Development of Denitrification Cost Methodology

This pdf file documents correspondence with Veolia, a vendor of a moving bed biofilm reactor (MBBR)

system that can be used to treat organic matter.

ERG, EPA’s technical contractor, contacted Veolia, a vendor of a MBBR system for costing and operating

and maintenance information.  EPA included costs for a denitrification system, the MBBR system from

Veolia, for plants with high nitrate/nitrate concentrations in the FGD wastewater.  This pdf documents

all correspondence between ERG and the Veolia vendor.
1

Danielle Lewis

From: Thomas Finseth

Sent: Thursday, July 24, 2014 11:23 PM

To: Danielle Lewis

Subject: FW: Denitrification System Costs for EPA

We will need to talk through this data to determine what other information we need.

From: An, Li [mailto:li.an@veolia.com] 

Sent: Monday, July 21, 2014 6:24 PM 

To: Thomas Finseth 

Cc: Wessman, Flemming; Caroline Dale; Thomson, Chris 

Subject: Re: Denitrification System Costs for EPA 

Hi Thomas, 

Below is what I have for you for the three options we estimated for you. If you have any questions please let me 

know. Thanks! 

The operation costs seem very high for this system. 

Design Basis

Influent Data

N-NO3 concentration 175 mg/l 

N-NO2 concentration 0 mg/l 

COD concentration 20 mg/l 

Inlet DO concentration 1 mg/l 

Temperature C 35 °C 

Effluent Data

Discharge N-NO3 concentration 100 mg/l 

Target N-NO3 conc for MBBR 

design 50 mg/l 

 

Design flowrates:

Option 1 – 100 gpm 

Option 2 – 500 gpm 

Option 3 – 1,000 gpm 

 
2

Process Assumptions

- influent is temperature controlled to 35C +/- 2C 

-pH is controlled with a range of 6.5 to 8.5 

-The nitrate concentration of 175 mg/l was expressed as N 

-The nitrate concentration limit of 100 mg/l was expressed as N and will be achieved as a maximum value 

(design to achieve average of 50 mg/l N-NO3) 

-Carbon dosing is based on Micro C - methanol or other suitable carbon sources may be used. In such case, the 

sludge production should be revised accordingly 

- Metals have been removed prior to biological treatment to ensure that the influent to the MBBR is not toxic to 

biological activity 

 

Design Summary

Veolia	proposed	three	options	for	ERG.	Option	one	is	with	a	design	flowrate	of	100	gpm;	option	2	with	a	

design	flowrate	of	500	gpm;	and	option	3	with	a	design	flowrate	of	1,000	gpm.	Each	option	contains	one	

MBBR	denitrification	tank	followed	by	a	discfiter	(option	2	and	3)/drumfilter	(option	1).	The	MBBR	

reactor	dimensions	for	option	1,	option	2	and	option	3	are	11’	Diameter	x	18’	SWD	(20’	SSH),	25’	

Diameter	x	16’	SWD	(18’	SSH),	and	22’	Diameter	x	20’	SWD	(22’	SSH),	respectively.	The	media	filling	

percentage	of	the	reactors	is	50%.	Micro	C	is	added	to	the	MBBR	tank	as	the	external	carbon	source.

The	discfilter/drumfilter	is	proposed	to	remove	85%	of	solids	from	the	MBBR	effluent.	

Estimated Prices

The	rough	order	of	magnitude	DB	prices	are	as	below:

Option	1:	design	flowrate		100	gpm	‐	$600,000		

Option	2:	design	flowrate	500	gpm	‐	$1,000,000

Option	3:	design	flowrate	1,000	gpm	‐	$1,500,000
3

The	price	includes	(same	scope	of	supply	for	each	option):

 One	(1)	MBBR	reactor	(1	x100%)

 AnoxKaldnes	Media

 Mixer

 Sieves

 Two	(2)	Micro	C	feed	pumps	(2	x	100%)

 One	(1)	Discfilter	(drumfilter)	package	(turn	key	ready)	(1	x	100%)

 One	(1)	pH	probe

 One	(1)	nitrate	probe

 One	(1)	level	sensor

 One	(1)	H3PO4	metering	pump	skid

 One	(1)	Polymer	feeding	system

 Start‐up	and	training

 Detailed	engineering

 Equipment	shipping,	unloading	and	installation

 Civil,	mechanical,	electrical,	instrumentation	and	controls

 Access	structure	(ladders,	platforms,	etc.)

 Performance	test

Estimated Chemical and Electrical Consumption

Estimated	chemical	consumption

Item

Consumed Amounts per Year Reference 

Option 1 Option 2 Option 3 rate
4

Phosphoric Acid (85%) 1,095 gal 6,205 gal 12,410 gal $0.63/Lb

Micro C 59,310 gal 296,535 gal 593065 gal $3.25/gal

Polymer for Discfilter/Drumfilter 

(emulsion, 30% active) 665 - 2,655 gal 3,320 - 13,265 gal 6,630 - 26,535 gal $3.4/Lb

Estimated	electrical	consumption

Item

Consumed Amounts per Year Reference 

Option 1 Option 2 Option 3 rate

Mixer (KWH/yr) 44,093 58,791 146,977 $0.08/KWH

Micro C feed pump (KWH/yr) 15 85 156 $0.08/KWH

H3PO4 metering pump 

(KWH/yr) 1 2 4 $0.08/KWH

Polymer feed system 

(KWH/Yr) 1 1 1 $0.08/KWH

Discfilter/Drumfilter (KWH/yr) 7,227* 54,049 91,192 $0.08/KWH

*Assumed	drumfilter	backwash	3	hours	per	day.

Li An, PhD

Process Engineer

WATER TECHNOLOGIES

office: +1-412-809-6673 / cell: +1-724-719-0130 / fax: +1-412-809-6512 

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - USA 

 

li.an@veolia.com 

www.veoliawaterstna.com

 

On Tue, Jul 8, 2014 at 12:13 PM, Thomas Finseth <Thomas.Finseth@erg.com> wrote: 

Hi Caroline,
5

Thank you for taking the time to speak with me yesterday about the design for the MBBR system that we would like to

include in EPA’s analysis for the steam electric industry.  The following are the answers to the specific follow up items

that we discussed yesterday:

BOD Concentrations in FGD Wastewater: The typical FGD wastewater BOD concentrations that would be present in the

wastewater that would be sent to the MBBR would be approximately 10 mg/L.  There isn’t a lot of BOD in FGD

wastewater; therefore, you will need to account for feed to the system.  

Nitrate Concentrations in FGD Wastewater: I have confirmed from our data that the nitrate concentrations that I

provided in my previous email are Nitrate/Nitrite (as N).

