## Form for Compliance with E.O. 12866 Docket Requirements

Title of Regulation: Water Quality Standards for the State of Florida’s Estuaries, Coastal Waters, and South Florida Inland Flowing Waters

Contact person: Erica Fleisig

Phone number: 202

- 566

- 1057

Was this regulation reviewed by OMB under Executive Order 12866

- Regulatory Planning
and Review ?

X Yes No

If you checked “no”, you are done with this form. Simply place it in the docket for your regulation. If you checked “yes”, please fill out the remainder of the form before placing it in the docket. Also docket any relevant documents referenced in the form.

For regulations th at are checked “Yes” above:

This regulation was reviewed by OMB under Executive Order 12866

- Regulatory Planning and
Review

.

Attached is the draft regulation and any other documents sent to OMB for review, such as analyses and assessments. E.O. 12866 requires agencies to make these publicly available.

E.O. 12866 also requires agencies to identify the substantive changes between the draft regulation sent to OMB for review and the reg ulation subsequently announced [ Please check the appropria te box below: ]

X EPA made substantive changes to this regulation (includes changes initiated by EPA or OMB). Attached is a document which: (1) identifies all the substantive changes made, and (2) notes those changes OMB suggested or recommended.

No substantive changes were made to this regulation Therefore, no f urther attachments are required

.

If you have questions about this regulation, please call the EPA contact person listed above.

## Economic Analysis of Proposed Water Quality Standards for the State of
Florida’s Estuaries, Coastal Waters , and South Florida Inland Flowing

Waters

January 201 2

Draft for Internal Review

– Do Not Quote or Cite

U.S. Environment al Protection Agency
Office of Water Office of Science and Technology 1200 Pennsylvania Avenue N.W. Washington, D.C. 20460January 2012 i

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  

## Table of Contents

Exe cutive Summary

................................ ................................ ................................ ................................ .... 1

1 Introduction

................................ ................................ ................................ ................................ ... 1

- 1

1.1 Requirement for the Proposed Rule

................................ ................................ ................................ . 1

- 1

1.2 Purpose and Scope of the Analysis

................................ ................................ ................................ .. 1

- 1

1.3 Organization of this Report

................................ ................................ ................................ ............. 1

- 2

2 Baseline for the Analysis

................................ ................................ ................................ ............... 2

- 1

2.1 Current Regulatory Framework

................................ ................................ ................................ ....... 2

- 1

2.1.1 Water Quality Standards

................................ ................................ ................................ ....... 2

- 1

2.1.2 Restoration of Designated Uses in Impaired Waters

................................ ............................ 2

- 3

2.1.3 Existing Regulations for Point Source Dischargers

................................ .............................. 2

- 4

2.1.4 Existing Regulations for Urban Areas

................................ ................................ .................. 2

- 6

2.1.5 Existing Requirements for Agriculture

................................ ................................ ................. 2

- 8

2.1.6 Existing Requirements for Forest ry

................................ ................................ .................... 2

- 13

2.1.7 Existing Requirements for Septic Systems

................................ ................................ ......... 2

- 13

2.1.8 Existing Requirements for Air Sources

................................ ................................ ............... 2

- 14

2.2 Existing Nutrient Discharges

................................ ................................ ................................ ......... 2

- 14

2.2.1 Wastewater Point Sources

................................ ................................ ................................ ... 2

- 14

2.2.2 Sto rmwater

................................ ................................ ................................ .......................... 2

- 16

2.2.3 Agriculture

................................ ................................ ................................ .......................... 2

- 17

2.2.4 Septic Systems

................................ ................................ ................................ .................... 2

- 17

2. 2.5 Atmospheric Deposition

................................ ................................ ................................ ..... 2

- 17

2.3 Current Water Quality Impairments

................................ ................................ .............................. 2

- 18

2.3.1 Category 5 Waters on State 303(d) List

................................ ................................ .............. 2

- 18

2.3.2 Nutrient TMDLs

................................ ................................ ................................ ................. 2

- 19

2.4 Summary of Assumptions and Uncertainties

................................ ................................ ................ 2

- 23

2.4.1 Regulatory Framework

................................ ................................ ................................ ....... 2

- 23

2.4.2 Sources of Nutrients

................................ ................................ ................................ ............ 2

- 24

2.4.3 Water Quality

................................ ................................ ................................ ...................... 2

- 25

3 Description of the Proposed Rule

................................ ................................ ................................ . 3

- 1

3.1 Proposed Criteria

................................ ................................ ................................ ............................. 3

- 1

3.1.1 Coastal Waters

................................ ................................ ................................ ...................... 3

- 1

3.1.2 Estuaries

................................ ................................ ................................ ................................ 3

- 1

3.1.3 South Florida Marine Waters

................................ ................................ ................................ 3

- 1

3.1.4 Down stream Protection Values

................................ ................................ ............................. 3

- 1January 2012 ii

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  3.1.5 Tidal Creeks

................................ ................................ ................................ .......................... 3

- 1

3.1.6 Marine Lakes

................................ ................................ ................................ ......................... 3

- 1

4 Potentially Incrementally Impaired Waters

................................ ................................ ............... 4

- 1

4.1 Data

................................ ................................ ................................ ................................ ................. 4

- 1

4.2 Method

................................ ................................ ................................ ................................ ............. 4

- 2

4.3 Results

................................ ................................ ................................ ................................ ............. 4

- 3

4.3.1 Land Use Potentially Affected

................................ ................................ .............................. 4

- 4

5 Potential Costs for Municipal Wastewater Source s

................................ ................................ ... 5

- 1

5.1 Data

................................ ................................ ................................ ................................ ................. 5

- 1

5.2 Method

................................ ................................ ................................ ................................ ............. 5

- 1

5.2.1 Reasonable Potential

................................ ................................ ................................ ............. 5

- 1

5.2.2 Projected Effluent Limits

................................ ................................ ................................ ...... 5

- 2

5.2.3 Potential Compliance Options

................................ ................................ ............................... 5

- 2

5.2.4 Potentially Affected Sources

................................ ................................ ................................ . 5

- 5

5.2.5 Unit Control Costs

................................ ................................ ................................ ................ 5

- 7

5.2.6 Potential Total Costs

................................ ................................ ................................ ............. 5

- 8

6 Potential Costs for Industrial Wastewater Sources

................................ ................................ .... 6

- 1

6.1 Data

................................ ................................ ................................ ................................ ................. 6

- 1

6.2 Method

................................ ................................ ................................ ................................ ............. 6

- 2

6.2.1 Reasonable Potential

................................ ................................ ................................ ............. 6

- 2

6.2.2 Potential Compliance Options

................................ ................................ ............................... 6

- 2

6.2.3 Potential Control Costs

................................ ................................ ................................ ......... 6

- 5

7 Potential Costs to Urban Stormwater Sources

................................ ................................ ........... 7

- 1

7.1 Data

................................ ................................ ................................ ................................ ................. 7

- 1

7.2 Method

................................ ................................ ................................ ................................ ............. 7

- 1

7.2.1 Required Controls

................................ ................................ ................................ ................. 7

- 1

7.2.2 Phase I MS4 Urban Land

................................ ................................ ................................ ...... 7

- 2

7.2.3 Phase II MS4 Urban Land

................................ ................................ ................................ ..... 7

- 2

7.2.4 Urban Land Outside MS4s

................................ ................................ ................................ .... 7

- 3

7.2.5 Summary of Potentially Affected Area

................................ ................................ ................. 7

- 3

7.3 Potential Costs

................................ ................................ ................................ ................................ . 7

- 4

8 Potential Costs to Agricultural Sources

................................ ................................ ....................... 8

- 1

8.1 Data

................................ ................................ ................................ ................................ ................. 8

- 1

8.2 Method

................................ ................................ ................................ ................................ ............. 8

- 1

8.3 Potential Costs

................................ ................................ ................................ ................................ . 8

- 3January 2012 iii

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  9 Potential Costs for Septic Systems

................................ ................................ ............................... 9

- 1

9.1 Data

................................ ................................ ................................ ................................ ................. 9

- 1

9.2 Method

................................ ................................ ................................ ................................ ............. 9

- 1

9.3 Potential Costs

................................ ................................ ................................ ................................ . 9

- 2

9.3.1 Unit Costs

................................ ................................ ................................ .............................. 9

- 2

9.3.2 Total Potential Costs

................................ ................................ ................................ ............. 9

- 3

10 Government Expenditures

................................ ................................ Error! Bookmark not defined. 1

10.1 New TMDLs

................................ ................................ ................................ ................................ 10

- 1 1

10.2 Site Specific Alternative Criteria

................................ ................................ ................................ . 10

- 2 2

10.3 Ambient Monitoring

................................ ................................ ................................ .................... 10

- 2 2

11 Summary of Potential Costs

................................ ................................ ................................ ....... 11

- 1

12 Description of Benefits of Reducing Nutrient Loads to Florida Estuaries

............................. 12

- 1

12.1 Effect of Nutrients on Bays, Estuaries and Coasts

................................ ................................ ........ 12

- 1

12.1.1 Ecological Effects

................................ ................................ ................................ .......... 12

- 1

12.1.2 Primary and Secondary Eutrophication Responses

................................ ....................... 12

- 3

12.1.3 Mitigating Factors

................................ ................................ ................................ .......... 12

- 4

12.2 Impacts of Nutrients on Environmental Goods and Services

................................ ........................ 12

- 5

12. 2.1 Impacts of Harmful Algal Blooms (HABs)

................................ ................................ ... 12

- 5

12.2.2 Impacts of Submerged Aquatic Vegetation Loss

................................ ........................... 12

- 5

12.2.3 Impacts of De graded Water Quality

................................ ................................ .............. 12

- 6

12.3 Types of Benefits Associated with Nutrient Reductions

................................ ............................... 12

- 6

12.3.1 Human Health Improvements

................................ ................................ ........................ 12

- 7

12.3.2 Ecological Improvements

................................ ................................ .............................. 12

- 8

13 Potential Incremental Benefits of the Numeric Nutrient Criteria

................................ .......... 13

- 1

13.1 Water Quality Index

................................ ................................ ................................ ...................... 13

- 1

13.1.1 Estimated Baseline Water Quality

................................ ................................ ................. 13

- 3

13.1.2 Estimated Water Quality from Attaining Criteria

................................ .......................... 13

- 7

13.1.3 Estimated Incremental Change in Water Quality due to the Proposed Rule

................. 13

- 7

13.2 Estimating Value of Water Quality Improvements

................................ ................................ ....... 13

- 8

13.2.1 Meta Analysis of Valuation Studies

................................ ................................ .............. 13

- 9

13.2.2 Func tion Transfer to Proposed Rule

................................ ................................ ............ 13

- 10

13.2.3 Estimating Annual Household WTP for Water Quality Improvements

...................... 13

- 12

13.2.4 Estima ting Total WTP for Water Quality Improvements

................................ ............ 13

- 14

13.3 Uncertainty and Limitations

................................ ................................ ................................ ........ 13

- 15

14 References

................................ ................................ ................................ ................................ .... 14

- 1January 2012 iv

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  Appendix A. Proposed Numeric Nutrient Criteria

................................ ................................ .......... A

- 1

Appendix B. Municipal WWTP Cost Estimates

................................ ................................ .............. B

- 1

Appendix C. Sample Industrial Discharger Analyses

................................ ................................ ...... C

- 1

Appendix D. Analysis of Downstream Protection Values

................................ ................................ D

- 1January 2012 v

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  

## List of Exhibits

Exhibit ES

- 1: NPDES

- Permitted Wastewater Dischargers Potentially Affected by Proposed Rule

............ 2

Exhibit ES

- 2: Acres Enrolled in FDACS BMP Program

................................ ................................ .............. 3

Exhibit ES

- 3: Summary of Poten tial Incremental Impairment under the Proposed Criteria

........................ 6

Exhibit ES

- 4: Potential Annual Costs Associated with Numeric Nutrient Criteria (2010 dollars)

............ 10

Exhibit ES

- 5 : Types of Benefits Associate d with Environmental Policies

................................ ................ 12

Exhibit ES

- 6: Potential Annual State Benefits Associated with the Proposed Criteria (Millions of 2010$)

................................ ................................ ................................ ................................ ............................ 13

Exhibit 2

- 1: Numeric Nutrient Criteria for Lakes and Flo wing Waters in Florida

................................ .... 2

- 2

Exhibit 2

- 2 : Plans Developed under the Northern Everglades and Estuaries Protection Program

.......... 2

- 10

Exhibit 2

- 3: Federal Agricultural Assistance Programs by Acres Enrolled and Program Spending

....... 2

- 12

Exhibit 2

- 4: NPDES Dischargers with Numeric Effluent Limits and Monitoring Requirements for Nitrogen and Phosphorus in Florida 1

................................ ................................ ............................... 2

- 14

Exhibit 2

- 5: Summary of NPDES Dischar gers in Florida Potentially Affected by Numeric Nutrient Criteria for Estuaries, Bays, and Coastal Waters 1

................................ ................................ ............ 2

- 16

Exhibit 2

- 6: Summary of MS4 Stormwater Control Projects in Florida

................................ .................. 2

- 17

Exhibit 2

- 7: Summary of Agricultural Lands Enrolled in FDACS BMP Program

................................ . 2

- 17

Exhibit 2

- 8: Summary of CWA Section 303(d) Listed Estuary Impairments for Nutrients in Florida 1

.. 2

- 18

Exhibit 2

- 9: Summary of Nutri ent

- Related TMDLs for Estuaries and Coasts in Florida

........................ 2

- 20

Exhibit 2

- 10: Map of Baseline WBID Impairments related to Nutrients in Florida

................................ 2

- 23

Exhibit 4

- 1: Summary of Potential Incremental Impairm ents Under the Proposed Rule

.......................... 4

- 3

Exhibit 4

- 2: Map of Potential Incremental Waters Not Attaining the Proposed Criteria

.......................... 4

- 4

Exhibit 4

- 3: Summary Land Use in Watersheds Surrounding Potential Incremen tal WBIDs of this Proposed Rule

................................ ................................ ................................ ................................ .... 4

- 5

Exhibit 5

- 1: Comparison of Common BNR Configurations

................................ ................................ ...... 5

- 3

Exhibit 5

- 2: Potential Treatment Required for Municipal Wastewater Treatment Plants

......................... 5

- 7

Exhibit 5

- 3: Unit Costs for BNR (2010 dollars)

................................ ................................ ........................ 5

- 7

Exhibit 5

- 4: Summary of Potential Municipal WWTP Compliance Costs

................................ ................ 5

- 8

Exhibit 5

- 5: Summary of Sensitivity Analysis for Potential M unicipal WWTP Compliance Costs (millions 2010 dollars)

................................ ................................ ................................ ....................... 5

- 9

Exhibit 6

- 1: Summary of Potentially Affected Industrial Dischargers

................................ ...................... 6

- 1

Exhibit 6

- 2: Effectiveness of Common Removal Mechanisms for Reduc ing Various Fractions of Nitrogen and Phosphorus

................................ ................................ ................................ ................................ .. 6

- 3January 2012 vi

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  Exhibit 6

- 3: Estimated Statewide Annual Industrial Control Costs

............ Error! Bookmark not defined.

Exhibit 7

- 1: Urban Land Area in Watersheds Surroun ding Potential Incremental Waters not Attaining the Proposed Criteria

................................ ................................ ................................ ............................... 7

- 1

Exhibit 7

- 2: Urban Land in Watersheds Surrounding Potential Incremental Impairments Potentially Needing Controls

................................ ................................ ................................ ............................... 7

- 3

Exhib it 7

- 3: Estimated Incremental Urban Stormwater Costs

................................ ................................ ... 7

- 4

Exhibit 8

- 1: Agricultural Land Use in Watersheds Draining to Potentially Incrementally Impaired WBIDs

................................ ................................ ................................ ................................ ........................... 8

- 1

Exhibit 8

- 2: Example Agricultural BMP Program Elements for the Caloosahatchee River and St. Lucie

River Watersheds

................................ ................................ ................................ ............................... 8

- 2

Exhibit 8

- 3: Total Acres Enrolled in FDACS BMP Program

................................ ................................ .... 8

- 3

Exhibit 8

- 4: Potential Agricultural Control Costs A ssociated with Incrementally Impaired Estuaries

..... 8

- 4

Exhibit 9

- 1: Summary of Estimated Upgraded Septic System Costs

................................ ........................ 9

- 3

Exhibit 10

- 1 : Summary of Estimated Government Expenditures

................................ ............................ 10

- 2

Exhibit 11

- 1 : Summary of Potential Annual Costs Associated with Numeric Nutrient Criteria (2010 dollars)

................................ ................................ ................................ ................................ ............. 11

- 1

Exhibit 11

- 2: Uncertainties of the Analysis

................................ ................................ ............................. 11

- 1

Exhibit 12

- 1: Eutrop hication Impacts and Responses for Estuaries and Coastal Waters

........................ 12

- 2

Exhibit 12

- 2: Types of Benefits Associated with Environmental Policies

................................ .............. 12

- 7

Exhibit 13

- 1: Comparison of Ranges of Numerical Sco res Associated with Narrative Classes in Two WQI Systems

................................ ................................ ................................ ................................ ............ 13

- 3

Exhibit 13

- 2: Percent Exceedence and Estimated Baseline WQI, TN

................................ ..................... 13

- 5

Exhibit 13

- 3: Percent Exceedence and Estimated Baseline WQI, TP

................................ ..................... 13

- 5

Exhibit 13

- 4: Percent Exceedence and Estimated Baseline WQI, Chl

- a

................................ ................. 13

- 6

Exhibit 13

- 5: Estimated Percentage of Incrementally Impaired Coastal and Estuary Miles in FL by WQI

Classifications

................................ ................................ ................................ ................................ .. 13

- 7

Exhibit 13

- 6: Total Potential Improved Coastal and Estuary WBIDs and Miles

................................ .... 13

- 8

Exhibit 13

- 7: Independent Variable Assignments

................................ ................................ ................. 13

- 11

Exhibit 13

- 8: Average Annual Hou sehold Willingness to Pay for Water Quality Improvement in Florida Estuaries and Coastal Waters (2010$) Across all WBIDs

................................ ............................. 13

- 13

Exhibit 13

- 9: Total Annual State Benefits Associated with the Proposed Criteria (Millions of 2010$ )

... 13

- 14

Exhibit 13

- 10: Total Annual State Benefits Associated with the Proposed Criteria, Higher Baseline Water Quality Scenario (Millions of 2010$)

................................ ................................ ............................ 13

- 15

Exhibit A

- 1: Proposed Chlorophyll

- a Crite ria for Coastal Waters

................................ ........................... A

- 1January 2012 vii

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  Exhibit A

- 2: Proposed Nutrient Criteria for Estuaries

................................ ................................ .............. A

- 2

Exhibit A

- 3: Proposed Nutrient Criteria for South Florida Marine Waters

................................ .............. A

- 6

Exhib it B

- 1 : Potential Costs to Municipal WWTPs for Compliance with Numeric Nutrient Criteria

..... B

- 1

Exhibit C

- 1: Effluent Data Summary, Kinder Morgan Tampaplex Bulk Terminal 1

................................ C

- 1

Exhibit C

- 2: Potential I ncremental Costs, Kinder Morgan Tampaplex Bulk Terminal

............................ C

- 2

Exhibit C

- 3: Effluent Data Summary, Mosaic Fertilizer

– Riverview Chemical Complex 1

.................... C

- 3

Exhibit C

- 4: Potential Incremental Costs, Mosaic Fertilizer

– Riverview Chemical Complex

................ C

- 4

Exhibit C

- 5: Effluent Data Summary, Trademark Nitrogen Corporation

................................ ................. C

- 5

Exhibit C

- 6: Effluent Data Summary, Anheuser Busch Inc., Main Street Sod Farm

............................... C

- 6

Exhibit C

- 7: Potential Incremental Costs, Anheuser Busch

– Main Street Sod Farm

.............................. C

- 7

Exhibit C

- 8: Effluent Data Summary, Coca

- Cola North America, Dunedin

................................ ............ C

- 8

Exhibit C

- 9: Potential Incremental Costs, Coca Cola North America

- Dunedin

................................ ..... C

- 9

Exhibit C

- 10: Effluent Data Summary, Tampa Phosphate Terminal and Warehouse

............................ C

- 11

Exhibit C

- 11: Potential Incremental Costs, Tampa Phosphate Terminal and Warehouse

...................... C

- 12

Exhibit C

- 12: Effluent Data Summary, YARA North America, Inc.

................................ ..................... C

- 13

Exhibit C

- 13: Effluent Data Summary, Smurfit Stone

- Fernandina Beach Mill

................................ ... C

- 18

Exhibit C

- 14: Potential Incremental Costs, Rayonier Performance Fibers, LLC

................................ ... C

- 20

Exhibit C

- 15 : Effluent Data Summary, Smurfit Stone

- Seminole Mill

................................ ................. C

- 21

Exhibit C

- 16: Pot ential Incremental Costs, Smurfit Stone

– Seminole Mill

................................ .......... C

- 22

Exhibit D

- 1: Summary of Potential Incremental Costs Associated with DPVs

................................ ....... D

- 2January 2012 viii

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  

## Acronyms and Abbreviations

A 2 /O Anaerobic

- anoxic ox idation

ANMP A gricultural nutrient management plan

BMAP Basin Management Action Plan

BMP Best management practice

BNR Biological nutrient removal

BOD B iochemical oxygen demand

C&D Construction and development

CAFO Confined animal feeding operation

cfs Cubic feet per second

CH Chlorophyll a

COI Cost of illness

CREP Conservation Reserve Enhancement Program

CRP Conservation Reserve Program

CSP Conservation Stewardship Program

CTA Conservation Technical Assistance

CWA Clean Water Act

DPV Downstream protection value

DO Dissolved Oxygen

DOF Department of Forestry

EAA Everglades Agriculture Area

EPA U.S. Environmental Protection Agency EQIP Environmental Quality Incentive Program

F.A.C. Florida Admin istrative Code

FC Fecal coliform

FDACS Florida Department of Agriculture and Consumer Services

FDEP Florida Department of Environmental Protection

FDOF Florida Division of Forestry

FDOH Florida Department of Health

F.S. Florida Statutes

FW RA Florida Watershed Restoration Act

GAC Granulated activated carbon

GIS Geographic information systems

GLCI Grazing Land Conservation Initiative

HABs Harmful algal blooms

HUC Hydrologic unit code

IPM Integrated pest management

IWR I mpaired Waters Rule

LSJR Lower St. Johns River

MEP Maximum extent practicable

MLE Modified Ludzack

- Ettinger

MS4 Municipal separate storm sewer system

NAICS North American Industry Classification System

NO 2 Nitrate

NO 3 NitriteJanuary 2012 ix

**Draft for I nternal Review Only** 

**- Do Not Quote or Cite**  NOI No tice of intent

NRCS Natural Resource Conservation Service

NPDES National Pollutant Discharge Elimination System

NWIS National Water Information System

O&M Operation and maintenance

OCBWG Orange Creek Basin Working Group

OIG Office of Inspec tor General

OSTDS Onsite sewage treatment and disposal system

PAC Powered activated carbon

PCS Permit compliance system

Pt

- Co Platinum cobalt units

RA Reasonable assurance

RBC Rotating biological contactor

SBR Sequencing batch reactor

S CR Selective catalytic reduction

SDT Secchi disk transparency

SDM Secchi disk measurement

SFWMD South Florida Water Management District

SIC Standard industrial classification

SJWMD St. Johns Water Management District

SMP Strategic monito ring plans

SMZ Special Management Zone

SSAC Sit e specific alternative criteria

SWET Soil and Water Engineering Technology

SWIM Surface Water Improvement and Management

SWMP Stormwater management program

TMDL Total maximum daily load

TN Tot al nitrogen

TP Total phosphorus

TSI Trophic state index

TSS Total suspended solids

UCT University of Cape Town

USDA United States Department of Agriculture

USGS United States Geological Survey

WAFR Wastewater facility regulation

WBID Waterbody identification

WLA Wasteload allocation

WOD Works of the District WQBEL Water quality

- based effluent limit WQI Water quality index WQL Water quality ladder WQS Water quality standards

WRF Water reclamation facility

WTP Will ingness to pay

WWTP Wastewater treatment plantJanuary 2012 Executive Summary

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  ES

- 1 

## Executive Summary

The U.S. Environmental Protection Agency (EPA) is pro posing numeric nutrient criteria applicable to

estuaries

, coastal waters , and south Florida inland flowing waters in the State of Flori da. The proposed criteria will supplement the state’s existing narrative nutrient criterion. Although th e proposed rule does not establish any requirements directly applicable to regulated entities or other sources of nutrient pollution, EPA developed this economic analysis to provide information on potential costs and benefits that may be associated with state implementation requirements that may be necessary to assure attainment

of water quality standards (WQS)

. 

### ES.1 Background and Purpose

The S tate of F lorida currently uses a narrative criterion to protect waters from nutrient pollution. In January of 2009, EPA determined that new or revised WQS for nutrients in the form of numeric nutrient criteria are necessary in Florida to meet the requirements of th e Clean Water Act ( CWA ) (U.S. EPA, 2009a). In August of 2009

, EPA entered into a phased Consent Decree with several environmental organizations that challenged the Agency for not having promulgated numeric nutrient criteria for the

state . In that Consent D ecree, EPA committed to promulgating num eric nutrient criteria for inland

, estuarine

, and coastal waters in Florida

. When promulgated, t his rule will satisfy th e req uirement s of the

Consent Decree.

The proposed rule establishes numeric water quality criter ia for n utrients applicable to estuaries

, coastal

waters , and south Florida inland flowing waters in Florida . EPA determined the proposed criteria to be protective of the s tate ’s designated uses for these waters . T he proposed rule does not establish any

re quirements directly applicable to regulated entities or other sources of nutrient pollution. Nonetheless, state implementation of the criteria may result in new or revised National Pollutant Discharge Elimination System (NPDES) permit conditions for point source dischargers and nutrient control requirements for other sources (e.g., agriculture, urban runoff, and septic systems). Therefore, to provide information on such potential impacts, this report provides EPA’s estimates of the potential costs and benef its of actions the State of Florida could take to implement the proposed criteria, and thus may be indirectly associated

with the proposed rule.



### ES.2 Baseline for the Analysis

The baseline for estimating the potential costs and benefits that may be assoc iated with the proposed rule is the conditions and requirements that would exist without the proposed rule

. These conditions include the current narrative nutrient criterion and procedures for identifying impaired waters, and the actions that

would be need ed to attain the narrative criterion (including those that have not yet been implemented). There are waters in Florida currently listed as impaired under the narrative criterion. FDEP has developed total maximum daily loads (TMDLs) for many of these waters , and has developed or is developing Basin Management Action Plans (BMAPs) to implement some of those TMDLs. Under TMDLs, point sources may receive revised water quality based effluent limits (WQBELs) for total nitrogen (TN) and/or total phosphates (TP). U nder BMAPs, nonpoint sources, including agriculture, urban stormwater, and septic systems, may be required to implement additional nutrient controls. For this analysis, EPA also considers

the baseline to include its 2010 numeric nutrient criteria for lakes and flowing waters, and the controls, costs, and benefits that may be necessary to attain those criteria.

