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### MEMORANDUM **TO:** Docket EPA - HQ - OW - 201 3 - 0 652 , for A laskan Seafood Processing Effluent

Limitations Guidelines , Notice of Availability of Data and Information **FROM:** U.S. Environmental Protection Agency **DATE:** August 20 1 3 **SUBJECT: Report of**  **Quality Activities Supporting Alaska Seafood Processing Cost**

**Estimates 1.**  **B ACKGROUND AND**  **P URPOSE OF THIS**  **R EPORT**  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 EP A 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 location s, and would grant the petition for Juneau, thus proposing to chang e the status of that location to “remote.” EPA also requested comment on additional locations that may have similar characteristics to the non - rem ote 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 thi s 1980 petition or amended effluent limitations . EPA estimate d costs for direct discharging Alaska seafood processors associated with the petitioning location s 1 of Cordova, Juneau, Ketchikan, and Petersburg to manage and dispose of seafood processing solid s by 1) screening and transport for ocean disposal, and 2) screening, cooperative by

products recovery , and ocean disposal of non - recoverable waste. EPA estimated costs for 15 surveyed processors in the petitioning location s 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 location s. EPA used e stimated costs for the three model processors to evaluate economic impacts for non surveyed processors in the petitioning location s 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 purpos es of this analysis. E PA estimated costs and economic impacts for processors in the Kenai Peninsula because EPA might consider reclassifying these location s as non -remote.2

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 imp lement 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 location s 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 . Activiti es used to c ontrol 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 Q APP 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. C**  **OLLECTING C**  **OST D**  **ATA** EPA collected information about the costs for Alaskan seafood processors to install and operate wastewater pollution control technologies, including b yproduct recovery processes and hauling waste for off

- shore disposal. EPA obtained current ( i.e., 201 0 - 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 s hipping to each processing location to the quoted equipment costs. In addition to equipment purchase and shipping , EPA obtained price s for fuel (electricity , gasoline, and diesel ), labor, and shipping by products from the seafood processing location to Seattle. T o 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.3

The criteria EPA use d 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? Cost s 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 . Com parability Are the costs comparable to costs

provided by sources that meet these acceptance criteria ? Com parable to costs obtained in §308 information

collection requests. Source: QAPP Table 2 - 3 . **3. E**  **VALUATING C**  **OST D**  **ATA Q**  **UALITY** 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. Ch e cklist findings were recorded in a spreadsheet, a cop y 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 m edian annual maintenance costs for fishery ve ssels 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 f or currency

or geographic scope. EPA considered these estimates to be “best available” and suitable for concept level cost estimate s . 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 adjusted4

the costs to the processing location locations using factors from Construction Cost Survey 2010, Alaska Housing Finance Corporation . Accuracy/Reliabilit

y. 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” by products 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 ty pe 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. E PA 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 equip ment, fuel, labor, and shipping. As a result, EPA could not sy stematically determine the comparability of the collected cost data. However, where individual questionnaire responses or other public sources included data applicable to costing scenarios appli ed to processors for which EPA developed costs, basic comparisons were made. Regarding capital costs, d uring August 2010 visits to Alaska seafood processors (and in communication conducted as follow -up to the visits), EPA obtain ed equipment costs. C osts provided b y seafood processors are compared to vendor prices in Table 3 - 1 .5 **T able**  **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

ANCO EAGLIN Pum

ps appropriate for transferring fish wa ste 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 pum ps 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 year b $80,000 per year

b Dock Street Brokers Work vessel 60,000 lb/load $72,000 per year

b Dock Street Brokers Scow 100,000 lb/load $68,000 per year b $74,000 per year

b 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 Pi one er 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.6