TSS Concentration for ABMet system: I have confirmed in our documentation that the ABMet system for which GE used

as its design basis assumed a TSS concentration of less than 100 ppm.  I will note however, that based on their brochure,

GE claims to be able to handle up to 250 mg/L.  However, please assume that you will need a solid separation process

for the MBBR solids and that they will be transferred back to the solids holding tank in the upstream chemical

precipitation system.  Please also specify approximately how much solid waste will be generated at transferred back to

the solids holding tank so we can make sure that we size the solids holding tank and filter presses appropriately.

Nitrate Concentrations for ABMet system: I have confirmed that GE is only expects to need a separate denitrification

step to remove nitrate when the nitrate/nitrate (as N) concentrations exceed 100 ppm.  GE specifically wrote: “If NO3‐N

levels exceed 100 ppm, then we would consider a dedicated denitrification step ahead of the ABMet bioreactors.”

Please let me know if you have any questions or need any additional information.

Thanks again for your time and help.

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633‐1698 (phone)

(703) 263‐7479 (fax)

thomas.finseth@erg.com
6

From: Wessman, Flemming [mailto:flemming.wessman@veolia.com] 

Sent: Tuesday, July 01, 2014 5:18 PM 

To: Thomas Finseth; Caroline Dale; Li An 

Cc: Thomson, Chris 

Subject: Re: Denitrification System Costs for EPA

 

Hi Thomas 

 

I have been on the road for a week, I am in the office tomorrow after 2 pm, give me a call on 412 298 0145 

 

Best regards 

Flemming 

 

2014-07-01 10:26 GMT-04:00 Thomas Finseth <Thomas.Finseth@erg.com>: 

Hi Flemming,

I just wanted to follow up regarding this request.  As Chris mentioned, I’m trying to determine whether you would be

willing to help EPA generate an order of magnitude cost estimate for a power plant to install an MBBR system to

pretreat its FGD wastewater to remove nitrate/nitrate.  Because this is just an estimate, I’m hoping that it wouldn’t take

too much of your time.  If you’re willing, I would appreciate if we could have a call to discuss the type of information that

I would be looking for.  Are you available for a call this week?

Either way, please let me know whether you are willing to help.  If you aren’t willing to help, that’s fine, but I would like

to know as soon as possible so I can find another vendor that can help.

Thanks,

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633‐1698 (phone)
7

(703) 263‐7479 (fax)

thomas.finseth@erg.com

From: Thomson, Chris [mailto:chris.thomson@veolia.com] 

Sent: Wednesday, June 25, 2014 10:37 AM 

To: Flemming Wessman 

Cc: Thomas Finseth 

Subject: Fwd: Denitrification System Costs for EPA

 

Flemming: 

 

Would you please look at the attached email from TJ Finseth? TJ is with Eastern Research Group and he is 

working with EPA in determining cost curves for new treatment regulations. TJ is hopeful that someone with 

Veolia can help him with some preliminary costs for new effluent guidelines for steam electric plants. Not to 

"pass the buck," but since this is not municipal, this is out of Kruger's area of expertise. At this point, TJ would 

like to know if Veolia is willing and able to help his research group assemble cost information for EPA's study. 

 

I've copied TJ on this email. 

 

Chris 

 

Chris Thomson, P.E. (MD and NC)

Product Manager, AnoxKaldnes

Kruger Inc.

4001 Weston Parkway

Cary, North Carolina 27513

919-653-4562 direct

919-677-0082 fax

919-523-9260 mobile

chris.thomson@veolia.com

www.krugerusa.com

www.veoliawaterstna.com

Kruger Inc. is a subsidiary of Veolia Water Solutions & Technologies
8

Service ● Value ● Responsibility

 

---------- Forwarded message ---------- 

From: Thomas Finseth <Thomas.Finseth@erg.com> 

Date: 16 June 2014 16:34 

Subject: Denitrification System Costs for EPA 

To: "chris.thomson@veolia.com" <chris.thomson@veolia.com> 

Chris, 

 

As we discussed this afternoon, the following is a summary of the work I am currently doing with EPA and the 

information that we are hoping that you and Veolia can help us with. 

 

As I mentioned on the phone, I work for Eastern Research Group, which is a technical contractor to the EPA 

Office of Water, engineering and analysis division. We are supporting EPA with the revisions to the steam 

electric effluent limitations guidelines and standards (ELGs). The ELGs are technology-based limits that would 

apply to all steam electric power plants and would be incorporated into plants’ NPDES permits by the 

states/regions. EPA proposed revisions to the ELGs in June 2013. The following links contain information 

related the proposed rule and the technical development document that was prepared in support of the rule. 

 

http://water.epa.gov/scitech/wastetech/guide/steam-electric/proposed.cfm

 

http://water.epa.gov/scitech/wastetech/guide/steam-electric/upload/Steam-Electric_TDD_Proposedrule_2013.pdf

 

One of the main focuses of the rule is on flue gas desulfurization (FGD) wastewater. EPA is proposing to set 

limits for FGD wastewater based on a chemical precipitation and biological treatment system (based on the GE 

ABMet system). EPA’s proposal would set limits for arsenic, mercury, selenium, and nitrate/nitrite for FGD 

wastewater. The reason I’m getting in touch with you is because as part of the public comment period, industry 

argues that the costs EPA estimated for the rule are underestimated because some plants have high nitrate 

concentrations in untreated FGD wastewater, and therefore would need more retention time in the bioreactor 

than what was assumed in the cost estimate. We had an initial discussion with GE and they suggested that 

instead of costing plants with high nitrate/nitrite in the influent for additional residence time in the ABMet 

system, it would be more cost effective to send the water to a denitrification system to remove the nitrate/nitrite 

prior to treating it in the ABMet system. GE suggested that we talk with you regarding your MBBR system. 

 
9

Therefore, what I am looking for would be a way to estimate the capital and O&M costs for an MBBR system 

for multiple flow rates, such that I could generate a cost curve to apply to the industry. The two plants that we 

are using as the basis for the high nitrate/nitrite concentrations have the following characteristics (note: we have 

characterization data for additional pollutants if needed): 

 

Plant Minimum 

Nitrate/Nitrite 

Concentration (ppm) 

Maximum 

Nitrate/Nitrite 

Concentration (ppm) 

Average 

Nitrate/Nitrite 

Concentration (ppm) 

Plant 1 83 150 124 

Plant 2 150 220 174 

The goal of this MBBR system would be to reduce the nitrate/nitrite concentrations to below 100 ppm, because 

that is the basis for the design of the ABMet system used in EPA’s cost methodology. So once we got the 

concentration to below 100 ppm, it should be low enough for the ABMet system to handle and reduce down to 

the levels required by the rule. 

