1

MEMORANDUM

TO: Docket EPA-HQ-OW-2013-0652, for Alaskan Seafood Processing Effluent 

Limitations Guidelines, Notice of Availability of Data and Information

FROM: U.S. Environmental Protection Agency

DATE: August 2013

SUBJECT: Report of Quality Activities Supporting Alaska Seafood Processing Cost 

Estimates

1. BACKGROUND AND PURPOSE OF THIS REPORT

Background. The U.S. Environmental Protection Agency (EPA) received a petition from 

Alaskan seafood processors in 1980. This petition requested that EPA suspend regulations 

applicable to seafood processors in “non-remote” locations in Alaska. It also requested that EPA 

change the regulations using a rulemaking process. In a Federal Register notice dated January 20, 

1981, EPA published a proposed response which would deny the petition and maintain the status 

of four of five locations (Anchorage, Cordova, Ketchikan, Petersburg) as “non-remote” 

processing locations, and would grant the petition for Juneau, thus proposing to change the status 

of that location to “remote.” EPA also requested comment on additional locations that may have 

similar characteristics to the non-remote locations. Finally, in the proposed response, EPA also 

indicated that the earlier suspension of the regulations for good cause would remain in effect 

until it issued a final response to the petition. However, EPA has not issued a final response to 

this 1980 petition or amended effluent limitations.

EPA estimated costs for direct discharging Alaska seafood processors associated with the 

petitioning locations

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of Cordova, Juneau, Ketchikan, and Petersburg to manage and dispose of 

seafood processing solids by 1) screening and transport for ocean disposal, and 2) screening,

cooperative byproducts recovery, and ocean disposal of non-recoverable waste. EPA estimated 

costs for 15 surveyed processors in the petitioning locations and in the Kenai Peninsula2, one of 

the additional locations being considered for reclassifying as non-remote, and three model plants. 

Surveyed processors are those that were surveyed in EPA’s §308 questionnaire for the seafood 

processing industry and include nearly all of the processors in the petitioning locations. EPA

used estimated costs for the three model processors to evaluate economic impacts for nonsurveyed processors in the petitioning locations and the Kenai Peninsula. 

 

1 Anchorage, though classified as a non-remote processing location, has no direct discharge seafood processing 

facilities and was not included in the analysis.

2 The Kenai and Seward are considered one processing location, the Kenai Peninsula for the purposes of this 

analysis. EPA estimated costs and economic impacts for processors in the Kenai Peninsula because EPA might 

consider reclassifying these locations as non-remote.
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To estimate the costs, EPA developed waste management scenarios and assumptions 

documented in Outline of Costing Assumptions Alaska Seafood Processing in Non-Remote 

Processing Locations included in Appendix A of this memorandum. EPA then collected prices 

for purchasing and operating the equipment required to implement the scenarios. EPA used the 

prices, scenarios, and assumptions to develop an Excel spreadsheet for estimating costs. Then, 

using site-specific information from EPA’s CWA §308 questionnaire, EPA estimated costs for 

15 seafood processors located in five seafood processing locations to implement the waste 

management scenarios. 

Purpose of this Report. This report describes the activities EPA used to control the 

quality of these cost estimates. Plans for these quality control activities are detailed in Revised 

Draft Quality Assurance Project Plan: Support for EPA Response to Industry Petition on ELGs 

for Non-Remote Alaskan Seafood Processors, conditionally approved on November 29, 2010 

(hereafter, the QAPP), and revised August 2013. 

Activities used to control cost estimate quality included:

 Maintaining a project file of the collected cost data (i.e., pollution control 

technology equipment prices and unit prices).

 Verifying that the collected cost data met the data acceptance specifications

presented in QAPP Table 2-3;

 For spreadsheets developed to estimate costs, checking spreadsheet data entry and 

calculations and documenting these checks; and

 Verifying that the estimated costs met the quality specifications presented in 

QAPP Table 2-4.

2. COLLECTING COST DATA

EPA collected information about the costs for Alaskan seafood processors to install and 

operate wastewater pollution control technologies, including byproduct recovery processes and 

hauling waste for off-shore disposal. EPA obtained current (i.e., 2010 - 2011) cost information 

from equipment vendors, including both vendors that serve the Alaska areas included in this 

study and vendors that don’t serve Alaska but sell the brands and models of equipment used in 

Alaska. In all cases, EPA added costs for shipping to each processing location to the quoted 

equipment costs.

In addition to equipment purchase and shipping, EPA obtained prices for fuel (electricity, 

gasoline, and diesel), labor, and shipping byproducts from the seafood processing location to 

Seattle. To estimate the costs of a building and a sump, EPA used standard R.S. Means 

construction costs and applied construction location factors to scale these costs to specific Alaska 

locations. 

EPA documented the source of all cost data. Vendor quotes, equipment brochures, and 

webpages were saved as pdf files and retained in the project file.
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The criteria EPA used to evaluate the quality of collected pollution control technology

cost information are summarized in Table 2-1 along with acceptable values for each criterion. 

Table 2-1. Pollution Control Technology Cost Data Acceptance Criteria

Acceptance Criterion: Description/Definition Specification

Currency (up to date) Does the information reflect current 

conditions? Costs are current (e.g., 2009 – 2011).

Geographic Scope Does the information reported reflect 

an area relevant to the study?

Costs are appropriate for the “non-remote” areas 

of Alaska included in this study.

Accuracy/Reliability Is the information reported true? Obtained from a vendor who does business in the 

Alaska areas included in this study.

Comparability

Are the costs comparable to costs 

provided by sources that meet these 

acceptance criteria?

Comparable to costs obtained in §308 information 

collection requests.

Source: QAPP Table 2-3. 

3. EVALUATING COST DATA QUALITY

While collecting cost data, EPA evaluated their quality to ensure they met the needs of 

the project. 

3.1 Verifying Cost Data Quality: Comparing Collected Data to QAPP Data Acceptance 

Specifications

EPA used the Pollution Control Technology Cost Data Check List from QAPP Appendix 

B to document how the collected data met the cost data acceptance criteria. Checklist findings 

were recorded in a spreadsheet, a copy of which is included in Appendix B of this memo. EPA’s 

verification of how well the cost data met the quality specifications is presented, by acceptance 

criterion, in this section.

Currency. With the exception of vessel maintenance and insurance, all costs were 

collected from vendors or documented Internet sources in 2010 or 2011 and thus meet the 

currency specification.

To estimate the cost for vessel maintenance and insurance for scow, waste boat, and 

tender, EPA used the median annual maintenance costs for fishery vessels on the Great Lakes

($10,396/year), taken from Great Lakes Fisheries Vessels Status of the Fleet, 2001. For the bow 

picker, EPA estimated vessel maintenance and insurance at 7% of the cost of the boat. These 

estimates did not meet the specifications for currency or geographic scope. EPA considered these 

estimates to be “best available” and suitable for concept level cost estimates. 

Geographic Scope. EPA obtained costs for equipment appropriate for the “non-remote” 

areas of Alaska included in this study. Vendor quotes assumed delivery of equipment to Seattle,

and EPA added costs for shipping the equipment from Seattle to each processing location. Also, 

for building costs, EPA used national average construction costs from R.S. Means, then adjusted 
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the costs to the processing location locations using factors from Construction Cost Survey 2010, 

Alaska Housing Finance Corporation.

Accuracy/Reliability. As listed in Table 2-1, the specification for accuracy and reliability

was that quotes be obtained from vendors who do business in the Alaska areas included in this 

study. Quotes for rotary wedge wire screens and “package” byproducts plants were obtained 

from vendors that do business in Alaska and thus met this specification. 

Although quotes for other equipment were from vendors that do not serve Alaska, they

were obtained from vendors that sell the type and brands of equipment used in Alaska. For this 

reason, although the quotes did not meet the specification, in EPA’s judgment, these quotes meet 

the criterion that the reported information is “true.”

Comparability. EPA requested seafood processors report their annual costs for waste 

management (dollars per year) in the §308 questionnaire. EPA intended to use these reported 

costs to evaluate comparability. Many respondents did not respond to this question and those 

who did respond did not itemize the costs. For this reason, EPA did not systematically compare 

costs reported in the questionnaire responses to prices that EPA obtained for equipment, fuel, 

labor, and shipping. As a result, EPA could not systematically determine the comparability of the

collected cost data. However, where individual questionnaire responses or other public sources 

included data applicable to costing scenarios applied to processors for which EPA developed 

costs, basic comparisons were made.

Regarding capital costs, during August 2010 visits to Alaska seafood processors (and in 

communication conducted as follow-up to the visits), EPA obtained equipment costs. Costs 

provided by seafood processors are compared to vendor prices in Table 3-1. 
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Table 3-1. Comparison of Fish Pump and Off Shore Disposal Costs

Source Description Size Units

Cost:

Low

End of 

Range

Cost:

High

End of 

Range

Fish pumps

EPA

Fluid Process 

Equipment, Inc

Moyno Pump 2000 Series rated at 10 gpm 

at 30' TDH. Includes open hopper with 

auger, 5HP motor. Includes cost for fluid 

detection control systems.

<112,000 lb/day $20,511

>112,000 lb/day $21,233

Industry

Rick Eaglin

ANCOEAGLIN

Pumps appropriate for transferring fish 

waste raw material for this 25 MT/day 

byproducts plant would likely cost 

$27,000 to $28,000

55,125 lb/day $27,000 $28,000

Industry Sandro Lane

To give you an idea, the pumps that we 

are using in KTN are in the $100,000 

range to move 600,000 lbs of heads per 

day to our process

600,000 lb/day $100,000

Off shore disposal operating costs

EPA

Alaska Glacier, 

Juneau site 

visit report

Bow picker 16,000 lb/load

$40,000

per 

yearb

$80,000

per yearb

Dock Street 

Brokers Work vessel 60,000 lb/load $72,000per yearb

Dock Street 

Brokers Scow 100,000 lb/load

$68,000

per 

yearb

$74,000

per yearb

Industry

Unnamed to 

prevent 

disclosure of 

CBI

Waste disposal vessel contract costs 

$1,000/day plus fuel. Waste managed is 

100 to 350 MT/day

770,000 lb/load

$90,000 

per 

yeara,c

Alaska 

General, 

Ketchikan

site visit report 

and APDES 

annual report

In 2009, waste was hauled daily during the 

salmon season to Bold Island by the Western 

Pioneer or Chichagof Shuttle vessel. These 

vessels have a capacity of 180,000 pounds 

each (in terms of pounds of waste). Waste was 

pumped from the vessels. The disposal vessel 

traveled about 12 miles out, to Bold Island. 