Point SourcesJanuary 2012 Executive Summary

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  ES

- 2 EPA’s permit compliance system (PCS) database indicates that there are 198 municipal wastewater dischargers and 245 industrial discha rgers with individual permits. Some of these permittees discharge to lakes and flowing waters that are not affected by the estuarine waters, coastal waters, or South Florida inland waters rule. For example, of the 198 municipal wastewater treatment plants (WWTP), EPA determined that only 107 discharge to estuarine waters, coastal waters, or South Florida inland waters. Given the nature of influent wastewater at municipal WWTPs, it is likely that all WWTPs have the potential to discharge nutrients. To identi fy industrial dischargers likely to discharge nutrients, EPA identified those dischargers in PCS with either numeric effluent limits and/or monitoring requirements for nitrogen and phosphorus. Based on these industrial categories, 

### Exhibit ES

- 1 summarizes the number of

NPDES

- permitted wastewater dischargers in Florida that may be affected by the rule.



### Exhibit ES

- 1 : NPDES

- Permitted Wastewater Dischargers Potentially Affected by Proposed Rule

Discharg er Category Number of Dischargers
Major Municipal 1 69
Minor Municipal 1 38
Total Municipal 107
Major Industrial 2 2 7

Minor Industrial 2 24

Total Industrial 5 1

Total 1 58

1. Based on treatment train descriptions in FDEP (2009) and permits, WLAs in TMDLs an d existing regulations,

assuming dischargers would have to install advanced BNR for compliance under the rule.
2. U.S. EPA (201 1 ).

T he Grizzle

- Figg Act of 1990 (F.S. 403.086) requires facilities discharging into Old Tampa Bay, Tampa Bay, Hillsborough Ba y, Boca Ciega Bay, St. Joseph Sound, Clearwater Bay, Sarasota Bay, Little Sarasota Bay, Roberts Bay, Lemon Bay, or Charlotte Harbor Bay, or into any river, stream, channel, canal, bay, bayou, sound, or other water tributary thereto, to provide advanced was te treatment. The Act also regulates wastewater discharges through ocean outfalls by prohibiting the construction of new ocean outfalls and the expansion of existing ocean outfalls for domestic wastewater discharge.

Urban Sources

Urban runoff from fertiliz ers applied to lawns , gardens, and golf courses, decomposition of natural rock and soils, air deposition from vehicle exhaust or power plants, detergents used to wash cars on the street, and pet waste can account for significant nutrient pollution in water sheds

. There are a number of rules and

programs in place that regulate these sources

. For example, the state’s Urban Turf Fertilizer Rule limits

the nutrient content of urban fertilizers, which decreases the amount of runoff from its application. T here

are also 36 local governments in Florida with strict rainy season urban fertilizer application bans a s of May

, 2011 (Sierra Club Florida, 2011) . Municipal separate storm sewer systems (MS4s) develop and implement management plan s that include measures that ma y reduce runoff of nutrients such as public education and pollution prevention/good housekeeping activities. To date, FDEP has issued 27 Phase 1 (large and medium

- sized) MS4 permits and 128 Phase II ( small) MS4 permits in Florida (FDEP, 2010 c )

.January 2012 Executive Summary

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  ES

- 3 Lastly, FDE P’s 1982 S tormwater R ule requires treatment of stormwater from new development and redevelopment prior to discharge.

Agricultural Sources

GIS analysis indicates that there are 7.2 million acres of agricultural land in the state of Florida . These lands may represent significant sources of nutrients from fertilizer and waste runoff, and are subject to several federal and state pollution control regulations . A number of rules and programs address nutrient discharges from these sources. Chapter 62

- 670, F.S. req uires all concentrated animal feeding operations (CAFOs) in the state of Florida that discharge water offsite to file an application for a NPDES permit with FDEP. It also prohibits discharge of process wastewater and runoff from any major egg production

fa cility to surface waters except in the event of a 25

- year, 24

- hour storm event. In addition, dairy operations within the Lake Okeechobee Drainage Basin [as defined in 62

- 670.200(8)] and its tributaries are also required to implement BMPs for the purpose of reducing phosphorus inputs to the lake. In 1999, the Florida Watershed Restoration Act (FWRA) established BMPs as the primary instrument for implementing the TMDL program in Florida . Under the FWRA (Section 403.067, F.S.), implementation

of BMPs that FDEP has verified as effective and FDACS has adopted by rule provides a presumption of compliance with state WQS. Under the program, landowners must maintain records and provide documentation regarding their implementation of BMPs and reasons why certain BMPs are applicabl e to their specific situation. 

### Exhibit ES

- 2 shows the number of acres that farmers have enrolled in the FDACS BMP program , by land use type

.



### Exhibit ES

- 2 : Acres Enrolled in FDACS BMP Program

Land Use Number of Acres 1 Land Use Number of Acres 1

Cropland and Pastureland 57,828 Poultry Feeding Operations 308
Improved Pastures 604,137 Nurseries and Vineyards 7,619
Unimproved Pastures 187,799 Tree Nurseries 2,794

Woodland Pastures 85,730 Sod Farms 6,113
Row Crops 55,797 Ornamentals 7,366
Field Crops 607,440 Specialty Farms 496
Tree Crops 102,137 Horse Farms 585

Citrus Groves 301,415 Diaries 6,163

Fruit Orchards 3,792 Aquaculture 15

Other Groves 324 Tropical Fish Farms 19

Abandoned Groves 12 Other Open Lands 11,715
Feeding Operations 389 Fallow Crop Land 2,269
Cattle Feeding Operations 854

Total 2,053,115
1. Based on FDACS BMP program NOI GIS data layer

.

There are also several statutes and regulations governing the discharge of phosphorus in the Lake Okeechobee watershed, including the Northern Everglades and Estuaries Protection Program. To encourage implementation of BMPs and various conservation measures, there are several national programs including the Conse rvation Stewardship Program, Conservation Reserve EnhancementJanuary 2012 Executive Summary

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**- Do Not Quote or Cite**  ES

- 4 Program, Conservation Technical Assistance, Environmental Quality Incentives Program, and Grazin g Land Conservation Initiative.

Forestry

The Florida Division of Forestry (FDOF) controls nonpoint forestry discharges of nutrients through the implementation of BMPs, as developed by the BMP Technical Advisory Committee and published in the Silviculture Best Management Practices Manual (FDOF, 2009). According to the manual, the BMPs

reflect “the minim um standards necessary for protecting and maintaining the State’s water quality as well as certain wildlife habitat values, during forestry activities,” and address many sources of pollution including sedimentation, nutrients, and turbidity.

FDOF periodic ally conducts state

- wide surveys of silviculture practices to assess compliance levels, identify areas and foresters in need of further education, and evaluate the effectiveness of BMPs. There have been 15 surveys since 1981 , with the most recent in 2009. Over that period, the aver age compliance

rate for all BMPs was 94%, with 84% in 1985 and 98% compliance in 2009. The 2009 survey also reported that the implemented BMPs are generally effective at preventing significant impacts to relevant waterbodies (FDOF , 2010)

. The manual contains 143 BMPs, within 14 categories organized by their application to different land types, waterbodies, activities, and special conditions.

Septic Systems

According to a Florida Department of Health database, there are a total of 944

, 006 septic systems in Florida, of which 802,500 are active (FDOH, 2011 ). Most of Florida’s septic systems are over 30 years old and were installed under standards less stringent than current standards for septic system installation. As a result, Flori da has identifi ed approximately $10.3 billion i n capital needs to address water quality or water quality

- related public health problems from decentralized wastewater treatment systems (U.S. EPA

2010c ). These costs represent capital expenditures associated with the rehabilitation or replacement of septic systems and clustered (community) systems.

In Florida, the Bureau of Onsite Sewage Programs in the Florida Department of Health (FDOH) and the environmental health section of County Health Departments regu late the use of onsite sewage treatment and disposal systems ( OSTDSs )

. U nless a variance from these prohibitions has been granted by FDOH

, FDOH does not permit the use of an OSTDS where the estimated domestic sewage flow is over 10,000 gpd or the commercia l sewage flow is over 5,000 gpd, where there is a likelihood that the system will receive toxic, hazardous or industrial wastes, where a sewer system is available, or if any system or flow is currently regulated by FDEP.

Summary of Baseline Requirements

To estimate the potential incremental impacts that may be associated with the rule, EPA assumed that the following actions have been or will be implemented in the absence of the rule, and did not estimate costs associated with these actions as part of this a nalysis:

 Actions necessary to meet existing NPDES permit conditions for municipal and industrial

wastewater

 Actions resulting from draft or approved TMDLs and BMAPs

 Controls required by the Grizzle

- Figg Act of 1990

 Controls on low

- density residential land, in compliance with the Urban Turf Fertilizer RuleJanuary 2012 Executive Summary

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- 5  Controls on land developed after 1982

, in compliance with the 1982 Stormwater Rule

 Controls required by the FDEP Dairy Rule and EPA CAFO regulations

 Agriculture land enrolled in BMPs under FDACS

 Requiremen ts for the Lake Okeechobee watershed

 BMPs for the forestry sector

EPA estimated potential costs compared to a baseline of controls that could be needed to attain FDEP’s July 2009 draft numeric nutrient criteria. EPA also considered the baseline to include its 2010 numeric nutrient criteria for lakes and flowing waters, and the controls, costs, and benefits that may be necessary

to attain those criteria.



### ES.3 Description of the Proposed Rule and Potential Incremental Impairment

EPA is proposing numeric wa ter quality criteria to protect ecological systems and aquatic life from nitrogen and phosphorus pollution in estuaries and coastal waters within the State of Florida, and flowing

waters in south Florida. These proposed criteria apply to Florida waters tha t are designated as Class I

, Class II or Class III waters and they implement the State’s narrative nutrient provision at Subsection 62

- 302

. 530(47 ) (b) , Florida Administrative Code (F.A.C.), which provides that “[i]n no case shall nutrient

concentrations of a body of water be altered so as to cause an imbalance in natural populations of aquatic

flora or fauna.”

To e valuate estuarine and South Florida marine waters not already listed as impaired under the narrative

criteria for nutrient

- related causes that may be identified as impaired under the proposed criteria , EPA analyzed the most recent five years of available water quality monitoring data for each potentially affected segment with sufficient monitoring data. Sufficient data include at least four measurem ents per year (for three consecutive years), with at least one measurement between May and September and on e measurement between October and April each year.

To estimate the waterbodies ( specifically identified as WBIDs) that may be listed as incrementall y impaired under Florida’s listing procedures, EPA identified WBID with each segment using GIS. Each segment does not fall completely within a single WBID. Thus, to ensure that the WBID is accounted for in the analysis, EPA identified WBID s containing at l east 10% of an incrementally impaired segment, excluding those WBIDs that are currently impaired or under a TMDL (to remove baseline impaired WBIDs). Exhibit ES

- 3 summarizes results of this analysis.January 2012 Executive Summary

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  ES

- 6 

### Exhibit ES

- 3 : Summary of Potential Incremental Impairment under the Proposed Criteria
Category Number of Coastal and Estuarine WBIDs

Total in State 1,143
Total in Analysis 1 952

Nutrient Data in IWR Run 44 2 513

Sufficient Data Availabl e 3 410 Potentially Exceeding Criteria 4 230
IWR = Impaired Waters Rule TMDL = total maximum daily load 1. Excluding waters for which FDEP has already developed a TMDL or listed as impaired for nutrients and DO 2. Data within last 5 years meeting data qua lity requirements. 3. Sufficient to calculate annual geometric means; based on at least 4 samples with at least one sample from May to September and one sample from October to April in a given year. 4. Based on annual geometric mean exceeding the applica ble criterion more than once in a three year period.

To estimate the urban areas, agricultural land, and septic systems that may need controls to attain the proposed criteria in incrementally impaired waters, EPA used GIS analysis to identif y the watersh eds [ 10

- digit Hydrologic Unit Code (HUC) ] associated with these incrementally impaired WBIDs . Each WBID in

the state may not fall completely within a single 10

- digit HUC. Thus, to ensure that lands (and sources) affecting water quality for each WBID are ac counted for in the analysis and that incidental ly overlapping HUCs are not included, EPA identified watersheds containing at least 10% of an incrementally impaired WBID, excluding those watersheds that contain at least 10% of a WBID that is currently impai red or under a TMDL (to remove baseline impaired watersheds). EPA estimated controls for agricultural land, urban land, and septic systems within these potentially affected watersheds.



### ES.4 Potential Costs to Municipal WWTPs

Point source dischargers rece ive water quality based effluent limitations (WQBELs) in permits based on analysis of reasonable potential to exceed water quality criteria. Because untreated municipal wastewater is typically high in nutrients, for this analysis, EPA assumed that all muni cipal WWTPs would receive WQBELs consistent with no mixing zones or dilution (i.e., criteria applied end

- of

- pipe). Potential controls that would facilitate attaining these limitations include biological nutrient removal (BNR), chemical precipitation, and e ffluent reuse.

For this analysis, EPA also assumed that WWTPs would implement advanced BNR as the most cost

effective treatment option. Although other treatment options may be able to reduce TN and TP concentrations below the levels achieved by BNR, those options tend to be significantly more expensive. EPA believes that other strategies to reduce nutrient loading to the watershed would likely be implemented before requiring these more expensive alternatives (in some cases, requiring dischargers to

obtain a variance from meeting the criteria). EPA also estimated additional costs for the second pollutant

when current TMDL s may have only addressed one nutrient pollutant (e.g.

, a WWTP under a current TMDL for TN may incur further costs for the TP criteria set in this proposal).

Thus, EPA estimated the potential costs to WWTPs based on a range of estimated unit costs for BNR. EPA estimated that potential compliance costs (annualized capital at 7% over 20 years plus annual O&M) to municipals WWTPs could range fr om approximately $94 .2 million to $ 117.5 million annually . TheJanuary 2012 Executive Summary

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**- Do Not Quote or Cite**  ES

- 7 low end of this range excludes costs to dischargers to waters on the 303(d) list for nutrient

- related causes since controls would likely be needed in the absence of the proposed rule. However, existing nutrient

related TMDLs for Florida waters sometimes establish WLAs for only the limiting pollutant

. For most estuaries and coastal waters, the growth

- limiting nutrient (i.e., the chemical which largely controls the rate of primary production) is n itrogen, t herefore t he high end of the range includes potential incremental costs

to facilities for T P on currently listed waters

. 

### ES.5 Potential Costs to Industrial Wastewater Sources

Unlike municipal WWTPs, industrial facilities do not necessarily disch arge nitrogen or phosphorus. Also, though some facilities may use the same treatments as WWTPs (such as BNR and chemical precipitation), treatment options for reducing nutrient loads from industrial sources can vary due to industry

- or facility

- specific co nditions. In some cases, industrial facilities may also be able to pursue options such as BMPs, product substitution, process modification or optimization, or retention pond

installation.

To estimate the potential costs to industrial facilities that may b e indirectly associated with EPA’s rule,

EPA first assumed that controls on dischargers to 303(d) listed waters or waters covered under a TMDL

are not attributable to the proposed rule because those costs would occur in the absence of the proposed

rule. Of the remaining industrial facilities, EPA estimated the costs of nutrient controls that may be necessary to meet the proposed criteria in different industrial categories. EPA estimated statewide control costs (annualized capital at 7% over 20 years plus an nual O&M) for industrial facilities could amount to approximately $7.6 million, annually.



### ES. 6 Potential Costs for Urban Stormwater Controls

Some areas served by MS4s in incrementally impaired watersheds may require additional nutrient controls. However, it is difficult to identify the additional controls that may be necessary to attain the proposed criteria without site specific analysis. Full implementation of existing stormwater management programs could be sufficient to attain the proposed criteria in some watersheds. In others, water quality monitoring after full implementation of existing stormwater management programs may indicate a need

for additional controls.

Current nutrient

- related TMDLs in Florida allocate between 5% and 85% of nutrient load r eductions to

stormwater sources within the watersheds Urban stormwater controls may remove up to 51% of TN and 75% of TP ( Sch u e ler et al., 2007 ). FDEP’s 1982 Stormwater Rule establishes that stormwater design criteria adopted by FDEP and the water managemen t districts shall achieve at least 80% reduction of the average annual load of pollutants that cause or contribute to violations of WQS (95% reduction for outstanding natural resource waters).

In its evaluation of EPA’s proposed numeric nutrient criteria rule, FDEP (2010b) assumed that nutrient reductions mandated in the 1982 Stormwater Rule would be sufficient to comply with the proposed

criteria . EPA assumed that the amount of urban land within Phase I MS4s that may require additional

nutrient controls c ould range from none [current implementation of BMPs to the maximum extent practicable (MEP) is sufficient] to all Phase I MS4 urban land developed before 1982 in watersheds surrounding incrementally impaired WBIDs . Under these assumptions, EPA estimated t hrough GIS analysis that additional stormwater controls may be needed on up to 31,200 acres of Phase I MS4 urban

land (approximately 68% of Phase I MS4 urban acres surrounding incrementally impaired WBIDs)

.

Because over

- application of fertilizers on lawns and gardens is the primary source of nutrient pollution from low density urban areas, EPA assumed that sufficient nutrient reductions could be achieved fromJanuary 2012 Executive Summary

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**- Do Not Quote or Cite**  ES

- 8 low density Phase II MS4 areas and other low density urban areas not covered under EPA’s NPDES

stor mwater program by full implementation of existing regulations such as the Urban Turf Fertilizer Rule. For higher density Phase II MS4 urban areas and other higher density urban areas not covered under EPA’s NPDES stormwater program, EPA assumed that additi onal stormwater controls could be needed in incrementally impaired watersheds. Again, using FDEP’s assumption that urban lands developed after 1982 would not need additional controls, EPA used GIS analysis to estimate that 34,500 acres of urban

land within Phase II MS4s and 21,400 acres of urban land outside MS4s may need additional controls to reduce nutrients discharges to surface waters (approximately 62% and 71% of Phase II MS4 urban land

and non

- MS4 urban land, respectively, surrounding incrementally

- i mpaired WBIDs)

.
Costs for stormwater controls can vary widely and depend on the type of land requiring control. For this analysis, EPA estimated unit costs from data on existing stormwater projects in Florida obtained from FDEP (2010a). The cost of these p rojects ranges from $62 per acre to $60,300 per acre, with a median cost of $6,800 per acre. Using the median cost per acre and the estimated number of acres needing additional controls, EPA estimated that costs for additional nutrient controls for stormwa ter could range

from $55.2 to $86.0 million per year.



### ES. 7 Potential Costs for Agricultur al Controls

EPA estimated that an incremental level of control of nutrient runoff from agricultural land could be needed on about 16,600 acres (approximately 82% of a ll agricultural land surrounding potentially incrementally impaired WBIDs)

. For this analysis, EPA e stimated the BMP programs that c ould be needed to attain the numeric criteria based on a study of agricultural BMPs to meet TMDL targets in the

Caloosahatch ee River, St. Lucie River, and Lake Okeechobee watersheds (SWET

, 2008). SWET (2008) developed scenarios of a mix of BMP s at three levels of control : an owner implemented program consisting of a set of practices that land owners might implement without ince ntives; a typical program consisting of practices that land owners might implement under a reasonably funded cost share program; and an alternative program of more aggressive controls to supplement the owner and typical programs if

additional reductions ar e necessary.
The BMPs in the owner implemented and typical program are similar to the BMPs adopted by FDACS. The alternative BMP program, which includes stormwater chemical treatment, is not yet required in the study basins which have significant contribu tions from agriculture. Thus, for this analysis, EPA assumed that nutrient controls for agricultural sources are best represented by the owner and typical programs.

EPA estimated potential nutrient control costs to agriculture by using GIS analysis to ass ess the amount of land used for different categories of agricultural operations in incrementally impaired watersheds, and the category

- specific unit costs of the owner and typical BMP programs estimated by SWET (2008). BMPs implemented under the FDACS prog ram represent a level of control that is similar to the owner implemented and typical BMP programs. However, the level of compliance with the FDACS BMP program in incrementally impaired watersheds is uncertain (FDACS 2011 ). Therefore, EPA estimated a

range of agricultural costs by including and excluding land enrolled in the FDACS BMP program. Using these assumptions, EPA estimated that the cost of additional agricultural BMPs that may be needed to

attain the proposed criteria c ould range from approximately $0.27 to $0.28 million per year.



### ES.9 Potential Costs for Septic System Controls

Some nutrient reductions from septic systems may be necessary for incrementally impaired waters to

meet t he proposed criteria . Properly operated and maintained systems usua lly provide treatment equivalent to secondary wastewater treatment (Petrus, 2003). However, even properly functioning septicJanuary 2012 Executive Summary

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  ES

- 9 systems could impact water quality. Nutrient loading reduction strategies could include greater use of inspection programs and repa ir of failing systems, upgrading existing systems to advanced nutrient removal, decentralized cluster systems where a responsible management entity would ensure reliable operation and maintenance, and connecting households and businesses to wastewater trea tment plants.

Based on current practice in Florida, EPA assumed for this analysis that the most likely compliance strategy to reduce nutrients loads from septic systems would be to upgrade existing convention septic systems to advanced nutrient removal sys tems.

Septic systems in close proximity to surface waters are most likely to contribute the greatest nutrient load to the waterbody. Most of the existing nutrient

- related TMDLs identify failing septic systems as contributing to nutrient impairments in surf ace waters. The Middle St. Johns River Nutrient TMDL considers wastewater from failed septic tanks within 50 feet as direct discharges of untreated wastewater

to the stream network ; for systems outside of the 50

- feet boundary, FDEP combine s septic system l oads with the nonpoint source loading for residential areas (Gao, 2009). In addition, Florida Administrative Code requires that in most cases septic systems “shall not be located laterally within 75 feet of the boundaries of surface waterbodies” (FAC 64E

- 6 .005(3)).

EPA assumed that some septic systems located near incrementally impaired estuaries, coasts , and south

Florida inland waters may be required to upgrade to advance d nutrient removal systems. However, the distance that septic systems can be safely located relative to these surface wate rs depends on a variety of

site

- specific factors. Given the uncertainty, EPA conservatively assumed that septic systems located

within 500 feet of in crementally impaired waters may require upgrading to account for some downstream transport of nutrients from nearby waters that may not be classified as incrementally impaired. GIS analysis indicates that there are 7,325 active septic systems within 500 feet of any water body in watersheds associated with incrementally impa ired waters.

Manufacturer estimates of capital costs to upgrade a conventional septic system to an advanced nutrient removal system (including installation costs) range from $2,000 per system to $6,500 per system, with annual O&M costs of $650 per year (Ch ang et al., 2010). Thus, annual costs could range from approximately $800 to $1,300 for each upgrade (capital costs annualized at 7% over 20 years plus annual O&M). Multiplying these unit costs by the total number of septic systems possibly needing upgrade s yields a cost estimate ranging from $5.9 to $9.5 million annually

. 

### ES.10 Government Expenditures

FDEP may incur costs associated with development of additional TMDLs. Because existing TMDLs for estuaries, coastal waters , and south Florida inland waters c over an average of four WBIDs each, EPA

estimated that FDEP may need to develop 58 new TMDLs to address the 230 incrementally impaired

WBIDs . EPA (2001) indicates that TMDL development for two similar pollutants costs an average of approximately $47,000. T hus, total TMDL development cost could be approximately $ 2.7 million

. Currently, FDEP operates its TMDL schedule based on a five

- phase cycle that rotates through the five

basins over five years (FDEP, 2003). Under this schedule, completion of TMDLs for hi gh priority waters will take 9 years; it will take an additional 5 years to complete the process for medium priority waters. Thus, assuming all the incremental impairments are high priority and FDEP develops the new TMDLs

over a 9

- year period, annual costs could be approximately $0.3 million.



### ES.11 Summary of Costs

Exhibit ES

- 4 summarizes the estimates of potential annual incremental control costs for each source.January 2012 Executive Summary

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  ES

- 10 

### Exhibit ES

- 4 : Potential Annual Costs Associated with Numeric Nutrient Criteria (2010 dollars)

Source Sector Type of Expenditure Annual Cost (millions) Municipal Wastewater 1 BNR to reduce TN and/or TP $94.2

- $ 117.5

Industrial Dischargers 2 BNR to reduce TN and TP; chemical precipitation to reduce
TP $7.6

Urban Stormwater 3 Stormwater controls $55.2

- $86.0
Agriculture 4 Owner/typical BMP program $0.3

- $0.3

Septic Systems 5 Upgrade to advanced nutrient
treatment $5.9

- $9.5

Government/Program Implementation 6 TMDL development $0.3

Total

-- $163.5

- $ 221.2 Note: Detail may not add to total due to independent rounding. BNR = biological nutrient removal; TMDL = total maximum daily load; TN = total nitrogen; TP = total phosphorus 1. Based on upgrading existing treatment processes to advanced B NR. 2. Based on extrapolation of average annual costs per flow for random sample of dischargers stratified by industrial category. 3. Based on median stormwater control costs from FDEP (2010a), and scenario of need for structural controls on land developed before 1982. 4. Based on implementing nutrient management on all crop land outside of incrementally and baseline impaired watersheds and scenarios in which all agricultural land not enrolled in the FDACS BMP program in incrementally impaired watersheds in curs owner/typical program costs from SWET (2008) or all agricultural land in incrementally impaired watersheds incurs owner/typical costs based on SWET (2008). 5. Based on upgrading to advanced nutrient removal active septic systems within 500 feet of wat er (based on GIS land use data) in the watersheds surrounding potential incrementally impaired WBIDs. 6. Based on average costs to complete TMDLs for incrementally impaired waters under a 9

- year schedule.



### ES.12 Description of Potential Benefits

Reductio n in nutrient concentrations to meet numeric nutrient standards in Florida estuaries, coasts , and

south Florida inland waters improve s ecological function and enhance provision of environmental goods

and services. One of the adverse effects of excess nutr ient loading is eutrophication, or the increase in organic carbon to an aquatic ecosystem caused by primary production stimulated by excess nutrients. This can lead to increases in the occurrence and intensity of water column phytoplankton, including harmf ul algal blooms (e.g. nuisance and/or toxic species), loss of critical submerged aquatic vegetation (SAV) 1

, and reduced and/or diurnally variable dissolved oxygen (DO). In turn, these ecological responses can lead

to significant or even complete losses in environmental goods and services provided by the affected waterbodies, such as commercial and recreational fishing, swimming, diving, and snorkeling.

