A presentation that I developed and was published during an annual IPC show.

5. Examples 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.

6. Examples 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.

7. Additional costs itemization and cost assumptions: For purposes of estimating operating costs increases due to the MP&M 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 [sub]total 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.

8. 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 MP&M 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. Additional costs itemization and cost assumptions:

9. For 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 MP&M 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 MP&M rule. Diving this incremental cost by the volume of wastewater to be treated yields the unit cost ($/gallon) for this application.

10. Summary: 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 MP&M rule.

11. Conclusion: This is the “nitty-gritty” of this exercise. We now have the necessary information to estimate what the cost of compliance will be for MP&M. 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 MP&M. You can see that our costs estimates for MP&M 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 MP&M compliance. Include this information with your formal comments to EPA – they will be MUCH MORE POWERFUL! MP&M

12. When 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

13. By email- E-mail to mpm .comments@ epa . gov Electronic 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. … Thank You!