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 b y Sandro Lane. Mr. Lane’s higher cost represent s 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 ye ar. Table 3 - 1 shows the range of annual costs 1 EPA 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 b y the unnamed source and Alaska General. **3.2 Reconciling Data Quality With User Requirements**  A s 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 woul d 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 anal yz ed 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

anal ys is, and shipping was usable for this project. Byproducts Recovery Plants. EPA contacted four companies that sell seafood by products 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. Onl y the resp onse from ANCO - EAGLIN provided a complete, detail ed 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 wo uld increase the annual costs by about 10%).7 **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. ANCO EAGLIN Provided 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 c ontrol 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. E**  **STIMATING P**  **OLLUTION C**  **ONTROL T**  **ECHNOLOGY C**  **OST S**  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 size 1 and 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 w ere pulled into the spreadsheet to calculate the costs for each processor . Finall y, the estimated costs were us ed to anal yz e the economic impact of the se 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 U sing 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 outlin e of scenarios and assumptions. The Project QA Coordinator and another senior engineer knowledg e able in the deve lopment of effluent limitations guidelines , reviewed this outline and discussed it with the project m anager . After addressing the review comments, a draft outline was

1 Equipment size was normalized to wastewater flow (gpm) to facilitate calculations.8

provided to the EPA project team . The project engineers and economis ts discussed the draft outline . The engineering team revised the draft outline based on that discussion and added a new se ction (modeling and financial impacts for non - questionnaire plants) based on discussions b etween engineers and economists, and the revised outline was complete d. These two drafts each included two versions of the by products recovery

scenario. Scenario 2a w as a worst - case scenario that assumed that each individual seafood processor would construct a separate by products recovery

plant. This worst - case was based on the assumption that seafood processor with different owners would not cooperate with b yproduct 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 estimate s, the assumptions were revised slightl y to better reflect Alaska condition s 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 s cenario s at each individual processor . To estimate installed capital costs, EPA applied direct and indirect escalation factors to the equipment and unit purcha se 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 fac tors in numerous past projects and found the resulting cost estimates agree very well with detailed cost estimates provided by construction companies. **4.3 Develop**  **ing Cost Curves**  EPA applied appropriate escalation factors to the collected equipment and unit co st 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 co st 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 consistentl y, and verified that the cost equations were developed correctl y and that they covered the ranges of sizes needed for the seafood processor s . The engineer provided a written report of his review . Cost curves developed for this project are listed in Table 4 - 1 .9

**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 slightl y different approach. For vessels, EPA included costs for one of four sizes of vessels, depending on the monthl y average pounds/day of waste generated by the processor s 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 directl y 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.10

**Table 4**  **- 2 Calculation of Cost Estimate Spreadsheet Inputs from Questionnaire**  **Cost Spreadsheet**  **Input Units**  **Variable Nam**  **e a**  **Description Discussion**  **b** 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 ty

pe of seafood product. Only fresh and frozen salmon and canned salmon were calculated. Average Non Salmon 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 g al/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 I n 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 Non Salmon 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 I n B 12 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.11

**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 p roduction and wastewate r information for each seafood processor to calculate the costs for each processor to manage and dispose of its waste solid s. EPA developed preliminary cost estimates , they were reviewed, and revised costs were complete d. 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 p rocessor 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 c alculations 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 c orrections 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 spreadsheet s . He checked that the calculation description matched the cell formula and that cell references were correct. Th e engineer checked that units were converted properly

and pro vided the spreadsheet developer with a written summary of the data checked, errors or problems found, and recommended revisions. (S ee 4 .3 for a discussion of his review of the cost curves.)  A project manager reviewed the costs by comparing the estimates fo r 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 .12

**Table 4**  **- 3**  **. Alaska Seafood**  **Processing Cost Estimate Spreadsheet Quality Activities**  **Cost Estimate Spreadsheet Quality Activity** S preadsheet developer created cost estimation spreadsheet S cientist checked calculation accuracy (Ketchikan and Petersburg) S cientist 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 S preadsheet revisions were planned

- obtained late - arriving shipping cost data

- researched costs for a 4 th 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 S preadsheet developer revised spreadsheet T echnical reviewer checked the revised spreadsheet S preadsheet developer made minor spreadsheet revisions **R evised costs**  **delivered to econom** **ists ( AK Seafood Cost Calculations April 2011.xlsx** **)** S ensitivity 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 **R evised costs**  **delivered to**  **econom ists**  **( AK Seafood Cost Calculations May 2011.xlsx** **)** D raft Economic Impact Analysis was reviewed and the need for clarifying footnotes for the economic analysis report wa s 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 th e 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 Pro ject File Management Plan. **5. E**  **VALUATING C**  **OST E**  **STIMATE Q**  **UALITY** Verification of the completed cost estimates means determining if estimated costs meet the data acceptanc e 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 .13

**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 b y the economists to ultimately prepare : Costs and Economic Impact Analysis for Alaska Seafood Processors (Facilities and Firms) DCN 0 0428 . Table 5 - 1 reproduce s the QAPP c ost e stimate quality specifications along with an assessment of whether the estimated costs met the specification s .

