Attachment 2 Page 1 of 3 

### Attachment 2 Request for Treatment Information and Costs

This attachment requests capital and O&M costs for Liberty Hydro’s zero valen t iron (ZVI) treatment system for three different influent flow rates (100 gpm , 350 gpm , and 800 gpm). EPA is aware that this system is a treatment train and consists of a chemical precipitation system,

“ simple bio ” system, ZVI system, and iron oxidation/filtration system and is requesting cost and design information for each part of the FGD wastewater trea tment system

. E PA has request ed

similar order

- of

- magnitude cost information from multiple vendors in the preparation of the costs for the proposed rule

.

B y October 30 , 2014 , please provide us with your design and cost information in response to

this cos t request. Please specify if any of the requested information is considered confidential

business information.

Capital and Operating Costs Breakout

Table A

- 3 lists the preferred capital and O&M cost breakout for each part of the treatment system. Therefore, EPA is requesting that Liberty Hydro provides a cost estimate for the chemical precipitation system, “ simple bio ” system, ZVI system, and iron oxidation/filtration system for each of the three specified flow ra tes (12 tables in total). How ever, if another format is more convenient or if costs cannot be broken out to this degree, please provide what is

available. T o ensure consistency among cost estimates, please make the following assumptions in your estimates:

 Use a contingency for the indirect capital costs;

 Do NOT include land costs;

 Please note the year basis for the costs (i.e. 2014 $)

Along with (or as part of) the co sts and information provided, EPA would appreciate an indication of how the treatment sy stem costs may change with increased scrubbe r purge flow rate (e.g., the step changes in treatment system size and cost that occur with increased flow rate).Attachment 2 Page 2 of 3 Table A

- 3 . FGD Wastewater Treatment System Capital and O&M Costs *

Type of Cost Capital Cost Category Cost

(Provide a Year Basis, i.e. 2014 $)

Direct Purchased equipment (includes all equipment for the installation or

the upgrade: mechanical equipment; piping; instrumentation; electrical equipment; spare parts; freight charges; taxes; insurance; and duties) (Year) $

Other Direct Costs (includes purchased equipment installation, buildings, site preparation, instrumentation and controls) (Year) $

Total Direct Costs (Year) $

Total Indirect Costs (Includes engineering costs, construction expe nses, contractor’s fees, and contingency) (Year) $

Total Capital Cost (Year) $

Type of Cost O&M Cost Category Cost

(Provide a Year Basis, i.e. 2014 $)

Operation and

Maintenance Operating labor (Year) $

Maintenance labor (Year) $

Maintenance materials (Year) $

Chemicals (Year) $

Energy (Year) $

Hazardous Sludge Disposal (Year) $

Nonhazardous Sludge Disposal (Year) $

Sludge removal (if separate from sludge disposal cost) (Year) $

Total Operation and Maintenance Cost (Year) $

*provide a table for each FGD purge flow rate (100 gpm, 350 gpm, and 800 gpm) and part of

the FGD wastewater treatment system (chemical precipitation system, “simple bio” system, ZVI system, and iron oxidation/filtration system)

Design Information

Chemical Precipitation System

1. Please provide a process flow diagram of the chemical precipitation system that was used for Liberty Hydro’s cost estimates

. 2. List purchased equipment for this system (include general function of each unit, size of each unit, materials of construction for each unit, footpri nt of the entire system, life span of the treatment system)

. 3. What chemicals does Liberty Hydro assume would be added to the system and at what dosages?Attachment 2 Page 3 of 3 4. How does this system differ from the system EPA define s for the proposed rule (see

A ttachment 1 ) ?

“Simp le Bio ” Treatment System

1. Please provide a process flow diagram of the “ simple bio ” system that was used for Liberty Hydro’s cost estimates

. 2. List purchased equipment for this system (include general function of each unit, size of each unit, materials of con struction for each unit, footprint of the entire system, life span of the treatment system)

. 3. What chemicals does Liberty Hydro assume would be added to the system and at what dosages?

ZVI Blue TM System

1. Please provide a process flow diagram of the ZVI Blue TM system that was used for Liberty Hydro’s cost estimates

. 2. List purchased equipment for this system (include general function of each unit, size of each unit, materials of construction for each unit, footprint of the entire system, life span

of the treatm ent system)

3. What is the longevity of the ZVI Blue TM media?

a. Does the system require additional zero valent iron be added to the system occasionally?

b. How will this change for different flow rates and operating conditions? (If this is not currently known, p lease provide details on how Liberty Hydro is investigating this factor)

. 4. What is Liberty Hydro’s plan for disposal of media or regeneration of media?

a. For disposal of media, please identify whether the waste is expected to be

hazardous.

b. For regeneration of media, please identify if there are any wastestreams generated from the regeneration process and identify how those wastestreams would be

handled.

5. Have any tests been performed on regenerating the media?

6. What does Liberty Hydro plan to do with wash water used to remove built up solids (containing selenium and other pollutants) in the ZVI system?

7. D oes Liberty Hydro plan on recycling any wastewater from the ZVI system (e.g., regeneration wastewater, wash water) back to the upstream chemical precipitation

tr eatment system? Which wastewaters and h ow much (estimate in gpm) is recycled in Liberty Hydro’s system?

Iron Oxidation/Filtration System

1. Please provide a proc ess flow diagram of the Iron Oxidation/Filtration system that was used for Liberty Hydro’s cost e stimates.

2. List purchased equipment for this system (include general function of each unit, size of each unit, materials of construction for each unit, footprint of the entire system, life span of the treatment system)

3. In the meeting with EPA on September 23, 2014, Liberty Hydro provided a $3 million cost estimate for an iron oxidation/filtration system that removes zero valent and oxidized

iron. Please provide additional details regarding the purpose and operation of this system.