 

I appreciate you taking the time to talk with me and help investigate this. Please let me know if you have any 

questions or want to talk further about the rule or exactly what I would need from you. 

 

Thanks, 

 

TJ Finseth 

ERG

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

(703) 633-1698 (phone) 

(703) 263-7479 (fax) 

thomas.finseth@erg.com

 

 

 

************************************************************************* 

This e-mail message and any attachments to it are intended only for the 

named recipients and may contain confidential information. If you are not 

one of the intended recipients, please do not duplicate or forward this 

e-mail message and immediately delete it from your computer. If you 

received this email in error, please notify postmaster@veoliawater.com

*************************************************************************
10

 

-- 

Flemming G. Wessman

Vice President, Sales & Marketing, Industrial Projects

WATER TECHNOLOGIES

 

off.: +1-412-809-6173 / cell: +1-412-298-0145 / fax: +1-412-809-6512

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - USA

 

www.veoliawaterstna.com

 

 

************************************************************************* 

This e-mail message and any attachments to it are intended only for the 

named recipients and may contain confidential information. If you are not 

one of the intended recipients, please do not duplicate or forward this 

e-mail message and immediately delete it from your computer. If you 

received this email in error, please notify postmaster@veoliawater.com

*************************************************************************

************************************************************************* 

This e-mail message and any attachments to it are intended only for the 

named recipients and may contain confidential information. If you are not 

one of the intended recipients, please do not duplicate or forward this 

e-mail message and immediately delete it from your computer. If you 

received this email in error, please notify postmaster@veoliawater.com

*************************************************************************
1

Danielle Lewis

From: An, Li [li.an@veolia.com]

Sent: Friday, August 08, 2014 3:25 PM

To: Thomas Finseth; Danielle Lewis

Cc: Wessman, Flemming; Caroline Dale; Chuck Blumenschein; Carl Bender

Subject: Re: Denitrification System Costs for EPA

Hi Thomas, 

Please see the answers in red below. 

Li An, PhD

Process Engineer

WATER TECHNOLOGIES

office: +1-412-809-6673 / cell: +1-724-719-0130 / fax: +1-412-809-6512 

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - USA 

 

li.an@veolia.com 

www.veoliawaterstna.com

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

On Thu, Jul 31, 2014 at 3:06 PM, Thomas Finseth <Thomas.Finseth@erg.com> wrote: 

Hi Li,

Thank you so much for the costing information that you provided.  We are working on incorporating it into our

estimated costs and have identified a few follow‐up questions.  We would appreciate your input on these follow‐up

questions so we have appropriate documentation.

1) Do you consider the provided costs (or any information provided in the email below) as confidential business

information (CBI)?  If so, we will not release the costs/information to the public.  Otherwise, these costs will be made

available to the public when EPA finalizes the rule. If you do consider the information as CBI, please identify the specific

costs/information that you consider CBI. NO

2) In your email, you stated “the rough order of magnitude DB prices are as below.” What does “DB” represent?  Are

the costs you provided an annualized cost?  Or do they represent a capital cost for the system?  Ultimately, it would be
2

preferable for us to receive a total capital cost for the system. We have provided you Design, Bid, Build price in another

email. Please ignore this one.

3) Are there any cost elements that are not included in the costs provided?  The following are the types of costs that

we have included in our estimates for other systems.  Please identify whether any of these should be added to the costs

that you provided:

a. Installation

b. Buildings

c. Site prep

d. Engineering

e. Construction

f. Other contractor fees The previous DB prices include items from a to e. Item f is not included. Note

it only includes small buildings not the major plant building.

4) What is the density of the 85% phosphoric acid?  We need this to calculate the total chemical costs based on the

gallons consumed and price in $/lb. S.G. 1.685

5) What is the density of the polymer for Discfilter/Drumfilter? We need this to calculate the total chemical costs

based on the gallons consumed and price in $/lb. you can use S.G. 1 to calculate for this purpose. We cannot tell what

kind of polymer is optimal without test.

6) Based on the design for each sized system, how much wastewater and how much solids would be expected to be

transferred back to the upstream chemical precipitation treatment system for additional processing? No wastewater or

solids are expected to be sent back to the upstream facilities.

7) Can you provide an estimate for the number of operators (FTEs) would be required to operate each system?  Please

note that EPA will already be including operators for the chemical precipitation system and the GE ABMet system. It is

no need of a full time operator for the MBBR system. The operator of other system can spend part of their time to take

care of MBBR system. MBBR is a very robust system.

8) Do you have any estimate for the amount of maintenance labor that may be needed during a typical year? Same to

above.

9) Do you have any estimate for the cost of maintenance materials that may be needed during a typical year?

Consider 1 to 2% of the installation cost.

Thanks again for all your help!

TJ
3

From: An, Li [mailto:li.an@veolia.com] 

Sent: Monday, July 21, 2014 6:24 PM 

To: Thomas Finseth 

Cc: Wessman, Flemming; Caroline Dale; Thomson, Chris 

Subject: Re: Denitrification System Costs for EPA

 

Hi Thomas, 

 

Below is what I have for you for the three options we estimated for you. If you have any questions please let me 

know. Thanks! 

The operation costs seem very high for this system. 

 

 

Design Basis

Influent Data

N-NO3 concentration 175 mg/l 

N-NO2 concentration 0 mg/l 

COD concentration 20 mg/l 

Inlet DO concentration 1 mg/l 

Temperature C 35 °C 

Effluent Data

Discharge N-NO3 concentration 100 mg/l 

Target N-NO3 conc for MBBR 

design 50 mg/l 

 

Design flowrates:

Option 1 – 100 gpm 

Option 2 – 500 gpm 

Option 3 – 1,000 gpm 

 

Process Assumptions
4

- influent is temperature controlled to 35C +/- 2C 

-pH is controlled with a range of 6.5 to 8.5 

-The nitrate concentration of 175 mg/l was expressed as N 

-The nitrate concentration limit of 100 mg/l was expressed as N and will be achieved as a maximum value 

(design to achieve average of 50 mg/l N-NO3) 

-Carbon dosing is based on Micro C - methanol or other suitable carbon sources may be used. In such case, the 

sludge production should be revised accordingly 

- Metals have been removed prior to biological treatment to ensure that the influent to the MBBR is not toxic to 

biological activity 

 

Design Summary

Veolia	proposed	three	options	for	ERG.	Option	one	is	with	a	design	flowrate	of	100	gpm;	option	2	with	a	

design	flowrate	of	500	gpm;	and	option	3	with	a	design	flowrate	of	1,000	gpm.	Each	option	contains	one	

MBBR	denitrification	tank	followed	by	a	discfiter	(option	2	and	3)/drumfilter	(option	1).	The	MBBR	

reactor	dimensions	for	option	1,	option	2	and	option	3	are	11’	Diameter	x	18’	SWD	(20’	SSH),	25’	

Diameter	x	16’	SWD	(18’	SSH),	and	22’	Diameter	x	20’	SWD	(22’	SSH),	respectively.	The	media	filling	

percentage	of	the	reactors	is	50%.	Micro	C	is	added	to	the	MBBR	tank	as	the	external	carbon	source.

