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

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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.com13 *************************************************************************

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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

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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

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

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