One trip required about an hour and a half to 

travel to the disposal site and about 1 hour to 

unload the boat and an hour and a half to 

return. The boat made one trip per day. Cost 

for waste disposal in 2009 was $139,553.

According to APDES annual report, in 2009, 

Alaska General operated 120 days and 

discharged 6.25 million pounds of waste.

180,000 lb/load $139,553

per yearc

aCost for 90 days/year

bDoes not include amortized cost for purchasing the vessel. 

c

Includes cost for leasing the vessel.
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As shown in Table 3-1, the vendor quotes for fish pumps EPA obtained from Fluid 

Process Equipment, Inc. are similar to the estimate provided by Rick Eaglin but lower than the 

estimate provided by Sandro Lane. Mr. Lane’s higher cost represents a food grade (stainless steel 

pump), while the lower costs were for grade suitable for non-food grade material. EPA estimated 

costs for non-food grade pumps and concluded that the vendor quote was comparable to quotes 

from other sources. 

The off shore disposal operating costs EPA estimated included costs for operating the 

vessel, including labor, fuel, and vessel maintenance and insurance. The annual costs are a 

function of the size of the vessel crew, type of fuel used, and the number of trips required per 

year. Table 3-1 shows the range of annual costs1EPA estimated for the 15 seafood processors. 

EPA’s estimated costs are similar to the costs reported by an unnamed source. The costs reported 

by Alaska General Seafood are higher than EPA’s estimated costs; however, Alaska General

managed more waste than the processors for which EPA estimated costs. EPA concluded that its 

estimated waste disposal costs were comparable to the costs reported by the unnamed source and 

Alaska General.

3.2 Reconciling Data Quality With User Requirements

As discussed in Section 3.1, some collected data did not meet the data acceptance 

specifications (Table 2-1). EPA determined how these off-specification data would be used to 

estimate costs, as discussed in this section. 

Several quotes for equipment costs did not meet the specification to obtain estimates 

from a vendor that does business in the Alaska areas included in this study. EPA concluded that 

these are usable, because EPA added costs to ship equipment from Seattle to each analyzed 

processing location. This represents costs that processors would pay for equipment. Further, the 

estimated for vessel maintenance and insurance did not meet the currency specification of 2009 –

2011. EPA concluded that this estimated rate was usable because any potential inaccuracy was 

small compared to the total estimated costs. 

Using its engineering experience and judgment, and based on cost data quality review, 

EPA concluded that the price information collected for labor, fuel, packaging materials, 

laboratory analysis, and shipping was usable for this project.

Byproducts Recovery Plants. EPA contacted four companies that sell seafood byproducts 

equipment. After a telephone discussion explaining the project and the required costs, EPA

requested a price quote for a complete “package plant” to produce salmon oil and salmon meal 

from seafood processing waste. Only the response from ANCO-EAGLIN provided a complete,

detailed quote, suitable for use in the cost estimate. An assessment of the usability of each 

vendor’s price quotes is presented in Table 3-2.

 

1 These annual costs do not include the amortized cost for purchasing the vessel (this would increase the annual 

costs by about 10%). 
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Table 3-2. Byproducts Recovery Plant Vendor Quotes

COMPANY COMMENTS

Alfa-Laval Provided itemized quote for producing fish oil. Did not include fish meal production. 

No details for operating cost estimates.

ANCOEAGLINProvided detailed itemized quote for producing fish oil and fish meal. Provided 

itemized equipment list, prices, estimated installation labor, and equipment layout for 

determining building sizes. Cost included boiler and air pollution control equipment 

and sufficient detail to estimate operating costs.

GEA Westphalia Provided quote for three sizes of package fish oil plant and one combined fish oil/fish 

meal plant. No equipment list. Insufficient details for operating cost estimates.

Haarslev Did not respond to request for quote.

After reviewing these assessments, EPA concluded that only the ANCO-EAGLIN quote 

was usable for developing cost estimates. The quotes from Alfa-Laval and GEA Westphalia were 

compared to the ANCO-EAGLIN quote but not used to develop costs. 

4. ESTIMATING POLLUTION CONTROL TECHNOLOGY COSTS

EPA applied direct and indirect escalation factors to the collected equipment purchase 

cost data to estimate equipment installed costs and then developed equations (curves) to relate

equipment size1and cost. EPA developed a detailed spreadsheet for estimating capital costs and 

operating and maintenance costs using the cost curves, assumptions about how each processor

would implement the two waste management scenarios, and unit costs for labor, energy, 

packaging, and shipping. Production and wastewater data for each processor were pulled into the 

spreadsheet to calculate the costs for each processor. Finally, the estimated costs were used to 

analyze the economic impact of these estimated costs on the seafood processors and the firms 

that owned them. 

The development and review of the estimated costs is described in the following sections:

4.1 Developing and Reviewing Costing Scenarios and Assumptions;

4.2 Using Escalation Factors to Account for Direct and Indirect Capital Costs in 

Calculating Installed Capital Costs;

4.3 Developing Cost Curves;

4.4 Extracting Facility Data from the Questionnaire Database; and

4.5 Developing and Checking the Cost Calculation Spreadsheet.

4.1 Developing and Reviewing Costing Scenarios and Assumptions

To estimate costs, EPA developed detailed descriptions of the two scenarios for waste 

management and documented these descriptions and the planned costing approach in a draft

outline of scenarios and assumptions. The Project QA Coordinator and another senior engineer 

knowledgeable in the development of effluent limitations guidelines, reviewed this outline and 

discussed it with the project manager. After addressing the review comments, a draft outline was 

 

1 Equipment size was normalized to wastewater flow (gpm) to facilitate calculations.
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provided to the EPA project team. The project engineers and economists discussed the draft 

outline. The engineering team revised the draft outline based on that discussion and added a new 

section (modeling and financial impacts for non-questionnaire plants) based on discussions 

between engineers and economists, and the revised outline was completed. These two drafts each 

included two versions of the byproducts recovery scenario. Scenario 2a was a worst-case 

scenario that assumed that each individual seafood processor would construct a separate 

byproducts recovery plant. This worst-case was based on the assumption that seafood processor

with different owners would not cooperate with byproduct recovery. During the completion of 

the cost estimates, EPA decided to omit Scenario 2a from the preliminary cost estimates. 

As EPA developed preliminary and then final cost estimates, the assumptions were 

revised slightly to better reflect Alaska conditions and seafood processor baseline conditions.

4.2 Using Escalation Factors to Account for Direct and Indirect Capital Costs in 

Calculating Installed Capital Costs

EPA used the equipment and unit purchase cost data described in Section 2 of this 

memorandum to develop a set of equations for estimating the installed capital cost of 

implementing the two scenarios at each individual processor. To estimate installed capital costs, 

EPA applied direct and indirect escalation factors to the equipment and unit purchase costs as 

described in the memorandum, Direct and Indirect Escalation Cost Factors for Developing 

Budgetary Estimates for Waste Handling at Seafood Processing Facilities included in Appendix 

C. As described in that memorandum, EPA has used these cost factors in numerous past projects 

and found the resulting cost estimates agree very well with detailed cost estimates provided by

construction companies. 

4.3 Developing Cost Curves

EPA applied appropriate escalation factors to the collected equipment and unit cost data

to estimate installed capital costs, then developed equations (cost curves) relating installed 

capital costs to equipment size (in terms of wastewater flow). To develop these curves, EPA

entered escalated cost and size information into an Excel spreadsheet, and then used the built-in 

charting and regression functions to plot the cost data as a function of size to calculate the line of 

best fit. The equipment cost equation (cost curve) was copied into the cost estimate spreadsheet. 

An engineer experienced with cost estimations provided technical review of the cost 

curves. The engineer reviewed the input of vendor information into the cost curve development 

spreadsheet, checked that escalation factors had been applied consistently, and verified that the 

cost equations were developed correctly and that they covered the ranges of sizes needed for the 

seafood processors. The engineer provided a written report of his review. Cost curves developed 

for this project are listed in Table 4-1. 
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Table 4-1. Cost Curves for Alaska Seafood Processing Waste Management

Equipment Item Input for Cost Curve Curve Type Sizing parameter

Wedge wire screens IPEC and Parkson price 

quotes

Linear regression –

4 points Maximum daily flow (gpm)

Waste pump Moyno price quotes Linear regression –

2 points Maximum daily flow (gpm)

Waste hopper Assman Corporation price 

quotes

Linear regression –

6 points

Average Salmon Season Waste 

(pounds/day)

Sump pump Surfilco, Northbrook, IL price 

quote

Linear regression –

3 points Maximum daily flow (gpm)

By products recovery 

plant ANCO-EAGLIN price quote See note a Highest monthly average waste generation (Metric tons/day)

Screen building costs R.S. Means estimate Linear regression –

4 points

Maximum daily flow (gpm), 

based on the building size 

needed for wedge wire screen

Wastewater sump 

construction costs R.S. Means estimate Linear regression –5 points

Maximum daily flow (gpm) 

used to estimate size required 

for 15 min hydraulic residence 

time

a) Costs based on ANCO-EAGLIN estimate for 25 MT per day plant, extrapolated using the equation: C2 = 0.75 x (P2/P1) x C1,

where P = Product and C = Cost

For certain equipment (vessels and flow meter/totalizers), EPA did not develop cost 

curves but used a slightly different approach. For vessels, EPA included costs for one of four 

sizes of vessels, depending on the monthly average pounds/day of waste generated by the 

processors during salmon season. Similarly, EPA included costs for one of five sizes of flow 

meters, depending on the maximum daily flow (gpm) at the individual processor. 

