## Water 

## &Process Technologies

Deborah Bartram VP, Water Programs 14555 Avion Parkway, Suite 200 Chantilly, VA, 20151 11 April, 2011

· Dear Ms. Bartram: James Harwood Industrial Sales Manager

- ABMet North America 3239 Dundas Street West Oakville ON L6M 4B2 Canada T905 465 3030 james.horwood@ge.com



### Note that any information contained within this letterthat is marked with 

# {.CBIL**-~onsidered** to be Confidential Business Information. This included both attachment graphs accompanying this letter. Thankyou for the opportunity to review the EPA costing methodology. In reviewing your memo of 22 March, 2011 and the previously submitted costing information related to the use ofthe ABMet® system in FGD applications, GE has revised the costing structure and the presented formatto better fit with the methodology. This methodology is only applicable for FGD applications as it tokes into accountthe specific nature of the water and typical requirements specific tothe power generation industry. Other applications, both within and outside of the power industry, should not use these equations. 

## 1 Cost Calculations Based on the attached curves contained with this letter, GE proposes the following structure modifications to the equations within the 22 March memo: Equipment Capital Cost=**_i~BJ-)** 

## __ _,__ Where: 

### y = Equipment capital cost in USD 

### x = 

### Design plant flow rate in gallons per minute (gpm)

Installation Capital Cost= 

### Equipment Capital Cost X Installed Cost Factor Where: Installed Cost Factor = 

### (C£,1) y = Installed Cost Factor as a percentage of Equipment Capital Cost 

### x =Design plant flow rote in gallons per minute (gpm) 

### (1)

[2)

(3)

### Heat exchanger costs have not been included in any of this workup. For operational costs. GE calculates the following: Nutrient Cost= 14) 

### Nutrient Cost per gallon X Nutrient Consumption 

### I 1000 X FGD scrubber flow lgpml X 60 (min/hrl X Operating hr/day X Operating days/year**~~~= ~**  

### Energy unit cost ($/kWh) X ABMet® Power Consumption 

### I 1000 X FGD scrubberflow (gpml X 60 (min/hrl X Operating hr/day X Operating days/year Labor Cost = 16) 

### Labor rate, $X/hour-worker X #ofworkers (FTEl X Operating hr/day X Operating days/year Materials Cost 

### = 17) 

### 0.111 X (Nutrient Cost 

### + Energy Cost 

### + Labor Cost) Where: Nutrient Consumption 

## = Nutrient cost per gallon 

## = ABMet® Consumption 

## = # wor""s IFTE)

# = Operation Bulk Nutrient Refill Sampling (estimated! Cell Backflush* Daily Plant Inspection Weekly Plant Walk down Nutrient consumption in gallons of nutrient per 1.000 gallons of water treated as per Section 2. Item 4 ofthis letter. ( GBI..)



### 0.36 kWh per 1.000 gallons ofwater treated as per Section 2. Item 5 ofthis letter. GE**recomm~nds** 

### calculation based on one (1) FTE as a requirement for the ABMft® system alone based on the following requirements: Frequency Duration Min worker# 1/month 2 hr 1 1/week 4 hr 1 varies 3 hr 1 daily 1 hr 1 weekly 2 hr 1 Monthly Plant Maintenance (probe monthly 1day 1 cleaning, etc) Weekly Estimate

- 18 hrs

## 2 System Design Basis

In response to the request from EPA for feedback regarding the ABMet® design basis. GE offers the following responses: 1. Design Basis for 2009 ABMet® FGD Installed Cost Curve a. Ifthe previously provided cost curve is no longer up to dote. please provide on updated cost curve. We would also like to convert the cost curve into on equation based on expected flow rote. If GE has already developed such on equation, please provide or comment on this approach. GE has provided an updated curve forthe GE supplied capitol equipment. Included withthis is on equation 

