Attachment 2

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Attachment 2

Request for Treatment Information and Costs

This attachment requests capital and O&M costs for Liberty Hydro’s zero valent 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 treatment system. EPA has requested

similar order-of-magnitude cost information from multiple vendors in the preparation of the costs 

for the proposed rule. 

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

this cost 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 rates (12 tables in total). However, if another format 

is more convenient or if costs cannot be broken out to this degree, please provide what is 

available. To 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 costs and information provided, EPA would appreciate an 

indication of how the treatment system costs may change with increased scrubber purge flow rate 

(e.g., the step changes in treatment system size and cost that occur with increased flow rate).
Attachment 2

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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 expenses, 

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, 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?
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4. How does this system differ from the system EPA defines for the proposed rule (see 

Attachment 1)?

“Simple 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 construction 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 BlueTM System

1. Please provide a process flow diagram of the ZVI BlueTM 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 treatment system)

3. What is the longevity of the ZVI BlueTM 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, please 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. Does Liberty Hydro plan on recycling any wastewater from the ZVI system (e.g., 

regeneration wastewater, wash water) back to the upstream chemical precipitation 

treatment system? Which wastewaters and how much (estimate in gpm) is recycled in 

Liberty Hydro’s system?

Iron Oxidation/Filtration System

1. Please provide a process flow diagram of the Iron Oxidation/Filtration 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 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.