4.4 Extracting Facility Data from the Questionnaire Database 

Installed capital and annual operating and maintenance costs are based on the maximum 

amount of wastewater generated and the amount of waste generated at a seafood processor. EPA

extracted production and waste generation data from the seafood processing questionnaire 

database and used these data to estimate wastewater flow and salmon and non-salmon season 

waste generation. These data were organized in an Excel spreadsheet and became input for 

estimating individual seafood processor costs. 

The questionnaire data required to calculate inputs for the cost spreadsheet were 

identified and extracted from the questionnaire database. An engineer not directly involved with 

the project provided independent technical review of the queries, to verify they retrieved the 

required information.

The cost spreadsheet inputs are summarized in Table 4-2 along with a discussion of how 

the questionnaire data were used in the calculation of the required inputs. 
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Table 4-2 Calculation of Cost Estimate Spreadsheet Inputs from Questionnaire

Cost 

Spreadsheet 

Input

Units Variable 

Name

a Description Discussionb

Average 

Salmon Waste lbs/yr AveSalWaste

5 yr average of 

B11&B24 x % 

yield

To calculate total salmon waste, multiply total salmon lbs 

processed in B-11, by the percent yield to waste from B-24, 

by species and type of seafood product. Only fresh and 

frozen salmon and canned salmon were calculated. 

Average NonSalmon Waste lbs/yr AveNonWaste 5 yr average of 

B11&B24

To calculate total non-salmon waste, multiply total lbs 

processed in B-11 by the percent yield to waste from B-24. 

All species and product were included expect for fresh and 

frozen salmon and canned salmon. 

Salmon Season days/yr Season

91 days or 13 

weeks of salmon 

season

Assumption 

Operating Days days/yr OpDays Plant operating 

days/yr Estimates from annual reports

Operating 

Weeks weeks/yr OpWeeks Plant operating weeks/yr Estimates from annual reports

Operating 

Weeks Non 

Salmon

weeks/yr OpWeeksNon

Operating weeks 

outside salmon 

season, see 

Processing Plant 

Assumptions 

bb.xls

Estimates from annual reports

Peak Day 

Waste lbs/day PeakDayWaste Q B-13 x % waste

To calculate peak day waste, multiply the peak day waste of 

all species/seafood product in B-13 by their respective waste 

percent yields in B-24. The peak day waste is determined to 

be the species/seafood product that generates the most waste 

on their peak day of all the other species/seafood products.

Max. 

Wastewater 

Flow

gal/min MaxFlow

PNF from EC 

Jordan, 1979,Table 

34 &B-13

To calculate maximum waste water flow, The peak day 

production waste by species/seafood product (see Peak Day 

Waste) is multiplied by the production normalized flow of 

3,400 gal per ton and then converted from gal/ day to 

gal/min. 

Ave. 

Wastewater 

Flow

gal/day AveFlow

The average wastewater flow was reported in B-26. 

Facilities that failed to complete this response had their 

values back calculated using average daily production 

multiplied by the production normalized flow of 3,400 

gal/ton.

Average 

Salmon Season 

Waste

lbs/day AveSalSeasonW

aste Q B-12

To calculate the average salmon season waste in lbs /day, 

the average lbs /day of production by month In B-12 is 

multiplied by the percent yield to waste in B-24 by 

species/seafood product. The lbs /day rate of all 

species/seafood product was then summed by month. The 

average salmon season waste is the highest rate of waste 

generation in the months June through August.

Average NonSalmon Season 

Waste

lbs/day AveNonSeason

Waste Q B-12

To calculate the average non-salmons season waste in lbs 

/day, the average lbs per day of production by month In B12 is multiplied by the percent yield to waste in B-24 by 

species/seafood product. The lbs per day rate of all 

species/seafood product were then summed by month. The 

average non-salmon season waste is the highest rate of waste 

generation in any of the months excluding June through 

August.

Average 

Wastewater

flow for elec

gal/min Calculated

To calculate the average wastewater flow in gal/min, the 

annual salmon production (i.e. fresh/frozen and canned 

salmon) is averaged over 2005 through 2009. This average is 

then multiplied by the production normalized flow of 3,400 

gal/ton over the 91 days of salmon season.

aVariable names used in the cost estimate spreadsheet. 

bAlpha-numbers (e.g., B-12) in this description refer to questionnaire numbers. 
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4.5 Developing and Checking the Cost Calculation Spreadsheet

EPA developed a detailed spreadsheet for estimating total installed capital costs and 

operating and maintenance costs for each individual processor. The spreadsheet used the 

equations (cost curves) for installed capital costs; assumptions about how each seafood processor

would implement the two waste management scenarios; unit costs for labor, energy, packaging, 

and shipping; and production and wastewater information for each seafood processor to 

calculate the costs for each processor to manage and dispose of its waste solids. EPA developed 

preliminary cost estimates, they were reviewed, and revised costs were completed. 

EPA used the spreadsheet to calculate total installed capital and annual operating and 

maintenance costs for the 15 seafood processors included in EPA’s survey. EPA also estimated 

costs for three model plants which the economists used to estimate impacts for facilities that

EPA did not survey, including facilities in the processing locations being considered for addition 

to the list of non-remote processing locations.

For the 15 seafood processors surveyed, EPA zeroed out any costs the processor had 

already incurred (for example, if the processor currently owns and operates a waste disposal 

vessel, calculated costs for the vessel and its operation were set to zero). 

After delivering the preliminary costs, EPA developed a revised cost estimate spreadsheet 

that received additional review before revised costs were delivered to the economists. The 

calculation spreadsheet received several reviews:

 A scientist checked that the calculations reflected the assumptions outlined in the 

Outline of Costing Assumptions Alaska Seafood Processing in Non-Remote 

Processing Locations. Where the calculations and assumptions documentation did 

not agree, the project manager determined if the documentation or calculations 

required corrections and ensured the corrections were made.

 A scientist involved in the spreadsheet development checked the accuracy of the 

calculations in the preliminary spreadsheet. 

 An engineer provided independent technical review of the preliminary and revised 

spreadsheets. He checked that the calculation description matched the cell 

formula and that cell references were correct. The engineer checked that units 

were converted properly and provided the spreadsheet developer with a written 

summary of the data checked, errors or problems found, and recommended 

revisions. (See 4.3 for a discussion of his review of the cost curves.)

 A project manager reviewed the costs by comparing the estimates for each 

processor and evaluating whether the trends in costs reflected the amount of 

seafood processed and the baseline waste management strategies. 

 After delivering the preliminary costs to the economists, the project team met to 

review the cost development. 

Quality activities related to the development of the cost estimate spreadsheet are listed in Table 

4-3.
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Table 4-3. Alaska Seafood Processing Cost Estimate Spreadsheet Quality Activities

Cost Estimate Spreadsheet Quality Activity

Spreadsheet developer created cost estimation spreadsheet

Scientist checked calculation accuracy (Ketchikan and Petersburg)

Scientist compared calculations and assumptions and manager ensured draft assumptions and 

spreadsheet were revised appropriately

Manager reviewed cost spreadsheet and compared estimated facility costs

Preliminary Costs delivered to economists (Draft AK Seafood cost model.xlsx)

Technical Reviewer conducted detailed documentation and spreadsheet review

Spreadsheet revisions were planned

- obtained late-arriving shipping cost data

- researched costs for a 4th size of waste hauling vessel

- revised rationale for vessel operating labor

- corrected error in calculation of Petersburg Scenario 2b waste hauling costs

- added missing escalation to wedge wire screen costs

- added missing cost for shipping samples to analytical laboratories

- added costs for “model” plants

Project team discussed costs and received directions for revisions

Spreadsheet developer revised spreadsheet

Technical reviewer checked the revised spreadsheet

Spreadsheet developer made minor spreadsheet revisions

Revised costs delivered to economists (AK Seafood Cost Calculations April 2011.xlsx)

Sensitivity analyses were reviewed and the annualized costs/ton of waste and identified possible 

error in electricity calculation

Technical reviewer confirmed error

Spreadsheet developer revised electricity formula

Technical reviewer checked revised electricity formula

Revised costs delivered to economists (AK Seafood Cost Calculations May 2011.xlsx)

Draft Economic Impact Analysis was reviewed and the need for clarifying footnotes for the 

economic analysis report was identified

4.6 Cost Estimate Documentation

EPA identified the preliminary cost calculation spreadsheet as “draft.” Revised versions 

are named AK Seafood Cost Calculations Month 2011.xlsx with Month replaced with the name 

of the month in which the file was delivered. When the spreadsheet is added to the docket 

supporting EPA’s Notice of Data Availability (NODA), the file will be renamed AK Seafood 

Cost Calculations FINAL 2011.xlsx. EPA will assign a dcn, store the file in the electronic project 

file, and index it using the procedures outlined in the Project File Management Plan. 

5. EVALUATING COST ESTIMATE QUALITY

Verification of the completed cost estimates means determining if estimated costs meet 

the data acceptance criteria specified in Table 2-4 of the QAPP. The results of this determination 

are presented in Section 5.1 and the use of the cost estimates is discussed in Section 5.2.
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5.1 Verifying Cost Estimate Quality: Comparing Estimated Costs to QAPP Quality 

Specifications

Cost estimate quality specifications are presented Table 2-4 of the QAPP. The first 

acceptance criterion is that the costs meet the requirements for economic analysis. The 

specifications for this criterion were that the estimates include both one-time costs for equipment 

purchase, installation, and other direct and indirect capital costs and on-going operating and 

maintenance costs. The costs estimates fully met these specifications and were used by the 

economists to ultimately prepare: Costs and Economic Impact Analysis for Alaska Seafood 

Processors (Facilities and Firms) DCN 00428.

Table 5-1 reproduces the QAPP cost estimate quality specifications along with an 

assessment of whether the estimated costs met the specifications.

Table 5-1. Cost Estimate Quality Specifications

Acceptance 

Criterion:

Cost Estimates

Specification Comparison of Cost Estimate to 

the Specification

Meet requirements 

for economic 

analysis

 Include one-time costs for equipment purchase and 

installation.

 Include on-going operating, and maintenance costs 

(annual costs).

 True

 True

Appropriate for 

actual processing 

plant locations

 Equipment costs include transportation to each 

processing location. Installation costs reflect the 

costs for supplies and labor in each processing 

location. 