### to establish o GE supplied capital cost+/- 15% based on the design basis and theadditional information within this package. GE has also provided o curve with on associated equation forthe installation/balanceofplant portion ofon ABMet® facility. This curve will provide o percentage, which when multiplied bythe associated GE capitol costwill provide o costforthe balance ofplant/installation portion ofa given facility. Addition ofthe calculated GE equipmentcost plus thecalculated BOP/installation costwill yield on estimated total projectcapitol cost. This combined cost is estimated to be +/- 25%. These costs includethe some assumptions as the December 20091 curve otherthan the geographical limitation:

• Unionized contractor labor is assumed • No special seismic criteria ore incorporated • Costs ore based on executing project structureofconsortium between GE and contractor with balance ofplantengineering as o sub-contractor • Costs ore based on ABMet® system being on 'island' with integration into thefull power plantsystem no being included (e.g. DCS interfaces,tie-in with existing wastewater plant, etc. omitted) • Costs ore assuming integration ofABMet® system into largerwaste water facility, for example integratingABMet®following conventional physical/chemical treatmentwith ABMet® backwash waste recycled to conventional system for solids removal

1 "CBI ABMet® Cost Curve" Letter from J. Harwood GE to Sarah Holman ERG dated 17 December. 2009.-rhe general scope ofsupply (GE equipment+ installation) and construction basis remains unchanged from the previous submittal:

• All process pumps, valves, and instruments • Process & instrument compressed air system, valves and lines • Nutrientsystem, storagetank, pumping • All process piping and supports within the ABMet® 'island' • Process equipment building with HVAC (concrete floor, block structure with steel roof) • Concrete bioreactortankwalls and floor with epoxy-coated rebar and epoxyflake-glass coating • Concrete backwash supply and backwash wastetankwalls and floor with epoxy-coated rebar and epoxy flake-glass coating • Concrete process & utilitysump with pumps • Support steel, access stairs, walkways, grating, handrails • Engineering, commissioning and project management laborfor ABMet® 'island' • Construction equipment, materials and labor for ABMet® 'island' Furthermore,the revised curve included the same omissions as the previous submittal:

• Utilityoverhead and labor • Planttie-in/integration (e.g. DCS interface, feed water, effluentwater line to discharge, etc) • Pilings, caissons, etc • Permitting • Financing charges • Otherwaste water processes such as pre or post-treatment, dewatering • Backwash waste disposal/solids handling b. Please provide a description ofthe assumed system design used as the basis for the provided cost curve. For example, how many bioreactortrains are assumed, how many bioreactor cells are assumed per train, what is the design residence time through each bioreactor cell, etc.The costs are based upon thefollowing: • Feed waterquality provided by ERG2 • Numberoftrains used in this basis as well as the reactor size is variable as perthetable below given thewide range offlow rates being evaluated • Two-stage system li.e. 2 reactors in series per train) • Retention time used in this design basis, expressed as EBCT3
, is 10 hoursfor thetotal system, 5 hours per stage • Custom project using typical component specifications from existing facilities suitablefor FGD applications. 

### FlowRate Number

### ofTrains ReactorDimensions (ea} (gpm} W x L x H(feet}

50 2 8 X8 X24 100 2 11 X 11 X25 150 3 11 X 11 X25 200 4 11 X 11 X25 300 3 15 X 15 X26 400 4 15 X 15 X26 600 6 15 X 15 X26 800 8 15 X 15 X26 1000 10 15 X 15 X26



### c. Is the system design based on standard-sized bioreactor cells that are designed to receive a maximum flow rate through each cell and where additional trains are added to accommodate increased flow? What are the design and maximum flow rates for each bioreactor cell? What determines whether additional trains are needed? How do total capital costs vary between configurations? For all systems (not including the 50 and 100gpm systems), the designs are based on all trains operating optimally forthe design flow rate. In events such as backwashing.the piping sized so thatthe remaining bioreactors can accommodate thefull design flowoverthe briefduration ofthe backwash events or in the event thatan individual bioreactor is to betaken off-linefor servicewhile still maintaining performance.