Eutrophication is a major concern for many bays, estuaries, and coasts within the United States, and is

pa rticularly severe for many Florida waters. Florida’s 2008 Integrated Report stated that 94 estuaries encompassing approximately 900 square miles of water a re impaired for nutrients, with nutrients ranked as the second most common source of impairment (FDEP 2008a)

. 2

. One additional coastal body

1 Submerged aquatic vegetation such as seagrass is a major determinant of the trophic structures of coastal ecosystems, providi ng food, habitat, and shelter for a wide range of fish species, marine mammals, reptiles, and birds.

2 The 2010 repo rt indicates cause of impairment as trophic status index (TSI), which measures the potential for algal or aquatic weed growth, the components of which include total nitrogen, total phosphorus, and chlorophyll.January 2012 Executive Summary

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**- Do Not Quote or Cite**  ES

- 11 representing 102 squ are miles is also impaired for c hlorophyll, typically considered an indicator of algal growth associated with eutrophication (FDEP, 2008 a ).

Eutrophication of estuaries

, coasts , and south Florida in land waters may have a significant impact on the value of environmental goods and services provided by the affected waterbodies. Low DO events in a single water body can cause millions of dollars in economic losses from recreational and commercial fishing alone (CENR, 2010). Additionally, the losses of SAV resulting from eutrophication can have profound economic impacts. For example, FDEP has estimated that each acre of seagrass is worth over $20,000 to the economy of Florida annually , or over $44 billion s tatewide (Carlson and Yarbro, 2008). In 2009, Florida seagrass communities supported an estimated harvest of $23 million for just six species of commercial fish and shellfish dependent on seagrass (Crist, 2010).

In the environment and economy in Florida , t he tourism

- focused goods and services provided by its bays, estuaries, and coastal waters are particularly va luable. The tourism industry in nearshore counties in

Florida contributes approximately $12.4 billion (2004 dollars) to the state’s economy annuall y 3 (NOEP, 2006). Coral reefs are an especially important contributor to the tourism sector in the state . Reef

- related recreational expenditures on activities such as snorkeling, scuba diving, fishing, and glass bottom boating

in four counties in southeaste rn Florida for a one year p eriod in 2000

- 2001 totaled $5.4 billion (Johns et al., 2001).

Reductions of nutrient loading to estuaries, coasts , and south Florida inland waters in Florida result in decreased eutrophication and its associated adverse impacts t o the environment and economy. Exhibit
ES

- 5 shows the types of benefits often associated with environmental policies, including improvements in water quality, and the types of methods that can be used to assign val ue to such benefits. Categories that may be applicable to nutrien t reductions in Florida include:

 Reduced human health risks such as skin irritation, gastrointestinal illness, and other symptoms associated with exposure to harmful algal blooms ( HABs )

,  Ec o logical be nefits including improved fish and shellfish harvests, improved recreational opportunities

, and enhanced ecosystem services such as biodiversity conservation , nutrient cycling, and many others, and

 O ther benefits such as aesthetic improvements a nd reduced biofouling

.

3 Tourism data is for 2004, the most recent ye ar for which data is available. Dollar values presented in this chapter are in 2010 dollars, inflated from original year dollars using CPI, except where otherwise noted.January 2012 Executive Summary

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**- Do Not Quote or Cite**  ES

- 12 

### Exhibit ES

- 5 : Types of Benefits Associated with Environmental Policies Category Examples Valuation Methods Human Health Improvements

Mortality risk reductions Reduced risk of fatality from

cancer an d acute risks Averting behavior, hedonics, stated preference

Morbidity risk reductions Reduced risk of nonfatal illness Averting behavior, hedonics, stated preference Ecological Improvements

Market products Harvests or extraction of food, fuel, fiber, t imber, fur, and leather Production function

Recreation activities and aesthetics Wildlife viewing, fishing, boating, swimming, hiking, scenic views Production function, averting behaviors, hedonics, recreation

demand, stated preference

Valued ecosystem f unctions Climate moderation, flood moderation, groundwater recharge, sediment trapping, soil retention, nutrient cycling, pollination by wild species, biodiversity, water filtration, soil fertilization, pest control Production function, averting behaviors, stated preference

Nonuse values Relevant species populations, communities, or ecosystems Stated preference

Other Benefits

Aesthetic improvements Visibility, taste, odor Averting behaviors, hedonics, stated preference

Reduced materials damage Reduced soiling and corrosion Averting behaviors, production function, cost function Source: U.S. EPA (2010 a )

Reducing excess nutrien ts in estuaries, coastal waters , and south Florida inland waters can result in significant economic benefits to Florida citizens . These benefits include maintenance of valuable coastal

based fishing and tourism industries in the state and increased coastal property values. There could also be significant indirect economic benefits including reduction in healthcare costs (due t o avo ided harmful algal blooms), the avoidance of costs associated with the need to find alternative recreational locations, enhanced opportunities for angling competitions, wildlife watching, and camping, and non

- use values such as habitat protection. Numeric nutrient criteria can also result in avoidance of future restoration costs because numeric criteria are easily measurable qualities of water that can be used to assess whether or not waters are in danger of becoming impaired , allowing for a more cost

- effec tive approach of pollutant reductions prior to waters being impaired

. Some of the benefits of reducing nutrients can be monetized, at least in part, by translating changes in nutrient concentrations into an indicator of water quality (a water quality inde x, WQI) and valuing these improvements in terms of willingness to pay (WTP) for the types of uses that are supported by different water quality levels. The parameters used to formulate the WQI are based on waterbody type, scientific understanding of ecosys tem response to varying conditions, and available data. For this preliminary analysis, EPA developed a WQI of the proposed nutrient criteria parameters only, although other parameters affect overall water quality. Thus, the benefits may overstate or unders tate potential water quality improvement under the proposed criteria depending on how other parameters affect water quality

. ( Note , none of the incrementally affected waters appear on FDEP’s list of impaired waters.)January 2012 Executive Summary

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**- Do Not Quote or Cite**  ES

- 13 EPA developed baseline and post

- compli ance WQI values assum ing that the waters not in attainment are at least of ‘fair’ water quality, given that FDEP has not already listed these waters as impaired under the

current narrati ve nutrient criterion, and that attaining the proposed criteria repres ents ‘good’ water quality. EPA used information on the percent exceedance of the proposed criteria across the incremental nonattainment waters to estimate the level between these two points representative of baseline water quality

. 4 EPA developed baseline WQI estimates for each WBID using three scenarios: 1) baseline WQI estimated from exceedences of TN criteria (a scenario in which nitrogen is the limiting nutrient of concern); 2) baseline WQI estimated from exceedences of TP criteria ( a scenario in which phosphorus is the limiting nutrient of concern); and 3) baseline WQI estimated from exceedences of Chl

- a criteria (a

scenario in which Chl

- a is the primary concern). The difference in WQI between baseline conditions and attainment of the proposed c riteria is a measure of the change in water quality that may be attributable to nutrient pollution controls

. However, some of these controls may represent baseline requirements and are not accounted for in this analysis. EPA assumed that all waters not currently attaining the proposed criteria will come into attainment, but did not estimate any water quality improvements in waters that already attain the proposed criteria

.
EPA then used regression analysis to determine average household WTP for improvements in wat er quality. EPA calculated the average household WTP at the WBID

- level for both full

- time and part

- time residents. EPA estimated total benefits at the WBID level by multiplying average household WTP with the number of households in each category and the pe rcentage of miles or area that comprise a given

WBID. This method results in monetized benefits associated with attaining the proposed criteria rang ing from $ 8 3.7 to $ 100.1 million , as shown in Error! Reference sourc e not found.

. However, benefits are overstated to the degree that improvements can be attributed to baseline controls

.



### Exhibit ES

- 6 : Potential Annual State Benefits Associated with the Proposed Criteria (Millions of 2010$)

Baseline WQ I Based on % of TN Exceedance Baseline WQ I Based on % of TP Exceedance Baseline WQ I Based on % of Ch

- **a** Exceedance

$100.1 $86.8 $83.7
Ch

- a = chlorophyll a TN = total nitrogen TP = total phosphorus WQI = water quality index

4 In cases in which exceedence data are not available for one or more pollutants in a waterbody, data for another pollutant are substituted, with the following order of preference: TN, TP, Chl

- a

.January 2012 1

. Introduction

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  1

- 1 

## 1 Introduction

T he U.S. Environmental Protection Agency (EPA) is pro posing numeric nutrient criteria applicable to estuaries, c oastal w aters , and south Florida inland flowing waters. The proposed criteria will augment the state’s existing narrative nutrient criteria. Alth ough th e proposed rule does not establish any requirements directly applicable to regulated entities or other sources of nutrient pollution, s tate implementation may result in new or revised National Pollutant Discharge Elimination System (NPDES) permit co nditions for point source discharg ers and controls on nonpoint sources of nutrient loadings. T his analysis provide s information on the potential for both costs and benefits to be associated with s tate actions that may be
necessary to a ssure attainment of s tate water quality designated uses protected by the criteria in the proposed rule

.



### 1.1 Requirement for the Proposed Rule

Section 303(c) of the Clean Water Act (CWA) requires states to adopt water quality standards (WQS) for

waters of the United States within t heir applicable jurisdictions. Section 303(c)(2)(A) and EPA’s implementing regulations at 40 CFR part 131 require that state WQS include the designated use or uses of the waters and the criteria necessary to protect those uses. EPA’s regulations at 40 CFR § 131.11(a)(1) provide that states “adopt those water quality criteria that protect the designated use,” and that such criteria “must be based on sound scientific rationale and must contain sufficient parameters or constituents to protect the designated us e.”

CWA section 303(c) also requires states to review their WQS at least once every three years and, if appropriate, revise or adopt new standards. States must submit these new or revised WQS to EPA for review and approval or disapproval. Section 303(c) al so directs the EPA Administrator to promulgate WQS to supersede state standards that it has disapproved or determined that a new or revised standard is needed to meet CWA requirements.

On January 14, 2009, EPA made a determination under section 303(c)(4)(B ) of the CWA that numeric nutrient water quality criteria for lakes and f lowing waters and for estuaries, coastal waters , and south

Florida inland waters are necessary for the State of Florida to meet the requirements of CWA section 303(c). As a result of an August 2009 Consent Decree with multiple environmental organizations, EPA proposed numeric nutrient water quality standards for lakes and flowing waters in Florida in January 2010, and established final standards in December 2010. When promulgated, t his rule will satisfy the requirements of the Consent Decree for estuari es, coastal waters, and south Florida inland flowing waters.



### 1.2 Purpose and Scope of the Analysis

The proposed rule establishes water quality criteria applicable to e stuaries, c oastal w ater s , and south

Florida inland waters in Florida . The proposed rule does not establish any requirements directly applicable to regulated entities or other sources of nutrient pollution to these waters. Nonetheless, state implementation of the criteria may res ult in new or revised National Pollutant Discharge Elimination System (NPDES) permit conditions for point source dischargers and nutrient control requirements on other sources (e.g., agriculture, urban runoff, and septic systems). Therefore, the purpose of this analysis is to provide e stimates (within the limits of uncertainties regarding future implementation by the State of

Florida ) of the potential costs and benefits that may ultimately be associated with the proposed rule to inform the public regarding these potential impacts. Actual impacts will depend on the particular implementatio n strategy pursued by the state.January 2012 1

. Introduction

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  1

- 2 This report provide s an assessment of the potential costs and benefits associated with implementation of the proposed rule above and beyond th ose that may result without the proposed rule. It is possible that implementation of existing criteria (e.g., narrative nutrient criteria) would eventually lead to imposition of

controls deemed necessary to comply with the proposed rule because both crit eria target the same endpoint of “no imbalance of flora and fauna,” such that the difference in costs is only a matter of timing. Under such a scenario, the proposed rule may result in cost savings by addressing the need for controls

sooner rather than lat er and avoiding more costly restoration as well as providing support to Florida for future TMDLs by completing one of the early steps in the TMDL process . However, with this analysis, EPA is conveying information related to the potential costs and benefits of implementing its numeric nutrient criteria as an “increment” to the costs and benefits associated with ongoing efforts to implement existing criteri a . EPA refers to these existing conditions and requirements (e.g., existing criteri a , actions required u nder existing nutrient

- related TMDLs) as the “baseline.”

To identify the potential incremental impact above the baseline , EPA evaluated potential changes to NPDES permit conditions for municipal and industrial wastewater facilities since these point source s may receive water quality based effluent limitations (WQBELs). For nonpoint sources, EPA identified waters that may not meet EPA’s criteria but are not currently listed by the state as impaired for nutrient

- related causes, and used land use data surround ing incrementally impaired watersheds (that are not also in baseline impaired watersheds) as an indication of the types of controls that will be needed to attain the criteria. EPA based its estimates of the types of controls and costs for different sources that may be needed on those currently being required throughout the state in watersheds impaired under existing

criteria . The data and methods behind each of these components of the analysis are described in detail within the report and appendices

.

To est imate potential incremental benefits, EPA identified the potential adverse effects associated with

excess nutrient loadings in estuaries, coastal waters, and south Florida inland waters, and the categories of benefits that may result from attaining criteri a. For quantitative estimates, EPA conducted a benefits transfer of studies that provide estimates of the value of water quality improvements. To do this, EPA linked changes in water quality to incremental benefits through use of a water quality index.

Num eric nutrient criteria provide a means of developing protective numeric effluent limi ts for wastewater point sources, and information that may help in limiting loads from nonpoint sources to prevent impairment in waters that do not yet exceed the criteria

. Thus, there is also potential for benefits from attaining designated us es where such uses are impaired and protecting designated uses from future impairment and the associated loss of value. However, the estimates of costs and benefits in this report do

n ot account for prevention of future impairments.



### 1.3 Organization of this Report

The remainder of this report is organized as follows:

 Section 2 describes the baseline for estimating potential incremental compliance actions.

 Section 3 provides a description o f the proposed rule

.  Section 4 provides as assessment of the potentially incrementally impaired waters under the rule

.  Secti on 5 provides estimates of controls and costs for wastewater point source dischargers.

 Section 6 provides estimates of controls and costs for industrial point sources.

 Section 7 provides discussion of the potential for incremental controls for urban runoff.January 2012 1

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- 3  Section 8 provides estimates of controls and costs for agriculture.

 Section 9 provides estimates of controls and costs for septic systems.

 Section 10 provides estimates of potential government expenditures.

 Section 11 summarizes the potential costs and describes the uncertainties of the analysis.

 Se ction 12 provides a description of potential incremental benefits.

 Section 13 provides monetized estimates of potential benefits.

 Section 14 provides references.

 Appendix A provides the proposed nutrient criteria

.  Appendix B provides facility

- specific cost estimates for municipal WWTPs

.  Appendix C provides detailed analysis for each of samp le industrial dischargers.

 Appendix D provides an analysis of whether the numeric nutrient criteria are being attained at “pour points .”January 2012 2. Baseline for the Analysis

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- 1 

## 2 Baseline for the Analysis

As described in Section 1

, th is report conveys i nformation related to the potential costs and benefits of implementing the proposed numeric nutrient criteria as an increment to ongoing efforts to attain existing

n utrient criteria. This section describes the se existing conditions. Because a number of exi sting programs and requirements are not yet fully implemented, current water quality may not reflect the ultimate

conditions that would result without the proposed rule. This section describes the information and assumptions EPA used to establish a baselin e for identifying the incremental requirements , costs, and

benefits that may be associated with the proposed rule.



### 2.1 Current Regulatory Framework

The current regulatory framework for controlling nutrients in Florida waters includes existing WQS, and

state a nd federal requirements for dischargers of nutrients.

2.1.1 Water Quality Standards

WQS include designated uses of waters (e.g., aquatic life support, recreation, drinking water), water quality criteria to protect the uses, and antidegradation policy. WQS also i nclude implementation procedures specifically addressing identification of impaired waters to the extent the procedures further define designated uses and protective criteria.

**Current Water Quality Criteria**

For nutrients, FDEP water quality c riteria for es tuaries are narrative in form: Chapter 62

- 302.530, Florida Administrative Code (F

. A

. C

. ), states that “in no case shall nutrient concentrations of a body of water be altered so as to cause an imbalance in natural populations of flora or fauna.” The proposed criteria address this aspect of the narrative criterion. The narrative criterion also state s that (for all waters of the state) “ the discharge of nutrients shall continue to be limited as needed to prevent violations of other stand ards

contained in this c hapter ( Chapter 62

- 302, F

. A

. C .) . Man

- induced nutrient enrichment (total nitrogen or total phosphorus) shall be considered degradation in relation to the provisions of Sections 62

- 302.300, 62

- 302.700, and 62

- 4.242, F.A.C.”

In December 2010, EPA established numeric criteria for TN, TP, and chlorophyll

- a for freshwater lakes and flowing waters in Florida that are not to be exceeded more than once in a three year period. Exhibit

2

- 1 summarizes these criteria, which var y by region (for streams) and characteristics of the waters (for lakes).January 2012 2. Baseline for the Analysis

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- 2 

### Exhibit 2

- 1 : Numeric Nutrient Criteria for Lakes and Flowing Waters in Florida

Region/Type of Water Chlorophyll

- a (mg/L) TN Criter ia (mg/L) TP Criteria (mg/L) Nitrate + Nitrite Criteria (mg/L)
Colored Lakes 1 0.020 1.27 0.050 NA Clear Lakes (high alkalinity) 2 0.020 1.05 0.031 NA Clear Lakes (low alkalinity) 3 0.006 0.50 0.011 NA Panhandle East Flowing Waters NA 1.03 0.18 NA
Panhan dle West Flowing Waters NA 0.67 0.06 NA

North Central Flowing Waters NA 1.87 0.30 NA West Central Flowing Waters NA 1.65 0.49 NA

Peninsula Flowing Waters NA 1.54 0.12 NA Springs NA NA NA 0.35
Chl

- a = chlorophyll

- a Pt

- Co = platinum

- cobalt NA = not appl icable TN = total nitrogen TP = total phosphorus 1. Long

- term Color > 40 Pt

- Co 2. Long

- term Color ≤ 40 Pt

- Co and Alkalinity > 20 mg/L CaCO 3

. 3. Long

- term Color ≤ 40 Pt

- Co and Alkalinity ≤ 20 mg/L CaCO 3

.

For streams that are upstream of lakes, a more stringent downstream protection value (DPV) may apply. The applicable DPVs are expr essed as an annual geometric mean value not to be exceeded more than once in a three year period

. **CWA Section 303(d) Listing Procedures**

Florida WQS also contain procedures for identifying impaired waters. FDEP first evaluates existing water quality data t o develop a Plann ing List of potentially impaired waters for further assessment. FDEP then

assesses waters on the Planning List through additional data gath ering and strategic monitoring . Waters
that FDEP determine s a re impaired as a result of pollutant di scharges are placed on the Verified List

, which also represents the CWA Section 303(d) list of impaired waters for which it will develop a TMDL.

FDEP uses chlorophyll

- a concentration as the primary means for assessing whether an estuary should be

assessed further for nutrient impairment. FDEP also considers other information indicating an imbalance in flora or fauna due to nutrient enrichment, including, but not limited to, algal blooms, excessive macrophyte growth, decrease in the distribution (either in density or areal coverage) of seagrass or other submerged aquatic vegetation, changes in algal species richness, and excessive diel oxygen swings (Chapter 62

- 303, F.A.C.). FDEP includes estuaries, estuary segments, or open coastal waters on the planning li st for nutrients if the annual mean chlorophyll

- a for any year is greater than 11 μg/l or if data indicate annual mean chlorophyll

- a values have increased by more than 50% over historical values for at least two consecutive years.

To be placed on the veri fied list, FDEP requires sufficient data from the last five years preceding the planning list assessment, combined with historical data (if needed to establish historical chlorophyll

- a levels). If data are insufficient, FDEP must collect additional data to meet the requirements. Once these additional data are collected, FDEP determines if there is sufficient information to develop a site

- specific threshold that better reflects conditions beyond which an imbalance in flora or fauna occurs in the water.

If th ere is insufficient information, FDEP will reevaluate the data using the thresholds from the planning list. However, FDEP need not use these same thresholds in developing the TMDL.January 2012 2. Baseline for the Analysis

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- 3 2.1.2 Restoration of Designated Uses in Impaired Waters

FDEP implements nutrient criteria through TMDLs (see Section 2.3.2 ) and the NPDES permit program (see Section 2.1.3 ). A TMDL is a calculation of the maximum amount of a given pollutant that a water body can receive and stil l meet WQS, and an allocation of that amount to point and nonpoint source categories

. FDEP typically uses site specific data to translate narrative criteria into numeric concentration targets, numeric load targets, or percent reduction requirements. Numeri c nutrient concentration targets in TMDLs for TN and TP in estuaries, bays, and coasts range from 0.51 mg/L to 5.4 mg/L and 0.044 mg/L to 0.18 mg/L, respectively.

FDEP develops Reasonable Assurance (RA) Plans and Basin Management Action Plans (BMAPs) to

i mplement the controls necessary to attain TMDLs in impaired water bodies.

**Reasonable Assurance Plans**
RA plans provide reasonable assurance that proposed pollution control mechanisms will result in the restoration of designated uses in impaired waters. The re are two nutrient

- related RA plans for estuaries

and coasts in Florida: Tampa Bay and Florida Keys.

The Tampa Bay Comprehensive Conservation and Management Plan (TBNEP, 1996) established restoration of seagrass in the bay to levels estimated in the 1950 s as a primary goal for overall bay restoration. In establishing and addressing this goal, the TBNEP cited a number of studies from the 1990s that clearly established nitrogen as the limiting nutrient in the Tampa Bay estuary and indicated that phosphorus loadings to the bay from the enriched Bone Valley region were not controlling estuarine production. The Tampa Bay Estuary Program (TBEP) partners adopted a “hold

- the

- line” target for TN loadings that capped the segment TN loads at levels that would ensure adequate water clarity and light to sustain seagrass recovery based on average annual 1992

- 1994 TN for the four mainstem bay segments:

 Old Tampa Bay: 486 tons/year,

 Hillsborough Bay: 1451 tons/year,

 Middle Tampa Bay: 799 tons/year, and

 Lower Tampa Bay: 349 tons/year.

In January 1998, in accordance with the Clean Water Act Section 303(d)(2), the State of Florida submitted for EPA approval a proposed TMDL for Tampa Bay, including the 1992

- 1994 bay

- segment TN loads listed above. EPA approved the Tampa Bay TMDL as submitted by FDEP on June 18, 1998. Subsequent to the TMDL, the TBEP developed an RA plan to outline the load allocations and control measures necessary to restore designated uses to the estuary system. FDEP concluded that the most recent RA plan “cons titutes reasonable progress towards continued attainment of water quality standards of Tampa Bay related to nutrients.”

FDEP (2008b) also concluded that the plan provides continued reasonable assurance that impairment of designated uses related to nutrien ts in Tampa Bay will be adequately addressed. The TBEP (2010; 2011) reports that, since 1996, the Bay has attained the annual water quality targets (FDEP

- approved chlorophyll

- a thresholds) over 87% of the time, and seagrass coverage has expanded by approxi mately 5,980 acres to a baywide total of 32,900 acres (5,100 acres from the goal of 38,000 acres).

FDEP developed an RA Plan for the Florida Keys in cooperation with local governments, state agencies, and federal agencies within the Florida Keys . The plan set s forth actions that have been taken or are planned to be taken to reduce nutrient loadings to near shore waters throughout the Florida Keys to attainJanuary 2012 2. Baseline for the Analysis

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- 4 WQS and restore beneficial uses. FDEP reviewed and accepted t he plan and sent it to EPA for review and comment in February 2009. EPA has not yet taken action and the Department has not included the results in the recently adopted Group 5 Verified List of Impaired Waters. In the proposed RA Plans, FDEP expects applicable water quality targets (insignificant increase above farfield concentrations) to be achieved by 2020, when all committed wastewater and stormwater management activities are complete.

**Basin Management Action Plans**
To implement TMDLs, FDEP may develop BMAPs with local stakeholders. State law re quires FDEP to adopt BMAPs by Secretarial Order. These Orders are enforceable. BMAPs set forth the strategy for achieving the pollutant reductions established in the TMDL, including permit limits on wastewater facilities, urban and agricultural best manage ment practices (BMPs) , conservation programs, financial

assistance

, and revenue generating activities

.

FDEP has adopted five nutrient BMAPs to date , including one for eight estuarine segments in the Lower St. John’s River (LSJR). The BMAPs rely heavily on existing programs [e.g., NPDES program, BMP manuals (see Section 2.1.5 )]. For example, e xisting BMAPs for the LSJR , Orange Creek watershed, and Upper Ocklawaha River rely on voluntary implementation of BMPs by farmers through the Florida Department of Agriculture and Consumer Services (FDACS) BMP program . However, Subsection 403.067(7)(b), F.S., requires that nonpoint pollutant sources (such as agriculture) included in a BMAP demonstrate compliance with pollutant reductions est ablished to meet a TMDL either by implementing BMPs or by conducting water quality monitoring prescribed by FDEP or a water management district. Thus, if necessary, farmers could be required to implement approved BMPs.

2.1.3 Existing Regulations for Point Source Dischargers

**Permitting**
A number of rules and programs regulate point source dischargers into estuarine, coastal, and South Florida inland flowing waters. Rules 62

- 620.320(1) and 62

- 620.620(1)(g), F.A.C., establish that a permit shall be issued only if th e applicant affirmatively provides FDEP with reasonable assurance that the construction, modification, or operation of the discharge facility will not discharge or cause pollution in contravention of WQS. As part of the permit application process, the appl icant must supply data characterizing the pollutants that may be discharged and provide reasonable assurance that the discharge will not violate water quality criteria in the receiving water.

FDEP’s permit writer’s guidance manual ( FDEP , 2006b ) indicates t hat at a minimum permit writers

should include limits in permits for a parameter if there is evidence that the discharge could cause or contribute to instream violations. However, FDEP may also include limits based on EPA’s reasonable potential approach, w hich requires sufficient effluent data as described in its Technical Support Document for Water Quality

- Based Toxics Control (U.S. EPA, 1991) , or based on the judgment of the permit writer that a limit is necessary to provide RA that the facility will ope rate in a way that will not cause water quality violations (FDEP, 2006b ) . For example, for the current narrative nutrient criterion for waters not covered under a TMDL, permit writers determine whether the discharge contains phosphorus or nitrogen,

and exa mine the quality of the receiving water and any other affected waters with regard to nutrient levels and biological impacts.