The	discfilter/drumfilter	is	proposed	to	remove	85%	of	solids	from	the	MBBR	effluent.	

 

Estimated Prices

 

The	rough	order	of	magnitude	DB	prices	are	as	below:

 

Option	1:	design	flowrate		100	gpm	‐	$600,000		

Option	2:	design	flowrate	500	gpm	‐	$1,000,000

Option	3:	design	flowrate	1,000	gpm	‐	$1,500,000

 

The	price	includes	(same	scope	of	supply	for	each	option):

 One	(1)	MBBR	reactor	(1	x100%)
5

 AnoxKaldnes	Media

 Mixer

 Sieves

 Two	(2)	Micro	C	feed	pumps	(2	x	100%)

 One	(1)	Discfilter	(drumfilter)	package	(turn	key	ready)	(1	x	100%)

 One	(1)	pH	probe

 One	(1)	nitrate	probe

 One	(1)	level	sensor

 One	(1)	H3PO4	metering	pump	skid

 One	(1)	Polymer	feeding	system

 Start‐up	and	training

 Detailed	engineering

 Equipment	shipping,	unloading	and	installation

 Civil,	mechanical,	electrical,	instrumentation	and	controls

 Access	structure	(ladders,	platforms,	etc.)

 Performance	test

Estimated Chemical and Electrical Consumption

Estimated	chemical	consumption

Item

Consumed Amounts per Year Reference 

Option 1 Option 2 Option 3 rate

Phosphoric Acid (85%) 1,095 gal 6,205 gal 12,410 gal $0.63/Lb

Micro C 59,310 gal 296,535 gal 593065 gal $3.25/gal
6

Polymer for Discfilter/Drumfilter 

(emulsion, 30% active) 665 - 2,655 gal 3,320 - 13,265 gal 6,630 - 26,535 gal $3.4/Lb

Estimated	electrical	consumption

Item

Consumed Amounts per Year Reference 

Option 1 Option 2 Option 3 rate

Mixer (KWH/yr) 44,093 58,791 146,977 $0.08/KWH

Micro C feed pump (KWH/yr) 15 85 156 $0.08/KWH

H3PO4 metering pump 

(KWH/yr) 1 2 4 $0.08/KWH

Polymer feed system 

(KWH/Yr) 1 1 1 $0.08/KWH

Discfilter/Drumfilter (KWH/yr) 7,227* 54,049 91,192 $0.08/KWH

*Assumed	drumfilter	backwash	3	hours	per	day.

 

 

Li An, PhD

Process Engineer

WATER TECHNOLOGIES

 

office: +1-412-809-6673 / cell: +1-724-719-0130 / fax: +1-412-809-6512

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - USA

 

li.an@veolia.com

www.veoliawaterstna.com
7

 

 

 

On Tue, Jul 8, 2014 at 12:13 PM, Thomas Finseth <Thomas.Finseth@erg.com> wrote: 

Hi Caroline,

Thank you for taking the time to speak with me yesterday about the design for the MBBR system that we would like to

include in EPA’s analysis for the steam electric industry.  The following are the answers to the specific follow up items

that we discussed yesterday:

BOD Concentrations in FGD Wastewater: The typical FGD wastewater BOD concentrations that would be present in the

wastewater that would be sent to the MBBR would be approximately 10 mg/L.  There isn’t a lot of BOD in FGD

wastewater; therefore, you will need to account for feed to the system.  

Nitrate Concentrations in FGD Wastewater: I have confirmed from our data that the nitrate concentrations that I

provided in my previous email are Nitrate/Nitrite (as N).

TSS Concentration for ABMet system: I have confirmed in our documentation that the ABMet system for which GE used

as its design basis assumed a TSS concentration of less than 100 ppm.  I will note however, that based on their brochure,

GE claims to be able to handle up to 250 mg/L.  However, please assume that you will need a solid separation process

for the MBBR solids and that they will be transferred back to the solids holding tank in the upstream chemical

precipitation system.  Please also specify approximately how much solid waste will be generated at transferred back to

the solids holding tank so we can make sure that we size the solids holding tank and filter presses appropriately.

Nitrate Concentrations for ABMet system: I have confirmed that GE is only expects to need a separate denitrification

step to remove nitrate when the nitrate/nitrate (as N) concentrations exceed 100 ppm.  GE specifically wrote: “If NO3‐N

levels exceed 100 ppm, then we would consider a dedicated denitrification step ahead of the ABMet bioreactors.”

Please let me know if you have any questions or need any additional information.

Thanks again for your time and help.
8

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633‐1698 (phone)

(703) 263‐7479 (fax)

thomas.finseth@erg.com

From: Wessman, Flemming [mailto:flemming.wessman@veolia.com] 

Sent: Tuesday, July 01, 2014 5:18 PM 

To: Thomas Finseth; Caroline Dale; Li An 

Cc: Thomson, Chris 

Subject: Re: Denitrification System Costs for EPA

 

Hi Thomas 

 

I have been on the road for a week, I am in the office tomorrow after 2 pm, give me a call on 412 298 0145 

 

Best regards 

Flemming 

 

2014-07-01 10:26 GMT-04:00 Thomas Finseth <Thomas.Finseth@erg.com>: 

Hi Flemming,

I just wanted to follow up regarding this request.  As Chris mentioned, I’m trying to determine whether you would be

willing to help EPA generate an order of magnitude cost estimate for a power plant to install an MBBR system to

pretreat its FGD wastewater to remove nitrate/nitrate.  Because this is just an estimate, I’m hoping that it wouldn’t take

too much of your time.  If you’re willing, I would appreciate if we could have a call to discuss the type of information that

I would be looking for.  Are you available for a call this week?
9

Either way, please let me know whether you are willing to help.  If you aren’t willing to help, that’s fine, but I would like

to know as soon as possible so I can find another vendor that can help.