2 ERG Memo to J. Harwood of GE dated 22 March, 2011. EPA DCN: SE00559.Cl. 3 EBCT = Empty Bed Contact Time. This is defined as the required reactor process volume/flow rate NOT including the displacement ofthe media. To compare this with previous correspondence using the term HRT (Hydraulic Retention Time). multiply the HRT by a foetor of2to arrive at EBCT.d. EPA is evaluating wastewater flow from 50 to 1,000 gpm and 10,000to 1,000,000 gpd. GE provided a cost curve based on gallons per day capacity (between 150,000 gpd and 1.450,000 gpdl. Are there significant changes to the costs below the flow range represented on the cost curve (i.e., can costs be extrapolated at flow less than the minimum)? With the revised curve, theflow range covered is from 50 gpm to 1,000 gpm. Extrapolation forvalues less than 50 gpm using the equations appears to bias high. Extrapolation using the equations toflows beyond 1,000 gpm has not been evaluated as partofthis submission.

e. EPA defines capital equipment as equipmentfor installation, mechanical or electrical, piping, instrumentation, spare parts, freight, taxes, and insurance. Capital installation costs including engineering costs, construction costs, and contractor's fees. Please confirm what specific cost components are included in the provided cost curve. Is the flush system (e.g., ·nush piping, pumps, and storage design spedficationsl included in the provided cost curve? GE's basis is similarto the EPA's definition with a few slight changes asthe process related engineering is included within the GE equipment scope. Insurance under the GE scope is only limitedto insurance carried by GE forGE supplied services/liability. Insurancecoverage such as builders' risk is included under installation. GE Capital Equipment Scope: • All pumps • All process valves • All process instruments • All reactor internals (media, biology, supplyand collection headers) • Nutrient dosing system including tank and first-fill • Compressed air system • Motor Control Center and PLC • Process engineering • Mechanical, electrical engineering forGE supplied portions of plant • Spare parts (initial supply) • Commissioning labor (GE supplied equipment)Installation Scope: • Pretreatment System (as required) • Unloading and storageofdelivered equipment at mutuallyagreed upon FOB point (assuming siteJ • Receiving and safe storage ofequipment atsite until readyfor installation • Equipment installation • Carbon media installation • Balance ofplantengineering • Civil works as required including building. equipmentfoundation (packed and level. concrete foundation) etc. • Plant utilities including compressed airdistribution • Equipmentaccess platforms,walkways, stairs etc. • All interconnecting piping between GEW&PT supplied skids/equipment • Electrical wiring interconnections between GEW&PT supplied skids/equipment (including wiring. conduitand otherappurtenances requiredto provide power connections as needed) from MCC tothe GEW&PT supplied motors orterminal boxes atthe GEW&PT supplied skid. • Equipmentanchor bolts • Waste Dewatering System (as required) • Waste disposal • Raw materials, chemicals. and utilities during equipmentstart-upand operation, unless otherwise specified. • All required permits • Supply oftelephone/fax/modem access while GE staffareon-site • Laboratory services, operating and maintenance personnel during equipment checkout. start-upand operation f. Does the capacity (in GPDI assume thatthe FGD operates 24 hours per day? What is the minimal operating period for the ABMet® system to ensure the viability ofthe bugs? Capacities assume 24 houra dayoperation. The ABMet® system is notdesignedto be operated in a batch mode, therefore, operations such as 12 hours a dayare not recommended. Equalization would be recommended to ensure as consistent operation as possible. There is no hard numberfor minimal operating period and such cases would have to be reviewed on an individual basis. likelythrough piloting.

### 2. Geographic Location. In past correspondence with EPA (January 19, 2008 and January 30, 2009), GE indicated that geographic location will affectthe overall design and cost of the ABMet® system. a. Facilities with ABMet® systems in place operate either open or closed bioreactor cells. What geographic factors will determine whether a plant should install open or closed bioreactors? How does GE scale the costs between open and closed systems? Please confirm the basis (open or closed) used for the costs represented in the 2009 cost curve. 