Based on this analysis, permit writers determine the level of nutrients that would “cause an imbalance in natural populations of a quatic flora and fauna” and translates those levels into numeric “targets” for the receiving water and any other affected waters. If there is reasonable potential, permit writers calculate permit limits to ensure that such a discharge will not cause or co ntribute to an exceedance of the nutrientJanuary 2012 2. Baseline for the Analysis

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- 5 target levels. FDEP’s permit writer’s guidance manual (FDEP, 2006b) indicates that WQBELs are

calculated based on EPA’s Technical Support Document for Water Quality

- Based Toxics Control (U.S. EPA, 1991). If suffic ient data are not available to determine reasonable potential, the permit can be issued

with an effluent limit based on water quality criteria in Florida and an administrative order attached to the permit that requires the studies necessary to determine re asonable assurance with a schedule to return the facility to compliance with the final permit limits (FDEP, 200 6b ).

**TMDLs (WLAs)**

E xisting requirements for point sources also include wasteload allocations ( WLAs ) established in existing

nutrient

- related TMDL s and revised NPDES permit conditions that reflect these allocations . Generally,

the WLAs are based on existing allowable or permitted loads or a sp ecified percent reduction . For example, under t he Roberts Bay TMDL, the three point source dischargers recei ve a WLA based on a TN concentration of 3 mg/L (U.S. EPA Region 4, 2005). Thus, effluent limits in the NPDES permits remained the same, and reflect advanced wastewater treatment (AWT) standards. I n the Escambia Bay TMDL, WLAs for point sources are percent reductions in loads (23% for TN and 30.5% for TP) (U.S.

EPA Region 4 , 2007); however, effluent limits for TN and TP in NPDES permits for the 2 municipal WWTPs covered by the TMDL are based on AWT levels for TN (annual average of 3 mg/L) and TP (annual aver age of 1 mg/L for TP).

**Grizzle**

**- Figg Act** 

In addition, the Grizzle

- Figg Act of 1990 (F.S. 403.086) requires facilities discharging into Old Tampa Bay, Tampa Bay, Hillsborough Bay, Boca Ciega Bay, St. Joseph Sound, Clearwater Bay, Sarasota Bay,

Little Sarasot a Bay, Roberts Bay, Lemon Bay, or Charlotte Harbor Bay, or into any river, stream, channel, canal, bay, bayou, sound, or other water tributary thereto, to provide advanced waste treatment,

as defined below:

 Annual average biochemical oxygen demand (BOD) le ss than 5mg/L

 Annual average suspended solids less than 5mg/L

 Annual average TN less than 3mg/L

 Annual average TP less than 1mg/L

 High level disinfection.

These requirements do not apply to facilities permitted prior to February 1, 1987, and which dischar ge secondary treated effluent, followed by water hyacinth treatment, to tributaries of tributaries of the named waters; to facilities permitted to discharge to the nontidally influenced portions of the Peace River, or to septic tanks or other means of indi vidual waste disposal (which are otherwise subject to state regulation). In addition, in those waters where the concentrations of phosphorus have been shown not to be a limiting nutrient or a contaminant, FDEP may waive or alter the compliance levels for p hosphorus.

The Act also regulates wastewater discharges through ocean outfalls by prohibiting the construction of new ocean outfalls and the expansion of existing ocean outfalls for domestic wastewater discharge, requiring that all discharges of domestic wastewater through ocean outfalls meet advanced wastewater treatment and management requirements no later than December 31, 2018, and requiring all domestic wastewater facilities that discharged through an ocean outfall on July 1, 2008 to install a functio ning reuse system (i.e., provides a minimum of 60% of the facility’s actual annual flow for reuse applications by December 31, 2025), and prohibits the discharge of domestic wastewater through ocean outfalls afterJanuary 2012 2. Baseline for the Analysis

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- 6 December 31, 2025, except as a backup disc harge that is part of a functioning reuse system authorized by

FDEP.

**Indian River Lagoon and Monroe County Regulations**

There are also regulations requiring advanced waste treatment for dischargers to Indian River Lagoon and Monroe County waters:

 Indian Riv er Lagoon System and Basin Act of 1990, contained in Chapter 90

- 262, Laws of Florida

 Monroe County, Chapter 99

- 395, Laws of Florida

- by July 1, 2010 domestic wastewater discharges greater than 100,000 gpd must have advanced waste treatment.

2.1.4 Existing Regul ations for Urban Areas

Urban runoff from fertilizers applied to lawns , gardens, and golf courses, decomposition of natural rock and soils, air deposition from vehicle exhaust or power plants, detergents used to wash cars on the street, and pet waste can ac count for significant nutrient pollution in watersheds

. A number of rules and programs regulate discharges from urban areas.

**Urban Turf Fertilizer Rule**

To address nutrients from fertilizers, the FDACS adopted the statewide Urban Turf Fertilizer Rule , which limits the phosphorus and nitrogen content in fertilizers for urban turf and lawns

. The rule requires that all fertilizer products labeled for use on urban turf, sports turf

, and lawns be limited to the amount of nitrogen and phosphorus needed to support healthy turf maintenance. F DACS estimated a 20 % to 25% reduction in nitrogen and a 15% reduction in phosphorus in every bag of fertilizer sold to the public. The rule also

restrict s phosphorous and nitrogen application rates in fertilizers. 5 The rule becam e effective December 31, 2007 , with a requirement for f ertilizer labels to reflect compliance by July 1, 2009

.
**Local Fertilizer Ordinances**

As of May 2011, there are 36 local government s in Florida with strict rainy season urban fertilizer application ban s (Sierra Club Florida, 2011)

. These bans typically prohibit application of fertilizer containing nitrogen and/or phosphorous during the four rainy summer months (from June 1

- September 30), set a specific distance from water bodies which must remain fertili zer

- free, specify yearly application limit for nitrogen and/or phosphorus, and use of slow

- release/controlled release nitrogen products (Sierra Club Florida, 2011). Pinellas County also included a fertilizer sales restriction in its ordinance.

**EPA Stormwat er Program** 

EPA’s Phase I stormwater rule covers large and medium

- size MS4s [Clean Water Act Section 402(p) sources], and the Phase II rule covers small MS4s (systems serving less than 100,000 people). Generally, Phase I MS4s are covered by individual permi ts and Phase II MS4s are covered by a general permit.

There are 2 7 Phase I NPDES MS4 permits in Florida and 1 28 Phase II permits.

Each regulated MS4 is required to develop and implement a stormwater management program (SWMP)

to reduce the contamination of stormwater runoff and prohibit illicit discharges. The MS4 Program

5 A maximum of 0.25 lbs phosphorus oxide ( P 2 O 5 ) per 1000 sq. ft. per application and not to exceed 0.5 lbs P 2 O 5 per 1000 sq. ft. per year. Applica tion rates above these levels would require a soil sample of the application site to justify an increase in P 2 O 5
. A maximum of 0.7 lbs of readily available nitrogen per 1000 sq. ft. at any one time based on the soluble fraction of nitrogen

formulated in th e fertilizer. A maximum of 1 lb TN per 1000 sq. ft. to be applied at any one time, not exceeding the annual nitrogen recommendations in the Fertilizer Guidelines for Established Turf Grass Lawns in Three Regions of Florida. Application rates above these le vels would require a turf tissue test at the application site to justify the increase in TN.January 2012 2. Baseline for the Analysis

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- 7 contains elements called minimum control measures that when implemented should result in a significant reduction in pollutants discharged into receiving waters:

 Public Education/Outreach

– educate the community on the pollution potential of common activities,

increase awareness of the direct links between land activities, rainfall

- runoff, storm drains, and local water resources, and provide the public clear guidance on steps and specific act ions that they can take to reduce their stormwater pollution

- potential through use of brochures/pamphlets, mailers, posters, and training for local business employees

 Participation/Involvement

– build on community capital to help spread the message on prev enting stormwater pollution, to undertake group activities that highlight storm drain pollution, and contribute volunteer community actions to restore and protect local water resources; includes facilitating opportunities for direct action, educational, an d volunteer programs such as riparian planting days, volunteer monitoring programs, storm drain marking, or stream

- clean up programs

 Illicit Discharge Detection and Elimination

– develop a program to detect and eliminate illicit discharges which primarily includes developing a storm sewer system map, an ordinance prohibiting illicit discharges, a plan to detect and address these illicit discharges, and an education program on the hazards associated with illicit discharges

 Construction Site Runoff Control

– develop a program to reduce pollutants in stormwater runoff for construction sites disturbing one or more acres which primarily includes developing an ordinance, requirements to implement erosion and sediment control BMPs, requirements to control other was te at the construction site, procedures for reviewing construction site plans, procedures to receive and consider information submitted by the public, and procedures for inspections and enforcement of stormwater requirements at construction sites.

 Post

- Co nstruction Runoff Control

– address post

- construction stormwater runoff from new development and redevelopments that disturb one or more acres which primarily includes developing strategies to implement a combination of structural and non

- structural BMPs, an ordinance to address
post

- construction runoff, and a program to ensure adequate long

- term operation and maintenance of

BMPs.

 Pollution Prevention/Good Housekeeping

– develop inspection and maintenance procedures and schedules for stormwater BMPs, imple ment BMPs to treat pollutants from transportation infrastructure, maintenance areas, storage yards, sand and salt storage areas, and waste transfer stations, establish procedures for properly disposing of pollutants removed from the MS4, and identify ways to incorporate water quality controls into new and existing flood management projects.

**Florida Stormwater Rule**

A 1982 Florida rule [ as authorized in Chapter 403, Florida Statues ( F.S.) ] requires treatment of

stormwater from new development and redevelopmen t prior to discharge using BMPs designed to achieve a specific level of treatment (i.e., performance standards). The rule also requires that older systems be managed as needed to restore or maintain the beneficial uses of waters , and that water management

districts establish stormwater pollutant load reduction goals to be adopt ed as part of a Surface Water Improvement and Management ( SWIM ) plan , other watershed plan, or rule

. In addition, Chapter 62

- 40, F.A.C., “Water Resource Implementation Rule,” establi shes that stormwater design criteria adopted by FDEP and the water management districts shall achieve at least 80% reduction of the average annual load of pollutants that cause or contribute to violations of WQS (95% reduction forJanuary 2012 2. Baseline for the Analysis

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- 8 outstanding natural resou rce waters). The rule also states that the pollutant loading from older stormwater management systems shall be reduced as necessary to restore or maintain the designated uses of waters.

2.1.5 Existing Requirements for Agriculture

Phosphorus and nitrogen in agric ultural runoff come from application of fertilizer to crops and pastures,

and animal wastes. A number of rules and programs address nutrient discharges from these sources.

**FDEP Dairy Rule and CAFO Requirements**

Chapter 62

- 670, F.S. requires all concentrated animal f eed ing o perations (CAFOs) in the state of Florida that discharge water offsite to file an application for a NPDES permit with FDEP. It also prohibits discharge of process wastewater and runoff from any major egg production facility to surface wate rs except in the event of a 25

- year, 24

- hour storm event. In addition, dairy operations within the Lake Okeechobee Drainage Basin [as defined in 62

- 670.200 (8)] and its tributaries are also required to implement BMPs for the purpose of reducing phosphorus i nputs to the lake. Specifically, dairy farms in the Lake Okeechobee Drainage Basin must provide fencing to keep dairy cows away from surface water and have a system for waste collection, storage, and treatment, particularly in areas of high

- intensity use.

The rule also contains requirements for land application of waste, setback distance from surface water sources, and groundwater monitoring. The Dairy Rule does not establish a specific off

- site phosphorus discharge concentration limitation, but rather req uires BMPs to be incorporated into the operation of dairies. These BMPs need to provide reasonable assurances that each dairy could meet state water quality standards and that acceptable phosphorus levels in off

- farm discharges would be achieved (Chapter 6 2

- 670, F.A.C.). Although the Interim Lake Okeechobee SWIM Plan (SFWMD, 1989) established a maximum discharge limitation of 1.2 mg/L total phosphorus, the dairies are exempt from permitting and enforcement under the Works of the District (WOD) Program 6 , sin ce they are under the jurisdiction of the Dairy Rule.

T he national CAFO rule, 40 CFR 122.23(d)

, requires CAFOs that have the potential to discharge be

evaluated on a case

- by

- case assessment to determine whether the CAFO

, due to its individual attributes,

d ischarges or has potential to discharg e. Discharges from the CAFO include discharges of manure, litter, or process wastewater from land application areas under the control of the CAFO. Agricultural stormwater discharges from CAFO areas (i.e., areas where a nimal waste has been applied in accordance with site specific nutrient management practices that ensure appropriate agricultural utilization of the nutrients) are exempt.

**Agricultural BMP Manuals**

In 1999

, the Florida Watershed Restoration Act (FWRA) estab lished BMPs as the primary instrument for implementing the TMDL program in Florida . Under the FWRA (Section 403.067, F.S.), implementation of BMPs that FDEP has verified as effective and FDACS has adopted by rule provides a presumption of compliance with s tate WQS

. Participation in this program also provides a r elease from the provisions of

Section 376.307(5), F.S. which requires that funds be paid for damages from the discharge of pollutants.

As part of the manual development process, FDEP verifies the BM Ps as effective at reducing pollutant loading to waters. Under the program

, landowners maintain records and provide documentation regarding

the selection of BMPs utilized and reasons why certain BMPs are not applicable to their specific situation.

6 Each of the five water management districts in Florida has a WOD program. WOD represent canals, water control structures, rights

- of

- way, lakes and flowing waters and other water resources for which each district has responsibility or owns

.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 9 The BMP manuals provide assessment tools to assist operator s in determining the appropriate and applicable BMPs according to the type of farm and the basin where the farm is located.

For example, the re are three levels of BMPs for cow/calf operations. Level I BMP s are those that are largely applicable to all ranchers, and include nutrient management, alternative water sources for cattle, grazing management, general erosion and sediment control, water resource management, animal mortality disposal, conservation buf fers and fences, integrated pest management (IPM), and wellhead, wetlands, and springs protection. Ranchers may have to implement Level II and III BMPs based on assessments identifying water quality risk features that require special attention or protectio n; these BMPs focus on high intensity areas, livestock use exclusion, and address the need for grade stabilization structures for sediment control and list situations that require comprehensive grazing management practices.

For container nurseries, BMP pr actices include erosion control, fertilization management, irrigation management, pesticide management, nursery layout, waste management, and container substrate and planting practices. FDACS requests that nurseries assess current practices to identify whi ch BMPs are already in practice and to identify any additional BMPs necessary.

Sod growers must implement a minimum number of BMPs to establish a foundation for environm ental protection. Depending on site specific conditions or geographic location, the far mer could be exempt from implementing some of the minimum BMPs. As part of minimum BMP requirements farms must implement nutrient management, irrigation scheduling and maintenance, sediment and erosion control measures, integrated pest management, wellhead , wetlands and springs protection, ditch construction and maintenance, conservation buffers, stormwater management and mowing management. In addition, growers must also use the BMP decision

- tree in the manual to identify other BMPs that are applicable to

t he operation. For example, growers who run seasonal sod farming operations may have fewer BMPs, while those farming in spring recharge basins or special regulatory areas may have additional BMPs that apply.

There are several citrus BMP manuals for differen t locations such as Gulf citrus, Indian and Peace River citrus, and Florida Ridge citrus. For citrus growers, the suggested BMPs include reducing the impact of pesticide use, reducing excessive nutrients, minimizing sediment transport and growth of aquatic plants, and reducing runoff flowing off

- site.

For vegetable and agronomic crops, farmers first must inventory current farm practices and then use the manual to identify additional BMPs applicable to their farming operation. These may include farm ponds, filter strips, flood protection, IPM, irrigation scheduling, maintenance and evaluation, fertilization management, riparian buffers, erosion control measures, wellhead and wetlands protection, access road mitigation, and ditch construction and maintenance.

Under the FDACS program, farmers must submit a notice of intent (NOI) identifying the approved BMPs they intend to implement. I mplementing the approved BMPs provides a presumption of compliance with

state WQS and makes producers eligible for cost

- share fo r certain BMPs

. **Northern Everglades and Estuaries Protection Program**
The Northern Everglades and Estuaries Protection Program (formerly the Lake Okeechobee Protection Act; Section 373.4595, F.S.) is a phased watershed program to reduce phosphorus loads and implement long

- term solutions to meet the TMDL for Lake Okeechobee and its tributaries. The initial phase of phosphorus load reductions is based on the District's Technical Publication 81

- 2 and WOD program, with subsequent phases of phosphorus load reduct ions based on the TMDLs (the TMDL boundary corresponds to the revised rule boundary).January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 10 Under the program, the SFWMD developed the Lake Okeechobee Watershed Construction Project Phase

II Technical Plan , the Caloosahatchee R iver Watershed Protection Plan and the St. Lucie R iver Watershed

Protection Plan

. The major provisions and goals of these three plans are described in Exhibit 2

- 2

.


### Exhibit 2

- 2 : Plans Developed under t he Northern Everglades and Estuaries Protection Program

Plan Key Provisions and Goals Lake Okeechobee
Watershed Construction Project Phase II Technical Plan (SFWMD, 2008)  Implement BMPs on >1.7 million acres of farmland or demonstrate compliance through monitoring  Adopt regulations to reduce impacts of develop ment on water quality and flow  Build treatment wetlands to cl ean water flowing into the lake  Use “green” nutrient control technolo gies to reduce phosphorus loads  Create >900,000 acre

- feet of wa ter storage north of the lake through a combination of above

- ground reservoirs, underground storage and alternative water storage projects on public and private lands. Caloosahatchee
River Watershed Protection Plan (SFWMD, 2009a)  BMPs on >430,000 acres of agricultur e an d 145,000 acres of urban lands  Complete pro posed regulatory rule revisions  Construct approximately 36,000 acres of reservoirs and 15,000 acres of Stormwater Treatment Areas (STAs) an d Water Quality Treatment Areas  Target reduction of TP loa ds of up to 166 metric tons per year (39%) and TN loads of up to 1 ,840 metric tons per year (38%)  Restore more than 2,000 acres of wetlands within the w atershed  Provide approximately 400,000 acre

- feet of water storage within the w atershed St. Lucie River

Watershed Protection Plan (SFWMD, 2009b)  BMPs on > 297,000 acres of agriculture and 84,000 acres of urban lands  Complete proposed regulator y rule revisions  Construct approximately 11,800 acres of rese rvoirs and >8,500 acres of STAs  Reduce TP loads b y up to 209 metric tons (55%) and TN loads by up to 1,210 metric tons (56%)  Restore 95,000 acres of wetlands and natural areas within the wat ershed  Remove >8 million cubic yards of sediment  Provide approximately 200,000 acre

- feet of water storage withi n watershed

**Water Management District Rules** 
A number of water management districts in Florida have specific rules in the F.A.C. governing agricultural discharges to surface waters. T he applicable regulations , by Water Management District, are

summarized be low

.
South Fl orida Water Management District

F.A.C. Section 40E

- 61:

 Addresses the reduction of phosphorus to Lake Okeechobee based on the SWIM Plan.

 Each parcel of land within the watershed must have a permit and comply with water quality performance limi tations.

 Requires individual permits for parcels of land used for improved pasture, vegetable farms, and hog, poultry or goat farms located in certain sub

- basins that require farms to meet annual average phosphorus limits, as well as bi

- weekly monitoring.

 Parcels of land used for urban stormwater, nurseries, golf courses, land spreading of sludge, sugar cane, sod farms, or horse farms located in individual permit sub

- basins must obtain a general permit thatJanuary 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 11 requires submitting an application or NOI with a s tatement indicating how phosphorus discharges will be controlled and meeting off

- site phosphorus discharge concentration limits.

 Landowners located in other sub

- basins are covered under a general permit, however, they do not have to submit an application/N OI assuming they do not exceed applicable phosphorus discharge limits.

F.A.C. Section 40E

- 63:

 Requires that any lands in the Everglades Agriculture Area which discharges water have a permit with goal of reducing phosphorous loads by 25%.

 A parcel of land q ualifies for a general permit if it is a residential property <40 acres in size, not served by a central drainage system, or if it is commercial or industrial property <5 acres not served by a central drainage system.

 Individual permits are required for a ll structures which discharge water that do not qualify for a general or master permit. In the permit application, permittees describe BMP implementation and operation and provide a water quality monitoring plan.

 Master permits (same requirements as indivi dual permits) are for lands that are contiguous, have interconnected drainage systems, or coordinated BMP plans.

F.A.C. Section 5M

- 3:

 Enforces implementation of agricultural BMPs in the Lake Okeechobee watershed.

 Defines the phosphorus management require ments of agricultural producers necessary to receive a presumption of compliance with state water quality standards including those established under TMDLs.

 Farmer implementation of manuals provides a presumption of compliance with WQS for those pollutant s addressed by the practices. It also releases farmers from legal provisions requiring that funds be paid for damages from the discharge of pollutants.

Northw est Water Management District

F.A.C. Section 40A

- 44:

District issues general surface water managem ent permits, letters of conceptual approval, individual surface water construction permits, and individual operation and maintenance permits for forestry and agricultural surface water management systems.

Applicants must demonstrate that proposed projects will not cause unacceptable water quality and quantity impacts, will not cause discharges which result in violations of applicable water quality standards, and will not cause unacceptable adverse impacts to natural resources, fish, and wildlife.

St. Johns River Water Management District

F.A.C. Section 40C

- 44:

 Requires a permit for the maintenance and operation of existing agricultural surface water
management systems

 Requires reductions in the volume of stormwater and wastewater discharged to waters of the state by implementing management practices designed to reduce the volume of water discharged off

- site, maximizing on

- site recycling to satisfy irrigation, freeze protection and pest control needs, implementingJanuary 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 12 and maintaining a Conservation Plan, which inc ludes a Nutrient Management Plan and Pesticide Management Plan, and providing treatment of the pollutants generated by the agricultural operation

Southwest Water Management District

F.A.C. Section 40D

- 26:

 Provides funding assistance for the development of production

- scale BMPs for agriculture that will result in reductions in water use and improvements in water quality and to natural systems

 Water quality

- related projects eligible for the Program include implementation of BMPs that improve ground or surfac e water quality impacted by ground water withdrawals and that improve natural system

functions within the Upper Myakka River Watershed.

**Agricultural Assistance Programs**
To encourage implementation of BMPs and various conservation measures, there are severa l national programs including:

 Conservation Stewardship Program (CSP)

– a voluntary conservation program that identifies and rewards through incentives those farmers and ranchers who meet the highest standards of conservation and environmental management o n their operations

 Conservation Reserve Enhancement Program (CREP)

– program in which farmers receive payment to convert cropland and marginal pastureland to native grasses, trees, wetlands, and related conservation buffer practices to improve water qualit y, soil, and wildlife habitat

 Conservation T echnical A ssistance (CTA)

– program through which Natural Resource Conservation Service ( NRCS ) and its partners provide help to land users to address opportunities, concerns, and problems related to the use of na tural resources and to help land users make sound natural resource management decisions on private, trib al, and other non

- federal lands

 Environmental Quality Incentives Program (EQIP)

– a voluntary conservation program for farmers

and ranchers that offers financial and technical help to assist eligible participants install or implement structural and management practice s on eligible agricultural land

 Grazing Land Conservation Initiative (GLCI)

– financial and technical assistance to landowners to support im proved management of grazing land resources ; successful in assisting landowners apply new technology to improve livestock production efficiency while maintaining or im proving their natural

resources.

Exhibit 2

- 3 pr esents acres enrolled and levels of spending associ ated with the CSP, CTA, and EQI P programs in Florida for the most recent year available. State

- level data on CREP enrollment a re currently unavailable due to privacy restrictions in the Farm Security and R ural Investment Act of 2002. The GLCI does not report state

- level data on acres enrolled or spending levels.



### Exhibit 2

- 3 : Federal Agricultural Assistance Programs by Acres Enrolled and Program Spending

Pro gram Acres Enrolled in Florida Program Spending in Florida (Year)
CSP 65,279 $1.2 million (2010)
CTA Not available $9.3 million (2010) EQIP 2.2 million 1 $16.7 million (2008) 2
CSP = Conservation Stewardship Program CTA = Conservation Technical Assistanc e EQIP = Environmental Quality Incentives ProgramJanuary 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 13 

### Exhibit 2

- 3 : Federal Agricultural Assistance Programs by Acres Enrolled and Program Spending

Pro gram Acres Enrolled in Florida Program Spending in Florida (Year)
Sources: USDA (2011), USDA (2010), USDA (2009 ). 1. This value is an estimate of acres enrolled during fiscal year 2008, calculated by dividing spending in fiscal year 2008 on contracts issued in 2008 by the average spending per acre on all outstanding contracts in 2008. 2. EQIP spending data presented represents FY2008 spending on contracts issued 1997

- 2008. Florida EQIP spending in 2008 on contracts issued in 2008 only totaled $3.6 million.

2.1.6 Existing Requi rements for Forestry

Florida’s Division of Forestry (FDOF) controls nonpoint forestry dischargers of nutrients through the implementation of BMPs, as developed by the BMP Technical Advisory Committee and published in the Silviculture Best Management Practi ces Manual (FDOF, 2009). According to the manual, the BMPs reflecct “the minimum standards necessary for protecting and maintaining the State’s water quality as well as certain wildlife habitat values, during forestry activities,” and address many sources of pollution including sedimentation, nutrients, and turbidity. The manual contains 143 BMPs, within 14 categories organized by their application to different land types, waterbodies, activities, and special conditions.

One of the BMPs included in the ma nual is the designation and management of Special Management Zones (SMZs), which are areas associated with particular waterbodies that are subject to specific criteria to protect the water from nutrient, debris, and other sources of pollution. There may be one or more applicable SMZs for different waterbody types, including the primary zone (where some forestry activity may be allowed, but subject to stringent restrictions), the secondary zone (where forestry is not restricted but has some special requireme nts), and the stringer (which is a row of trees left at the bank to act as a barrier).

The manual describes other BMPs according to the waterbody affected or the activity being performed in close proximity to it, and many pertain to the SMZs. The most rel evant of these with regard to nutrient loading are those that relate to the application of fertilizer. For example, there can be no aerial application or transfer/loading stations in the primary zones (which are the most sensitive areas adjacent to

waterbo dies). There are also stated guidelines about how much fertilizer should be applied, and at what times, to minimize the potential for unintended migration of nutrients to the water, and stated maximum

per

- acre application rates.

Currently, BMPs are impleme nted primarily through educational outreach efforts such as workshops, demonstrations, and “master logger” certification classes to achieve forestry BMP implementation (FDOF, 2010). FDOF periodically conducts state

- wide surveys of silviculture practices to assess compliance levels, identify areas and foresters in need of further education, and evaluate the effectiveness of the BMPs. There have been 15 surveys since 1984, with the most recent in 2009. Over that period, the average compliance rate with all BM Ps has been 94%, with 84% in 1985 and 98% compliance in 2009. The 2009 survey report also indicated that the implemented BMPs were generally effective at preventing significant impacts to the relevant waterbodies, although the report presented little data to support this

conclusion (FDOF, 2010).