Thanks,

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633‐1698 (phone)

(703) 263‐7479 (fax)

thomas.finseth@erg.com

From: Thomson, Chris [mailto:chris.thomson@veolia.com] 

Sent: Wednesday, June 25, 2014 10:37 AM 

To: Flemming Wessman 

Cc: Thomas Finseth 

Subject: Fwd: Denitrification System Costs for EPA

 

Flemming: 

 

Would you please look at the attached email from TJ Finseth? TJ is with Eastern Research Group and he is 

working with EPA in determining cost curves for new treatment regulations. TJ is hopeful that someone with 

Veolia can help him with some preliminary costs for new effluent guidelines for steam electric plants. Not to 

"pass the buck," but since this is not municipal, this is out of Kruger's area of expertise. At this point, TJ would 

like to know if Veolia is willing and able to help his research group assemble cost information for EPA's study. 

 

I've copied TJ on this email. 

 

Chris 
10

 

Chris Thomson, P.E. (MD and NC)

Product Manager, AnoxKaldnes

Kruger Inc.

4001 Weston Parkway

Cary, North Carolina 27513

919-653-4562 direct

919-677-0082 fax

919-523-9260 mobile

chris.thomson@veolia.com

www.krugerusa.com

www.veoliawaterstna.com

Kruger Inc. is a subsidiary of Veolia Water Solutions & Technologies

Service ● Value ● Responsibility

 

---------- Forwarded message ---------- 

From: Thomas Finseth <Thomas.Finseth@erg.com> 

Date: 16 June 2014 16:34 

Subject: Denitrification System Costs for EPA 

To: "chris.thomson@veolia.com" <chris.thomson@veolia.com> 

Chris, 

 

As we discussed this afternoon, the following is a summary of the work I am currently doing with EPA and the 

information that we are hoping that you and Veolia can help us with. 

 

As I mentioned on the phone, I work for Eastern Research Group, which is a technical contractor to the EPA 

Office of Water, engineering and analysis division. We are supporting EPA with the revisions to the steam 

electric effluent limitations guidelines and standards (ELGs). The ELGs are technology-based limits that would 

apply to all steam electric power plants and would be incorporated into plants’ NPDES permits by the 

states/regions. EPA proposed revisions to the ELGs in June 2013. The following links contain information 

related the proposed rule and the technical development document that was prepared in support of the rule. 

 

http://water.epa.gov/scitech/wastetech/guide/steam-electric/proposed.cfm

 

http://water.epa.gov/scitech/wastetech/guide/steam-electric/upload/Steam-Electric_TDD_Proposedrule_2013.pdf
11

 

One of the main focuses of the rule is on flue gas desulfurization (FGD) wastewater. EPA is proposing to set 

limits for FGD wastewater based on a chemical precipitation and biological treatment system (based on the GE 

ABMet system). EPA’s proposal would set limits for arsenic, mercury, selenium, and nitrate/nitrite for FGD 

wastewater. The reason I’m getting in touch with you is because as part of the public comment period, industry 

argues that the costs EPA estimated for the rule are underestimated because some plants have high nitrate 

concentrations in untreated FGD wastewater, and therefore would need more retention time in the bioreactor 

than what was assumed in the cost estimate. We had an initial discussion with GE and they suggested that 

instead of costing plants with high nitrate/nitrite in the influent for additional residence time in the ABMet 

system, it would be more cost effective to send the water to a denitrification system to remove the nitrate/nitrite 

prior to treating it in the ABMet system. GE suggested that we talk with you regarding your MBBR system. 

 

Therefore, what I am looking for would be a way to estimate the capital and O&M costs for an MBBR system 

for multiple flow rates, such that I could generate a cost curve to apply to the industry. The two plants that we 

are using as the basis for the high nitrate/nitrite concentrations have the following characteristics (note: we have 

characterization data for additional pollutants if needed): 

 

Plant Minimum 

Nitrate/Nitrite 

Concentration (ppm) 

Maximum 

Nitrate/Nitrite 

Concentration (ppm) 

Average 

Nitrate/Nitrite 

Concentration (ppm) 

Plant 1 83 150 124 

Plant 2 150 220 174 

The goal of this MBBR system would be to reduce the nitrate/nitrite concentrations to below 100 ppm, because 

that is the basis for the design of the ABMet system used in EPA’s cost methodology. So once we got the 

concentration to below 100 ppm, it should be low enough for the ABMet system to handle and reduce down to 

the levels required by the rule. 

 

I appreciate you taking the time to talk with me and help investigate this. Please let me know if you have any 

questions or want to talk further about the rule or exactly what I would need from you. 

 

Thanks, 

 

TJ Finseth 

ERG

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

(703) 633-1698 (phone) 
12

(703) 263-7479 (fax) 

thomas.finseth@erg.com

 

 

 

************************************************************************* 

This e-mail message and any attachments to it are intended only for the 

named recipients and may contain confidential information. If you are not 

one of the intended recipients, please do not duplicate or forward this 

e-mail message and immediately delete it from your computer. If you 

received this email in error, please notify postmaster@veoliawater.com

*************************************************************************

 

-- 

Flemming G. Wessman

Vice President, Sales & Marketing, Industrial Projects

WATER TECHNOLOGIES

 

off.: +1-412-809-6173 / cell: +1-412-298-0145 / fax: +1-412-809-6512

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - USA

 

www.veoliawaterstna.com

 

 
13

************************************************************************* 

This e-mail message and any attachments to it are intended only for the 

named recipients and may contain confidential information. If you are not 

one of the intended recipients, please do not duplicate or forward this 

e-mail message and immediately delete it from your computer. If you 

received this email in error, please notify postmaster@veoliawater.com

*************************************************************************

 

************************************************************************* 

This e-mail message and any attachments to it are intended only for the 

named recipients and may contain confidential information. If you are not 

one of the intended recipients, please do not duplicate or forward this 

e-mail message and immediately delete it from your computer. If you 

received this email in error, please notify postmaster@veoliawater.com

*************************************************************************

************************************************************************* 

This e-mail message and any attachments to it are intended only for the 

named recipients and may contain confidential information. If you are not 

one of the intended recipients, please do not duplicate or forward this 

e-mail message and immediately delete it from your computer. If you 

received this email in error, please notify postmaster@veoliawater.com

*************************************************************************
1

Danielle Lewis

From: An, Li [li.an@veolia.com]

Sent: Friday, August 08, 2014 3:05 PM

To: Chuck Blumenschein

Cc: Thomas Finseth; Danielle Lewis; Carl Bender; Flemming Wessman

Subject: Re: Denitrification System Costs for EPA

Hi Thomas, 

Here are the estimated Design, Bid, Build ranges: 

Option one - 100 gpm

mid range $650,000; upper range (+30%) $850,000 

Option two - 500 gpm

mid range $1,550,000; upper range (+30%) $2,000,000 

Option three - 1,000 gpm

mid range $2,300,000; upper range (+30%) $3,000,000 

For rough budget, equipment cost could be 35 - 55% of the installation cost based on our experience. 

