vendor CBI_FilterPressSpecsSE05839.A59 Filter press purchase costs Purchased equipment costs Development of a cost equation for filter press 

units as a function of required filter press size. Development of algorithms to determine required number and sizes of filter presses as a function of the flow rate of sludge generated by chemical precipitation 

FPCostEquations.xlsx 

SE05839.A60 Sand filter purchase costs Purchased equipment costs Sand filter information provided by a vendor Siemens Telecon_FilteSE05839.A61 Sand filter purchase costs Purchased equipment costs Sand filter information and purchase costs provided 

by a vendor 

Siemens Telecon_Filte

SE05839.A62 Sand filter purchase costs Purchased equipment costs Carbon steel tank information and specifications SandFilterSpecs.pdf 
Memorandum 

September 30, 2015 Page 6 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename 

provided by a vendor 

SE05839.A63 Direct capital costs Total direct capital costs Development of cost factors used to estimate total 

direct capital costs (i.e., installation, site prep,buildings, land, and instrumentation and controls) as a function of purchased equipment. 

CBI_Chem Precip Dir

SE05839.A64 Indirect capital costs Total indirect capital costs Development of the cost factor used to estimate 

total indirect capital costs (i.e., engineering, construction, contractor fees, and contingency costs) as a function of total direct costs. 

Indirect Capital Cost F

SE05839.A65 Operating labor costs Operation and maintenance 

costs

Development of a cost equation for operating labor costs 

CBI_Chem Precip Op

SE05839.A66 Labor costs maintenance 

materials costs 

Operation and maintenance costs

Development of cost factors used to estimate labor and maintenance materials costs as a function of annual FGD wastewater flow 

CBI_Chem Precip LabMaterials.xlsx 

SE05839.A67 Chemical purchase costs Operation and maintenance 

costs 

Development of chemical dosage rates CBI_Chem Precip Ch

Plants_2014.xlsx 

SE05839.A68 Chemical purchase costs Operation and maintenance 

costs 

Chemical purchase costs provided by vendors CBI_Chemical Unit C

SE05839.A69 Energy costs Operation and maintenance 

costs 

Development of an equation to estimate pump and clarifier mixer horsepower as a function of FGD wastewater flow 

Pump Clarifier Electri

SE05839.A70 Energy costs Operation and maintenance 

costs 

Lime slurry transfer pump specifications provided by a vendor 

LimeSlurryPumpProp

SE05839.A71 Energy costs Operation and maintenance 

costs 

Development of an equation to estimate filter press horsepower as a function of chemical precipitation sludge flow 

FP Electricity.xlsx 

SE05839.A72 Sludge disposal costs Operation and maintenance 

costs 

Development of an equation to estimate chemical precipitation dewatered sludge generation as a function of FGD wastewater flow. Estimation of density of dewatered chemical precipitation dewatered sludge 

CBI_Chem Precip DeGeneration.xlsx 

FGD Costs - Biological Treatment System SE05839.A73 Backwash flow rate Input data Development of equation to estimate ABMet 

backwash flow rate and backwash solids generation. 

CBI_ABMet Backwas

SE05839.A74 Biological treatment 

treatment-in-place 

Input data Plant-specific assessments and determinations of 

FGD wastewater treatment in place for biological treatment. 

Biological Treatment 

SE05839.A75 Capital and O&M costs for Purchased equipment costs Correspondence with General Electric (GE) CBI_GE ABMet Cost
Memorandum 

September 30, 2015 Page 7 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename 

GE’s ABMet system Installation costs 

Energy costs Labor costs Chemical costs 

regarding costing information for their ABMet biological treatment system. 

SE05839.A76 Capital costs for GE’s 

ABMet xystem 

Purchased equipment costs Installation costs 

Summary of correspondence with General Electric (GE) regarding updated costing information for their ABMet biological system as of 2014. 

CBI_ABMet Cost Upd

SE05839.A77 Capital Costs for Heat 

Exchanger 

Purchased Equipment Costs Freight Costs 

Development of costing equations for purchase and freight associated with heat exchanger and cooling water pumps. 