 Operating costs (electricity, diesel fuel, labor, 

chemicals, etc., reflect the costs in each processing 

location).

 True

 Electricity, diesel fuel, gasoline, 

and labor reflect processing 

location costs. Chemical costs do 

NOT reflect processing location

costs. 

a

Unit costs are on 

specified, standard 

year basis

 Input costs escalated to 2010, using Means 

Construction Index or other standard cost index, 

adjusted for Alaska as necessary.

 Indexing was not used, cost data 

reflects 2010-11 (exception is 

maintenance and insurance 

estimate dated 2001, accepted as 

usable without indexing).

Complete

 Include costs for all elements necessary to 

implement the waste management option.

 Reflects EPA’s current 

understanding. EPA will solicit 

public comment to verify this 

assumption.

Accurate 

(spreadsheet input)

 Cost spreadsheet inputs reflect design assumptions 

agreed on with project team.

 Cost spreadsheet inputs reflect baseline conditions at 

each facility.

 True, with exceptions noted in 

revised assumptions outline.

 Reflects EPA’s current 

understanding. EPA will solicit 

public comment to verify this 

assumption.

Accurate 

(spreadsheet 

calculations)

 Spreadsheet calculations are correct.

 Unit conversions are correct.

 True

 True
14

Table 5-1. Cost Estimate Quality Specifications

Acceptance 

Criterion:

Cost Estimates

Specification Comparison of Cost Estimate to 

the Specification

Reasonable

 Order-of-magnitude of costs is comparable to costs 

for similar installations at similar plants.

 Cost trends follow the design basis trends (i.e., costs 

for large plants are greater than the costs for small 

plants).

 See discussion

 True

aCosts for boiler feed chemicals, used in Scenario 2, were not site-specific, but represent less than 0.5% of the annual 

costs for byproduct plant operation.

To evaluate the reasonableness of the cost estimate, EPA planned to compare its 

estimated costs to costs for similar installations at similar seafood processors. During August 

2010 visits to Alaska seafood processors and follow-up to the visits, EPA sought costs for similar 

installations but obtained only limited information. Table 5-2 presents costs provided by Alaska 

General Seafood in Ketchikan for converting from discharging ground up solid waste through its 

Tongass Narrows outfall to hauling it to Bold Island. The Alaska General costs are compared to 

EPA’s costs estimated for a similar sized installation.
15

Table 5-2. Comparison of Cost Estimate to Facility Project Costs

Source Description Size Price

Alaska General Seafood

Ketchikan

Site Visit Report

Grinding waste to less than 0.5 inch in any 

dimension required several steps. Heads were 

ground in a hammer mill. The ground heads 

combined with other waste then passed through 

the Vaughan chopper pump, Muffin Monster, 

dewatering screen, and Autio grinder, and was 

then pumped into the boat. Dewatering was 

accomplished with a rotary screen, 0.100 inch 

mesh size. Dewatered waste was pumped to the 

vessel using a progressive cavity pump after it 

passed through the Autio grinder. When AGS 

converted from discharging ground up solid 

waste through its Tongass Narrows outfall to 

hauling it to Bold Island, they installed a 

concrete pad on land with waste disposal 

equipment at a capital cost of $165,000. No 

alterations or expansion to the existing dock 

were required.

10 - 12 million 

pounds fish /year

3.5 - 4.5 million 

pounds waste/year

$165,000

EPA Cost Estimation 

Spreadsheet

Scenario 1 includes costs for:

Pump (waste from existing sump to screen)

Rotary wedge wire screen

Screen building

Waste hopper

Move existing grinder 

Vessel (scow)

New sump for screened wastewater

Wastewater discharge pump

Monitor screened wastewater for TSS and O&G

Measure volume of wastewater discharged

4.5 million pounds 

waste/year

$591,000

Limit to EPA Estimated Costs for:

Pump (waste from existing sump to screen)

Rotary wedge wire screen

Waste hopper

Move existing grinder pump 

$292,000
16

EPA’s estimated costs for Scenario 1 are significantly greater than the costs Alaska 

General reported incurring to convert from discharge through an outfall to hauling waste for off 

shore disposal. EPA’s costs for Scenario 1 are more than three times higher than costs reported 

by Alaska General, but include elements such as a vessel, screen building, new sump, and new 

sump pump that Alaska General did not need. Limiting the costs to elements that reflect the 

changes Alaska General made reduced EPA’s estimated costs to $292,000 compared to 

$165,000. Although EPA’s estimated costs are still greater than the Alaska General reported 

costs, they are reasonable given EPA’s limited information about the size and layout of the 

seafood processing plant.

EPA will include estimated costs in the docket supporting the Federal Register NODA. 

The NODA and supporting data will be open for public comment. EPA expects additional 

validation of the waste management cost estimate through the public comment process. 

5.2 Validating Cost Estimates and Reconciling Estimate Quality with User 

Requirements

According to EPA’s Guidance for QAPPs (QA/G-5), data validation is “an analyte- and 

sample-specific process that extends the evaluation of data beyond method, procedural, or 

contractual compliance (i.e. data verification) to determine the analytical quality of a specific 

data set.” Although EPA did not validate the cost estimates, EPA may do so by using 

engineering judgment to evaluate whether the estimates “make sense” in the context of their

knowledge of the Alaska seafood processing industry. This evaluation may include analysis of 

the results, for example calculation of the total annualized costs per ton of waste processed. EPA 

may investigate the input data and assumptions for processors with the highest (or lowest) 

estimated unit costs and use engineering judgment to understand whether the result is logical 

given the processor’s circumstances. 

The cost estimates must be reviewed to determine if they can be used to answer the key

questions identified in Section 2.2 of the QAPP, in particular:

 What technologies for control of wastewater pollutant discharges from Alaskan 

seafood processors are technically and logistically feasible for facilities in nonremote locations?

 What would implementation of these technologies cost?

This quality activity report will support EPA in making this determination.

6. COSTING DOCUMENTATION

Details of costing calculations are provided in individual documents included in Docket 

EPA-HQ-OW-2013-0652, supporting the Alaskan Seafood Processing Effluent Limitations 

Guidelines, Notice of Availability of Data and Information. These documents are listed in 

Appendix E. 
17

7. POLLUTANT REMOVALS

EPA developed estimates of the incremental effluent reduction benefits (pounds of 

pollutants removed) for screening versus grinding. Typically, EPA estimates the discharges of 

pollutants at baseline (in this case, grinding) and compares them to discharges assuming the 

technology basis is installed (in this case screening). EPA could not use its standard approach for 

developing reductions in TSS and oil and grease because it does not have baseline information 

on TSS and oil and grease discharges. Facilities that employ grinding do not monitor for TSS 

and oil and grease. Rather, they collect data on the mass of incoming raw product and the mass 

of the final product. As a result, for today’s notice and in the analysis supporting EPA’s 1981 

proposed petition response, EPA used total waste generated (i.e., difference between the mass of 

incoming product minus the mass of the final product) as a proxy for the pounds of pollutants 

removed that would no longer be discharged in the facility effluent with the addition of 

screening. This is appropriate because, as indicated above, total waste generated is regularly 

reported utilizing mass balance data regularly collected by processors for weights of incoming 

raw product and final products. Moreover, available mass balance data also show that facilities 

using screening technology and by-product recovery achieve waste removals in excess of 90 

percent.

EPA estimated total loads of waste generated for individual processing facilities using 

data provided by processors in NPDES permit annual reports and reported in questionnaire 

responses. Processors report tons of waste generated by subtracting the tons of final product from 

the tons of raw product. Raw and final product weight data are extensive and reliable. Raw 

product weights are derived from carefully weighed incoming fish landings, which serve as the 

basis for paying fishermen for their catch. These fish landing weights are also reported to Alaska 

state agencies to determine state taxes. Final products are weighed carefully for packaging and 

related purposes.
Appendix A

OUTLINE OF COSTING ASSUMPTIONS

ALASKA SEAFOOD PROCESSING

IN NON-REMOTE PROCESSING LOCATIONS
Outline of

Costing Assumptions

Alaska Seafood Processing

In Non-Remote Processing Locations

U.S. Environmental Protection Agency

Office of Water (4303T)

1200 Pennsylvania Ave., NW

Washington, DC 20460

August 2013
A-1

1. INTRODUCTION

EPA estimated incremental facility specific costs for direct discharging Alaska Seafood 

Processing facilities associated with the petitioning locations of Cordova, Juneau, Ketchikan, and 

Petersburg to meet the ELGs as promulgated for non-remote locations. EPA conducted its analysis for 

two scenarios5: 

Scenario 1: Screening and discharge of resulting wastewater and transport of screened 

solids for ocean disposal, and 

Scenario 2b: Screening and discharge of resulting wastewater and cooperative by-product 

recovery of screened wastes.

EPA also estimated incremental facility specific costs for facilities located in the Kenai 

Peninsula and Sitka processing locations, currently classified as remote. As indicated in EPA’s 

proposal (46 FR 2546. (January 9, 1981), EPA is considering reclassifying these locations as 

non-remote. 6 No direct dischargers are currently located in Anchorage, another original 

petitioning location. Dutch Harbor, although surveyed, is not included in this analysis because all 

three facilities that have operated there over the long term have installed screening technology as 

well as individual by-product recovery and already comply with the non-remote ELGs as 

promulgated. Therefore, no additional costs would be incurred by these three facilities. 

This report documents assumptions EPA used to develop cost estimates. The project 

economists used the facility specific costs to develop total annualized costs and industry wide 

total annualized compliance costs estimates and to evaluate the financial and economic impacts 

of these costs and presented the results in Report to the Record Costs and Economic Impact 

Analysis for Alaska Seafood Processors (Facilities and Firms), DCN 00428.