I will answer your other questions in another email. 

Li An, PhD

Process Engineer

WATER TECHNOLOGIES

office: +1-412-809-6673 / cell: +1-724-719-0130 / fax: +1-412-809-6512 

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - USA 

 

li.an@veolia.com 

www.veoliawaterstna.com

Right-click here t

pictures. To help

privacy, Outlook

auto matic downlo

picture from the 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

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2

From: Chuck Blumenschein [mailto:chuck.blumenschein@veolia.com] 

Sent: Wednesday, August 06, 2014 3:01 PM 

To: Thomas Finseth 

Cc: Li An; Danielle Lewis; Carl Bender 

Subject: Re: Denitrification System Costs for EPA

 

Sorry. That would be too much effort. If you would like to subcontract us to conduct a detailed 

cost estate we would be pleased to assist you. 

Sent from my iPhone 

On Aug 6, 2014, at 2:54 PM, Thomas Finseth <Thomas.Finseth@erg.com> wrote: 

Chuck,

Thank you for providing the additional information regarding the difference between

design/build and design, bid, build.

I would like to ask two favors of you.

1) When you provide the additional information, can you please provide as much

detail regarding your assumptions as possible?  For example, could you provide line

item costs, including things like, purchased equipment, installation, engineering, etc.  

That will help us get a better understanding of what costs you have included in your

estimates.

2) I will be on vacation next week, so if you could copy Danielle Lewis on the delivery

(copied on this email too) that would allow us to start looking at the information

before I’m back the following week.

Thanks again for your help.

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633‐1698 (phone)

(703) 263‐7479 (fax)

thomas.finseth@erg.com
3

From: Blumenschein, Chuck [mailto:chuck.blumenschein@veolia.com] 

Sent: Tuesday, August 05, 2014 3:37 PM 

To: Thomas Finseth 

Cc: Li An 

Subject: Fwd: Denitrification System Costs for EPA

 

TJ: 

 

there are a number of good references on the web about DB vs. conventional 

design, bid, and build. Typically, the power industry uses consulting firms to 

conduct detailed engineering design and then follows the path of the design, bid, 

build model. The costs for this approach are typically high than a DB approach. 

 We will send you a range of estimates following the conventional design, bid, 

build approach by early next week. 

 

http://thedesignbuildblog.wordpress.com/2010/08/02/design-build-vs-designbid-build/

 

 

http://en.wikipedia.org/wiki/Design%E2%80%93build

 

 

 

 

Chuck

Charles D. Blumenschein, P.E., BCEE

Technical Director, Industrial Projects

WATER TECHNOLOGIES
4

 

office: +1-412-809-6660 / cell: +1-412-596-2346 / fax: +1-412-809-6111

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - 

USA

 

chuck.blumenschein@veolia.com

www.veoliawaterstna.com

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

http://www.youtube.com/watc

h?v=SuogoqkrZ4&list=PLB1997A16C1918473

 

 

 

---------- Forwarded message ---------- 

From: An, Li <li.an@veolia.com> 

Date: Tue, Aug 5, 2014 at 2:33 PM 

Subject: Fwd: Denitrification System Costs for EPA 

To: Chuck Blumenschein <chuck.blumenschein@veolia.com> 

please see below. I just tell him when he can expect the response. 

 

Li An, PhD

Process Engineer

WATER TECHNOLOGIES

 

office: +1-412-809-6673 / cell: +1-724-719-0130 / fax: +1-412-809-6512
5

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - 

USA

 

li.an@veolia.com

www.veoliawaterstna.com

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

---------- Forwarded message ---------- 

From: An, Li <li.an@veolia.com> 

Date: Thu, Jul 31, 2014 at 3:27 PM 

Subject: Re: Denitrification System Costs for EPA 

To: Thomas Finseth <Thomas.Finseth@erg.com> 

Hi Thomas, 

 

I will be off tomorrow. Will answer your questions early next week or by end of 

next week. Below are answers to question 2 &4. 

 

DB represents Design & Build 

Specific gravity of 85% H3PO4 is 1.685 

 

Li An, PhD

Process Engineer

WATER TECHNOLOGIES
6

 

office: +1-412-809-6673 / cell: +1-724-719-0130 / fax: +1-412-809-6512

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - 

USA

 

li.an@veolia.com

www.veoliawaterstna.com

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

Right-click here to download 

pictures. To help protect your 

privacy, Outlook prevented 

auto matic downlo ad o f this 

picture from the Internet.

 

On Thu, Jul 31, 2014 at 3:06 PM, Thomas Finseth <Thomas.Finseth@erg.com> 

wrote: 

Hi Li,

Thank you so much for the costing information that you provided.  We are working on

incorporating it into our estimated costs and have identified a few follow‐up

questions.  We would appreciate your input on these follow‐up questions so we have

appropriate documentation.

1) Do you consider the provided costs (or any information provided in the email

below) as confidential business information (CBI)?  If so, we will not release the

costs/information to the public.  Otherwise, these costs will be made available to the

public when EPA finalizes the rule. If you do consider the information as CBI, please

identify the specific costs/information that you consider CBI.

2) In your email, you stated “the rough order of magnitude DB prices are as below.”

What does “DB” represent?  Are the costs you provided an annualized cost?  Or do

they represent a capital cost for the system?  Ultimately, it would be preferable for us

to receive a total capital cost for the system.
7

3) Are there any cost elements that are not included in the costs provided?  The

following are the types of costs that we have included in our estimates for other

systems.  Please identify whether any of these should be added to the costs that you

provided:

a. Installation

b. Buildings

c. Site prep

d. Engineering

e. Construction

f. Other contractor fees

4) What is the density of the 85% phosphoric acid?  We need this to calculate the

total chemical costs based on the gallons consumed and price in $/lb.

5) What is the density of the polymer for Discfilter/Drumfilter? We need this to

calculate the total chemical costs based on the gallons consumed and price in $/lb.

6) Based on the design for each sized system, how much wastewater and how much

solids would be expected to be transferred back to the upstream chemical

precipitation treatment system for additional processing?

7) Can you provide an estimate for the number of operators (FTEs) would be required

to operate each system?  Please note that EPA will already be including operators for

the chemical precipitation system and the GE ABMet system.

8) Do you have any estimate for the amount of maintenance labor that may be

needed during a typical year?

9) Do you have any estimate for the cost of maintenance materials that may be

needed during a typical year?

Thanks again for all your help!

TJ

From: An, Li [mailto:li.an@veolia.com] 

Sent: Monday, July 21, 2014 6:24 PM 

To: Thomas Finseth 

Cc: Wessman, Flemming; Caroline Dale; Thomson, Chris 

Subject: Re: Denitrification System Costs for EPA

 
8

Hi Thomas, 

 

Below is what I have for you for the three options we estimated for you. If you 

have any questions please let me know. Thanks! 