2.1.7 Existing Requirements for Septic Systems

Nutrients from poorly maintained or failing s eptic systems or onsite sewage treatment and disposal systems (OSTDSs) can threaten both surface and groundwater s. In addition t o runoff to surface water from mounded leach fields, nutrients can leach into groundwater beneath the system and be carried to nearby surface waters

.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 14 In Florida, the Bureau of Onsite Sewage Programs in the Florida Department of Health (FDOH) and the

envir onmental health section of County Health Departments regulate the use of OSTDSs. FDOH does not permit the use of an OSTDS where the estimated domestic sewage flow is over 10,000 gpd or the commercial sewage flow is over 5,000 gpd

, where there is a likeliho od that the system will receive toxic,

hazardous or industrial wastes

, where a sewer system is available

, or if any system or flow is currently regulated by FDEP , unless a variance from these prohibitions has been granted by FDOH.

2.1.8 Existing Requirements for Air Sources

Atmospheric deposition of nitrogen can be a significant source of nutrient loadings to bays, estuaries and

coastal waters. H owever, the specific sources of atmospheric nutrients are not typically well known and can originate from local, regio nal

, and international sources, including automobiles, power plants,

volcanoes

, and industrial air emissions.

Florida Air Quality Regulations place an ambient air quality limit on nitrogen dioxide of 0 .05 ppm (F.A.C. 62

- 204.240(5)). The major source of ni trogen dioxide is motor vehicle exhaust . O ther sources include electricity generation , emissions from poultry litter, and other manufacturing processes. There are no other nitrogen

- or phosphorus

- based pollutants that have air quality standards in Florida

, and atmospheric deposition is not considered to be a primary source of nutrient loading in the Southeastern United States (USGS, 2010).



### 2.2 E xisting Nutrient Discharge s

Sources of n utrient discharges to estuaries, coastal waters , and south Florida inland wate rs include wastewater point sources (e.g., municipal wastewater treatment plants (WWTPs), industrial facilities), urban stormwater, agricultural runoff, septic systems, and atmospheric deposition.

2.2.1 Wastewater Point Sources

EPA’s permit compliance system (P CS) database indicates that there are 198 municipal wastewater dischargers and 245 industrial dischargers with individual permits. 7 Many of these permittees discharge to lakes and flowing waters and are not affected by the proposed rule. Also, not all indu strial dischargers are likely to have the potential to discharge nutrients.

Given the nature of influent wastewater at municipal WWTPs, it is likely that all WWTPs have the potential to discharge nutrients. To identify industrial dischargers likely to disc harge nutrients, EPA identified those dischargers in PCS with either numeric effluent limits and/or monitoring requirements for nitrogen and phosphorus ( Exhibit 2

- 4 ). Note that the discharger counts in the exhibit include discharges to all waters in the states (e.g., lakes, streams, estuaries, and coastal waters).



### Exhibit 2

- 4 : NPDES Dischargers with Numeric Effluent Limits and Monitoring Requirements for Nitrogen and Phosphorus in Florida 1

SIC Code SIC Code Description No. with Nutrient Effluent Limits No. with Nutrient Monitoring Requirements

7 There are also 34,508 municipal and industrial dischargers covered under generic or general permits . FDEP regulat es these dischargers based on categories of wastewater facili ties or activities that involve the same or similar types of operations or

wastes

. EPA did not include these dischargers in its analysis.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 15 Majors Minors Majors Minors

0174 Citrus Fruits 1 0 1 0

1099 Miscellaneous Metal Ores, NEC 0 0 0 1

1422 Crushed and Broke n Limestone 0 0 0 1

1475 Phosphate rock 14 1 15 5

1479 Chemical and fertilizer mineral mining, NEC 1 0 1 0

2015 Poultry slaughtering and processing 1 0 1 0

2033 Canned fruit and vegetables 1 1 1 1

2034 Dried and Dehydrated Fruits, Vegetables, and Soup Mixes 0 1 0 1

2037 Frozen Fruits, Fruit Juices, and Vegetables 0 0 0 1

2082 Malt beverages 0 2 0 2

2085 Distilled and blended liquors 0 1 0 2

2491 Wood Preserving 0 0 0 2

2499 Wood Products, NEC 0 0 0 1

2611 Pulp Mills 2 3 0 0

2621 Paper Mills 0 0 1 0

2631 Paperboard Mills 0 0 2 0

2821 Plastics Materials, Synthetic Resins, and Nonvulcanizable Elastomers 0 0 1 0

2824 Manmade Organic Fibers, Except Cellulosic 0 0 2 0

2869 Industrial Organic Chemicals, NEC 0 1 0 1

2873 Nitrogenous fertilizers 0 1 0 2

2874 Phosphatic fertilizers 12 16 1 1

2879 Pesticides and agricultural chemicals, NEC 1 0 1 0

2892 Explosives 1 0 1 0

3582 Commercial Laundry, Drycleaning, and Pressing Machines 0 0 0 1

3679 Electronic Components, NEC 0 0 0 1

3699 Electrical mach inery, equipment, and supplies, NEC 0 1 0 1

3822 Automatic Controls for Regulating Residential and Commercial Environments and Appliances 0 0 0 6

4011 Railroad haul line operating 0 2 0 2

4226 Special Warehousing and Storage, NEC 0 0 0 1

4911 Electric services 6 0 13 0

4931 Electric and Other Services Combined 0 0 0 1

4941 Water supply 0 8 0 20

4952 Wastewater treatment plants 78 0 46 53

4953 Refuse Systems 0 1 0 2

4959 Sanitary Services, NEC 1 0 1 0

5146 Fish and Seafoods 0 0 0 1

5169 Chemicals and Allied Products, NEC 0 0 0 1

5171 Petroleum Bulk stations and Terminals 0 0 0 1

5541 Gasoline Service Stations 0 0 0 1

7996 Amusement parks 0 4 0 6

8422 Arboreta and Botanical or Zoological Gardens 0 0 0 1January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 16 

### Exhibit 2

- 4 : NPDES Dischargers with Numeric Effluent Limits and Monitoring Requirements for Nitrogen and Phosphorus in Florida 1

SIC Code SIC Code Description No. with Nutrient Effluent Limits No. with Nutrient Monitoring Requirements Majors Minors Majors Minors

8733 Noncommercial Research Organizations 0 0 0 1

9511 Air and Water Resource and Solid Waste Management 0 0 0 2

9999 Nonclassifiable 0 1 0 0
Total 119 44 88 123 Source: U.S. EPA (2010 b ), accessed June 2010. Major = generally discharge greater than 1 mgd and have the potential to discharge to xics in toxic
amounts Minor = generally discharge less than 1 mgd and do not discharge toxics in toxic amounts. NEC = not elsewhere classified SIC = Standard industrial classification 1. Including TN, ammonia, nitrate, and organic nitrogen, and TP.

Based on these industrial categories, Exhibit 2

- 5 summarizes the number of NPDES

- permitted wastewater dischargers in Florida that may be affected by the proposed rule (i.e., those with potential to

d ischarge nutrients t o estuaries

, coastal waters , or south Florida inland waters )

. Based on FDEP (2010 d ) analysis, EPA assumed that stormwater treatment areas and drinking water treatment plants would not be

affected. 8



### Exhibit 2

- 5 : Summary of NPDES Dischargers in Florida Potentially Affected by Numeric Nutrient Criteria for Estuaries, Bays, and Coastal Waters 1

Discharger Category Major Dischargers Minor Dischargers Total Municipal Wastewater 69 3 8 10 7
Industrial Wastewater 2 2 7 24 5 1

Total 9 6 62 1 58 Source: U.S. EPA (201 1 ). SIC = Standard Industrial Classification TMDL = total maximum daily load 1. Excludes dischargers to lakes and streams except those to South Florida canals (identified based on receiving waterbody name and information contained TMDLs, permits, and laboratory reports). 2. For majors dischargers includes SIC codes 1475, 1479, 2015, 2611, 2621, 2631, 2821, 2824, 2874, 2879, 2892, and 4911; for minor dischargers includes SIC codes 1099, 1422, 1475, 2033, 2034, 2037, 2082, 2085, 2491, 2499, 2611, 2869, 2873, 2874, 3582, 3679, 3699, 3822, 4011, 4226, 4931, 4941, 4952, 4953, 5146, 5169, 5171, 5541, 7996, 8422, 8733, 9511, and 9999.

2.2.2 Stormwater

There are 27 Phase I MS4 permits and 133 Phase II MS4 permits in the st ate. Most of these permits cover discharges to both fresh and marine waterbodies. Under existing permits, these entities implement stormwater controls that target a number of pollutants including nutrients. For example, in 2009, FDEP’s TMDL Water Quality R estoration Grants Program funded almost $111 million in structural storm water controls treating approximately 156,000 acres and estimated to remove approximately 204,000 pounds of TN and 30,000 pounds of TP (FDEP, 2010a), as summarized in Exhibit 2

- 6

.

8 FDEP (2010) assumed that reject wastewater from drinking water facilities (SIC 4941) will be disposed by other means than surface water discharge and that stormwater treatment areas (SIC 3822) developed for Everglades restoration efforts within th e Everglades Protection Area have separate criteria and are not included.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 17 

### Exhibit 2

- 6 : Summary of MS4 Stormwater Control Projects in Florida

Number of Projects Total Cost of Projects Area Treated (acres) TN Reduction (lbs/yr) TP Reduction ( lb/yr)
40 $110.9 million 155,976 204,054 29,828 Source: FDEP (2010a).

2.2.3 Agriculture

The 2007 Census of Agriculture (USDA NASS, 2009) indicates that there are 47,463 farms and

9.2 million acres of farmland in Florida. Three million of these acres are crop land, of which 1.6 million acres are irrigated. Livestock and poultry inventory includes 1.7 million cattle; 20,000 hogs and pigs;

11.8 million layers; and 73 million broilers and other chickens.

Farmers implement BMPs as part of the FDACS BMP program desc ribed in Section 2.1.5

. Exhibit 2

- 7 shows the number of acres that farmers have enrolled in the FDACS BMP program.



### Exhibit 2

- 7 : Summary of Agricultural Lands Enrolled in FDACS BMP Program FDACS BMP Program Type Number of Acres
Citrus 509,553
Cow/Calf 448,602

Dairies 37,535 Equine 75
Grasses 3,271
Leatherleaf Ferns 144 Nursery 20,662 Poultry Feeding Operations 312 Row Crops 754,71 3
Sod Farms 33,813 Specialty Farms 306

Tri

- County Agricultural Area 3,841

Total 1,812,827 Source: Based on GIS analysis of 2010 FDACS data on enrollments.

2.2.4 Septic Systems

There are 944,006 septic systems in Florida , of which 802,500 are active (FDOH, 2011 ). Most of the septic systems in Florida are over 30 years old and were installed under standards less stringent than current standards. In the 2008 Clean Watershed Needs Survey (U.S. EPA, 2010 b ), the state identified approximately $10.3 billion in ca pital need for decentralized wastewater treatment to address a water quality or a water quality

- related public health problem existing as of January 1, 2008, or expected to occur within the next 20 years. These costs represent capital expenditures associat ed with the rehabilitation and replacement of septic systems and clustered (community) systems

.
2.2.5 Atmospheric Deposition

Atmospheric deposition of nutrients from fossil fuel combustion and other activities can represent a

substantial source of nutrient load ing to waterbodies in Florida (Paerl et al. 2002). The Tampa Bay Nitrogen Management Consortium’s 2009 Reasonable Assurance Addendum found that atmosphericJanuary 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 18 deposition contributed 29% of the TN load in Old Tampa Bay, 33% in Middle Tampa Bay, 75% in Lower

Ta mpa Bay, and 4% in Hillsborough Bay (TBEP, 2010). In Florida Bay, atmospheric deposition accounts for 11% of TN and TP deposition (FDEP, 2010a).

In current TMDLs, FDEP has utilize d several methods to calculate deposition rates. In the nutrient budget

for the Lower St. Johns River Estuary, FDEP used deposition rates from Pollman and Roy (2003), which estimated atmospheric contribution at 2% of TN loading and 10% of inorganic N loading (Magley and Joyner, 2008). For Roberts Bay, FDEP (2005 a ) calculated atmo spheric deposition loads by converting wet deposition rates from a nearby National Atmospheric Deposition Program monitoring station to total nitrogen, and assuming that dry deposition contributed an equal amount to wet deposition (FDEP, 2005).

In 2004, t he most recent year for which data was available, FDEP estimated that atmospheric deposition contributed 10,700 pounds of TN per year to Roberts Bay (FDEP, 2005). Gao ( 2009 ) used a similar method for the Indian River Lagoon, where atmospheric deposition co ntributes 618,570 pounds of TN per year and 13,972 pounds of TP per year, which is 19% of nonpoint source TN and 3% of nonpoint TP (Gao, 2009 ). Both the Lower St Johns River Estuary and the Roberts Bay TMDLs indicate that phosphorus deposition is not signi ficant.

Given the wide range of deposition rate estimates for Florida estuaries, atmospheric deposition may be a significant source of nutrient loading in certain specific estuaries, but the significan ce of the contribut ion

to estuaries, coastal waters , an d south Florida inland waters statewide that are not currently listed as impaired is uncertain

.


### 2.3 Current Water Quality Impairments

FDEP has previously determined that several waterbodies exceed the existing narrative nutrient WQS, as

identified on the Flori da CWA Section 303(d) list

.
2.3.1 Category 5 Waters on State 303(d) List

Exhibit 2

- 8 shows the number of waterbody segments or count of waterbody identification (WBIDs) labels listed as impaired for nutrients and/or diss olved oxygen (DO). TMDLs for DO impairments typically limit TN and/or TP concentrations as a means of achieving the DO targets, although DO impairments could also be due to excessive biological oxygen demand or other causes not related to

excess TN or TP. Category 5 waters are those impaired waters for which a TMDL is needed but has not yet been completed. Thus, the list in Exhibit 2

- 8 does not include WBIDs for which FDEP or EPA has developed a draft or final TMDL ( see Section 2.3.2 for list of TMDLs).



### Exhibit 2

- 8 : Summary of CWA Section 303(d) Listed Estuary Impairments for Nutrients
in Florida 1

Impairment Listing Number of WBIDs 2

Nutrients 36 DO 22 Both (Nutrients and DO) 36
Total 94 Source: FDEP (2011 ) DO = Dissolved Oxygen WBID = waterbody identification 1. Does not include waterbodies for which a TMDL has already been approved. 2. Includes estuaries, coastal wate rbodies, and beaches.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 19 2.3.2 Nutrient TMDLs

As of 2011, t here are approximately 116 WBIDs for estuaries and coastal waters covered under TMDLs

or RAs for nutrients, as show in Exhibit 2

- 9

.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 20 

### Exhibit 2

- 9 : Summary of Nutri ent

- Related TMDLs for Estuaries and Coa sts in Florida

TMDL/ Waterbody TMDL Year WBIDs Total Nitrogen Total Phosphorus
TMDL (lbs/yr) Percent Reduction Target (mg/L) TMDL (lbs/yr) Percent Reduction Targe t (mg/L)
Alafia River Tidal Segment 2009 1621G

- 54% 0.65

- - -

Allen Creek Tidal 2009 1604

- 51.5% 0.75

- - -

Arlington River 2009 2265A

- - - - - - Banana River above Barge Canal 2009 3057C 116,314

- - 7,825

- -

Banana River below Mathers, Banana Ri ver

above 520 Causeway 2009 3057A, 3057B 144,780

- - 12,181

- -

Bessey Creek 2008 3211 29,981

- 0.72 3,373 0.081 Bishop Creek
Tidal 2009 1569

- 32.3% 0.75

- - -

Black Point

Channel 2009 1637 164,120

- - - - - Boggy Bayou 2011 692 8,115 40%

- 500 37%

- Brushy Creek 2009 1498

- - 0.75

- - - Bullfrog Creek Tidal Segment 2009 1666A

- 47% 0.65

- - -

C

- 23 Canal 2008 3200 242,202

- 0.72 27,248

- 0.081 C

- 24 Canal 2008 3197 348,957

- 0.72 39,258

- 0.081 C

- 44 Canal 2008 3218 242,929

- 0.72 27,330

- 0.081 C aloosahatchee River 2009 3240A, 3240B, 3240C 9,086,094

- - - - - Cockroach Bay 2009 1778

- 54% 0.54

- - - Coffee Pot Bayou 2009 1700

- 33% 0.63

- - -

Coral Creek

- East Branch 2010 2078B

- - 0.74

- - 0.044

Cross Canal

-

North Tidal 2009 1625

- 54.8% 0. 75

- - -

Double Branch 2009 1513 F

- 42.75% 0.75

- - - Escambia Bay 2007 548A A, 548AC - 22.9%

- - 30.5%

-

Florida Everglades (Agriculture Area) 2007 3252A, 3252C, 3260, 3263, - - - - - 0.1

Florida Everglades (Protection Area) 2007 3252B, 3265F, 3265H - - - - - 0.16

Florida Keys 2008 [1] [1] [1] [1] [1] [1] [1] Hendry Creek 2008 3258B

- - 0.74

- - 0.6 Imperial River 2008 3258E 18,865

- 0.74

- - -

Indian River above 520 Causeway 2009 2963D 147,524

- - 11,845

- -

Indian River above M. Brewer 2009 2963 F 177,220

- - 9,320

- -January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 21 

### Exhibit 2

- 9 : Summary of Nutri ent

- Related TMDLs for Estuaries and Coa sts in Florida

TMDL/ Waterbody TMDL Year WBIDs Total Nitrogen Total Phosphorus
TMDL (lbs/yr) Percent Reduction Target (mg/L) TMDL (lbs/yr) Percent Reduction Targe t (mg/L)
Indian River above Melbourne Causeway 2009 2963B, 2963C 189,068

- - 20,592

- -

Indian River above NASA

Causeway 2009 2963E 173,232

- - 14,793

- -

Klosterman Bayou Tidal

Segment 2008 1508 1,331

- - - - -

Lake Tarpon Canal Fresh 2 009 1541B

- 47% 0.75

- - - Lake Tarpon Canal Marine 2009 1541A

- 32.3% 0.75

- 26.5% 0.18

Lake Wauberg Outlet 2003 2741 2,062.4 51% 1.01 373.7 50% 0.056

Lower Rocky Creek 2009 1563

- 54.5% 0.75

- - -

Lower St. John's
River 2008 2213A to 2213H 3,035,446

- 5.4

- - -

Lower Sweetwater Creek 2004 1570A 57,565 20%

- - - -

Manual Branch 2011 3240I 37,093 20% 0.53 8,490 10% 0.12

McKay Bay 2009 1584B

- * 22% 0.62

- - - Moccasin Creek 2009 1530

- 40.6% 0.75

- 40% 0.18 Mullet Creek Tidal 2009 1575

- 36.7% 0.75

- - -

Myrtle Slough 2009 1995 163,656 24.28%

- 39,068 24.38%

- Myrtle Slough 2009 2054 1,300,729 23.67%

- 312,000 23.50%

- Newfound Harbor 2009 3044A 30,661

- 3,247

- - Nonsense Creek 2009 1913

- - 0.89

- -

North Fork St. Lucie Estuary 2008 3194B 10 3,747

- 0.72 11,672

- 0.081

North Fork St.

Lucie River 2008 3194 140,134

- 0.72 15,765

- 0.081

North Prong Alligator Creek 2009 2071 15,481 48.07%

- 3,699 47.88%

-

Palm River 2009 1536E

- * 35% 0.62

- - - Peace River Lower Estuary 2009 2056A 8,525,972 2 7.81%

- 2,038,559 27.79%

-

Peace River Mid Estuary 2009 2056B 8,097,090 27.23%

- 1,936,430 27.23%

- Phillippi Creek 2009 1937 73,365 70%

- 20,440 70%

- Prarie Creek 2009 1962 510,831 23.72%

- 122,326 23.69%

- Roberts Bay 2005 1968D 679,090 0.6%

- - - - Rocky Creek 2004 1507, 1507A 59,860 61% 0.51 10,585 59% 0.09

Old Tampa Bay 1998 1558F to 1558I 971,995

- - - - - Hillsborough Bay 1998 1558D, 1558E 2,902,115

- - - - -January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 22 

### Exhibit 2

- 9 : Summary of Nutri ent

- Related TMDLs for Estuaries and Coa sts in Florida

TMDL/ Waterbody TMDL Year WBIDs Total Nitrogen Total Phosphorus
TMDL (lbs/yr) Percent Reduction Target (mg/L) TMDL (lbs/yr) Percent Reduction Targe t (mg/L) Middle Tampa Bay 1998 1558B, 1558C 1,597,970

- - - - - Lower Tampa Bay 1998 1558A, 1558BZ 697,880

- - - - -

Six Mile Creek 2009 1536F

- * 32% 0.62

- - - Smacks Bayou 2009 1683 37% 0.63

- - - South Fork St. Lucie Estuary 2008 3210 24,463

- 0.72 2,752

- 0.081

South Fork St.

Lucie River 2008 3210A 90,471

- 0.72 10,178

- 0.081

South In dian River 2009 5003B, 5003C 278,273

- - 53,599

- -

South Indian River, Indian River above Sebastian Inlet 2009 5003D, 2963A 684,715

- - 111,594

- -

Spruce Creek 2008 2674A

- - - - - 0.16 St. Lucie Estuary 2008 3193

- - 0.72

- - 0.081 Stevenson Creek 2 008 1567 39,915

- - - - - Sweetwater Creek 2009 1516

- 22.7% 0.75

- - -
TMDL = total maximum daily load WBID = waterbody identification

“

- ” = value not specified or determined in TMDL “*” = TMDL defined in terms of concentration and not a daily load.
1. Reasonable assurance document for Florida Keys i ncludes WBIDs: 6005EB, 6006A, 6006B, 6009, 6011A to 6011C,
6012A to 6012D, 6013A to 6013D, 6014A to 6014C, 6016, 6017, 6018, 6019. Load allocations equal an in significant increase in natural background conce ntration at 500 meters ( insignificant means less than 10 μg/l for TN and 2 μg/l for TP and background means the Halo Zone condition in the absence of anthropogenic loads ).

FDEP typically develops plans for implement ing TMDLs through the BMAP process

. Cur rently, BMAPs

cover 8 estuary WBIDs , and an additional 32 WBIDs are covered under Reasonable Assurance

document s

. For the eight marine WBIDs in the Lower St. Johns River watershed, the BMAP indicates that reductions are needed from point and nonpoint sour ces. For example, the BMAP allows for aggregate permits (combined allocations with MS4 allocations) for municipal WWTPs that likely require upgrade to advanced water treatment (LSJR TMDL Executive Committee , 2008). For agriculture runoff, the BMAP specifie s implementation of FDACS BMP manuals and construction and operation of regional storm water facilities (LSJR TMDL Executive Committee , 2008). For urban runoff, the BMAP identifies continued implementation of MS4 permits, designation of certain non

- MS4 are as as Phase II MS4s, and voluntary permit trading schemes as measures that would likely reduce nutrient loads (LSJR TMDL
Executive Committee , 2008). The BMAP also suggests phase

- out of septic systems in specific watershed areas (LSJR TMDL Executive Committ ee , 2008).

Exhibit 2

- 10 provides a map of the WBIDs that are on the state’s CWA Section 303(d) list for nutrients

, have a nutrient

- related TMDL or RA , or that EPA determined to be impaired under the inland waters

n utrient rule

.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 23 

### Exhibit 2

- 10 : Map of Baseline WBID Impairments related to Nutrients in Florid a

2.4 Summary of Assumptions and Uncertainties

This section summarizes the assumptions EPA made regarding the baseli ne for analyzing the potential incremental impacts of the proposed rule.

2.4.1 Regulatory Framework

The current regulatory framework in Florida with respect to nutrients in estuaries, bays, and coasts includes existing water quality criteria and procedures for i dentifying waters as exceeding the nutrient WQS. FDEP is addressing current impairments through requirements on a range of sources, established inJanuary 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 24 BMAPs. In addition, regulations of specific sources (e.g., storm water, certain agricultural producers)

addre ss nutrients and other pollutants in discharges, and require actions that will reduce nutrient pollution.

Because the costs and benefits of nutrient controls implemented as a result of existing regulations (e.g., MS4 permit requirements, FDEP dairy rule), BMAPs, TMDLs, or 303(d) listings will be incurred without

th e proposed rule, these requirements represent the baseline of this analysis . EPA assumed that additional controls would not be needed for these waters or areas even in cases in which existing TMDL or BMAP targets are less stringent than EPA’s proposed criteria because EPA assumed that FDEP will likely pursue approval of TN and TP targets established under existing TMDLs as site specific alternative criteria (SSAC) . Thus, EPA did not include in this analysis costs associated with the following:

 Actions necessary to meet existing NPDES permit conditions for municipal and industrial

wastewater

 Control actions established in existing BMAPs

 Control actions needed to reduce nutrients in waters on the 303( d) list or covered under TMDLs

 BMPs for the forestry sector

 Controls required by the FDEP Dairy Rule and EPA CAFO regulations

 Phase I and Phase II MS4 Permits

 Requirements for urban areas developed after 1982 under Florida’s stormwater rule

 Urban Turf Fert ilizer Rule.

EPA also assumed that controls that it estimated may be necessary for attainment of its December 2010 rule establishing numeric nutrient criteria for lakes and flowing waters in Florida are not attributable to the proposed rule. Thus, in estim ating the incremental impact of the proposed rule, EPA identified the level of new requirements that may be needed in each potential source sector . Note that these assumptions could result in over or under estimation of potential costs and benefits because it is uncertain how effective baseline controls will be in reducing nutrients to the necessary levels under the proposed rule.

2.4.2 Sources of Nutrients

Municipal WWTPs and industrial wastewater dischargers in certain sectors have a reasonable potential to

dis charge nutrients at levels that may contribute to the exceedance of EPA’s numeric nutrient criteria. Nonpoint sources, including urbanized and developed land, agricultural land, and septic systems are also possible sources of nutrients. Due to the extent o f implementation of BMPs in forestry however, EPA assumed that loads from forest land are not likely to be substantial. Thus, this analysis is based on the following assumptions:

 All municipal wastewater sources discharg ing to applicable waters are potenti ally affected by the

rule ;  Industrial dischargers in sectors that include dischargers with current effluent limits or monitoring requirements for nutrients are potentially af fected by the rule ; and
 Urban and agricultural land and septic systems may need co ntrols for waters to attain standards.