# ( CBT)

b. GE indicated that in colder climates, the system would need to be resized to accommodate for higher residence time. Please indicate how GE would define a "colder climate" and how this would affect the costs represented in the 2009 cost curve. Intheorythis is correctos a reduction intemperature will slowthe biological kinetics resulting in a requirement foran increased retention time in orderto achieve the same result. Development and validation work conducted since 2009 has verified thatthe retention time used in this costshould be sufficientfor 99%+ ofthe potential FGO installations inthe US. Therefore, the system should not need resizing.



### c. In the 2008 meeting with EPA, GE indicated that geographic location will affect the installation costs ofthe system. Howwill location impact the installation costs represented in equation (2) above? Individual State regulations and policies may have an impacton the installation costs. Some states/utilities do not require unionized laborfor example which could lowerthe installation portion. Others, like Pennsylvania, require the exclusive use ofsteel sourced in the US, which can be a premium depending on thetiming and the market. Given the numberofvariables, it is difficultto quantify any specific impacts.

### 3. Heat Exchangers. Has GE evaluated the use ofheat exchanges with the ABMet® technology to achieve on optimal operating temperature for the influent prior to entering the bioreoctors? GE has utilized heatexchangers within thetwa facilities at Duke Energy. In these cases, the heatexchanges were used as an insurance policy to ensure thatthefeed water temperature remained belowthe maximum operatingtemperature during the hottest months ofthe summer. They were used as a means ofmaintaining a consistentfeed water temperaturethroughouttheyear. Itis possible thatthey could be utilized tocontrol to a constantfeed temperatureyear-round, butthis function has not been evaluated atthis time.



### a. Does GE offer the heat exchangers as part ofa package? How do the costs relate to the overall capital costs ofthe ABMet® system? Are the costs of heat exchangers included in the 2009 cost curve? GE has notsupplied this equipmenttodate. Heat exchangers are not included within this cost curve. 

### b. What materials ofconstruction would be needed to conduct the heat transfer for FGD wastewater without scaling the equipment? The units used previouslywere oftitanium construction. It may be possible for an alternative material thatwill offersimilar performance at a reduced cost. A heat exchangervendorwould be ableto offerthe mostcomprehensive analysis ofthe options. 

### 4. Nutrient Costs. Does GE recommend that nutrients be continuously fed into the bioreactors to maintain bacteria regardless ofwhether the FGD scrubberwastewater is fed? Ifso. how does GE determine the minimal nutrientfeed rates during instances where FGD scrubber purge is not being fed into the system? Does GE have nutrient cost data in 

### $ per gallon of FGD scrubber wastewatertreated and/or in 

### $ per unit of nutrient added? GE recommends that nutrient is fed continuously during operation. During cases where the system is in stand-bywithout receiving feed water, nutrientwould only be dosed periodically everyfewdays as partofa maintenance mode. 

# ( CBl.) 

# ,.

# (col)

5. Energy Consumption. The energy costs are assumed primarily from the cost of pumping. EPA plans to include energy costs for heat exchanger operations. Can GE provide energy consumption data for operating the ABMet® system? Energy consumptions overthe range offlows do varysomewhat dueto some constants such as PLC power. Estimated power consumption forthe process includingABMet® pumps, instruments, compressor and controls (not including balance of plantcomponents such as HVAC, lighting, etc) ranges from 0.32 kWh/1,000 gal to 0.40 kWh/1,000 gal.



### Best Regards.

James Harwood Industrial Soles Manager

- ABMet

enc. GRAPH- ABMet® FGD GE Equipment Cost $US per Gallons per Minute Capacity GRAPH- ABMet® FGD Installation Cost Component as a % 

### of GE Equipment

# e**~ater** &Process Technologies 

### ABMet FGD GE Equipment Cost $US per Gallons per Minute Capacity- Water

### &

# ~:OCe~s Technologies 

### ABMet FGD Installation Cost Component as a% ofGE Equipment