The operation costs seem very high for this system. 

 

 

Design Basis

Influent Data

N-NO3 concentration 175 mg/l 

N-NO2 concentration 0 mg/l 

COD concentration 20 mg/l 

Inlet DO concentration 1 mg/l 

Temperature C 35 °C 

Effluent Data

Discharge N-NO3 concentration 100 mg/l 

Target N-NO3 conc for MBBR 

design 50 mg/l 

 

Design flowrates:

Option 1 – 100 gpm 

Option 2 – 500 gpm 

Option 3 – 1,000 gpm 

 

Process Assumptions

- influent is temperature controlled to 35C +/- 2C 

-pH is controlled with a range of 6.5 to 8.5 

-The nitrate concentration of 175 mg/l was expressed as N 
9

-The nitrate concentration limit of 100 mg/l was expressed as N and will be 

achieved as a maximum value (design to achieve average of 50 mg/l N-NO3) 

-Carbon dosing is based on Micro C - methanol or other suitable carbon sources 

may be used. In such case, the sludge production should be revised accordingly 

- Metals have been removed prior to biological treatment to ensure that the 

influent to the MBBR is not toxic to biological activity 

 

Design Summary

Veolia	proposed	three	options	for	ERG.	Option	one	is	with	a	design	flowrate	

of	100	gpm;	option	2	with	a	design	flowrate	of	500	gpm;	and	option	3	with	a	

design	flowrate	of	1,000	gpm.	Each	option	contains	one	MBBR	

denitrification	tank	followed	by	a	discfiter	(option	2	and	3)/drumfilter	

(option	1).	The	MBBR	reactor	dimensions	for	option	1,	option	2	and	option	

3	are	11’	Diameter	x	18’	SWD	(20’	SSH),	25’	Diameter	x	16’	SWD	(18’	SSH),	

and	22’	Diameter	x	20’	SWD	(22’	SSH),	respectively.	The	media	filling	

percentage	of	the	reactors	is	50%.	Micro	C	is	added	to	the	MBBR	tank	as	the	

external	carbon	source.

The	discfilter/drumfilter	is	proposed	to	remove	85%	of	solids	from	the	

MBBR	effluent.	

 

Estimated Prices

 

The	rough	order	of	magnitude	DB	prices	are	as	below:

 

Option	1:	design	flowrate		100	gpm	‐	$600,000		

Option	2:	design	flowrate	500	gpm	‐	$1,000,000

Option	3:	design	flowrate	1,000	gpm	‐	$1,500,000

 

The	price	includes	(same	scope	of	supply	for	each	option):

 One	(1)	MBBR	reactor	(1	x100%)

 AnoxKaldnes	Media
10

 Mixer

 Sieves

 Two	(2)	Micro	C	feed	pumps	(2	x	100%)

 One	(1)	Discfilter	(drumfilter)	package	(turn	key	ready)	(1	x	100%)

 One	(1)	pH	probe

 One	(1)	nitrate	probe

 One	(1)	level	sensor

 One	(1)	H3PO4	metering	pump	skid

 One	(1)	Polymer	feeding	system

 Start‐up	and	training

 Detailed	engineering

 Equipment	shipping,	unloading	and	installation

 Civil,	mechanical,	electrical,	instrumentation	and	controls

 Access	structure	(ladders,	platforms,	etc.)

 Performance	test

Estimated Chemical and Electrical Consumption

Estimated	chemical	consumption

Item

Consumed Amounts per Year Reference 

Option 1 Option 2 Option 3 rate

Phosphoric Acid (85%) 1,095 gal 6,205 gal 12,410 gal $0.63/Lb

Micro C 59,310 gal 296,535 gal 593065 gal $3.25/gal

Polymer for Discfilter/Drumfilter 

(emulsion, 30% active) 665 - 2,655 gal 3,320 - 13,265 gal 6,630 - 26,535 gal $3.4/Lb
11

Estimated	electrical	consumption

Item

Consumed Amounts per Year Reference 

Option 1 Option 2 Option 3 rate

Mixer (KWH/yr) 44,093 58,791 146,977 $0.08/KWH

Micro C feed pump (KWH/yr) 15 85 156 $0.08/KWH

H3PO4 metering pump 

(KWH/yr) 1 2 4 $0.08/KWH

Polymer feed system 

(KWH/Yr) 1 1 1 $0.08/KWH

Discfilter/Drumfilter (KWH/yr) 7,227* 54,049 91,192 $0.08/KWH

*Assumed	drumfilter	backwash	3	hours	per	day.

 

 

Li An, PhD

Process Engineer

WATER TECHNOLOGIES

 

office: +1-412-809-6673 / cell: +1-724-719-0130 / fax: +1-412-809-6512

250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - 

USA

 

li.an@veolia.com

www.veoliawaterstna.com

 
12

<image001.jpg>

<image002.jpg> <image003.jpg> <image004.jpg>

 

On Tue, Jul 8, 2014 at 12:13 PM, Thomas Finseth <Thomas.Finseth@erg.com> 

wrote: 

Hi Caroline,

Thank you for taking the time to speak with me yesterday about the design for the

MBBR system that we would like to include in EPA’s analysis for the steam electric

industry.  The following are the answers to the specific follow up items that we

discussed yesterday:

BOD Concentrations in FGD Wastewater: The typical FGD wastewater BOD

concentrations that would be present in the wastewater that would be sent to the

MBBR would be approximately 10 mg/L.  There isn’t a lot of BOD in FGD wastewater;

therefore, you will need to account for feed to the system.  

Nitrate Concentrations in FGD Wastewater: I have confirmed from our data that the

nitrate concentrations that I provided in my previous email are Nitrate/Nitrite (as N).

TSS Concentration for ABMet system: I have confirmed in our documentation that the

ABMet system for which GE used as its design basis assumed a TSS concentration of

less than 100 ppm.  I will note however, that based on their brochure, GE claims to be

able to handle up to 250 mg/L.  However, please assume that you will need a solid

separation process for the MBBR solids and that they will be transferred back to the

solids holding tank in the upstream chemical precipitation system.  Please also specify

approximately how much solid waste will be generated at transferred back to the

solids holding tank so we can make sure that we size the solids holding tank and filter

presses appropriately.

Nitrate Concentrations for ABMet system: I have confirmed that GE is only expects to

need a separate denitrification step to remove nitrate when the nitrate/nitrate (as N)

concentrations exceed 100 ppm.  GE specifically wrote: “If NO3‐N levels exceed 100

ppm, then we would consider a dedicated denitrification step ahead of the ABMet

bioreactors.”
13

Please let me know if you have any questions or need any additional information.