The cost estimates reflect the amount and type (salmon vs. non-salmon) of waste 

generated at the affected plants and costs to purchase, install, and operate appropriately sized 

equipment. Consistent with costing estimates for the existing regulation, these conceptual-level 

cost estimates do not identify equipment installation locations or the location of individual 

project components (e.g., large pieces of equipment, buildings, etc.) Rather, EPA accounted for 

this through general costing factors and contingencies to cover possible site-specific layouts and 

features. Preliminary cost estimates, developed using the agreed on assumptions, were used to 

develop a preliminary financial and economic analysis. After initial reviews, EPA revised the 

 

5

EPA originally included two versions of Scenario 2, the byproducts recovery scenario. Scenario 2a was a worstcase scenario that assumed that each individual processing plant would construct a separate byproducts recovery 

plant. This worst-case was based on the assumption that facilities with different owners would not cooperate with 

byproduct recovery. During the completion of the cost estimates, EPA chose to omit Scenario 2a from the cost 

estimates because for most processors this option is not cost-effective. Notable exceptions include the three longstanding processors in Dutch Harbor, Alyeska, Unisea, and Westward, all of which operate individual byproduct 

recovery facilities, and Trident at Akutan near Dutch Harbor.

6 The Kenai Peninsula includes Seward as one processing location for the purposes of this analysis. Sitka is a 

separate processing location.
A-2

preliminary costs. The revisions refined some assumptions related to the vessels used for off 

shore disposal and corrected errors. Major revisions included:

 Adding a fourth size of vessel for hauling waste disposal, with a waste capacity of 

60,000 tons, more than the smallest vessel (16,000 ton bow picker) and less than 

the next largest vessel (100,000 ton scow)7. 

 Increasing the hours the waste disposal vessel crew was assumed to work during 

salmon season, from only the hours the vessel was loaded, unloaded, and 

underway to 728 hours per season (8hr/day x 91 days/season). For non-salmon 

season, EPA continued to assume the crew worked the hours the vessel was 

loaded, unloaded, and underway.

 For the annual costs for operating the byproducts recovery plant in Petersburg, 

correcting an error calculating the cost for trucking the waste from the processing 

plant to the assumed byproducts plant location. These costs are estimated as 

$10/metric ton of waste. For the preliminary estimate, EPA mistakenly calculated 

these costs based on the annual salmon season waste volume multiplied by 91 day

salmon season, resulting in a cost of $2.2 million per year. This cost was 

corrected to $24,688 per year.

 For the capital cost for the rotary wedge wire screen, EPA included only

equipment costs and mistakenly omitted the other direct costs (electrical, 

plumbing, and mechanical costs related to installation) and the indirect costs 

(related to contractor expenses - engineering, permits, scheduling, performance 

bonds, insurance, markup, overhead and profit).

Other changes with less impact on the total costs included:

 Adding site-specific shipping costs as estimated by Lynden Shipping (Lynden’s 

quote did not arrive until after the preliminary costs were completed);

 Updating the diesel, gasoline, and electricity costs (due to the very rapid increase 

in fuel costs during the spring of 2011). 

 

7

The fourth vessel is the 205,000 ton tender.
A-3

2. COSTING SCENARIOS

2.1 Baseline

 Grind waste to less than 0.5 inch in any dimension

 Monitor waste discharge particle size and zone of deposit (dive survey)

 Discharge ground waste through existing outfall

2.2 Scenario 1

 Screen wastewater stream (0.5 - 0.7 mm wedge wire screen)

 Grind screened solids prior to off shore disposal

— Allows near-shore disposal

— Allows use of existing grinder pump

— Facilitates transfer to disposal vessel and pump off of the vessel

 Haul screened and ground solids off-shore (bow picker, work vessel, fishing scow 

or tender) 

 Monitor screened wastewater for TSS and O&G

 Measure volume of wastewater discharged

 Discharge screened wastewater through existing outfall

2.3 Scenario 2a (not costed)

 Screen wastewater stream

 Process screened salmon wastes in onsite byproduct plant 

 Haul non-salmon waste and non-recoverable salmon waste for off-shore disposal 

 Monitor screened wastewater for TSS and O&G 

 Measure volume of wastewater discharged

 Discharge screened wastewater through existing outfall

2.4 Scenario 2b

 Screen wastewater stream

 During salmon season, truck wastes to combined processing location byproducts 

plant

 Process screened salmon wastes in combined processing location byproduct plant 

— Keep waste from salmon separate from waste from longline-caught fish 

that may contain embedded stainless steel hooks
A-4

— produce commodity grade:

 salmon oil and 

 salmon meal.

 Byproducts plant also operates a combined processing location waste disposal 

boat

 Haul non-salmon waste and non-recoverable salmon waste for off-shore disposal 

 Monitor screened wastewater for TSS and O&G 

 Measure volume of wastewater discharged

 Discharge screened wastewater through existing outfall
A-5

3. GENERAL COSTING ASSUMPTIONS

For this cost estimate, EPA assumed that plants will only recover byproducts during 91 

day salmon season. Information acquired primarily from industry sources indicates the nonrecoverable portion of salmon waste is approximately five percent1

. Outside of salmon season, 

all waste will be hauled offshore for disposal. This assumption is applied to both Scenarios 1 and 

2b for which costs were developed.

3.1 Scenario 1- Screen and Haul

 Wastewater will be collected in the existing sumps prior to screening

o Screen cost based on maximum flow rate 

 peak production rate X 3,400 gal/ton raw fish processed

o Costs from Parkson and IPEC rotary screens

 Wastewater will be pumped to a rotary screen from the existing sump using new pumps

o Include costs for 2 pumps 

o Pump sized based on lb/day2fish waste to screen

o Type of pumps (Moyno positive displacement pumps)

o Size of pumps 

 Assumed 30 ft head

 Estimated required pump horsepower;

 EPA estimated electric power in kilowatts (kW) from pump horsepower 

multiplied by 0.7457 kW/horsepower,3then multiplied the kWhr by the 

operating hours per year to determine total kWh/yr.

o Include plumbing and electrical hook up allowance as percent of equipment costs

 Screen, 0.5 - 0.7 mm wedge wire, Parkson or IPEC

o Operating costs based on motor HP and operating hours per year 

 

1

Site Visit Report, Alaska Seafood Processing Industry Petition Response, Alaska Protein Recovery, Ketchikan, 

Alaska. August 13, 2010.

2 Lb/day salmon waste is derived from questionnaire reported production and per cent waste. Respondents reported 

the avg lb/day for the peak month in the peak year; for costed plants, peak is always salmon.

3

Perry’s Chemical Engineers Handbook, Sixth Edition
A-6

o Solids will discharge to a hopper 

 Hopper size based on lb/day salmon season waste

o Assumed screen will require construction of a new heated building and a concrete 

pad, located adjacent to existing plant and dock 

o Assumed plants have space to construct screen building

o Assumed screened wastewater flows by gravity to new discharge sump 

 Screened solids management

o Screened solids will be pumped from the hopper to waste boat

 Pumping will use existing grinder pump, allowance for relocating the 

pump to the hopper exit

 Solids are discharged from the screen at 20% solids

 Off shore hauling will be in bow picker, work vessel, fishing scow, or tender

o Waste boat size based on average pounds waste/day during heavy (salmon) 

season

o Trips per year = total waste per year/boat load 

o Check number of trips required for peak week 

 If significantly more than 2 trips/day, use a larger boat

o Capital costs to purchase vessel include off-loading pump

o Operating costs for labor (captain and 1-3 hands), fuel, and maintenance

o Assumed crew is paid for full 91 day salmon season and for waste disposal runs 

during non-salmon season

o Assumed 10 mile RT for waste disposal

 No additional dock space is required - waste boat loading will be scheduled with fishing 

vessel unloading.

o the docks are not constantly occupied by fishing vessels (EPA observation)

o processors that are currently required to haul waste have not built a new dock for 

the waste boat
A-7

 Monitoring

o Use the requirements from Kodiak general permit (e.g., wastewater flow and 

weekly grab samples for TSS, O&G, pH) 

o Assumed plant will send samples to a lab for TSS and O&G and estimated costs 

per sample, including shipping costs; run pH onsite.

o Assumed plants will no longer be required to conduct a dive survey (ignored cost 

savings: insignificant)

o Assumed facilities will be required to install a flow meter

o Assumed labor costs for increased record keeping and reporting (3 hr/week of 

operation for a QC technician)

 Screened wastewater will flow into a new discharge sump

o Assumed new sump will be located next to existing sump and not require 

demolition or removing existing concrete

o Include costs for new discharge pumps

o Existing outfall pipe used to discharge screened wastewater. 

3.2 Scenario 2a - Individual processing plant onsite byproducts recovery of salmon 

waste 

Not costed.

3.3 Scenario 2b - Combined processing location byproducts recovery of salmon waste 

 A best-case scenario, assuming that existing and planned byproducts recovery plants that 

currently take waste from other companies will continue to do so.

 Plants will incur all of the capital costs for Scenario 1, screen and haul 

o Plants that cooperate to process byproducts will cooperate in owning and 

operating a waste disposal vessel

o Vessel will be smaller, because less waste to haul
A-8

 For existing and planned byproducts recovery plants, EPA assumed

o Icicle plants in Seward and Petersburg that operate their own byproducts recovery

will continue to refuse other plants’ waste 

o Trident plants in Ketchikan and Cordova that operate byproducts recovery will 

accept and have capacity for all salmon season waste from the other plants in 

Ketchikan and Cordova 

o Scientific Fisheries that operates a byproducts recovery plant in Kenai has 

capacity for Kenai waste (except Icicle) or will expand as needed to accommodate 

the waste

o Assumed that the Sitka Meal Oil and Gelatin plant will be built in Sitka and will 

take all of the salmon-season waste from the three Sitka facilities 

o The owner of the byproducts plant will receive all of the profit

o Waste generators are not paid for their waste but do not need to pay to truck their 

waste to the byproducts plant

o The existing byproducts plant will also operate a waste disposal boat that will 

dispose of all non-recoverable processing waste 

o All waste generators will share the cost of non-recoverable waste disposal in 

proportion to the amount of waste they generate. If they already operate a vessel, 

they will have no additional vessel costs from Scenario 2b. 

o In short, for processing locations with existing byproduct recovery, under 

Scenario 2b processors have the same costs as for Scenario 1, except they have 

less waste to haul off shore and they cooperate in the off shore disposal, resulting 

in lower waste disposal costs.