Summary of HE Vend

SE05839.A78 ORP monitor costs Purchased equipment costs 

Operation and maintenance costs 

Derivation of ORP Monitor costing methodology. CBI_ORP Monitor Co

SE05839.A79 ORP monitor costs Purchased equipment costs 

Operation and maintenance costs 

Summary of correspondence with ABB regarding capital costs and O&M requirements associated with an ORP Monitor. 

CBI_ORP Monitor Ve

SE05839.A80 Denitrification costs Purchased equipment costs 

Operation and maintenance costs 

Summary of vendor correspondence with Veolia. Denitrification Vendo

SE05839.A81 Denitrification costs Purchased equipment costs 

Operation and maintenance costs 

Derivation of denitrification costing methodology. Denitrification Cost M

SE05839.A82 Building costs Direct capital cost Development of factor used to calculate costs 

associated with constructing a building to house biological treatment equipment. 

Biological Treatment 

SE05839.A83 Maintenance materials 

costs 

Operation and maintenance costs 

Development of factor used to calculate costs associated with purchasing materials used for maintaining the biological treatment system. 

CBI_Biological TreatmFactor.xlsx 

FGD Costs - Evaporation Treatment System SE05839.A84 Capital and O&M costs for 

evaporation system 

Purchased equipment cost Installation cost Energy cost Chemical cost Sludge generation 

Compilation of data from GE and HPD regarding costing information for the vapor compression evaporation system. Cost curves and equations developed from vendor data were used to estimate system level costs for installing and operating a vapor compression evaporation system. 

CBI_ Evaporation Cos

FGD Costs – Sensitivity Analysis SE05839.A85 Sodium bisulfite sensitivity 

analysis 

Operation and maintenance costs 

Methodology used to estimate O&M costs associated with sodium bisuflite addition. 

CBI_Sodium bisulfite 

Fly Ash Costs 
Memorandum 

September 30, 2015 Page 8 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename SE05839.A86 Fly Ash Handling 

Conversion 

Specifications of the Fly Ash Dry Vacuum System 

Telecon and submitted data from fly ash handling vendor discussing the specifications of the fly ash dry vacuum system and other assumptions about the conversion. File also includes the conveyance pump energy requirements for different sized systems used in the fly ash handling cost methodology. 

NonCBI_CBPG FA CInfo.pdf 

SE05839.A87 Fly Ash Conveyance Cost Equations and Factors 

Developed for Fly Ash Conveyance Capital and O&M Costs 

Development of factors and equations for the fly ash handling conveyance capital and O&M costs. These equations and factors include the conveyance equipment capital cost equation, redundant equipment capital cost equations, direct capital cost factor, operating and maintenance labor rates, operating and maintenance hours, and maintenance materials cost factor. 

CBI_Fly Ash Conveya

SE05839.A88 Fly Ash Intermediate 

Storage 

Cost Equations and Factors Developed for Fly Ash intermediate Storage Capital and O&M Costs 

Development of factors and equations for the fly ash handling intermediate capital and O&M costs. These equations and factors include the intermediate storage equipment capital cost equation (for concrete and steel silos), direct capitalcost factor, water truck labor and operating hours, water truck fuel costs (maintenance materials), operating and maintenance labor rates, operating and maintenance hours, maintenance materials cost factor, and pugmill energy requirements. 

CBI_Fly Ash Int Stora

SE05839.A89 Fly Ash Disposal Fly Ash Typical Moisture 

Content 

Development of the typical moisture content used to calculate the amount of moisture conditioned fly ash to be transported to a landfill. 

CBI_Fly Ash Moistur

Bottom Ash Costs SE05839.A90 Bottom Ash Handling 

Conversion 

Bottom Ash Handling Conversion Costs 

Email correspondence and attached bottom ash cost data from bottom ash handling vendor discussing several operating characteristics and capital cost relationships for bottom ash handling conversions. File also contains information on the conveyance energy requirements for the MDS and Remote MDS pumps. 