**Table 5 -**  **1 . Cost Estimate**  **Quality Specifications**  **Acceptance Criterion:**  **Cost Estimates Specification**  **Com parison 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., refl ect the costs in each processing location).  True

 E lectricity, diesel fuel, gasoline, and labor reflect processing location costs. C hemical 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). Com plete  Include costs for all elements necessary to

im plement 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 verif

y this assumption. Accurate (spreadsheet calculations)  Spreadsheet calculations are correct.  Unit conversions are correct.  True  True14 **Table 5 -**  **1 . Cost Estimate**  **Quality Specifications**  **Acceptance Criterion:**  **Cost Estimates Specification**  **Com parison 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. T o evaluate the reasonableness of the cost estimate, EPA planned to compare its estimated costs to costs for s imilar installations at similar seafood processors . During August 2010 visits to Alaska seafood processors and foll ow -up to the visits, EPA sought costs for similar installations but obtained only limited information . Table 5 - 2 presents c osts provided by Alaska General Seafood in Ketchikan for converting from discharging ground up solid waste through its Tongass Narrow s 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 wa ste 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:** Pum p (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 wa ste/year $591,000

**Limit to E PA**  **Estimated Costs for**  **:** Pum p (waste from existing sump to screen) Rotary wedge wire screen Waste hopper Move existing grinder pump $ 292,00016

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 cost s 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. Li miting 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 NO DA . 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 Estimate**  **s and**  **Reconciling Estimate Quality with User Requirements**  According to EPA’s Guidance for QAPPs (QA/G - 5), data validation is “an anal yt e - and sample - specific process that extends the evaluation of data beyond method, procedural, or contractual compliance (i.e. data verification) to determine the anal ytical 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 anal ys is 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 processor s 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 technicall y and logistically feasible for facilities in non remote locations?  What would implementation of these technologies cost? This quality

activity report will support EPA in making this determination. **6. C**  **OSTING D**  **OCUMENTATION** Details of costing calculations are provided in individual documents included in Docket EPA - HQ - OW - 201 3 - 0 652 , supporting the Alaskan Seafood Processing Effluent Limitations Guidelines , N otice of Availability of Data and Information. These documents are listed in Appendix E.17

**7. P**  **OLLUTANT R** **EMOVALS** EPA developed estimates of the incremental effluent reduction benefits (pounds of pollutants removed) for screening versus grinding. Ty pically , 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 th e final product. As a result, for today ’s notice and in the anal ys is 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 prox y 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 regularl y reported utilizing mass balance data regularl y 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 b y- product recovery achieve waste removals in excess of 90 percent. EPA estimate d total loads of waste generated for individual processing facilities using data provided b y 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 A SSUMPTIONS**  **ALASKA SEAFOOD PROCE SSING**  **IN NON -**  **REMOTE PROCESSING LOCATION**  **S**

# Outline of

**Costing Assumptions Alaska Seafood Processing**  **In Non -**  **Remote Processing Location**  **s**

U.S. Environmental Protection Agency Office of Water (4303T) 1200 Pennsylvania Ave., NW Washington, DC 20460 August 2013A - 1

**1. I**  **NTRODUCTION** 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 scenarios 5 : 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. (January9, 1981) , EPA is considering reclassifying these locations as non - remote. 6 No direct dischargers are currentl y located in Anchorage, another original petitioning location. Dutch Harbor, although surv eyed, 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

compl y with the non - remote ELGs as promulgated. Theref

ore, 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 0 0428. The cost estimates reflect the amount and ty pe (salmon vs. non - salmon) of waste generated at the affected plants and costs to purchase, install, and operate appropriatel y 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 review s , EPA revised the

5 EPA originally included two versions of Scenario 2, the byproducts recovery scenario. Scenario 2a was a worst case scenario that assumed that each individual processing plant would construct a separate byproducts recovery plant. This worst - case was based o n 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 - effec tive. Notable exceptions include the three long standing 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 smalle st vessel (16,000 ton bow picker) and less than the next largest vessel (100,000 ton scow) 7