 For new byproducts recovery facilities, EPA assumed

o Trident and Ocean Beauty will cooperate to build a new byproducts plant in 

Petersburg 

 Space and infrastructure are available at Trident’s Mitkof plant (currently 

not operating)

 No costs for land, cost for renovating the existing building
A-9

 Both Trident and Ocean Beauty will have costs to truck waste to the new 

combined byproducts plant (assumed $10/metric ton).

o Taku and Alaska Glacier will cooperate to build a new byproducts plant in Juneau 

 Neither processor has space for the byproducts plant

 Land and building required for new plant

 Both Taku and Alaska Glacier will have costs to truck waste to the new 

combined byproducts plant (assumed $10/metric ton).

o Costs and profits will be distributed to the participants in the new ventures in 

proportion to the amount of waste processed

 Cost model estimates product yield

 Salmon oil yield: 2% of total salmon season raw waste weight

 Salmon meal yield: 20% of total salmon season raw waste weight

 Assumed plant as costed by ANCO-Eaglin is used to produce oil and meal

o Other equipment costs included (diesel fuel tank, CIP system)

o Include other one-time costs 

 Permitting (e.g., CAA permit for diesel-fueled boiler, SPCC plan )

 Engineering

 Equipment shipping from Seattle to Petersburg or Juneau

 Installation

 Contractor costs

o Operating costs (power, steam, packaging, transportation of product to Seattle)

 Assumed the facilities use plastic-lined SpaceKraft totes for oil and 

SuperSacks for meal. 

 Assumed the product can be loaded directly from the meal plant to the 

SuperSack tote.

 Packaging costs do not include costs for nitrogen layering of the salmon 

oil. 
A-10

o Maintenance and Insurance

o Labor – will require trained operators and a qualified plant manager

 Assumed staff work during 91 day salmon season and a 15 day start up 

and 15 day shut down period.

o Estimated non-recoverable salmon season wastes (e.g., bone and non-salmon fish 

processed during salmon season) at 5% of total salmon waste 

 Size byproducts plant for the average lb/day in the highest month of the peak year, 

assuming it operates 20 hours per day. 

 Assumed byproduct plant operates only during salmon season. At other times waste 

volume is too small to run the plant and screened waste must be hauled for offshore 

disposal. 

o Pumps and screens are operated whenever the processing plant operates

o During salmon season, screened solids are transferred to the recovery plant

o During salmon season, wastes that may contain stainless steel hooks are diverted 

from the recovery plant and transferred to the disposal vessel

o At other times, all screened solids are transferred to the disposal vessel 

4. PROCESSING LOCATION ASSUMPTIONS

 Facility-specific costs were estimated for processing plants for which EPA received a 

questionnaire response. This includes plants in five processing locations: 

o Ketchikan, Petersburg, Juneau, Cordova, and the Kenai Peninsula. 

 Concept level costs were estimated for model plants. Concept level model plant costs 

were developed to represent processing plants for which EPA did not receive a 

questionnaire:

o Ketchikan: Alaska General Seafood (but not Pacific Sun),

o Juneau: Taku Fisheries, 

o Sitka: North Pacific and Seafood Producers Coop (but not Silver Bay)

o Kenai Peninsula: Polar Seafoods, Sea Level Seafoods, Pacific Star, Salmantof, 

City of Homer/Fish Factory (but not Kenai Landing or Deep Creek)

4.1 Ketchikan 

 If Ketchikan becomes “non-remote,” Alaska General Seafoods and Trident Cannery will 

incur costs only for new flow meters and effluent monitoring.
A-11

o For these plants, costs for Scenario 1 and 2b will be the same.

o EPA estimated facility specific costs for the Trident Cannery and used those costs 

for the Alaska General Seafoods plant 

 Under Scenario 1, Trident Norquest will continue to separate food grade waste, install a 

rotary screen, and transfer as much salmon waste as possible to APR1. Norquest will 

purchase and operate a waste boat for non-salmon season waste (the cannery only 

operates during salmon season).

 Under Scenario 1, E.C. Phillips will continue to separate food grade waste, install a rotary

screen, and purchase and operate a waste boat for non-food grade salmon waste and nonsalmon waste.

 For Scenario 2b, assumed APR will take all Ketchikan salmon waste generated during 

salmon season (E.C. Phillips, Trident Norquest, and Pacific Sun, if it is operating)

o All plants will cooperate in operating a boat for off shore waste disposal during 

salmon season and also during non-salmon season

o Costs for buying and operating the boat will be allocated based on the amount of 

waste generated by each plant

o Because Trident Cannery (and Alaska General) already haul waste, their Scenario 

2b boat costs will be zero

4.2 Petersburg

 Ocean Beauty (OB) will continue to operate and will operate during salmon season, only

 Icicle will maximize the use of its existing byproduct plant 

o Icicle will not take OB or Trident waste

o Icicle will incur costs to haul its residual waste, in any scenario, but not costs for a 

new screen or waste transfer pumps, because they already have a screen

o Icicle will incur costs for a hopper, moving its grinder pump so it can be used to 

transfer waste to the disposal vessel, screened wastewater sump, and discharge 

pumps

o Icicle will incur costs for a new flow meter and for effluent monitoring 

 

1 APR is Alaska Protein Recovery, a byproducts plant partially owned by Trident Seafoods and which, as of 2010, 

took all Trident Cannery and Alaska General waste and salmon heads from Trident NorQuest and E.C. Phillips.
A-12

o Icicle Scenario 1and 2b costs will be the same

 In Scenario 2b, Trident and OB will build a combined byproducts plant. 

o Both Trident and OB will transport their screenings from the processing plant to 

the byproducts plant 

o Trident and OB will cooperate in hauling salmon season residuals. Trident will 

also haul non-salmon season residuals (when OB is not operating)

4.3 Juneau 

 In Scenario 1, AK Glacier has costs for screening and monitoring, but no new costs for 

hauling their waste off shore because they already own and operate a boat. 

 In Scenario 2b, AK Glacier and Taku will build a combined byproducts plant. 

o Assumed neither has a building or land available

o Costs and profits will be allocated based on the amount of waste processed 

o The AK Glacier Scenario 2b financial impacts will be used to model impacts on 

Taku

4.4 Cordova 

 Trident North (Cannery) will incur costs only for a new flow meter and effluent 

monitoring if Cordova becomes “non-remote.” 

o Costs for Scenario 1and 2b will be the same for the Trident Cannery.

 Trident will maximize the use of its existing byproduct plant for Trident North and South 

waste. 

 Under Scenario 1, Trident South will screen, separate food grade waste and transfer as 

much salmon waste as possible to Trident North recovery plant. Trident South nonrecoverable waste will be disposed of at sea: Under Scenario 1, Trident South will 

purchase and operate a waste disposal boat. Under Scenario 2b, they use the cooperative 

boat. 

 Under Scenario 1, Trident North will take OB and Copper River food grade heads 

o OB and Copper River will screen and haul the rest of their waste

o Each plant will purchase and operate its own waste disposal boat
A-13

 Under Scenario 2b, OB and Copper River will send all of their waste to the Trident 

recovery plant. 

o Trident, OB, and Copper River will cooperate in hauling residuals for off shore 

disposal during salmon season and also during non-salmon season

4.5 Sitka

 Facility specific costs for E.C. Phillips are used to model costs for North Pacific and 

facility specific costs for Trident NorQuest, Ketchikan are used to model costs for 

Seafood Producers Coop. Model plant costs for the Silver Bay plant in Sitka; this plant 

was analyzed qualitatively

 Assumed Absolute Fresh Seafoods is not operating: no costs or financial impacts

4.6 Kenai Peninsula

 Seward and Kenai were analyzed as one processing location

 Icicle Seward will maximize the use of its existing byproduct plant

o Icicle will not take waste from any other plant

o Icicle will incur costs to haul its residual waste, in any scenario, but not screening 

costs because they already have a screen.

o Icicle will incur costs for a hopper, moving its grinder pump so it can be used to 

transfer waste to the disposal vessel, screened wastewater sump, and discharge 

pumps

o Icicle will incur costs for a flow meter and effluent monitoring

o Icicle Scenario 1 and 2b costs will be the same

 Inlet Fish Producers has NPDES permits for three locations on the Kenai Peninsula. Inlet 

operates seafood processing at two of these locations. For the purpose of estimating costs, 

EPA assumed 

o all of Inlet’s production occurs at one location. 

o all of Inlet’s costs for compliance with non-remote ELGs would be incurred at 

one location.

 In Scenario 2b, EPA assumed all operating plants take their waste to the Scientific 

Fisheries/Alaska Marine Nutrition byproducts plant at Kenai Landing
A-14

o EPA estimated costs for Inlet, Snug Harbor and Ocean Beauty and will estimate 

financial impacts

o EPA assumed they will all cooperate in purchasing and operating a waste disposal 

boat

 Boat size and operating costs were based on total processing location 

waste

 Costs were allocated to Inlet, Snug Harbor, and OB based on their portion 

of the total Kenai Peninsula waste generation rate (without Icicle)

4.7 Dutch Harbor

 EPA did not estimate costs for Dutch Harbor plants because as described below have 

management operations in place that allow them to meet the non-remote ELG 

requirements.

 Dutch Harbor differs from all of the other processing locations in this analysis. 