In contrast, loads from forest land may not substantially impact bays, estuaries, and coasts given the existing extent of BMP implementation in the forestry sector. Data are insufficient on atmospheric deposition of n utrients to estuaries, coastal waters, and south Florida inland waters for EPA to estimate the potential need for controls.January 2012 2. Baseline for the Analysis

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  2

- 25 2.4.3 Water Quality

FDEP has already listed numerous lakes and flowing waters for nutrient

- related impairment under the existing narrative nutrient criteria, and developed TMDLs for many of these waters. Some of these TMDLs established TN and TP targets, and these targets are either higher or lower than the EPA numeric

criteria. I n estimating the incremental impacts associated with the rule

, EPA made the following assumptions with respect to current water quality:

 The costs and benefits of nutrient controls for point and nonpoint sources that are already required under existing nutrient

- related TMDLs are not attributable to this proposed rule

.  Development of TMDLs for waters on the current 303(d) list for nutrient

- related impairment and the costs and benefits of nutrient controls needed to attain future TMDL targets associated with these impaired waters are not attributable to this rule.

 FDEP will likely pursue approval of TN and TP targets established under existing TMDLs as site specific alternative criteria (SSAC) such that this rule will not result in incremental costs or benefits to waters under existing TMDLs.

Using these assumptions, EP A identified waters that may be identified as impaired under the rule but are not currently on the 303(d) list or under a TMDL (potential incremental impairments).January 2012 3. Description of the Proposed Rule

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  3

- 1 

## 3 Description of the Proposed Rule

This section describes the proposed rule establishing nu meric nutrient criteria for estuaries, coastal waters, and canal s and natural waters in South Florida , and describes how EPA estimated potential attainment of the proposed criteria

.


### 3.1 Proposed Criteria

EPA is proposing criteria for coastal waters and estuari es, inland waters that flow into coastal waters and estuaries (downstream protection values), tidal creeks, and marine lakes.

3.1.1 Coastal Waters

The proposed rule establishes numeric criteria for chlorophyll

- a for coastal WBIDs not in South Florida

. The propos ed criteria represent annual geometric mean value s not to be exceeded more than once in any consecutive three year period. Appendix A provides the proposed criteria for the affected WBIDs

.
3.1.2 Estuaries

The proposed rule establishes numeric criteria for TN, TP , and chlorophyll

- a for 23 estuary watersheds, divided into 126 individual segments. The proposed criteria represent annual geometric mean values not to be exceeded more than once in any consecutive three year period. Appendix A provides the proposed

crite ria for each segment.

3.1.3 South Florida Marine Waters

The proposed rule establishe s numeric criteria for TN, TP, and chlorophyll

- a for 40 marine segments along the South Florida coast. The proposed criteria represent annual geometric mean value s not to be

exce eded more than once in any consecutive three year period. Appendix A provides the proposed criteria for each segment.

3.1.4 Downstream Protection Values

The downstream protection values (DPVs) a pply at pour points entering estuary watersheds. The DPV

criteria ar e the same as the criteria for the segment to which each pour point empties.

3.1.5 Tidal Creeks

Tidal dominated c reeks are small sub

- estuaries containing a mix of tidal and freshwater flows.

3.1.6 Marine Lakes

Marine lakes are land

- locked water bodies that maintain marine character through narrow submarine

connections to the ocean. In Florida, m arine lakes have the same conductivity and alkalinity levels as

some freshwater lakes . Thus

, the proposed rule establishes the same proposed criteria for marine lakes

that EPA promulgated for clear lakes

. Note that EPA included analysis of marine lakes in its economic analysis for the 2010 inland (freshwater) nutrient criteria rule

.January 2012 4

. Potentially Incrementally Impaired Waters

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  4

- 1 

## 4 Potentially Incrementally Impaired Waters

This section provides a description of the data and methods EPA used to evaluate whether Florida estuaries, coastal waters, and inland flowing waters in South Florida are currently attaining the proposed
criteria. EPA also presents in this section the results of the analysis, and a summary of land use

surro unding waters that may not attain the proposed criteria.



### 4.1 Data

FDEP maintains a database of ambient water quality monitoring data for waters across the state and periodically updates this database under t he impaired waters rule (IWR). The IWR database d oe s not contain data for every WBID potentially affected under the rule because FDEP has not monitored all

waters. However, the IWR database is the most extensive source of nutrient monitoring data available.

In 1996, FDEP redesigned its watershed monitoring approach, segregating water quality monitoring into

three tiers:

 Tie r 1 includes regular monitoring, using a probabilistic monitoring design to estimate water quality across the state on the basis of a representative subsample of waterbodies.

 Tier 2 provi des more intensive monitoring of waterbodies identified as impaired or at risk; FDEP implements it through strategic monitoring plans (SMPs) at the state water management

district level.

 Tier 3 monitoring is intensive monitoring for the development of TMDL s or the investigation of variances or site specific alternative criteria (SSAC).

Tier 1 is implemented through two mechanisms: the Status Network and the Trend Network. Ther e are 52

basins in Flor ida, divided into 5 districts. Through the Status Network, one basin from each district is

assessed each year. FDEP established the ordering of these assessments on the basis of various priority factors such as whether the water includes surface water drinking sources, whether a TMDL must be developed for the wate r, or wh ether SWIM plans are underway. FDEP divides waterbodies into categories (large lakes, small lakes, large rivers, small rivers, confined aquifers, and unconfined aquifers) and randomly chooses a selection of each for monitoring.

Surface water monito ring through the Trend Network consists of 75 fixed location sites in flowing waters

that a re sampled on a monthly basis. These sites enable FDEP to obtain chemistry, discharge, and loading data at the point where land use activities may have a large effec t on the watershed. In addition, some sites are located at or near the Florida State boundary with Alabama and Georgia to obtain chemistry and loading data for m ajor streams entering Florida. The sites are not designed to monitor point sources of pollution and are specifically located away from known outfalls or other regulated point source dischargers.

Special monitoring is also done on a subset of waterbodies that are identified as imp aired or potentially impaired. After regular monitoring, FDEP identifie s data gaps regarding these waterbodies and

determines the number of samples for each para meter that are needed to allow assessment using the IWR

process as described in Section 2.1.1

. FDEP then prioritized these needs accordin g to EPA’s categories for identifying monitoring needs:

 Any WBID on the 1998 303(d) list of impaired waters.January 2012 4

. Potentially Incrementally Impaired Waters

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  4

- 2  Potentially impaired waters for which additional data are needed, including those identified in the

IWR.

 Waters for wh i ch verified impaired th resho ld has been met, but monit oring must be maintained.

 Waters for which data are insufficient.

 Waters for which there are no data.

FDEP tracks (but does not necessarily monitor) each waterbody it identifies as needing special monitoring
every quarter to ensur e sufficient data to conduct IWR assessment.

The IWR Run 44 database contains measurements of TN, TP, and/or chlorophyll

- a from January 2006 through June 201 1 for 415 estuaries in Florida.



### 4.2 Method

Compared to current conditions, potential incrementally imp aired waters under the proposed rule represent those waters that exceed EPA’s criteria for which FDEP has not already developed a TMDL or listed as impaired for nutrients and DO (because TMDLs for DO often target nutrient reductions). Using the last 5 year s of data (2006

– mid 2011) from IWR Run 4 4

, EPA used the following method for identifying potential incrementally impaire d estuaries, coastal, and south Florida inland flowing waters:

 Identify all state WBIDs

 Exclude WBIDs for which this rule is not appli cable (e.g., lakes and inland flowing water WBIDs listed as incrementally impaired under the Florida inland rule)

 Exclude WBIDs for waters on the 303(d) list or for which there is a draft or approved nutrient

r elated TMDL (because EPA assumed controls to r educe nutrients already required in the absence of EPA’s rule would be sufficient)

 Exclude monitoring data flagged for quality concerns (e.g., result codes indicating QA/QC issues)

 Identify specifically applicable criteria for each segment or WBID on the b asis of waterbody type (estuaries, beach, coastal) and location (see Appendix A )

.

o Identifying stations within 500 feet of the pour points of estuaries to which DPVs could apply.

 Calculate the annual geometric mean of TN, TP, an d chlorophyll

- a values from water quality stations data within a boundary (e.g., estuarine segment, coastal WBID) id entified with GIS, and

compare to applicable criteria.

EPA used FDEP’s 2011 d raft data procedures for calculating annual geometric means f or TN, TP, and chlorophyll

- a. FDEP specifies that at least four samples, with at least one sample in the summer season (May to September) and at least one sample in the winter season (October to April) are needed to

calculate a n annual geometric mean value

. EPA assigned nondetects a value of one

- half of the detection level in these calculations. This procedure ensures that annual assessments represent seasonal variations
in nutrient concentration. FDEP also states that waters with insufficient data ar e not to be listed as impaired. EPA followed this same methodology and did not consider waters with insufficient data as potentially impaired.January 2012 4

. Potentially Incrementally Impaired Waters

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  4

- 3 For coastal WBIDs (See Section 3.1.1 ), more than one annual geometric mean greater than th e applicable numeric criterion for TN, TP, or chlorophyll

- a in a three year period represents potential incremental impairment of the WBID.

For applicable criteria for estuarine segments and South Florida marine segments (See Sections 3.1.2 an d

3.1.3 ), EPA used GIS software to match the water quality stations to their applicable segments and calculated annual geometric me a n s using all data for a given segment. If more than one annual geometric

mean was greater than the applicable numeric criterion for TN, TP, or chlorophyll

- a in a three year period, EPA identified the segment to be incrementally impaired. EPA then identified incrementally impaired WBIDs to be WBIDs that overlap at least 10% of its a rea with an i ncrementally impaired
segment.



### 4.3 Results

Exhibit 4

- 1 Error! Reference source not found. summarizes the potential incremental ly impair ed waters

under the rule based on the analysis of water quality data described above

.


### Exhibit 4

- 1 : Summary of Potential Incremental Impairments Under the Proposed Rule
Category Number of Coastal and Estuarine WBIDs

Total in State 1,14 3
Total in Analysis 1 952

Nutrient Data in IWR Run 44 2 513

Sufficient Data Available 3 410
Potentially Exceeding Criteria 4 ,5 230
IWR = Impaired Waters Rule TMDL = total maximum daily load 1. Excluding waters for which FDEP has already developed a TMDL o r listed as impaired for nutrients and DO 2. Data within last 5 years meeting data quality requirements. 3. Sufficient to calculate annual geometric means; based on at least 4 samples with at least one sample from May to September and one sample from Oct ober to April in a given year. 4. Based on annual geometric mean exceeding the applicable criterion more than once in a three year period
5. Eight coastal WBIDs meet the applicable coastal nutrient criteria but do not meet estuarine criteria for the segme nts to which they are mapped. To err on the side of estimating the maximum likely impacts of the rule, EPA included t hese WBIDs a mong the potential incremental impair ments

.

Note that , based on available data, some waters do not attain proposed criteria f or TN, TP, and chlorophyll

- a while others do not attain proposed criteria for a single pollutant. For the purpose of estimating controls for nonpoint sources, EPA did not distinguish among the pollutants and assumed that controls to reduce TN, TP

, and chlo rophyll

- a are the same. Exhibit 4

- 2 shows the locations of

i ncrementally impaired estuaries and coastal waters.January 2012 4

. Potentially Incrementally Impaired Waters

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  4

- 4 

### Exhibit 4

- 2 : Ma p of Potential Incremental Waters No t A ttain ing the Proposed Criteria

4.3.1 Land Use Potentially Affected

Land use surrounding the potential incrementally impaired waters provides information on the types of controls that may be needed to attain EPA’s criteria. EPA used 10

- digit hydrologic unit codes (HUCs) to represent the watersheds for estimating land use. First EPA identified any HUC

- 10 watershed that intersected at least 10% with one of the baseline WBIDs (e.g. 303(d) listed, TMDL, or WBID already incrementally impaired under the inlan d ru le) as a baseline HUC

- 10. Then EPA identified any HUC

- 10 watershed that intersected at least 10% with an identified incrementally impaired WBID under this proposed rule. However, the 10

- digit HUC boundaries do not overlap with most of the WBIDsJanuary 2012 4

. Potentially Incrementally Impaired Waters

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  4

- 5 potentiall y affected by the proposed rule (e.g., estuary, coastal, and beach WBIDs). Thus, EPA could not use the same method it used for the inland nutrient criteria rule in which it used the percent of e ach WBID

that fell within a 10

- digit HUC. Rather, EPA assumed that any land in a HUC

- 10 (excluding baseline

HUC

- 10s) potentially draining (adjacent) to an identified incrementally impaired water could need

controls. Exhibit 4

- 3 summarizes the area of land in different use cat egories that surround potential incrementally impaired WBIDs identified in this proposed rule.



### Exhibit 4

- 3 : Summary Land Use in Watersheds Surrounding Potential Incremental WBIDs of this Proposed Rule

Land Use Type Number of Acres Percent of Total Agriculture 20,322 1.3%
Communications and Utilities 8,460 0.5%
Forest 662,561 42.3%
Industrial 8,834 0.6%

Other 39,016 2.5% Transportation Corridors 18,322 1.2%
Urban 131,739 8.4%
Water 70,300 4.5%
Wetla nds 605,885 38.7%

Total 1,565,439 100.0%January 2012 5

. Potential Costs for Municipal Wastewater Sources **Draft for Internal Review Only**

**- Do Not**  **Quote or Cite** 5

- 1 

## 5 Potential Costs for Municipal Wastewater Sources

Municipal wastewater dischargers receive WQBELs for pollutants of concern in NPDES permits. This section describes EPA’s method for estimating potential revised effluent limitations for TN and TP as a result of state implementation of the proposed rule, and the resulting potential pollution control actions

and c osts

.


### 5.1 Data

EPA’s permit compliance system (PCS) database contains the municipal WWTPs with NPDES permits in Florida (through February 2011). Receiving waterbody name and information in NPDES permits, accompanying NPDES permit fact sheets, and FDEP NPDES laboratory reports indicate whether the WWTP discharges to an estuary or coastal water.

EPA also used FDEP ’s Wastewater Facility Regulation ( WAFR ) database and electronically available permits to identify existing treatment capabilities at the potentially affected WWTPs to determine whether an additional level of treatment would be necessary under the proposed rule.



### 5.2 Method

EPA evaluated existing FDEP procedures for implementing WQBELs and setting effluent limits based on WLAs in existing nutrient TMDLs as a basis for estimating likely state implementation of the numeric criteria contained in the proposed rule. NPDES

- permitted wastewater sources may receive revised WQBELs reflecting the proposed criteria whether or not the receiving WBID is identified as potentially incrementally impaired under this proposed rule.

5.2.1 Reasonable Potential

NPDES permitting authorities determine the need for WQBELs for point sources based on analysis of reasonable potential to exceed the water quality criteria . The proposed rule does not include implementation procedures for determining reasonable potential. However, for pollutants with numeric criteria, FDEP generally follows the procedures in EPA’s Technical Support Document for Water Quality

- Based Toxics Control (U.S. EPA, 1991) for other pollutants with numeric criteria. For example, for aquatic life criteria, the Technical Support Do cument for Water Quality

- Based Toxics Control (U.S. EPA, 1991) recommends finding that a permittee has reasonable potential if it cannot be demonstrated with a high confidence level that the upper bound of the lognormal distribution of effluent concentrati ons is below the criteria at specified low

- flow conditions (U.S. EPA, 1991).

Medium to highly concentrated untreated domestic wastewater typically contains 40 mg/L to 70 mg/L of TN and 7 mg/L to 12 mg/L of TP (Metcalf and Eddy, 2003). Effluent concentrati ons of TN and TP in treated domestic wastewater depend on the treatment used. For example, activated sludge with single stage nitrification results in typical TN concentrations of 20 mg/L to 30 mg/L and TP concentrations of

6 mg/L to 10 mg/L (Metcalf and E ddy, 2003). For advanced nutrient removal, technologies are available to reliably attain an annual average of 3 mg/L for TN and 0.1 mg/L or less for TP. (U.S. EPA, 2008)

. Based on information from FDEP’s WAFR database and electronically available permits

, all municipal WWTPs discharging to potentially affected waters operate at least secondary treatment (e.g., activated sludge with single stage nitrification), with a number operating advanced nutrient removal. Effluent concentrations of 3 mg/L for TN and 0.1 mg/L for TP are the target levels of treatment for this analysis.January 2012 5

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- 2 To determine reasonable potential on a facility

- specific basis, site specific data such as instream nutrient

concentrations and low flow conditions would be necessary . However, because most WWTPs are likely to discharge nutrients at concentrations above applicable TN and/or TP criteria

, EPA assumed that all

WWTPs would have reasonable potential to cause or contribute to an exceedance of the proposed

numeric criteria

.
5.2.2 Projected Effluent Limits

Based on EPA’s Technical Support Document for Water Quality

- Based Toxics Control (U.S. EPA, 1991) procedures, d ischargers with reasonable potential would likely receive WQBELs based on Chapter

62

- 650, F.A.C., Water Quality Based Effluent Limitations, which requires effluent limits to be based on the characteristics of discharge, the receiving water characteristics, and applicable criteria . Because data on water low flow conditions and other site specific data are not available for every discharger, EPA assumed for this analysis that dischargers would receive effluent limits equal to the numeric nutrient criteria (i.e, assumption of no dilution). Applying criteria end

- of

- pipe would also prevent a discharger from causing an additional impairment.

F DE P’s TMDL Protocol (FDEP, 2006a ) states t hat because point source dischargers already generally provide a high level of treatment, initial control strategies to be considered may generally pertain to stormwater point and nonpoint sources. For example, in th e Roberts Bay Nutrient TMDL (U.S. EPA Region 4, 2005), point source WLAs are set at existing permitted loads because each facility had made significant reductions in their permitted discharge, and provided treatment beyond technology

- based

effluent treatme nt levels for nitrogen.

For this analysis, consistent with FDEP’s existing permitting procedures for TMDLs, EPA assumed dischargers would receive WQBELs based on levels attainable with advanced nutrient removal (3 mg/L TN and 0.1 mg/L TP; see Section 5.2. 3).

5.2.3 Potential Compliance Options

Potential controls to reduce TN and TP in WWTP effluents include biological nutrient removal (BNR), chemical precipitation, and effluent reuse. The specific level of performance achieved through implementation of advanced w astewater treatment systems can vary based on factors such as influent water quality, climate, and operator exp erience. For example, EPA (2008 ) reports WWTPs are achieving average TN values ranging from 3.5 mg/L to 1.3 mg/L and TP values ranging from 0.43 mg/L to 0.09 mg/L with advanced nutrient removal technologies that target both nitrogen and phosphorus.

EPA recognizes that most numeric nutrient criteria for TN and TP criteria for estuaries and DPVs are below 3 mg/L TN and 0.1 mg/L or less for TP target performance levels. In these cases, EPA assumed that the discharger will either implement technology consistent with levels that attain an annual average of 3 mg/L for TN and 0.1 mg/L or less for TP and achieve performance at levels that meet the WQBEL,

o r cannot achieve the required performance level and pursue other means of complying with WQS such as site specific alternative criteria, variances, or use designation modifications.

**BNR**
BNR removes TN and TP from wastewater through the use of microorgani sms under different

environmental con ditions in the treatment process (Metcalf and Eddy, 2003). There are a number of BNR process configurations available. Some BNR systems are designed to remove only TN or only TP, while others remove both. BNR configurat ions vary in their sequencing of environmental conditions (i.e.,January 2012 5

. Potential Costs for Municipal Wastewater Sources **Draft for Internal Review Only**

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- 3 aerobic, anaerobic, or anoxic) 9 and timing ( Jeyanayagam , 2005). Common BNR system configurations

include:

 Modified Ludzack

- Ettinger (MLE) Process

– continuous

- flow suspended

- growth process wi th an initial anoxic stage followed by an aerobic stage; used to remove TN

 A naerobic

- A noxic O xidation (A 2 /O) Process

– MLE process preceded by an initial anaerobic stage;

used to remove both TN and TP

 Step Feed Process

– alternating anoxic and aerobic stag es; however, influent flow is split to several feed locations and the recycle sludge stream is sent to the beginning of the process; used to remove TN

 Bardenpho Process (Four

- Stage)

– continuous

- flow suspended

- growth process with alternating

anoxic/aerobic /anoxic/aerobic stages; used to remove TN

 Modified Bardenpho Process

– Bardenpho process with addition of an initial anaerobic zone; used to

remove both TN and TP

 Sequencing Batch Reactor (SBR) Process

– suspended

- growth batch process sequenced to simulat e the four

- stage process; used to remove TN (TP removal is inconsistent)

 Modified University of Cape Town (UCT) Process

– A 2 /O Process with a second anoxic stage where the internal nitrate recycle is returned; used to remove both TN and TP

 Oxidation Ditch

– continuous

- flow process using looped channels to create time sequenced anoxic, aerobic, and anaerobic zones; used to remove both TN and TP.

Exhibit 5

- 1 provides a comparison of the TN and TP removal capabilities of common BNR configurations. Because the performance of each process is dependent on site specific conditions

, this exhibit represents on ly a general comparison of treatment performance among different BNR configurations.



### Exhibit 5

- 1 : Comparison of Common BNR Configurations

Process Nitrogen Removal Phosphorus Removal

MLE Good None
A 2 /O Good Good Step Feed Moderate None
Four

- Stage Bardenpho Excellent None Modified (Five

- Stage) Bardenpho Excellent Good SBR Moderate Inconsistent Modified UCT Good Excellent Oxidation Ditch Excellent Good Source: Jeyanayagam (2005).
A 2 /O = anaerobic

- anoxic oxidation BNR = biological nutr ient removal MLE = Modified Ludzack

- Ettinger SBR = Sequencing Batch Reactor UCT = Uni versity of Cape Town

9 Anoxic is a condition in which oxygen is availab le only in the combined form (e.g., NO2

- or NO3

- ). However, anaerobic is a condition in which neither free nor combined oxygen is available (WEF and ASCE/EWRI, 2006).January 2012 5

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- 4 Most large treatment plants should be able to achieve effluent concentrations of 3 mg/L for TN and 0.1 mg/L for TP ( Jeyanayagam, 2005 ; CBP, 2002 ). However, site specific conditions may allow some

facilities to achieve even lower conc entrations.

For example, the C ity of Clearwater, Florida, operates two five

- stage Bardenpho WWTPs. The second anoxic zone in the process provides denitrification of the nitrates created in th e aeration zone (U.S. EPA,

2008 ). TP is removed biologically in the anaerobic zone, and alum is fed to the second anoxic zone (the fourth reaction basin) for the dual purpose of phosphorus polishing and meeting the state requirement of

low

- level trihalomethane levels in the reuse water (U.S. EPA, 2008 ). In addition, a gravity sand filter is used to remove phosphorus tied to suspended solids in the final effluent. The annual average concentrations are 2.32 mg/L TN and 0.11 mg/L TP at the Marshall Street plant, and 2.04 mg/L TN and 0.20 mg/L TP at the Northeast plant. Bot h plants operate with high efficiency and low variability (U.S. EPA, 2008 ).

In addition, the Lee County, Fiesta Village WWTP employs oxidation ditches with methanol addition prior to denitrification filters to achieve an annual average TN concentrati on of 1.38 mg/L (U.S. EPA,

2008 ). To achieve average effluent TP concentrations of 0.1 mg/L, the facility uses alum addition and the denitrification filters to remove particu late phosphorus (U.S. EPA, 2008 ).

**Chemical Precipitation**

Chemical precipitation primari ly uses aluminum and iron coagulants or lime to form chemical flocs with phosphorus. These flocs then settle out to remove phosphorus from the wastewater (Viessman and Hammer, 1998). Compared to biological removal of phosphorus, however, chemical processes have higher operating costs, produce more sludge, and result in added chemicals in sludge (Metcalf and Eddy, 2003). When TP levels close to 0.1 mg/L are required, a combination of biological and chemical processes may be less costly than either process by itself. In addition, chemical precipitation can be coupled with filtration to achieve levels at or below 0 .1 mg/L. For example, EPA (2008 ) provides the following examples of WWTPs with low TP effluent concentrations:

 Lee County, Florida: Oxidation ditch w ith denitrification filter with alum, TP = 0.098 mg/L

 Chelsea, Michigan: Chemical addition with flocculating clarifier, TP = 0.09 mg/L (full

- year data)

 McMinnville, Oregon: Chemical addition with tertiary clarifier and filter, TP = 0.058 mg/L (seasonal,

6 months of data)

 Pinery, Colorado: 5

- Stage Bardenpho with chemical and filter, TP = 0.031 mg/L

 Breckenridge, Colorado: Enhanced biological phosphorus removal with chemical addition and filter, TP = 0.01 mg/L (literature report)

 Brighton, Michigan: Chemical addition with tertiary filter and infiltration basin, TP = 0.01 mg/L (full year data)

**Effluent Reuse**
Effluent reuse does not reduce the concentration of nutrients in the effluent. However, partial effluent reuse (e.g., a portion of the wastewater is discha rged to the receiving water and a portion is used in reuse applications) can decrease the volume of nutrient

- containing wastewater discharged, decreasing the total nutrient load to the receiving water sufficient to meet the WQS. If the waterbody has no ass imilative capacity, only 100% effluent reuse (i.e., no discharge to the receiving water) would be allowable.January 2012 5

. Potential Costs for Municipal Wastewater Sources **Draft for Internal Review Only**

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- 5 Effluent water can be reused for several nonpotable purposes including agricultural and landscape irrigation, industrial uses, and groundwater rech arge. Costs associated with reuse applications include conveyance systems and storage tanks for reuse water as well as additional treatment that may be needed to meet reuse standards (e.g., low bacteria and turbidity concentrations). FDEP has adopted reuse d water standards that ensure protection of human health, such as the APRICOT Act of 1994 that contains provisions for backup water discharges and groundwater injection. However, the feasibility of effluent reuse as a control option for reducing nutrient l oads to receiving waters depends on demand for reuse

water.

**Site Specific Alternative Criteria**
If the characteristics of a receiving water allow attainment of designated uses with nutrient concentrations higher than EPA’s proposed criteria , SSAC may be de veloped that could result in less stringent effluent limitations. Because dischargers may be required to obtain additional data to assess the appropriateness of SSAC, the extent to which dischargers use this mechanism to obtain regulatory relief is uncerta in. However, there may be a greater likelihood of pursuing SSAC in cases where using data and scientific evaluations associated with previous TMDL development efforts can result in significant cost savings.

**Variance s** 
Following EPA’s Technical Support Docum ent for Water Quality

- Based Toxics Control (U.S. EPA, 1991) procedures, if dilution is not available, WQBELs based on criteria end

- of

- pipe could be below the levels that can be reliably attained with advanced nutrient removal technologies (3 mg/L TN and 0. 1 mg/L TP). In these cases, the discharger may request a variance for reductions beyond those attainable

with advanced nutrient removal technologies (e.g., available cost

- effective treatment controls).

