Title: Determining and Estimating Wastewater Treatment Operating Costs
 1Determining and Estimating Wastewater Treatment 
Operating Costs
-  Identify your daily, weekly, monthly or 
annual generation of wastewater by several 
methods  - Measurements from instruments, e.g., flow meters, 
identifying a flow rate, usually 
gallons-per-minute (GPM)  - Identifying and itemizing potable water supply, 
for industrial uses, from your local utilitys 
billing statements  - Best estimate from historical operations and / or 
combination of 1 and 2 above  
  2Determining and Estimating Wastewater Treatment 
Operating Costs
-  Identify your waste treatment operating 
costs  - Acid, caustic, sulfide, magox, etc. Any and all 
materials or chemicals used solely in waste 
treatment need to be accounted and itemized.  - Additionally, itemize associated costs such as 
hazardous waste disposal, laboratory analysis, 
equipment repair, parts, filters, miscellaneous 
supplies, etc.  - Estimate, if possible, electricity consumption, 
in Kw/Hr., of your waste treatment equipment to 
derive a /KwHr. cost  
  3Determining and Estimating Wastewater Treatment 
Operating Costs
- Benefits 
 - Derivation of a unit cost, ideally in /gallon, 
representative of your wastewater treatment 
operations and a representative daily flow or 
discharge of wastewater, in gallons/day.  - Establishing a unit cost baseline that can be 
compared to existing wastewater discharge 
standards as a measure of performance / 
compliance.  - An accurate representation of your existing 
wastewater treatment costs that will enable 
refining and optimizing of your systems 
performance. 
  4Cost Itemization
-  Using a spreadsheet program, such as Excel, 
Lotus Notes, etc., will enable you to itemize and 
calculate operating cost data. In the following 
example, calendar year 2000 has been itemized by 
certain categories to identify and generate a 
/gallon cost as well as estimated gallons/day 
discharged. This data will be subsequently used 
to estimate operating costs for MPM compliance.  
  5Examples of cost itemization
Here you can see how monthly operating costs have 
been itemized along with wastewater information, 
including gallons per day. Monthly totals were 
obtained from daily flowmeter measurements and 
multiplied by the days worked. If flow meters 
are unavailable, estimates from industrial 
water billings can be used as an estimate. To 
obtain gallons per day from monthly totals, 
simply divide the monthly wastewater total by the 
number of days worked in the month. 
 6Examples of cost itemization
Once you obtain the total monthly operating costs 
and the monthly wastewater gallons, divide the 
total monthly dollar cost by the monthly gallons 
to obtain a /gallon cost. In the example above 
for January, 23,912 divided by 1,815,780 gallons 
equals a unit cost of 0.0132 / gallon. 
 7Additional costs itemization and cost assumptions
For purposes of estimating operating costs 
increases due to the MPM rule, on the assumption 
of recycling wastewater (instead of treatment  
discharge), careful identification of wastewater 
streams for recycling is paramount. For example, 
developer and stripper rinses are ideal 
candidates for recycling in that they are dilute 
and contain virtually no copper or other metal 
constituents. In the example above, capital costs 
of the additional microfiltration (MF) treatment 
/ recycling system for developer and stripper 
rinses have been identified and ammortized over 
60 months. This equates to a monthly cost of 
7273, which will be later applied to the overall 
operating costs. Additionally, monthly flow or 
volume of wastewater to be treated needs to be 
identified and added to the monthly ammortization 
costs for a subtotal cost for this application. 
 In this case 40 of the monthly total wastewater 
flow has been estimated and applied to this 
situation. The corresponding operating costs 
will later be added to the overall operating 
costs to determine the incremental cost of 
treatment. 
 8Additional costs itemization and cost assumptions
In this additional example, batch treatment costs 
need to be revised to reflect the incremental 
increase in chemicals and materials in response 
to the proposed MPM rule. Again, itemize those 
elements that are critical and in support of the 
batch treatment process. Depending on the 
historical performance of your individual batch 
treatment system, estimate the increase in 
material costs to be applied. 
 9For example, a 25 cost increase has been 
estimated for the batch treatment chemicals and 
materials. Consequently, we have taken the 
operating costs and applied a 1.25 factor in 
order to derive the estimated cost increases. In 
order to accurately account for wastewater, we 
have subtracted the amount recycled from 
developer and stripper rinses with the resulting 
number being the anticipated amounts for batch 
treatment as a result of the MPM rule. 
The total monthly incremental costs are derived 
by subtracting the estimated monthly costs, as 
stated above, from the original monthly operating 
costs. This incremental cost reflects additional 
batch treatment in order to comply with the 
proposed MPM rule. Diving this incremental cost 
by the volume of wastewater to be treated yields 
the unit cost (/gallon) for this application. 
 10Summary
All these /gallon numbers we have derived for 
the various components and assumptions from 
wastewater treatment operations will be summed to 
represent the total operating costs in /gallon. 
As you can see, we have itemized and summed the 
original operating costs, op costs for the MF 
unit and incremental treatment costs, all in 
/gallon, to derive an estimated treatment cost 
in response to the proposed MPM rule. 
 11Conclusion
MPM
This is the nitty-gritty of this exercise. We 
now have the necessary information to estimate 
what the cost of compliance will be for MPM. 
The remaining annual volume of wastewater 
represents the amount of wastewater requiring 
treatment mutiplied by the unit cost and adding 
the annual costs for the MF unit yields the 
annual operating costs. Comparing this number and 
subtracting it from the original operating costs 
will derive the incremental cost of compliance 
for MPM. You can see that our costs estimates 
for MPM compliance more than double the original 
or existing operating costs. This type of 
information is critical in that the EPA needs to 
understand and accept the financial impact this 
rule will have on the PCB industry. We urge you 
to develop your operating costs estimates in a 
similar fashion, with emphasis on operating 
costs, i.e., financial impact, for MPM 
compliance. Include this information with your 
formal comments to EPA  they will be MUCH MORE 
POWERFUL! 
 12When and Where To Send Written Comments
EPA must receive comments on the proposal by May 
3, 2001. Submit written comments to   By 
mail- Mr. Michael Ebner, Office of Water, 
Engineering and Analysis Division (4303) U.S. 
EPA 1200 Pennsylvania Ave., NW Washington, DC 
20460   By hand delivery (includes FedEx and 
UPS)- Mr. Michael Ebner U.S. EPA 401 M St., SW, 
Room 611 West Tower Washington, DC 20460   
 13Thank You!
By email- E-mail to mpm.comments_at_epa.gov Electroni
c comments must be identified by the docket 
number W-99-23 and must be submitted as an ASCII, 
or WordPerfect 5/6/7/8/9 or Microsoft Word 97 
file avoiding the use of special characters and 
any form of encryption. EPA also will accept 
comments and data on disks in Word Perfect 
5/6/7/8/9, Microsoft Word 97 or ASCII file 
format. Electronic comments on this notice may be 
filed online at some Federal Depository 
Libraries. Please submit any references cited in 
your comments. EPA requests an original and three 
copies of your comments and enclosures (including 
references). Commenter who want EPA to 
acknowledge receipt of their comments should 
enclose a self- addressed, stamped envelope. No 
facsimiles (faxes) will be accepted.