Thanks again for your time and help.

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633‐1698 (phone)

(703) 263‐7479 (fax)

thomas.finseth@erg.com

From: Wessman, Flemming [mailto:flemming.wessman@veolia.com] 

Sent: Tuesday, July 01, 2014 5:18 PM 

To: Thomas Finseth; Caroline Dale; Li An 

Cc: Thomson, Chris 

Subject: Re: Denitrification System Costs for EPA

 

Hi Thomas 

 

I have been on the road for a week, I am in the office tomorrow after 2 pm, give 

me a call on 412 298 0145 

 

Best regards 

Flemming 

 

2014-07-01 10:26 GMT-04:00 Thomas Finseth <Thomas.Finseth@erg.com>: 

Hi Flemming,

I just wanted to follow up regarding this request.  As Chris mentioned, I’m trying to

determine whether you would be willing to help EPA generate an order of magnitude

cost estimate for a power plant to install an MBBR system to pretreat its FGD
14

wastewater to remove nitrate/nitrate.  Because this is just an estimate, I’m hoping that

it wouldn’t take too much of your time.  If you’re willing, I would appreciate if we could

have a call to discuss the type of information that I would be looking for.  Are you

available for a call this week?

Either way, please let me know whether you are willing to help.  If you aren’t willing to

help, that’s fine, but I would like to know as soon as possible so I can find another

vendor that can help.

Thanks,

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633‐1698 (phone)

(703) 263‐7479 (fax)

thomas.finseth@erg.com

From: Thomson, Chris [mailto:chris.thomson@veolia.com] 

Sent: Wednesday, June 25, 2014 10:37 AM 

To: Flemming Wessman 

Cc: Thomas Finseth 

Subject: Fwd: Denitrification System Costs for EPA

 

Flemming: 

 

Would you please look at the attached email from TJ Finseth? TJ is with Eastern 

Research Group and he is working with EPA in determining cost curves for new 

treatment regulations. TJ is hopeful that someone with Veolia can help him with 

some preliminary costs for new effluent guidelines for steam electric plants. Not 

to "pass the buck," but since this is not municipal, this is out of Kruger's area of 

expertise. At this point, TJ would like to know if Veolia is willing and able to 

help his research group assemble cost information for EPA's study. 
15

 

I've copied TJ on this email. 

 

Chris 

 

Chris Thomson, P.E. (MD and NC)

Product Manager, AnoxKaldnes

Kruger Inc.

4001 Weston Parkway

Cary, North Carolina 27513

919-653-4562 direct

919-677-0082 fax

919-523-9260 mobile

chris.thomson@veolia.com

www.krugerusa.com

www.veoliawaterstna.com

Kruger Inc. is a subsidiary of Veolia Water Solutions & Technologies

Service ● Value ● Responsibility

 

---------- Forwarded message ---------- 

From: Thomas Finseth <Thomas.Finseth@erg.com> 

Date: 16 June 2014 16:34 

Subject: Denitrification System Costs for EPA 

To: "chris.thomson@veolia.com" <chris.thomson@veolia.com> 

Chris, 

 

As we discussed this afternoon, the following is a summary of the work I am 

currently doing with EPA and the information that we are hoping that you and 

Veolia can help us with. 

 

As I mentioned on the phone, I work for Eastern Research Group, which is a 

technical contractor to the EPA Office of Water, engineering and analysis 

division. We are supporting EPA with the revisions to the steam electric effluent 

limitations guidelines and standards (ELGs). The ELGs are technology-based 

limits that would apply to all steam electric power plants and would be 

incorporated into plants’ NPDES permits by the states/regions. EPA proposed 
16

revisions to the ELGs in June 2013. The following links contain information 

related the proposed rule and the technical development document that was 

prepared in support of the rule. 

 

http://water.epa.gov/scitech/wastetech/guide/steam-electric/proposed.cfm

 

http://water.epa.gov/scitech/wastetech/guide/steam-electric/upload/SteamElectric_TDD_Proposed-rule_2013.pdf

 

One of the main focuses of the rule is on flue gas desulfurization (FGD) 

wastewater. EPA is proposing to set limits for FGD wastewater based on a 

chemical precipitation and biological treatment system (based on the GE ABMet 

system). EPA’s proposal would set limits for arsenic, mercury, selenium, and 

nitrate/nitrite for FGD wastewater. The reason I’m getting in touch with you is 

because as part of the public comment period, industry argues that the costs EPA 

estimated for the rule are underestimated because some plants have high nitrate 

concentrations in untreated FGD wastewater, and therefore would need more 

retention time in the bioreactor than what was assumed in the cost estimate. We 

had an initial discussion with GE and they suggested that instead of costing 

plants with high nitrate/nitrite in the influent for additional residence time in the 

ABMet system, it would be more cost effective to send the water to a 

denitrification system to remove the nitrate/nitrite prior to treating it in the 

ABMet system. GE suggested that we talk with you regarding your MBBR 

system. 

 

Therefore, what I am looking for would be a way to estimate the capital and 

O&M costs for an MBBR system for multiple flow rates, such that I could 

generate a cost curve to apply to the industry. The two plants that we are using 

as the basis for the high nitrate/nitrite concentrations have the following 

characteristics (note: we have characterization data for additional pollutants if 

needed): 

 

Plant Minimum 

Nitrate/Nitrite 

Concentration (ppm) 

Maximum 

Nitrate/Nitrite 

Concentration (ppm) 

Average 

Nitrate/Nitrite 

Concentration (ppm) 

Plant 1 83 150 124 

Plant 2 150 220 174 

The goal of this MBBR system would be to reduce the nitrate/nitrite 

concentrations to below 100 ppm, because that is the basis for the design of the 
17

ABMet system used in EPA’s cost methodology. So once we got the 

concentration to below 100 ppm, it should be low enough for the ABMet system 

to handle and reduce down to the levels required by the rule. 

 

I appreciate you taking the time to talk with me and help investigate this. Please 

let me know if you have any questions or want to talk further about the rule or 

exactly what I would need from you. 

 

Thanks, 

 

TJ Finseth 

ERG

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

(703) 633-1698 (phone) 

(703) 263-7479 (fax) 

thomas.finseth@erg.com

 

 

 

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Flemming G. Wessman

Vice President, Sales & Marketing, Industrial Projects
18

WATER TECHNOLOGIES

 

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250 Airside Drive - Airside Business Park - Moon Township, PA 15108 - 

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www.veoliawaterstna.com

 

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received this email in error, please notify postmaster@veoliawater.com

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