Section 120.542, F.S. indicates that FDEP is authorize d to grant variances to requirements of their rules or to rules required by EPA with approval of the variance from EPA. Under Chapter 62

- 110.104, F.A.C.

, a discharger must demonstrate that any hardship asserted as a basis for the need to receive a specific variance is peculiar to the affected property and not self

- imposed, and that the grant of a variance will be consistent with the general intent and purpose of Chapter 403, F.S. (Environmental Control Chapter of Florida Statutes), as applicable.

To demons trate the need for a variance under these statutes and procedures, dischargers would likely prepare documentation of the conditions warranting the variance. For example, to evaluate the potential for control costs to cause economic and social hardship, dis chargers are likely to follow EPA’s (1995) Interim Economic Guidance for Water Quality Standards Workbook which provides worksheets and instructions for public and private sector entities. Following EPA (1995), dischargers conduct a two

- step analysis, firs t determining whether the control costs would have a substantial adverse financial impact and, if so, whether that impact would cause widespread adverse impacts on the surrounding community.

5.2.4 Potentially Affected Sources

To identify potential incremental t reatment needs, EPA compared existing requirements and current treatment capabilities for municipal dischargers to the estimated revised effluent limits for TN and TP.

C ompleted TMDLs for potentially affected waters provide wasteload allocations (WLAs) fo r both T N and TP for 14 municipal WWTPs, and for only TN for 26 WWTPs. EPA assumed that FDEP would likely seek to adopt the current TMDL nutrient targets as SSAC because scientific analysis has determined that they represent the maximum allowable nutrient loads for these waters. Because these dischargers are already required to meet the WLAs in the TMDLs, EPA assumed that additional treatment would only be needed for TP for the dischargers that currently have only WLAs for TN.January 2012 5

. Potential Costs for Municipal Wastewater Sources **Draft for Internal Review Only**

**- Do Not**  **Quote or Cite** 5

- 6 In addition, EPA identified 12 municipal WWTPs discharging to waters listed as impaired for nutrients and/or DO on the state’s current 303(d) list. EPA assumed that in the absence of its rule, these dischargers would be given WLAs under a TMDL. Thus, costs to reduce nutrients at these WWTPs would be attributable to the existing impairment and not the proposed rule. However, EPA also conducted sensitivity analyses of the potential for additional controls under the proposed rule if these WLAs require reductions for only TN or TP and not b oth pollutants (as is the case with several existing TMDLs).

Similarly, EPA identified 8 WWTPs discharging to the Atlantic Ocean for which existing regulations (e.g., Grizzle

- Figg Act) already require treatment to 3 mg/L TN and 1 mg/L TP by 2018, and elimi nation of all discharges (except in emergency situations) by 2025. For this analysis, EPA assumed that no additional treatment controls would be needed for compliance with the proposed rule because facilities would likely receive a temporary variance or in terim limits that would apply until the time in which the discharge would need to be eliminated.

Lastly, EPA identified another 2 WWTPs covered under the Grizzle

- Figg Act which already requires dischargers to meet advanced wastewater treatment levels of 3 mg/L for TN and 1 mg/L for TP. Therefore, EPA assumed that only additional treatment for TP would be needed for compliance with potential revised effluent limits.

EPA used FDEP’s WAFR database and electronically available permits to identify existing trea tment capabilities of WWTPs. There are 11 dischargers already operating treatment processes capable of achieving levels of 3 mg/L for TN and 0.1 mg/L for TP (e.g., A 2 /O, modified Bardenpho, modified UCT, oxidation ditches or other BNR coupled with chemica l precipitation). A total of 19 dischargers are already operating treatment processes that remove only TN to levels of 3 mg/L (consistent with performance of

MLE and four

- stage Bardenpho processes), and 2 are operating processes that remove only TP to leve ls of 0.1 mg/L (consistent with chemical precipitation without BNR). Note that these counts include dischargers covered under baseline regulations or provisions as described above. Municipal WWTPs without these configurations or those not operating advance d nutrient removal technologies would likely need to retrofit existing treatment to reduce nutrients to the necessary levels.

Exhibit 5

- 2 summarizes the varying levels of treatment that could be required by munici pal WWTPs

under the proposed rule based on the current regulatory framework and existing effluent treatment

controls.January 2012 5

. Potential Costs for Municipal Wastewater Sources **Draft for Internal Review Only**

**- Do Not**  **Quote or Cite** 5

- 7 

### Exhibit 5

- 2 : Potential Treatment Required for Municipal Wastewater Treatment Plants

Disc harge r

Category Number of Dischargers
Reduce TN

and TP 1 Reduce TN Only 2 Reduce TP Only 3 No Reductions 4 Total

Major 9 0 31 29 69
Minor 24 2 1 11 38
Total 33 2 32 40 107
Source: Based on treatment t rain descriptions in FDEP (2009 ) and permits, WLAs in TMDLs and existing regulations, assuming dischargers would have to install advanced BNR for compliance under the rule.
A 2 /O = anaerobic

- anoxic oxidation BN R = biological nutrient removal MLE = Modified Ludzack

- Ettinger TMDL = total maximum daily load TN = total nitrogen TP = total phosphorus UCT = University of Cape Town
WLA = wasteload allocation 1. Includes dischargers without treatment processes capable of achieving the target levels or existing WLA for TN and TP, or for which the treatment train descrip tion is missing or unclear. 2. Includes dischargers with chemical precipitation only. 3. Includes dischargers with MLE, four

- stage Bardenpho, and BNR specified to achieve less than 3 mg/L, those with WLA under a TMDL for TN only, or those covered under th e Grizzle

- Figg Act. 4. Includes dischargers with A 2 /O, modified Bardenpho, modified UCT, oxidation ditches, or other BNR coupled with chemical precipitation, those with WLAs under a TMDL for both TN and TP, those discharging to waters on the 303(d) list fo r nutrients or DO, and ocean dischargers.

5.2.5 Unit Control Costs

EPA (200 8 ) provides unit cost estimates for advanced nutrient removal technologies retrofits and expansions for various TN and TP performance levels. Ex hibit 5

- 3 shows retrofit and expansion costs for

estimates EPA (2008 ) derived from wastewater treatment cost estimating software (CAPDETWorks ) . T he costs for those facilities represent estimated design costs and not actual installed process costs.



### Exhibi t 5

- 3 : Unit Costs for BNR (2010 dollars)

Description Capital ( million $/gpd) 1 O&M ($/MG /day )

TN Less T han 3 mg/L

Phased oxidation ditch retrofit $0.52 $49
MLE retrofit $0.79 $91 Step

- feed retrofit $0.7 2 $101
Denitrification filter retrofit $0.79 $173 Average $0.70 $103 TP Less Than 0.1 mg/L Fermenter, sand filtration, and 1

- pt chemical addition retrofit $0.52 $118

2

- pt chemical addition and filter retrofit $0.32 $238

2

- pt chemical addition and fil ter expansion $0.32 $238 A/O with fermenter, filter, and chemical addition expansion $1.72 $431 Average $0.72 $256January 2012 5

. Potential Costs for Municipal Wastewater Sources **Draft for Internal Review Only**

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- 8 

### Exhibi t 5

- 3 : Unit Costs for BNR (2010 dollars)

Description Capital ( million $/gpd) 1 O&M ($/MG /day )

TN Less Than 3 mg/L and TP Less Than 0.1 mg/L

PID retrofit with 1

- pt chemical addition, clarifier, and filter $0.99 $221

5

- stage Bardenp ho and chemical addition retrofit $1.44 $284

Nitrification, chemical addition, and denitrification filter retrofit $0.83 $497
Nitrification with 1

- point chemical addition and denitrification filter expansion $0.83 $497

5

- stage Bardenpho, chemical additi on, and filter expansion $2.75 $529 Average $1.37 $405
Source: U.S. EPA (2008 )

. Est imates developed using CAPDETWorks software

, and flow of 10 mgd. A/O = anaerobic/oxic BNR = biological nutrient removal gpd = gallons per day MG = million gallons mgd = mi llion gallons per day mg/L = milligrams per liter O&M = operation and maintenance TN = total nitrogen TP = total phosphorus WWTP = wastewater treatment plant 1. Capital and O&M costs updated from original reported year dollars (May 2007 and July 2007) to J une 2010 dollars using the Engineering News Record Construction Cost Index (index values of 7942, 7959, and 8566 for May 2007, July 2007, and June 2010, respectively).

5.2.6 Potential Total Costs

EPA estimated potential total control costs based on the treatme nt scenario shown in Exhibit 5

- 2 and assuming the average unit costs shown in Exhibit 5

- 3 are indicative of those that similar facilities in

Florida would incur to implemen t advanced nutrient removal technologies. Exhibit 5

- 4 summarizes the potential costs to municipal WWTPs , which could total approximately $94 .2 million annually (based on annualizing capital costs at 7% over 20 year s and adding annual O&M . All estimates reflect the unit costs multiplied by total flows contained in EPA’s PCS database, as shown in Appendix B

.



### Exhibit 5

- 4 : Summary of Potential Municipal WWTP Compliance C osts

Reductions

Needed Facilities Costs ( millions 2010 dollars)

Number Flow (mgd) Capital O&M ($/year) Total Annual ($/year) 1 TN <3 mg/L; TP <0.1 mg/L 33 216 $294.8 $31.9 $59.7

TN <3 mg/L 2 0.3 $0.2 $0.01 $0.03 TP <0.1 mg/L 32 213 $153.5 $19.9 $34. 4

None 40 660 $0.0 $0.0 $0.0

Total 107 1

, 089 $449 $52 $94 .2 mgd = million gallons per day mg/L = milligrams per liter O&M = operation and maintenance TN = total nitrogen TP = total phosphorus WWTP = wastewater treatment plant
1. Capital costs annualized at 7% over 20 years, plus annual O&M.January 2012 5

. Potential Costs for Municipal Wastewater Sources **Draft for Internal Review Only**

**- Do Not**  **Quote or Cite** 5

- 9 This es timate does not include costs to facilities discharging to 303(d) list waters for nutrient

- related causes since these controls would likely be needed in the absence of the rule. However, existing nutrient

–

re lated TMDLs for Florida waters sometimes establish WLAs for only the limiting pollutant and not TN

and TP both . Since EPA is proposing both TN and TP criteria for estuaries and inland flowing waters in South Florida, these facilities could receive WLAs for both TN and TP , instead of just the limiting pollutant

. Exhibit 5

- 5 summarizes the sensitivity of the cost estimate to the inclusion of these incremental impacts.


### Exhibit 5

- 5 : Summary of Sensitivity Analysis for Potential Municipal WWTP Compliance Costs (millions 2010 dollars) Compliance Scenario Capital O&M ($/yr) Total Annual ($/yr) 1
Base case plus controls for TP for 9 dischargers to 303(d) listed waters withou t compliance technologies in place 2 $553 $65 $117 .5

Base case plus controls for TN for 6 dischargers to 303(d) listed waters without compliance technologies in place 3 $474 $53 $98

1. Capital costs annualized at 7% over 20 years plus annual O&M costs.
2

. Reflects potential that the TMDL could include WLAs for TN only in the absence of the proposed rule.
3 . Reflects potential that the TMDL could include WLAs for TP only in the absence of the proposed rule. For most estuaries and coastal waters, the growth

- limiting nutrient (i.e., the chemical which largely controls the rate of primary production) is nitrogen, such that it is the reduction in the supply of nitrogen that is the primary focus of most estuarine nutrient TMDLs. EPA therefore presents the range from base

case to base case plus controls for TP for 9 dischargers to 303(d) listed waters in the total cost analysis.January 2012 6. Potential Costs for Industrial Wastewater Sources **Draft for Internal Review Only**

**- Do Not Quote or Cite**  6

- 1 

## 6 Potential Costs for Industrial Wastewater Sources

The proposed criteria may result in in dustrial sources of wastewa ter to estuaries, coa stal waters , and south

Florida inland waters receiv ing revised WQBELs in NPDES permits , depending on whether there is potential for these discharge s to cause or contribute to exceedance of a WQS. Unlike municipal WWTPs, however, not all industrial discharg ers are likely to discharge nutrients because industrial processes, treatments, and waste stream compositions vary widely. This section describes how EPA identified

industrial wastewater sources with the potential to receive revised effluent limitations fo r TN and TP as a result of state implementation of the proposed rule

, and the resulting potential pollution control costs

.


### 6.1 Data

EPA’s PCS database provides information on numeric effluent limits and permit monitoring requirements for industrial dischargers in Florida ( Exhibit 2

- 4 ). EPA used the standard industrial classification (SIC)

code s of those dischargers with current limit s or monitoring requirement s for nutrients to identify the

universe of facilities with p otential to discharge nutrients at levels of concern for the numeric criteria

. 10
This analysis resulted in identification of 51 industrial facilities that di scharge to estuaries, coastal waters

, and south Florida inland waters potentially affected by the pr oposed rule.

Completed nutrient and DO TMDLs for estuaries, bays, coastal waters, and South Florida canals indicate

that 4 of the 51 potentially affected dischargers have WLAs for both TN and TP. As with municipal WWTPs, EPA assumed that FDEP would likely seek to adopt the current TMDL nutrient targets as SSAC because scientific analysis has determined that they represent the maximum allowable nutrient

concentrations for these waters to meet designated uses . Because these dischargers are currently required to meet allowable nutrient discharge requirements, EPA assumed that additional treatment would not be needed for dischargers under a nutrient

- related TMDL.

In addition, EPA also identified 6 industrial dischargers out of the 51 potentially affected facil ities that discharge to waters listed as impaired for nutrients and/or DO on the current 303(d) list in Florida . EPA assumed that in the absence of the proposed rule, these dischargers would be given WLAs under a TMDL. Thus, costs to reduce nutrients at th ese facilities would be attributable to the existing impairment and not the proposed rule.

Exhibit 6

- 1 categorizes the remaining 41 dischargers possibly subject to WQBELs as a result of EPA’s

criteria by industrial sector.



### Exhibit 6

- 1 : Summary of Potentially Affected Industrial Dischargers Industrial Category Major Dischargers Minor Dischargers Total Dischargers
Chemicals and Allied Products 1 2 3
Electric Services 12

- 1 2

Food 2 1 3 Mining 1 1 2
Other

- 18 18 Pulp and Paper 3

- 3
Total 19 22 41 U.S. EPA (201 1 ).

10 PCS contains SIC codes rather than North American Industry Classification System (NAICS ) codes.January 2012 6. Potential Costs for Industrial Wastewater Sources **Draft for Internal Review Only**

**- Do Not Quote or Cite**  6

- 2 

### 6.2 Method

Treatment to reduce nutrient levels from industrial sources is facility

- specific and varies based on process operations, existing treatment t rain, and composition of waste streams. Thus, EPA estimated the potential compliance actions and costs that may be associated with the proposed rule for industrial dischargers through evaluation of individual facility permits, fact sheets, and effluent mon itoring data

.
6.2.1 Reasonable Potential

EPA evaluated the potential need for compliance controls and their costs for each major and minor industrial discharger. T o estimate potential control costs , EPA first determined whether the discharger s would have reasona ble potential to cause or contribute to an exceedance of the numeric TN and TP criteria using effluent data for discharge flow s , TN, and TP from EPA’s PCS database and other

information in the facility’s NPDES permit. F or those with reasonable potential , E PA estimated projected revised WQBELs, calculated based on available dilution, if any

. Where no dilution is available, EPA assumed that the average monthly effluent limit would be equal to the criterion. In cases in which dilution is available, EPA multipl ied the applicable criterion by the dilution ratio.

If current data indicated that the facility would not be in compliance with the potential revised WQBEL,

EPA determined the pollution controls most likely necessary for compliance and the cost of those

co ntrols. Appendix C provides the detailed analysis for each of the dischargers.

6.2.2 Potential Compliance Options

Potential controls to reduce TN and TP in industrial effluents may include BNR, chemical p recipitation with or without filtration, reverse osmosis, and source control

.

**BNR**
BNR removes TN and TP from wastewater through the use of microorganisms under different

environmental con ditions in the treatment process (Metcalf and Eddy, 2003). A certain amount of biological organisms must be present in the w astewater for biological treatment to be feasible for industrial wastewater. Thus, EPA assumed BNR a feasible control option for any industrial discharger currently operating any type of biological treatment (e.g., activated sludge). Section 5.2.3 discusses

available BNR process configurations

, and provides potential unit cost estimates that may also be applicable for industrial waste treatment.

**Chemical Precipitation**

Chemical precipitation may be a feasible compliance option fo r industrial facilities. EPA assumed that chemical precipitation could be employed at any type of industrial facility. Section 5.2.3 provides detailed estimates of potential unit costs for chemical precipitation that may also b e applicable for industrial waste

treatment.

**Reverse Osmosis**

Advanced BNR is not effective for removing the dissolved fraction of organic nitrogen, and BNR and chemical precipitation cannot remove dissolved phosphorus to extremely low levels, as shown in Exhibit

6

- 2

.January 2012 6. Potential Costs for Industrial Wastewater Sources **Draft for Internal Review Only**

**- Do Not Quote or Cite**  6

- 3 

### Exhibit 6

- 2 : Effectiveness of Common Removal Mechanisms for Reducing Various Fractions of Nitrogen and Phosphorus

Pollutant Species Common Removal Mecha nism Technology Limit for Removal Mechanisms (mg/L)
Ammonia

- Nitrogen Nitrification <0.5

Nitrate

- Nitrogen Denitrification 1

– 2 Particulate Organic Nitrogen Solids Separation <1
D issolved Organic Nitrogen None 0.5

– 1.5
D issolved Phosphorus Microbial U ptake; Chemical Precipitation 0.1 Particulate Phosphorus Solids Separation <0.05 Source: Jeyanayagam (2005)

Industrial wastewater may contain dissolved organic nitrogen and phosphorus concentrations at levels above the applicable criteria (note that wi thout facility

- specific laboratory analysis of TN and TP components, EPA cannot evaluate the fraction of dissolved organic species at each facility). However, RO is capable of targeting and removing the dissolved organic fraction from wastewater effluents.

Reverse osmosis entails usi ng a porous membrane to separate desired components (e.g., water) from undesired components (e.g., dissolved nitrogen or phosphorus)

. The membranes control the flow of ionic species across the membrane. Under normal os mosis con ditions, solvent permeate s the membrane from the low concentration side to the high concentration side. Under reverse osmosis, the application of external pressure on the high concentration side forc es the solute to permeate the membrane into the low

conce ntration side

. According to Ahn and James (1999 ), RO effectively removes dissolved non

biodegradable organic matter (including dissolved organic nitrogen).

There are a number of studies that examine the effectiveness of RO for removing nutrients from dome stic and industrial wastewater. Most of the available literature pertains to bench

- (i.e., laboratory) and pilot

scale RO units. However, Merlo et al. (2011) provides full scale data for RO plants treating domestic wastewater (note that these plants are no t discharging to surface water under NPDES permits but rather

treat effluent from domestic wastewater treatment plants with RO for use in replenishing groundwater or contributing to blended drinking water). Merlo et al. (2011) reported TN removal rates ran ging from 84%
to 91% and removal rates for organic nitrogen f rom 65% to 95%. The lower removal efficiencies occur where RO is preceded by ultrafiltration rather than microfiltration. Phosphate results from van Voorthuizen et al. ( 2005) show removal efficie ncy rates from 93% to 98%. However, none of the studies demonstrate effluent concentrations below 1.4 mg/L TN or 0.1 mg/L phosphate.

Carollo Engineers (2010) estimated capital and O&M costs for RO with microfiltration of $8.10/gpd and $3,000/MG, respective ly, for Florida dischargers based on bid

- data available from eleven wastewater

treatmen t plants. The unit costs include costs associated with residual disposal via a brine concentrator.

However, although removal efficiencies are high for TN and TP, limited performance data result in significant uncertainty regarding the effluent concentrations that can be achieved with RO. For example, it is uncertain whether efficiencies greatly decrease with decreasing influent concentrations or whether

there is some limi t to the technology beyond which it cannot improve . For extremely low TN and TP levels, RO may become cost prohibitive due to the need to operate multiple units in series (to increase removal rates) or issues regarding residuals disposal.January 2012 6. Potential Costs for Industrial Wastewater Sources **Draft for Internal Review Only**

**- Do Not Quote or Cite**  6

- 4 **Source Control**

S ource control targets reductions in pollutants at the source of entry into the wastewater system or within a specific treatment process rather than targeting reductions in total effluent. In most cases, it is more cost effective for industrial dischargers to control the source of nutrients in the effluent through BMPs, product substitution, process modifications, or process optimization than to treat the entire effluent prior to discharge

. For example, in the Chesapeake Bay most industrial dischargers have reduced nutrient loads through pollution prevention (CBP, 2004).

Source control can include a wide variety of activities. For example, to meet its WLA under the LSJR TMDL, Anheuser Busch improved pond nutrient removal at its Lem Turner location with hyacin th management, a baffle system to improve retention time, and the use of aeration in some zones. To reduce the nutrient load at its Main Street location, the discharger increased the crop area to which they land applied a portion of the wastewater (Busby

, 2009). Also under the LSJR TMDL, Georgia Pacific reduced the amount of nutrients added to its treatment ponds (Busby

, 2009).

**Variance**
Section 120.542, F.S. indicates that FDEP is authorized to grant variances to requirements of their rules or to rules requ ired by EPA with approval of the variance from EPA. Under Chapter 62

- 110.104, F.A.C. a discharger must demonstrate that any hardship asserted as a basis of the need for a specific variance is peculiar to the affected property and not self

- imposed, and that the grant of a variance will be consistent with the general intent and purpose of Chapter 403, F.S. (Environmental Control Chapter of Florida Statutes), as applicable. Any person seeking such a variance shall file a petition containing the following

infor mation:

 The petitioner’s name and signature

 The statute or rule from which the variance is sought

 Facts showing that a variance should be granted for one of the reasons set forth in Section 403.201,

F.S.:

There is no practicable means known or available fo r the adequate control of the pollution

Compliance with the particular requirement or requirements from which a variance is sought will necessitate the taking of measures which, because of their extent or cost, must be spread over a considerable period of time

To relieve or prevent hardship of a kind other than those provided for above

The period for which the variance is sought, including the reasons and facts supporting the period

The requirements that the petitioner can meet, including the date or time when they will be met

The steps or measures that the petitioner is taking to meet the requirement from which the variance is sought; if the request is pursuant to paragraph 403.201(1)(b), Florida Statutes, the petitioner shall include a schedule when compl iance will be achieved

The social, economic, and environmental impacts on the applicant and on residents of the area and of the state if the variance is granted

The social, economic, and environmental impacts on the applicant and on residents of the area a nd
of the state if the variance is denied.January 2012 6. Potential Costs for Industrial Wastewater Sources **Draft for Internal Review Only**

**- Do Not Quote or Cite**  6

- 5 Section 403.201, F.S. also states that FDEP should not grant a variance which would result in the provision or requirement being less stringent than a comparable federal provision or requirement. However, EPA’s nu meric nutrient criteria represent a translation of the existing narrative nutrient criteria

in Florida to provide more effective implementation, not a more stringent requirement.

6.2.3 Potential Control Costs

To estimate total statewide costs, EPA calculated the estimated average treatment unit cost for the facilities by industrial category

. EPA then multipl ied the average unit cost by the flow reported in PCS. For those facilities for which flow is not reported in PCS, EPA used the average flow of the other majo r or minor facilities in that industrial category (as shown in Appendix C ).

Error! Reference source not found. show s EPA’s estimate of potential statewi de industrial discharger

costs.

Exhibit 6

- 3: Estimated Statewid e Annual Industrial Control Costs

Industrial Category Total Number of Facilities Total Annual Costs (million $/yr)

Chemicals and Allied Products 3 $0.30

Electric Services 12 $ 0

Food 3 $0.17

Mining 2 $0. 04

Other 18 $ 0

Pulp and Paper 3 $7. 13

Total 41 $7. 6

mgd = million gallons per day 1. Estimated annual cost divided by flow.January 2012 7

. Potential Costs to Urban Stormwater Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  7

- 1 

## 7 Potential Costs to Urban Stormwater Sources

State implementation of the proposed criteria may affect urban stormwater dischargers through changes to NPDES perm it requirements, and the development of TMDLs and BMAPs. This section provides

estimates of urban land that may require additional nutrient controls as a result of state implementation of

EPA’s rule and potential control costs that may be needed to attain EPA’s criteria . These estimates are only approximat ions for informational purposes ; actual control actions will depend on site specific conditions and control strategies.



### 7.1 Data

As shown in Exhibit 4

- 3 , urban land us e (excluding industrial land, mine land, and inactive/underdeveloped la nd) accounts for approximately 8 % of the land use in watersheds draining to incrementally impaired waterbodies (WBIDs). Under the baseline, a number of urban areas are already required to control nutrients in stormwater dischargers through BMP implementat ion under MS4 NPDES permits. As described in Section 4.3.1 , EPA identified potentially affected urban land by overlaying land

use data with the 10

- digit HUCs EPA determined to be draining (adjacent) to incrementally impaired waterbodies (WBIDs). EPA then identified MS4 permit boundaries around this urban land by analyzing these data using GIS permit boundary data from the Florida Geographic Data Library (FGDL)

. Exhibit

7

- 1 summarizes EPA’s analysis identifying urban areas in incrementally impaired watersheds.



### Exhibit 7

- 1 : Urban Land Area in Watersheds Surrounding Potenti al
Incremental Waters not Attaining the Proposed Criteria Urban Land Type Number of Acres
Phase I MS4 46,000
Phase II MS4 65

, 8 00

Non

- MS4 30,0 00

Total 131 ,7 00 Note: Detail may not add to total due to independent rounding.



### 7.2 Method

This section describ es how EPA estimated the potential costs of additional controls that may be required to meet EPA’s proposed numeric nutrient criteria in watersheds that drain to incrementally impaired waterbodies (WBIDs) based on baseline permit requirements noted in Sect ion 2.1.4. The incremental controls that may be necessary based on state implementation of the proposed criteria depend on existing permit requirements and regulations dictating BMP implementation, as well as the relative contribution of nutrients to impa ired waters from urban runoff.