Approximately 90 percent of their production is pollock; most of the remainder is crab, 

with a small amount of other fish. This mix of production affects the amount of waste 

generated and thus the size, design, and cost of facilities to screen and manage screened 

solids

 Dutch Harbor production is dominated by three large processors

o Alyeska

o Westward

o Unisea

 The three large processors (100 – 200 million pounds/year per plant)

o operate close to year-round 

o have individual NPDES permits with TMDL-based limits

o operate onsite byproducts recovery plants for much (but not all) of their waste, 

notably producing fish oil used as biodiesel for on-site power generation to 

operate the processing plant 

o screen their wastewater with a 0.5 mm mesh screen

o haul some stickwater for off shore disposal during peak season in order to meet 

their BOD5 discharge limit 
A-15

 Two Icicle barges are towed to Dutch Harbor for the pacific cod/pollock season

o neither vessel screens or has a byproduct plant. 

o they discharge under the general permit for near shore (0.5 - 1 mile off shore) 

vessels. 

o they grind waste to 0.5 inch prior to discharge.

o costs were not developed primarily because these facilities have operated 

intermittently

 One smaller producer Harbor Crown Seafoods/ Bering Star Fisheries (14 - 15 million 

pounds/year)

o recently reopened under new ownership (Copper River is a part owner)

o grind and discharge under the general permit.

o costs were not developed primarily because this facility began operating after the 

time period for which EPA gathered and analyzed data

EPA slightly refined the cost estimates used to model the financial impacts of facilities 

for which EPA did not collect detailed financial information (see Section 5 of this outline). The 

refinements included adjustments to the model plant costs to more accurately reflect the likely

costs for the processors which did not receive a survey questionnaire. Use of these costs for 

model plants is discussed in Report to the Record, Costs and Economic Impact Analysis for 

Alaska Seafood Processors (Facilities and Firms) DCN 00428.
Appendix B

POLLUTION CONTROL COST DATA QUALITY CHECKLIST
B-1

EPA collected information about the costs for Alaskan seafood processors to install and 

operate wastewater pollution control technologies, including byproduct recovery processes and 

hauling waste for off-shore disposal. EPA’s plans for collecting these data are described in 

Section 2.4.2.2, Pollution Control Technology Costs, of Quality Assurance Project Plan: Support 

for EPA Response to Industry Petition on ELGs for Non-Remote Alaskan Seafood Processors, 

August 2013 (QAPP). QAPP Table 2-3 presents the criteria EPA planned to use to evaluate the 

quality of collected data. 

EPA used the Pollution Control Technology Cost Data Check List from QAPP Appendix 

B to document how the collected data met the cost data acceptance criteria. Checklist findings 

were recorded in a spreadsheet, a copy of which is presented in this Appendix. 

EPA’s verification of how well the cost data met the quality specifications is presented, 

by acceptance criterion, in Section 3.1 of this memorandum.

Item/Unit 

Cost Cost Information Source

Currency

(up to date)

Geographic

Scope

Accuracy/

Reliability

Year

Basis

2009 

-

2011?

Appropriate 

for "nonremote" AK 

areas?

Vendor 

does 

business in 

AK?

equipment

Vessel, tender Dock Street Brokers 2011 Yes Yes Yes

Vessel, scow Dock Street Brokers 2011 Yes Oregon Yes

Vessel, waste 

boat

Dock Street Brokers 2011 Yes Washington Yes

Vessel, 

bowpicker Alaska Glacier Seafood 2010 Yes Yes Yes

Wedgewire 

Screen Parkson 2010 Yes Yes Yes

Wedgewire 

Screen IPEC 2010 Yes Yes Yes

Waste pump Moyno 2010 Yes Michigan No

Waste pump Cornell 2011 Yes NY No

Waste hopper Assman Corporation 2011 Yes Indiana No

Waste grinder 

relocation APSCO and Means 2011 Yes Yes Yes

Sump pump Surfilco, Northbrook Illinois 2011 Yes Illinois No

Flow meter

Great Plains Industries Wichita, 

KS 2011 Yes Kansas No

construction 

costs R.S. Means 2010 Yes Yes Yes

by-products 

recovery 

plant

Anco-Eaglin 2011 Yes Yes yes

by-products 

recovery 

plant

Alfa-Laval 2011 Yes Yes yes
B-2

Item/Unit 

Cost Cost Information Source

Currency

(up to date)

Geographic

Scope

Accuracy/

Reliability

Year

Basis

2009 

-

2011?

Appropriate 

for "nonremote" AK 

areas?

Vendor 

does 

business in 

AK?

by-products 

recovery 

plant

GEA Westfalia 2011 Yes Yes yes

cost factors

vessel maint 

& insurance

Great Lakes Fisheries Vessels 

Status of

2001 No unknown NA best 

available

unit prices

construction 

location 

factors

Reed Construction Data 2010 Yes Yes Yes

labor - vessel 

crews

Source: Alaska Department of 

Labor and Workforce 

Development, Research and 

Analysis Section 2010 Yes Yes Yes

laboreffluent 

monitoring

Source: Alaska Department of 

Labor and Workforce 

Development, Research and 

Analysis Section 2010 Yes Yes Yes

labor -

byproducts 

plant

Perry's Chemical Engineers 

Handbook Source: Alaska 

Department of Labor and 

Workforce Development, 

Research and Analysis Section 2010 Yes Yes Yes

diesel -

Ketchikan

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

diesel -

Petersburg

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

diesel -

Juneau

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

diesel -

Cordova

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

diesel -

Seward/Kenai

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

gasoline -

Ketchikan

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

gasoline -

Petersburg

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

gasoline -

Juneau

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

gasoline -

Cordova

http://www.alaskagasprices.com/ 2011 Yes Yes Yes

gasoline -

Seward/Kenai

http://www.alaskagasprices.com/ 2011 Yes Yes Yes
B-3

Item/Unit 

Cost Cost Information Source

Currency

(up to date)

Geographic

Scope

Accuracy/

Reliability

Year

Basis

2009 

-

2011?

Appropriate 

for "nonremote" AK 

areas?

Vendor 

does 

business in 

AK?

electricity -

Ketchikan

Used average of other locations 2011 Yes Yes Yes

electricity -

Petersburg

City of Petersburg Residential 

Utility

Rates

2011 Yes Yes Yes

electricity -

Juneau

Alaska Electric Light and Power

Company 2011 Yes Yes Yes

electricity -

Cordova Cordova Electric Cooperative 2011 Yes Yes Yes

electricity -

Seward/Kenai

City of Unalaska, City of 

Seward

Electric Rates & Charges 2010

2010 Yes Yes Yes

lab analysis 

& sample 

shipping

Analytica Alaska Incorporated 2011 Yes Yes Yes

totes (oil) SpaceKraft 2011 Yes Yes Yes

totes (meal) 

supersack

BAGS Corp 2011 Yes Yes No

shipping Lynden 2011 Yes Yes Yes

shipping Peter Stitzel 2011 Yes Yes not a vendor

shipping Kevin O'Sullivan 2011 Yes Yes not a vendor

shipping Rick Isaacson 2011 Yes Yes not a vendor
Appendix C

DIRECT AND INDIRECT ESCALATION COST FACTORS FOR DEVELOPING 

BUDGETARY ESTIMATES FOR WASTE MANAGEMENT AT SEAFOOD 

PROCESSING FACILITIES
C-1

MEMORANDUM

TO: The Record

FROM: Project Team

DATE: August, 2013

SUBJECT: Direct and Indirect Escalation Cost Factors for Developing Budgetary 

Estimates for Waste Management at Seafood Processing Facilities

EPA is using a listing of the direct and indirect cost factors used to escalate the budgetary

cost estimates for seafood processing facilities in Alaska. The direct cost escalation factors are 

for costs such as plumbing and electrical work that are added to the cost of purchased equipment 

to develop an installed equipment cost. Indirect costs are for engineering, scheduling, and other 

costs that are added to the installed capital cost to cover the contractor’s overall project costs. 

Direct and Indirect Cost Escalation Factors

To estimate the installed capital cost for seafood waste management systems, EPA used 

the direct and indirect escalation factors shown in Tables 1 and 2 respectively. The factors in 

Table 1 were developed from U.S. Department of Defense construction programs1and from 

project team experience with construction costs for various industrial sectors. The factors in 

Table 2 were developed taken mainly from RSMeans Construction Cost data2supplemented with 

information from U.S. Department of Defense construction programs. The specific references 

and/or sources of the escalation cost factors used to develop capital costs for seafood processing 

waste management systems are included in Tables 1 and 2. 

In general, EPA developed the escalation cost factors for plumbing, electrical, 

mechanical systems, and site preparation from projects related to construction activities at naval 

industrial facilities. These projects require moving liquids and sometimes semi-solids between 

various processing steps, similar to seafood waste management. The escalation cost factors have 

been tested on completed naval construction projects. For example, EPA used these escalation 

cost factors to prepare a conceptual cost estimate for a water treatment facility at a naval steam 

generating plant. EPA estimated the conceptual installed capital costs to be $12.8 million dollars 

for the water treatment facility, and the actual bids received from the construction company hired 

to build the water treatment facility were $12 million. 

The direct cost escalation factors in Table 1 are comparable to the factors presented in 

RSMeans. For example, in RSMeans the total mechanical and electrical cost escalation factor for 

 

1 U.S. Army Corp of Engineers, DD Form 1391 Processor System Reference Guide

2 RSMeans Building Construction Cost Data, 68th Annual Edition, 2010.
C-2

an industrial factory ranges between 21 percent and 35.5 percent. EPA used 33.3 percent (17.5 + 

15.8) for mechanical and electrical systems at the seafood processing waste treatment systems. 

According to RSMeans, the site work cost escalation factor for an industrial factory ranges 

between 6.95 percent and 17.95 percent. EPA used a cost escalation factor of 14 percent for the 

seafood waste management facilities. The plumbing cost escalation factor used by EPA for the 

seafood waste management facilities is outside the RSMeans published range for an industrial 

factory (3.7 percent to 8.1 percent), however EPA believes that because the majority of the 

process equipment associated with the seafood waste management requires plumbing systems 

similar to the Naval facilities, using the plumbing factor that somewhat higher than the RSMeans 

range is appropriate.