.  In creasing 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 b yproducts recovery plant in Petersburg, correcting an error calculating the cost for trucking the waste from the processing plant to the assumed by

products 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 mistakenl y 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 Lyn den Shipping (Ly

nden’s quote did not arrive until after the preliminary costs were completed);  Updating the diesel, gasoline, and el ectricity 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. C**  **OSTING S**  **CENARIOS 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 by product plant  Haul non - salmon waste and non - recoverable salmon waste for off - shore disposal  Monitor screened wastewater for TSS and O&G  Measure volum e 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 b yproducts plant  Process screened salmon wastes in combined processing location by product plant

— Keep waste from salmon separate from waste from longline - caught fish that may contain embedded stainless steel hooksA - 4 — produce commodity grade :  salmon oil and  salmon meal .  By

products plant also operates a combined processing location waste disposal boat  Haul non - salmon waste and non - recoverable salmon waste fo r off - shore disposal  Monitor screened wastewater for TSS and O&G  Measure volume of wastewater discharged  Discharge screened wastewater through existing outfallA - 5

**3. G** **ENERAL C**  **OSTING A**  **SSUMPTIONS** For this cost estimate, EPA assumed that plants will only recover by

products during 91 day salmon season. In formation acquired primarily from industry

sources indicates the non recoverable portion of salmon waste is approximately five percent 1

. Outside of salmon season, all waste will be hauled offshore for disposal. This assumption is applied to both Scenario s 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 In clude costs for 2 pumps o Pump sized based on lb/day2 fish waste to screen o Ty pe of pumps (Moy

no 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, 3 then multiplied the kWhr by the operating hours per year to determine total kWh/yr. o In clude 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, Ke tchikan, 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 Chemi cal Engineers Handbook, Sixth EditionA - 6 o Solids will discharge to a hopper

 Hopper size based on lb/day salmon season wast e 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 b y 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 wil l 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 ye ar = total waste per ye ar/boat load o Check number of trips required for peak week

 If significantl y 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 boatA - 7

 Monitoring o Use the requirements from Kodiak general permit (e.g., wastewater flow and weekl y 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 c osts 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 Assume d new sump will be located next to existing sump and not require demolition or removing existing concrete o In clude 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 by products recovery

plants that currentl y 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 b yproducts will cooperate in owning and operating a waste disposal vessel o Vessel will be smaller, because less waste to haulA - 8

 For existing and plann ed by products recovery

plants, EPA assumed o Ici cle plants in Seward and Petersburg that operate their own by products recovery will continue to refuse other plants’ waste o Trident plants in Ketchikan and Cordova that operate by products 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 b yproducts recovery plant in Kenai has capacity for Kenai waste (except Icicle) or will expand as needed to accommodate the wa ste 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 b yproducts plant will receive all of the profit o Waste generators are not paid for th eir waste but do not need to pay to truck their waste to the byproducts plant o The existing by

products 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 b yproducts recovery facilities, EPA assumed o Trident and Ocean Beauty will cooperate to build a new by products plant in Petersburg

 Space and infrastructure are available at Trident’s Mitkof plant (currentl y not operating)

 No costs for land, cost for renovating the existing buildingA - 9  Both Trident and Ocean Beauty will have costs to truck waste to the new combined by

products plant (assumed $10/metric ton). o Taku and Alaska Glacier will cooperate to build a new b yproducts plant in Juneau

 Neither processor has space for the b yproducts plant

 Land and building required for new plant

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

products 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 proc essed

 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 cos ts included (diesel fuel tank, CIP system) o In clude 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 (p ower, 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 by

products plant for the average lb/day in the highest month of the peak year, assuming it operates 20 hours per day .  Assumed by

