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 be
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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
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- 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%)
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 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
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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

 

 

 

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-- 

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

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