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 es timated 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 gpm2 

### 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 - meth anol or other suitable carbon sources may be used. In such case, the

sludge production should be revised accordingly

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

biological activity

Design Summary

Veolia	proposed	three	options	fo r	ERG.	Option	one	is	with	a	des ign	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	followe d	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),	a nd	22’	Diameter	x	20’	SWD	(22’	S SH),	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	f rom	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	‐ $1,500,0003 

### 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	1 00%)

 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

rate Option 1 Option 2 Option 34 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

rate Option 1 Option 2 Option 3



### 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.com6 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 att ached email from TJ Finseth? TJ is with Eastern Research Group and he is

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

Veolia can help him with some preliminary costs for ne w 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 & Technologies8 

### 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 summar y 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 Resear ch Group, which is a technica l contractor to the EPA

Office of Water, engineeri ng and analysis division. We are supporti ng EPA with the revisions to the steam

electric effluent limitations guidelines a nd standards (ELGs). The ELGs are technology- b ased limits that would

apply to all steam electric power pl ants 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 t echnical development document that wa s prepared in support of the rule.

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

http://water.epa.gov/scitech/waste tech/guide/steam-electric/uplo ad/Steam-Electric_TDD_Proposedrule_2013.pdf

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

limits for FGD wastewater based on a chemical precipita tion and biological treatmen t system (based on the GE

ABMet system). EPA’s proposal would set limits for ar senic, mercury, selenium, an d 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 theref ore 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 n itrate/nitrite in the influent for a dditional 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 sy stem. 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 co uld generate a cost curve to apply to the industry. The two plants that we

are using as the basis for the high nitr ate/nitrite concentrations have the fo llowing characteristic s (note: we have

characterization data for addi tional 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 n itrate/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 sy stem 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 confi dential 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 confi dential 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 confi dential 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

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### 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 be2 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!

TJ3 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 es timated 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 Assumptions4 

### - 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 - meth anol or other suitable carbon source s may be used. In such case, the

sludge production should be revised accordingly

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

biological activity

Design Summary

Veolia	proposed	three	options	fo r	ERG.	Option	one	is	with	a	des ign	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	followe d	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),	a nd	22’	Diameter	x	20’	SWD	(22’	S SH),	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	f rom	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	1 00%)

 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

rate Option 1 Option 2 Option 3

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/gal6 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

rate Option 1 Option 2 Option 3



### 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.com7 

### 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 att ached email from TJ Finseth? TJ is with Eastern Research Group and he is

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

Veolia can help him with some preliminary costs for ne w 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.

Chris10 

### 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 summar y 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 Resear ch Group, which is a technica l contractor to the EPA

Office of Water, engineeri ng and analysis division. We are supporti ng EPA with the revisions to the steam

electric effluent limitations guidelines a nd standards (ELGs). The ELGs are technology- b ased limits that would

apply to all steam electric power pl ants 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 t echnical development document that wa s prepared in support of the rule.

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

http://water.epa.gov/scitech/waste tech/guide/steam-electric/uplo ad/Steam-Electric_TDD_Proposedrule_2013.pdf11 

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

limits for FGD wastewater based on a chemical precipita tion and biological treatmen t system (based on the GE

ABMet system). EPA’s proposal would set limits for ar senic, mercury, selenium, an d 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 theref ore 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 n itrate/nitrite in the influent for a dditional 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 sy stem. 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 co uld generate a cost curve to apply to the industry. The two plants that we

are using as the basis for the high nitr ate/nitrite concentrations have the fo llowing characteristic s (note: we have

characterization data for addi tional 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 n itrate/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 sy stem 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 confi dential 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.com13 *************************************************************************

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

named recipients and may contain confi dential 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 confi dential 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 confi dential 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 ques tions 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

picture from the Internet.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 subc ontract 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.com3 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 go od 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 TECHNOLOGIES4 

### 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: Denitrifica tion 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: +1-412-809-65125 

### 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 que stions 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 TECHNOLOGIES6 

### 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 EPA8 

### 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 N9 

### -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 - metha nol or other suitable carbon sources

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

- Metals have been removed prior to bi ological treatment to ensure that the

influent to the MBBR is not toxic to biological activity

Design Summary

Veolia	proposed	three	options	fo r	ERG.	Option	one	is	with	a	des ign	flowrate

of	100	gpm;	option	2	with	a	des ign	flowrate	of	500	gpm;	and	opt ion	3	with	a

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

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

(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	f illing

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	f rom	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	Media10 

###  Mixer

 Sieves

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

 One	(1)	Discfilter	(drumfilter)	package	(turn	key	ready)	(1	x	1 00%)

 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

rate Option 1 Option 2 Option 3

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/Lb11 

### Estimated	electrical	consumption

Item Consumed Amounts per Year Reference

rate Option 1 Option 2 Option 3



### 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.com12 

### <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 FGD14 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 att ached 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 gui delines for steam electric plants. Not

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

expertise. At this point, TJ would like to know if Veo lia 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 V eolia 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 inform ation 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 proposed16 

### revisions to the ELGs in June 2013. Th e 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-el ectric/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 lim its for arsenic, mercury, selenium, and

nitrate/nitrite for FGD wast ewater. The reason I’m ge tting 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 w ith GE and they suggested that instead of costing

plants with high nitrate/nitr ite 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 n itrate/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 multip le flow rates, such that I could

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

as the basis for the high nitrate/nitr ite concentrations have the following

characteristics (note: we have characteriz ation 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 the17 

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

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

to handle and reduce down to th e levels requir ed 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 wa nt 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 Projects18 

### 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

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