product plant operates onl y 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. P**  **ROCESSING L**  **OCATION A**  **SSUMPTIONS**  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 S eafood (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 D eep 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 APR 1 . Norquest will purchase and operate a waste boat for non - salmon season waste (the cannery onl y 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 non salmon 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 b y 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  Ici cle will maximize the use of its existing by product plant o Ici cle will not take OB or Trident waste o Ici cle 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 Ici cle 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 Ici cle 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 Ici cle Scenario 1and 2b costs will be the same  In Scenario 2b, Trident and OB will build a combined by products plant. o Both Trident and OB will transport their screenings from the processing plant to the by products plant o Trident and OB will cooperate in hauling salmon season residuals. Trident will also haul non - salmon season residuals (when OB i s 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 by products 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 u sed 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 by product 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 non recoverable wa ste 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 boatA - 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 c ooperate 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 anal yz ed 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  Ici cle Seward will maximize the use of its existing by product plant o Ici cle will not take waste from any other plant o Ici cle will incur costs to haul its residual waste, in any scenario, but not screening costs because they

already have a screen. o Ici cle 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 Ici cle will incur costs for a flow meter and effluent monitoring o Ici cle 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 by products plant at Kenai LandingA - 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 b ecause 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 proce sso rs o Alyeska o Westward o Uni s ea  The three large proce sso rs (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 b yproducts 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 BOD 5 discharge limitA - 15

 Two Icicle barges are tow ed to Dutch Harbor for the pacific cod/pollock season o n either vessel screens or has a b y product 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 c osts 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 recentl y reopened under new ownership (Copper River is a part owner) o grind and discharge under the general permit. o c osts 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 p rocessor s which di d 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 0 0428 .

### Appendix B

**POLLUTION CONTROL CO ST DATA QUALITY CHEC**  **KLIST**B - 1

EPA collected information about the costs for Alaskan seafood processors to install and operate wastewater pollution control technologies, including b yproduct 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 Re sponse to Industry Petition on ELGs for Non - Remote Alaskan Seafo od 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 cop y 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 "non**   ** remote" 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 Il linois 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 yesB - 2

**Item/Unit Cost**  **Cost Information Source Currency**  **(up to date) Geographic** 

**Scope Accuracy/** 

**Reliability Year**  **Basis 2009** 

**- 2011?**  **Appropriate**

**for "non**   ** remote" 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 - Ju neau 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 - Ju neau 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 YesB - 3

**Item/Unit Cost**  **Cost Information Source Currency**  **(up to date) Geographic** 

**Scope Accuracy/** 

**Reliability Year**  **Basis 2009** 

**- 2011?**  **Appropriate**

**for "non**   ** remote" 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 - Ju neau 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 FACT**  **ORS FOR DEVELOPING BUDGETARY ESTIMATES**  **FOR WASTE MANAGEMENT AT SEAFOOD**  **PROCESSING FACILITIE S** C - 1



### MEMORANDUM **TO:** The Record **FROM:** Project Team **DATE:** August , 201 3 **SUBJECT: Direct and Indirect Escalation Cost Factors for Developing Budgetary** 

**Estimates for Waste Management at Seafood Processing Facilities** EPA i s 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 s ys tems, 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 constructi on programs 1 and from project team experience with construction costs for various industrial sectors. The factors in Table 2 were developed taken mainl y from RSMeans Construction Cost data2 supplemented with information from U.S. Department of Defense cons truction programs. The specific references and/or sources of the escalation cost factors used to develop capital costs for seafood processing waste management s ys tems 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, 68 th 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 s ys tems. 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 E PA for the seafood waste management facilities is outside the RSMeans published range for an industrial factory (3.7 percent to 8.1 percent), however E PA 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 E xperience with similar Naval industrial type projects Mechanical Systems Equipment supports and anchors, duct work,

HVAC systems, etc. and installation labor 17.5 E xperience with similar Naval industrial type projects Electrical Systems Wire, conduit, load location s, switches,

starters, etc. and installation labor 15.8 E xperience with similar Naval industrial type projects Instrumentation Programmable logic controllers (PLCs),

wiring, monitors, data loggers, etc, and installation labor 1 7.7 E xperience with similar Naval industrial ty

pe 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 manag ement 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 cos t. 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 , E PA did not appl y 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 Cos t @ 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 = $1,2 91 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 sho w 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 - 201 3 - 0 652 , 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 By Products Plant Costs CBID - 2

**Project File Section Name**  **Project**

**File Section**  **DCN Title**  **CBI/NonCBI** Seafood By - Product Production Alternative 4.1.2 00214CBI Costing Spreadsheet - Petersburg By Products 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 NonCBID - 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