Table 1. Direct Cost Escalation Factors

Direct Cost 

Factor Description Percent of Equipment Cost References

Plumbing Carbon steel pipe, fittings, valves, pipe 

racks, and installation labor 13.3

Experience with similar 

Naval industrial type 

projects

Mechanical 

Systems

Equipment supports and anchors, duct work, 

HVAC systems, etc. and installation labor 17.5

Experience with similar 

Naval industrial type 

projects

Electrical 

Systems

Wire, conduit, load locations, switches, 

starters, etc. and installation labor 15.8

Experience with similar 

Naval industrial type 

projects

Instrumentation

Programmable logic controllers (PLCs), 

wiring, monitors, data loggers, etc, and 

installation labor

17.7

Experience with similar 

Naval industrial type 

projects

Site Work Moving and relocating existing equipment 

and space/building modifications 14.0

Experience with similar 

Naval industrial type 

projects

Seafood Waste Treatment Cost Methodology

In general, EPA obtained costs for seafood waste management equipment (e.g., rotary

screens, pumps, tanks, etc) from vendors or from published literature, and applied the 

appropriate direct cost escalation factor percentage (e.g., electrical, plumbing, etc) to equipment 

cost to derive an installed capital cost. Not all of the Table 1 factors are applicable to each piece 

of equipment. For example, EPA did not apply the mechanical systems factor to pumps because 

the pumps will be installed in an existing structure with adequate supports and anchors and the 

pumps do not require duct work or HVAC. Similarly, EPA did not apply the instrumentation or 

site work factors because they are not required for pump installation. The example below shows 

how the direct cost escalation factor percentages were applied to the quoted price for a pump to 

derive an installed cost.
C-3

 Pump Quoted Price: $10,000

 Pump Plumbing Cost @ 13.3% Escalation = $10,000 x (13.3/100) = $1,330

 Pump Electrical Cost @ 15.8% Escalation = $10,000 x (15.8/100) = $1,580

 Installed Pump Cost: $10,000 + $1,330 + $1,580 = $12,910

EPA applied the individual indirect cost escalation factors shown in Table 2 to the 

installed capital costs to estimate a total indirect cost. The example below shows how indirect 

costs were estimated using the example for the pump. 

 Installed Pump Cost: $12,910

 Pump Engineering Cost @ 8% Escalation = $12,910 x (8/100) = $1,032

 Pump Permits Cost @ 2% Escalation = $12,910 x (2/100) = $258

 Pump Scheduling Cost @ 0.8% Escalation = $12,910 x (0.8/100) = $103

 Pump Performance Bond Cost @ 2.5% Escalation = $12,910 x (2.5/100) = $323

 Pump Insurance Cost @ 2.0% Escalation = $12,910 x (2.3/100) = $258

 Pump Contractor Mark-up @ 10% Escalation = $12,910 x (10/100) = $1,291

 Pump Contractor Overhead and Profit @ 10% Escalation = $12,910 = $1,291

The total indirect cost is the sum of the engineering, permits, scheduling, performance 

bond, insurance, markup, and overhead and totals $4,556. The total installed capital cost for the 

pump is the total of the direct costs and indirect costs and is show below: 

Total Installed Capital Cost for the Pump: $12,910 + $4,556 = $17,466

Based on the direct and indirect cost factors used by EPA, the total installed capital cost 

is approximately 1.75 times the purchase price for the actual equipment.
C-4

Table 2. Indirect Cost Escalation Factors

Indirect Cost 

Factor Description

Percentage of 

Installed 

Equipment Cost

References

Engineering

System design and equipment 

specifications including 

drawings

8

U.S. Army Corp of Engineers 

DD 1391 Military 

Construction Forms and 

Instructions

Permits

Building permits, 

environmental permits and 

control plans

2

R.S. Means Building 

Construction Cost Data, 68th 

Annual Edition, 2010

Scheduling

Project management scheduling 

including equipment 

procurement timing

0.8

R.S. Means Building 

Construction Cost Data, 68th 

Annual Edition, 2010

Performance 

Bonds

Security bond issued by the 

contractor to guarantee 

satisfactory completion of the 

project

2.5

R.S. Means Building 

Construction Cost Data, 68th 

Annual Edition, 2010

Insurance

Risk, workers compensation, 

equipment lien/lease, public 

liability

2

R.S. Means Building 

Construction Cost Data, 68th 

Annual Edition, 2010

Contractor 

Markup

Handling cost for all goods and 

services 10

R.S. Means Building 

Construction Cost Data, 68th 

Annual Edition, 2010

Contractor 

Overhead and 

Profit

Office overhead including 

project management and 

contractor profit for job

10

R.S. Means Building 

Construction Cost Data, 68th 

Annual Edition, 2010
Appendix D

Documents Supporting Cost Estimates
D-1

Details of costing calculations are provided in individual documents included in Docket 

EPA-HQ-OW-2013-0652, supporting the Alaskan Seafood Processing Effluent Limitations 

Guidelines, Notice of Availability of Data and Information. These documents are listed in the 

following table.

Project File Section 

Name

Project 

File 

Section

DCN Title CBI/NonCBI

Cost Estimates 4.0 00237 Byrpoduct Yield Memo and 

Supplemental Information NonCBI

Cost Estimates 4.0 00238 Outline of Costing Assumptions NonCBI

Cost Estimates 4.0 00239

Direct and Indirect Escalation Cost 

Factors for Developing Budgetary 

Estimates for Waste Management at 

Seafood Processing Facilities

NonCBI

Cost Data 4.1 00217 Screen Costing Analysis NonCBI

Cost Data 4.1 00217A Screen Costing - Costing Spreadsheet #3 

- Screens costs NonCBI

Cost Data 4.1 00217B Screen Costing - Costing Spreadsheet #3 

- Screens costs_BB_4_12_2011 NonCBI

Cost Data 4.1 00217C

Screen Costing - Costing Spreadsheet #4 

-Screen Weight - wt versus peak day 

wastewater flow

NonCBI

Cost Data 4.1 00217D Screen Costing - Costing Spreadsheet #5 

- Screen Building Costing NonCBI

Cost Data 4.1 00217E Screen Costing - Costing Spreadsheet #5 

- Screen Building Costing_MJB NonCBI

Cost Data 4.1 00217F Screen Costing - Parkson - Quote NonCBI

Cost Data 4.1 00227 Fuel Costing Analysis - Fuel Summary 

for AK and WA NonCBI

Cost Data 4.1 00227A Fuel Costing Analysis - EIA btu 

Conversion factors NonCBI

Cost Data 4.1 00227B Fuel Costing Analysis - Calculations for 

Gas and Diesel NonCBI

Cost Data 4.1 00228 Labor Cost Estimates NonCBI

Screening, Barging, 

and Ocean Disposal 

Alternatives

4.1.1 00219 Vessels Costing Data NonCBI

Screening, Barging, 

and Ocean Disposal 

Alternatives

4.1.1 00219A Vessels Costing Analysis - Draft vessel 

costing NonCBI

Screening, Barging, 

and Ocean Disposal 

Alternatives

4.1.1 00219B Vessels Costing Analysis - Waste 

Hauling Boats 3_30_11 NonCBI

Screening, Barging, 

and Ocean Disposal 

Alternatives

4.1.1 00225A Costing Analysis for Other Equipment -

Screen Solids Hopper Costs NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00213CBI Costing Spreadsheet - Juneau ByProducts Plant Costs CBI
D-2

Project File Section 

Name

Project 

File 

Section

DCN Title CBI/NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00214CBI Costing Spreadsheet - Petersburg ByProducts Plant Costs CBI

Seafood By-Product 

Production 

Alternative

4.1.2 00216 By Product Recovery Plant Information 

for Costing NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00216A

By Product Recovery Plant Information 

for Costing - By Product Plant Annual 

Costs

NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00216B By Product Recovery Plant Information 

for Costing - Cost Elements Jan NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00216C

By Product Recovery Plant Information 

for Costing - Anco Eaglin - Electrical 

Estimates

NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00229 Alfa Laval Background Information NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00230 Alfa Laval Background Information NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00231 Westfalia Background Information NonCBI

Seafood By-Product 

Production 

Alternative

4.1.2 00232 GEA Westfalia Report NonCBI

Facility Cost 

Estimates 4.2 00212

Costs Analysis - Scenario 1 Electrical, 

Electrical Requirements for Pumps, and 

Maintenance Labor & Equipment Costs

NonCBI

Facility Cost 

Estimates 4.2 00215 Costing Analysis for Pumps - Product Sheets NonCBI

Facility Cost 

Estimates 4.2 00215A1 Costing Analysis for Pumps - Plumbing costs to move existing muffin monster NonCBI

Facility Cost 

Estimates 4.2 00215A2 Costing Analysis for Pumps - Fish Waste Moyno NonCBI

Facility Cost 

Estimates 4.2 00215A3 Costing Analysis for Pumps -Wastewater Sump Costs NonCBI

Facility Cost 

Estimates 4.2 00215A4 Costing Analysis for Pumps -Wastewater Sump Pump Costs NonCBI

Facility Cost 

Estimates 4.2 00215A5 Costing Analysis for Pumps - Fish Waste Cornell Pump Costs NonCBI

Facility Cost 

Estimates 4.2 00218 AK & Seattle Construction Costing Estimate NonCBI

Facility Cost 

Estimates 4.2 00218A P161 Concept Study Costs NonCBI
D-3

Project File Section 

Name

Project 

File 

Section

DCN Title CBI/NonCBI

Facility Cost 

Estimates 4.2 00220 Electricity Costing Analysis NonCBI

Facility Cost 

Estimates 4.2 00220A Electricity Costing Analysis - EIA data Electricity cost AK_WA_AK city NonCBI

Facility Cost 

Estimates 4.2 00220B Electricity Costing Analysis - EIA Btu conversion factors NonCBI

Facility Cost 

Estimates 4.2 00221 Transportation Costing Analysis NonCBI

Facility Cost 

Estimates 4.2 00222 Flowmeter Costing Analysis NonCBI

Facility Cost 

Estimates 4.2 00222A Costing Spreadsheet #10 - Flow Meter Cost NonCBI

Facility Cost 

Estimates 4.2 00223 Lab Analysis and Sample Shipping Cost Analysis NonCBI

Facility Cost 

Estimates 4.2 00224 Shipping Containers Costing Analysis NonCBI

Facility Cost 

Estimates 4.2 00224A Shipping Containers Costing Analysis -Totes NonCBI

Facility Cost 

Estimates 4.2 00225 Costing Analysis for Other Equipment NonCBI

Facility Cost 

Estimates 4.2 00226 Shipping Equipment Costing Analysis NonCBI

Facility Cost 

Estimates 4.2 00226A Shipping Equipment Costing Analysis -Shipping Matrix NonCBI

Facility Cost 

Estimates 4.2 00226B Shipping Equipment Costing Analysis - Lynden shipping cost estimate NonCBI

Facility Cost 

Estimates 4.2 00300 Scenario 2a and 2b Sketches NonCBI

Facility Cost 

Estimates 4.2 00301CBI AK Seafood Cost Calculations May 2011 CBI

Facility Cost 

Estimates 4.2 00302CBI processing plant assumptions CBI