NonCBI_CBPG BA H

SE05839.A91 Bottom Ash MDS Capital 

Costs 

Cost Equations and Factors Developed for the Bottom Ash MDS Capital Costs 

Development of factors and equations for the bottom ash handling MDS capital costs. These equations and factors include the MDS conveyance 

NonCBI_Btm Ash MD
Memorandum 

September 30, 2015 Page 9 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename 

and intermediate storage equipment capital cost equation (includes installation). 

SE05839.A92 Bottom Ash Conveyance Cost Equations and Factors 

Developed for Bottom Ash Conveyance O&M Costs 

Development of factors for the bottom ash MDS conveyance O&M costs. These factors include the conveyance operating and maintenance labor rates, operating and maintenance labor hours, maintenance materials cost factor. 

CBI_Btm Ash Convey

SE05839.A93 Bottom Ash Intermediate 

Storage 

Cost Equations and Factors Developed for Bottom Ash Intermediate Storage O&M Costs 

Development of factors for the bottom ash intermediate storage O&M costs. These factors include the intermediate storage operating and maintenance labor rates, operating and maintenance labor hours, maintenance materials cost factor, and pugmill energy requirements. 

CBI_Btm Ash Interme

SE05839.A94 Bottom Ash Wet Sluicing Cost Equations and Factors 

Developed for Bottom Ash Wet Sluicing O&M Costs 

Development of factors for the bottom ash wet sluicing O&M costs. These factors include the wet sluicing operating and maintenance labor rates, operating and maintenance labor hours, and maintenance materials cost factor. 

CBI_Btm Ash Wet Slu

SE05839.A95 Bottom Ash Remote MDS 

Capital Costs 

Cost Equations and Factors Developed for the Bottom Ash Remote MDS Capital Costs 

Development of factors and equations for the bottom ash handling remote MDS capital costs. These equations and factors include the remote MDS conveyance and intermediate storage quipment capital cost equation (includes installation) and buildings. 

NonCBI_Btm Ash Re

SE05839.A96 Bottom Ash Disposal Bottom Ash Typical 

Moisture Content 

Development of the typical moisture content used to calculate the amount of moisture conditioned bottom ash to be transported to a landfill. 

CBI_Bottom Ash Moi

SE05839.A97 Bottom Ash Recurring 

Costs 

MDS/Remote MDS Drag Chain Replacement Frequency and Cost 

Telecon and email correspondence with bottom ash handling vendor containing information on bottom ash handling conversions and specific costs for bottom ash conversions, drag chain replacement costs, and drag chain replacement frequency. 

CBI_UCC Ash Handl

SE05839.A98 Bottom Ash Recurring 

Costs 

Remote MDS Volume Estimate for Tank Rental Costs 

Development of the equation to estimate the volume of the remote MDS conveyor to estimate the volume of surge capacity required for maintenance. 

CBI_Bottom Ash Rem

SE05839.A99 Bottom Ash Recurring 

Costs 

Remote MDS Tank Rental Costs 

Telecon with Rain for Rent detailing the cost elements for renting tanks for additional storage capacity. 

NonCBI_Rain for Ren
Memorandum 

September 30, 2015 Page 10 Table 1. List of Supplemental Cost Document Appendices DCN Relevant Cost Element Topic Description Filename IGCC Costs SE05839.A100 Capital and O&M costs for 

evaporation system 

Monitoring costs Methodology used to estimate compliance costs for 

plants discharging IGCC wastewater. 

CBI_IGCC Cost Meth

Pollutant Loadings and Removals SE05839.A101 Pollutants of concern Pollutant removals Results of the pollutants of concern analysis. POC Analysis.xlsx SE05839.A102 FGD treatment system 

evaluation 

Pollutant loading concentrations 

Data used to determine specific pollutants showing removals at BAT FGD wastewater treatment systems. 

BAT FGD Treatment