7.2.1 Required Controls

FDEP’s existing stormwater rules already require at least an 80% reduction in pollutant loads from urban

areas deve loped after 1982. FDEP (2010b) estimated that approximately 78% of all urban land in the st ate was developed prior to 1982. FDEP (2010b) also indicated that additional controls on stormwater runoff from the lands developed after 1982 should not be needed to meet EPA’s numeric nutrient criteria for lakes and flowing waters. Thus, for this analysi s, EPA assumed the same to be true for the proposed

numeric nutrient criteria for estuaries, coastal waters , and south Florida inland waters

.January 2012 7

. Potential Costs to Urban Stormwater Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  7

- 2 In addition, the primary source of nutrients from low density residential land is from over

- application of

fertil izers on lawns and gardens. Thus, full implementation of the Urban Turf Fertilizer Rule should result in further reductions in nutrient loadings to surface waters (existing ambient monitoring data may not yet fully reflect nutrient reductions because the r ule has only been in effect since July 2009). Other controls that target quantity of stormwater runoff from low density residential land may not be as cost

- effective as

the Urban Turf Fertilizer Rule which reduces the source of nutrients in stormwater runo ff. Thus, EPA excluded low density residential land from the analysis of urban area control costs because baseline regulations and controls should be sufficient for compliance with nutrient criteria under the proposed rule.

To estimate the level of contro l needed on post

- 1982 developed lands that are not low density residential

, EPA used information from existing TMDLs. N utrient reductions associated with previous completed

nutrient

- related TMDLs for estuaries in Florida indicate that, on average, nonpoint source pollution load reductions of approximately 40% are necessary to meet TMDL targets for nutrients (range of 10% to 70%). In the absence of site specific analysis, the type and location of pollution controls capable of achieving a 40% reduction are un certain. However, u rban stormwater controls can remove up to 51% of TN and 75% of TP ( Schueler et al., 2007 ) . Thus, EPA assumed that installation of stormwater pollution controls would result in the nutrient reductions necessary to attain the proposed crit eria.

7.2.2 Phase I MS4 Urban Land

Under existing regulations, NPDES permits for Phase I MS4s require implementation of controls to the maximum extent practicable (MEP)

, and do not generally require compliance with numeric effluent limits. In fact, EPA’s PCS dat abase indicates that none of the Phase I MS4s in Florida have numeric effluent limits. However, it is unclear what level of treatment the MEP represents. Thus, it is uncertain whether current stormwater pollution controls to the MEP are fully implemented i n Phase I MS4 areas and whether additional controls would be necessary under the proposed rule

. Although urban runoff is currently regulated, state implementation of the proposed criteria may result in changes to MS4 NPDES permit requirements or additiona l TMDLs and BMAPs that require additional pollution controls. However, the combination of additional pollution controls necessary will likely depend on the specific nutrient reduction targets, the controls already in place, and the relative amounts of

nutr ients contained in the urban runoff at each particular location. As a result

, stormwater programs usually use an iterative approach for assessing compliance that begins with implementation of controls followed by monitoring and re

- evaluation. Estimating th e complete set of pollution controls required to meet a particular water quality target would usually require site specific analysis

. However, in the absence of such analyses, EPA estimated potential urban control costs u sing FDEP’s assumption s that all ur ban land developed after 1982 would not need to implement additional stormwater controls to comply with EPA’s numeric nutrient criteria and that no additional controls would be needed on low density residential land. EPA estimated that between 0 acres (cur rent controls to the MEP are sufficient) to 31,200 acres [ 46,000 acres of urban land in watersheds surrounding potential incremental waters not attaining the proposed criteria × (100%

- 13 %) of potentially affected Phase I MS4 land that is not low density residential × 78% of u rban land developed before 1982] of potentially affected Phase I MS4 urban land may require additional stormwater pollution controls.

7.2.3 Phase II MS4 Urban Land

NPDES permits for Phase II MS4s require development of a stormwater manageme nt plan and implementation of six minimum control measures detailed in Section 2.1.4

. However, implementing structural stormwater controls are not required (the minimum control measures are primarily nonstructuralJanuary 2012 7

. Potential Costs to Urban Stormwater Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  7

- 3 and outreach

- based). Thus, some level of incremental control could be needed to reduce nutrients under the proposed rule.

GIS analysis of land use data indicates that approximately 21 % of potentially affected land in Phase II MS4 areas is low density r esidential

. For t he urban land that is not low density residential , some additional structural BMPs may be necessary to comply with EPA’s numeric nutrient criteria (existing TMDLs indicate that needed reductions in nonpoint source pollutant loads range from 10% to 70%, wit h an average of 40%; see Exhibit 2

- 9 ). Because nutrient reductions from low density residential land under the existing Urban Turf Fertilizer Rule are likely sufficient, and the state of Florida asserts that urban land developed a fter 1982 is already in compliance with EPA’s numeric nutrient criteria, EPA estimated that approximately 34

, 5 00 acres of Phase II MS4 urban land may require additional stormwater control under the proposed rule [ 55

, 8 00 acres of potentially affected Phase II MS4 land × (100%

- 21 %) of potentially

affected Phase II MS4 land that is not low density residential × 78% of urban land developed before 1982].

7.2.4 Urban Land Outside MS4s

Some urban land is not covered under EPA’s NPDES stormwater program. However, regu lations such as the Urban Turf Fertilizer Rule are applicable. GIS analysis of land us e data indicate s that approximately

8 % of potentially affected non

- MS4 urban land is low density residential. Thus, because nutrient reductions from low density residenti al land under the existing Urban Turf Fertilizer Rule are likely sufficient, and the state of Florida asserts that urban land developed after 1982 are already in compliance with EPA’s numeric nutrient criteria, EPA estimated that approximately 21, 4 00 acres of urban land outside of MS4 areas may possibly require additional stormwater controls to meet EPA’s numeric nutrient criteria [ 30

, 0 00 acres of potentially affected non

- MS4 land × (100%

- 8 %) of potentially affected

non

- MS4 land that is not low density re sidential × 78% of urban land developed before 1982]. Note that under TMDLs, FDEP may designate areas outside of MS4s that are significant contributors to pollutant loads as Phase II MS4s, and require those areas to obtain NPDES permits.

7.2.5 Summary of Potenti ally Affected Area

Exhibit 7

- 2 summarizes the acres of urban land in the watersheds surrounding the potential incremental waters not attaining the proposed criteria tha t could potentially need incremental controls based on the assumptions described above.



### Exhibit 7

- 2 : Urban Land in Watersheds Surrounding Potential Incremental Impairments Potentially Needing Controls

Urban Land Type Estimated Acres in Watersheds Surro unding Incremental Impairments Estimated Acres Potentially Needing Controls
Phase I MS4 46,000 0

- 31,200
Phase II MS4 65,800 34,500

Non

- MS4 30,000 21,400

Total 131,700 55,900

- 87,100 Note: Detail may not add to total due to independent rounding 1. P hase I MS4s range represents implementation of BMPs to the MEP resulting in compliance with EPA’s rule or controls on all pre

- 1982 developed land that is not low density residential; Phase II MS4s and urban land outside of MS4s represent controls on all pr e

- 1982 developed land that is not low density residential.January 2012 7

. Potential Costs to Urban Stormwater Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  7

- 4 

### 7.3 Potential Costs

Unit costs for stormwater treatment controls may vary based on the type of land needing controls (e.g., pervious versus impervious, high density versus low density). FDEP (2010a) provides unit costs in dollars per acre treated for completed stormwater retrofit projects throughout the state. Costs range from $62 per acre treated to $60,300 per acre treated depending on site specific characteristics, with a median cost of $6,800 per acre. Specific information regarding the characteristics of land potentially requiring controls is not available. Thus, EPA estimated control costs based on median unit costs from FDEP (2010a), with O&M costs equal to 5% of capital costs [consistent with F DEP (2010b) assumption of O&M equal to 5% of capital costs]. These estimates are shown in Exhibit 7

- 3

.


### Exhibit 7

- 3 : Estimated Incremental Urban Stormwater Costs

Urb an Land Type Estimated Acres Potentially Needing Controls 1 Capital Costs (million $) 2 O&M Costs (million $/yr) 3 Annual Costs (million $/yr) 4

Phase I MS4 0

- 31,200 $0

- $213.3 $0

- $10. 7 $0

- $30.8
Phase II MS4 34,500 $235.9 $11.8 $34.1

Non

- MS4 21,400 $ 146.5 $7.3 $21.2

Total 55,900

- 87,100 $382.4

- $595.7 $19.1

- $29.8 $55.2

- $86.0 1. Phase I MS4 range represents implementation of BMPs to the MEP resulting in compliance with EPA’s rule or controls on all pre

- 1982 developed land that is not low densit y residential; Phase II MS4 and urban land outside of MS4s represent controls on all pre

- 1982 developed land that is not low density residential. 2. Represents acres potentially needing controls multiplied by median stormwater retrofit costs from FDEP (201 0b). 3. Represents 5% of capital costs. 4. Capital costs annualized at 7% over 20 years plus annual O&M costs.January 2012 8. Potential Costs to Agricultural Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  8

- 1 

## 8 Potential Costs to Agricultural Sources

Agricultural dischargers in Florida do not generally receive discharge permits unless specific regula tions require them (e.g., the South Florida Water Management District WOD program). However, state implementation of the proposed criteria may result in incremental requirements for these dischargers through the identification of additional nutrient

- impair ed waters, and subsequent development of TMDLs

and BMAPs. This section provides estimates of agricultural land that may require additional nutrient controls as a result of state implementation of EPA’s rule and potential control costs that may be needed

to attain EPA’s criteria . These estimates are only approximat ions for informational purposes ; actual

control actions will depend on site specific conditions and control strategies.



### 8.1 Data

As shown in Exhibit 4

- 3 , EPA e stimated that agricultural land accounts for just over 1% of land in watersheds draining to potentially incrementally impaired waterbodies (WBIDs). Exhibit 8

- 1 shows the agricultural acreage subdivided into the specific type of ag ricultural operation that presently occurs there.



### Exhibit 8

- 1 : Agricultural Land Use in Watersheds Draining to Potentially Incrementally Impaired WBIDs

Agricultural Land Use Number of Acres
Cropland and P astureland 38
Improved Pastures 7,449
Unimproved Pastures 1,511

Woodland Pastures 2,001
Row Crops 253
Hay 4,648

Fruit Orchards 26

Other Groves 59
Poultry Feeding Operations 19
Nurseries and Vineyards 16

Tree Nurseries 279

Ornamentals 256

Horse Farms 61
Aquaculture 4
Other Open Lands 336
Fallow Cropland 3,367

Total 20,322 Based on GIS analysis of land use data from five water management districts (for entire state)



### 8.2 Method

When developing nutrient TMDLs for impaired waters, site specific a nalysis is generally needed to determine the nutrient reductions required from agricultural nonpoint sources and to identify theJanuary 2012 8. Potential Costs to Agricultural Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  8

- 2 appropriate agricultural BMPs capable of attaining the necessary reductions. Reductions obtained from any one practice will var y with onsite conditions including soils and proximity to waters, BMP implementation, and nutrients applied or produced.

Because this type of analysis for the waters that may not attain the proposed criteria is beyond the scope of this analysis, EPA estim ated the potential incremental costs of additional agricultural BMPs that may be necessary to meet t he proposed criteria using a study of BMP requirements and costs performed for the SFWMD as part of development of nutrient TMDLs for the Caloosahatchee Riv er and St. Lucie River (SWET, 2008). SWET (2008) develops t hree types of BMP programs: the set of BMPs that land owners would likely implement without incentives (owner program); the set of BMPs that would be implemented under a reasonably funded cost shar e program or modest regulatory approach (typical program); and more aggressive and costly controls (alternative program) that could be needed if additional nutrient reductions are required.

The BMPs in SWET’s (2008) owner and typical programs are similar to the BMPs adopted in FDACS BMP manuals (Section 2.1.5 ) and those detailed in existing BMAPs [although it is uncertain whether the mix of BMPs farmers are implementing under the FDACS BMP manuals reflect the same level of cont rol as the SWET (2008) owner/typical program in all cases]. Exhibit 8

- 2 shows the BMP program components SWET (2008) estimated would be appropriate for each type of agricultural activity.



### Exhibit 8

- 2 : Example Agricultural BMP Program Elements for the Caloosahatchee River
and St. Lucie River Watersheds

Land Use Owner/Typical Program

Citrus Reduced fertilization/nutrient management, grass management between trees,
add itional stormwater retention, and limited wetland restoration/retention

Cow Calf, Improved Pastures P reduced to zero/nutrient management, rotational grazing, new water facilities, retention basin by working pens, improved grass management, feed placement , critical area fencing, and moderate wetland restoration/retention

Cow Calf, Unimproved Pastures Some rotational grazing, new water facilities, retention basin by working pens, improved grass management, feed placement, and moderate wetland restoration/r etention

Cow Calf, Rangeland
and Wooded Pasture Some rotational grazing, new water facilities, retention basin by working pens, improved grass management, feed placement, and moderate wetland restoration/retention

Field Crop (Hayland) Production/Other Ar eas P reduced to zero/nutrient management, rotational grazing, new water facilities, retention basin by working pens, improved grass management, feed placement, critical area fencing, and moderate wetland restoration/retention

Ornamental Nursery Reduced P fertilization, water management, additional stormwater retention, cover crop, and limited wetland restoration/retention

Row Crop Reduced P fertilization, water management, additional stormwater retention, cover crop, and limited wetland restoration/reten tion

Horse Farms P reduced to zero/nutrient management, rotational grazing, new water facilities, retention basin by working pens, improved grass management, feed placement, critical area fencing, and moderate wetland restoration/retention
R/D = retentio n/detention Source: SWET (2008).

SWET (2008) estimates costs for an alternative program which it indicates may be necessary if additional nutrient reductions are needed beyond what the owner/typical program could obtain. However, these alternative practi ces, which include stormwater chemical treatment are not yet required in historically nutrient impaired waters heds with significant contributions from agriculture (e.g., Lake Okeechobee).January 2012 8. Potential Costs to Agricultural Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  8

- 3 Thus, it is highly uncertain whether such controls would ever be req uired. T herefore, for this analysis

, EPA believes it is reasonable to assume that costs to the agricultural sector are best represented by t he

owner and typical BMP program unit costs described above

. FDEP must verify that FDACS BMPs are reasonably expect ed to be effective [Section 403.067(7)(c)(3), F.S.]. However, it is unclear whether all necessary BMPs are implemented in all cases because individual agricultural operators apply the FDACS BMP manuals with little state oversight. Therefore, EPA

estimated potential incremental costs by applying unit costs based on two scenarios: 1) potentially

affected agricultural acres that are not currently enrolled in the FDACS BMP program (assuming that acreage currently enrolled in FDACS BMP program do not require add itional BMPs) and 2) all potentially affected agricultural acres whether or not they are currently enrolled in the FDACS BMP program (assuming that acreage currently enrolled in FDACS BMP program may require additional BMPs, although such an estimate may d ouble count some costs)

. Exhibit 8

- 3 shows the total acres in the state that are enrolled in the FDACS BMP program, by land use.



### Exhibit 8

- 3 : Total Acres Enrolled in FDACS BMP Progr am
Land Use Number of Acres 1 Land Use Number of Acres 1

Cropland and Pastureland 57,828 Poultry Feeding Operations 308
Improved Pastures 604,137 Nurseries and Vineyards 7,619
Unimproved Pastures 187,799 Tree Nurseries 2,794

Woodland Pastures 85,730 So d Farms 6,113
Row Crops 55,797 Ornamentals 7,366
Field Crops 607,440 Specialty Farms 496
Tree Crops 102,137 Horse Farms 585

Citrus Groves 301,415 Diaries 6,163

Fruit Orchards 3,792 Aquaculture 15

Other Groves 324 Tropical Fish Farms 19

Abandoned Gro ves 12 Other Open Lands 11,715
Feeding Operations 389 Fallow Crop Land 2,269
Cattle Feeding Operations 854

Total 2,053,115
1. Based on FDACS BMP program NOI GIS data layer

.



### 8.3 Potential Costs

Exhibit 8

- 4 shows estimates of the potential incremental costs to agriculture that may be needed to reduce nutrients to levels that attain EPA’s criteria. EPA derived these estimates by multiplying the number of potentially affected acres in each category of agricultural operation with the unit costs of the owner plus typical programs from SWET (2008).January 2012 8. Potential Costs to Agricultural Sources

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  8

- 4 

### Exhibit 8

- 4 : Potential Agricultural Control Costs Associated with Incrementally Impaired
Estuaries

Agricultural BMP Category Number of Acres 1 Owner plus Typical Program Unit Cost ($/ac/yr) 2 Total Owner plus Typical Program Costs ($/yr)
Animal Feeding 19 $18.56 $400

Fruit Orchards 3 26 $156.80 $4,000
Cow Calf Production, Improved
Pastures 7,449 $15.84 $118,000

Cow Calf Production, Rangelan d and Wooded Pasture 2,001 $4.22 $8,500

Cow Calf Production, Unimproved Pastures 1,511 $4.22 $6,400

Cropland and Pasture Land (general) 4 38 $27.26 $1,000

Field Crop (Hayland) Production 4,640

- 4,648 $18.56 $86,100

- $86,300

Horse Farms 61 $15.84 $1,000

Ornamental Nursery 245

- 256 $70.00 $17,100

- $18,000
Row Crop 253 $70.40 $17,800

Sod/Turf Grass 0 $35.20 $0

Other Areas 5 358 $18.56 $6,600

Total 6 16,600

- 16,619

-- $266,900

- $267,800 Note: Detail may not add to total due to independent rounding. 1. Based on GIS analysis of land use data from five water management districts (for entire state) and FDACS BMP program NOI GIS data layer. Low end reflects acres in incrementally impaired HUCs (that are not included in HUCs for baseline impairme nt) that are not enrolled in BMPs under FDACS; high end reflects all acres in incrementally impaired HUCs, including those that are already enrolled in FDACS BMP enrollment. 2. Cost estimates from SWET (2008); representative of 2010 prices (Bottcher, 2010)

. 3. Owner/typical BMP unit costs based on costs for citrus crops. 4. Owner/typical BMP unit costs based on average costs for improved pastures, unimproved/wooded pasture, row crops, and field crops. 5. Includes FLUCCS Level 3 codes 2230, 2400, 2410, and 2 540. 6 . Excludes land not in production.January 2012 9. Potential Costs to Septic Systems

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  9

- 1 

## 9 Potential Costs for Septic Systems

Discharges from septic systems in Florida do not require surface water discharge permits. However, state implementation of the proposed criteria may affect these systems throu gh the identification of additional impaired waters

, and subsequent development of TMDLs and BMAPs. This section provides estimates of septic systems that may require additional nutrient controls as a result of state implementation of EPA’s rule and potent ial control costs that may be needed to attain EPA’s criteria . These estimates are only approximat ions for informational purposes ; actual control actions will depend on site specific conditions and control strategies.



### 9.1 Data

EPA obtained the locations of sep tic systems in Florida from the FDOH GIS data file of OSTDSs inspected by the Department’s Bureau of Onsite Sewage (FDOH, 2011). These data indicate that there are 944,006 septic systems in Florida, of which 802,500 are active. EPA used the data from the 8 02,500 active septic systems provided by FDOH (2011) to estimate the septic systems that may drain to incrementally impaired waterbodies (WBIDs).



### 9.2 Method

Nutrient reductions from septic systems could be necessary under the proposed rule . Implementation

stra tegies could include upgrading existing systems to advanced nutrient removal and connecting households and businesses that use septic systems to centralized wastewater treatment. The feasibility of connecting to centralized treatment compared to septic upg rades would depend on existing wastewater treatment capacity and the costs of the connections. For example, Monroe County estimates that it would cost approximately $15,000 per household to connect to a sewer system, including costs for connection

and sewe r piping, septic tank destruction, and treatment plant construction and upgrades.

Because of the cost, time, and issues associated with new wastewater treatment plant construction, EPA assumed that upgrading septic systems would in most cases be the lower cost and more feasible compliance strategy for nutrients. In areas where existing centralized treatment capacity is available, typical connection costs are also likely to exceed average septic system upgrade costs. For example, the City of Jackson ville (2 003) estimates that connection costs average $ 17,840 per house ($15,000 in 2003 dollars, updated to 2010 dollars using Region CPI), while the Florida Government Utility Authority (2009) estimates a range of $5,130 to $15,140 per house for 188 houses in Leh igh Acres. These costs are significantly higher than upgrading existing septic systems as described below.

Most of the existing nutrient

- related TMDLs for estuaries and coastal waters identify failing septic systems as contributing to nutrient impairments in surface waters. Those septic systems in close proximity to surface waters are likely to contribute the greatest load to the waterbody . For example, for the Middle St. Johns River Nutrient TMDL, FDEP included wastewater from failed septic tanks within 50 feet as direct discharges of untreated wastewater to the stream network; for those outside of the 50

- feet boundary, FDEP combined septic system loads with the nonpoint source loading for residential areas (Gao, 2009).

Properly operated and maintained sys tems usually provide treatment equivalent to secondary wastewater treatment (Petrus, 2003). However, even properly functioning septic systems could impact water quality, depending on septic system location and magnitude of the criteria

. Site specific data would be needed to determine which septic systems are contributing to nutrient impairments and the magnitude of thatJanuary 2012 9. Potential Costs to Septic Systems

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  9

- 2 contribution. In the absence of site specific data on the contributions of septic systems to nutrient loadings

in the watersheds surroundin g the potential incremental waters not attaining the proposed criteria , EPA assumed that systems located within 500 feet of waterbodies in the potentially affected watersheds may need to reduce nutrient loads.



### 9.3 Potential Costs

Because it is generally less expensive to upgrade an existing septic system than to connect to a centralized treatment system (as discussed above), EPA based its estimate of potential compliance costs on the incremental costs of upgrading conventional septic systems to advanced nutrie nt

- reducing systems. EPA assumed that all existing conventional systems are operated and maintained properly (any costs associated with improving existing functionality would not be attributable to EPA’s proposed rule).

9.3.1 Unit Costs

Biomicrobics manufactures the RetroFAST system as a retrofit of existing septic systems to improve nutrient removal (the system is added to existing septic tank and drainfield systems). The system is a

fixed

- film activated sludge process and ranges from $1,650 plus an additional $ 400 to $500 for installation ( Wastewater Technologies , 2010). Capital cost for the upgrade could range from approximately $2,000 to $2,100. Anderson et al. (1998) indicated that the system can achieve average TN concentrations less than 11 mg/L and TP conc entrations of 5.4 mg/L. SeptiTech also manufactures an onsite wastewater treatment system utilizing fixed film biological filters. The system costs approximately $3,000 to $4,000 to install (Everhart, 2009) and can consistently achieve effluent TN concentr ations less than 10 mg/L in warmer weather (14 mg/L average over 12 month study period in Massachusetts) (U.S. EPA, 2003a).

Aquapoint manufactures the Bioclere onsite wastewater treatment system which uses a fixed film biological trickling filter and clari fier to remove organics and nutrients from domestic wastewater. EPA (2003a) indicated that TN concentrations from a Bioclere system averaged 16 mg/L over a 13

- month study period of residential wastewater in Massachusetts. During warmer months effluent conc entrations were consistently below 10 mg/L. Installation of the system for a single family home to a new or existing conventional septic system costs approximately $6,500 (this cost does not include the septic tank and drainfield that are already present w ith existing systems) (McNeer, 2009).

Pursuant to section 369.318, F.S., the Florida Department of Health (FDOH) studied onsite disposal system standards needed to achieve nitrogen reductions protective of groundwater quality within the Wekiva Study Area. FDOH (2004) reported that a conventional septic tank and drainfield costs from $5,500 to $7,000 for a three

- bedroom home, and a comparable nitrogen

- reducing system with a drip irrigation drainfield costs from $7,500 to $9,000 (based on estimates from licen sed contractors and engineers that design and install nutrient

- reducing systems in the area). However, details on the nitrogen

reducing system components are insufficient to estimate the incremental costs of upgrading to nitrogen removal. For example, it i s not clear whether the existing septic tank could be used and the nitrogen

reducing technology could be retrofitted or whether the entire system would need to be replaced.

Based on this information, EPA estimated that capital costs for upgrading existing septic systems to achieve nutrient removal could range from $2,000 (approximate cost of RetroFAST system for 250 gallons/day) to $6,500 (cost of fixed film biological trickling filter). For O&M costs, EPA relied on a study that compared the annual costs as sociated with various septic system treatment technologies including conventional OSTDS and fixed film activated sludge systems similar to those described above. Chang et al. (2010) estimated the incremental O&M costs for an advanced system to be $650 per year.January 2012 9. Potential Costs to Septic Systems

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  9

- 3 Thus, based on annual O&M costs of $650 and annualizing capital costs at 7% over 20 years, annual costs could range from approximately $800 to $1,300 for each upgrade

.
9.3.2 Total Potential Costs

The GIS analysis indicates that there are approximately 7, 32 5 septic systems within 500 feet of incrementally impaired waterbodies (WBIDs) in the watersheds draining to incrementally impaired

WBIDs

. Exhibit 9

- 1 shows estimates of the potential incremental costs to septic systems that may n eed to be upgraded to reduce nutrients to levels that attain EPA’s criteria.



### Exhibit 9

- 1 : Summary of Estimated Upgraded Septic System Costs

Number of Active Septic Systems 802,500
Number of Septic System s within 500 Feet of Potentially Incrementally Impaired Waters 7,325

Capital Costs ($) $2,000

- $6,500 O&M Cost ($/yr) $650 Annual Costs (millions) 1 $5.9

- $9.5

Based on adding annual O&M costs to capital costs annualized at 7% rate over 20 years.January 2012 10

. Government Expenditures **Draft for Internal Review Only**

**- Do Not Quote or Ci**  **te** 10

- 1 

## 10 Government Expenditures

State implementation of the proposed criteria may result in additional costs related to the development of TMDLs for WBIDs added to Florida’s 303(d) list of impaired waters. This section describes how EPA

estimated potential increm ental costs associated with government expenditures to develop additional

TMDLs.



### 10.1 New TMDLs

EPA determined that e xisting nutrient

- related TMDLs for estuaries and coastal waters address an average

of approximately four WBIDs each. Using the average number of WBIDs per TMDL

, EPA estimated that 58 (230 ÷ 4) additional nutrient TMDLs may be required under the proposed rule.

The process for developing TMDLs in Florida includes (FDEP, 2005 b ):

 gathering and analysis of data

 meeting quality assurance specifications

 computer modeling

 adoption through state’s public rulemaking process

 public hearing before adoption

 development of a BMAP with detailed implementation strategies (1

- 2 year process after adoption with additional public meetings).

FDEP may also hold public m eetings after data collection and prior to development of a draft TMDL.

EPA had previously estimat ed the cost of developing TMDLs based on performing eight basic steps (U.S. EPA, 2001) :

 characterizing the watershed

 modeling and analyzing the waterbody an d its pollutants to determine the reduction in the pollutant load that would eliminate the impairment

 allocating load reductions to the appropriate sources

 preparing an implementation plan

 developing a TMDL support document for public review

 performing pub lic outreach

 conducting formal public participation and responding to it

 management (including tracking, planning, legal support, etc.).

EPA (2001) indicates that the average cost per case of impairment is approximately $28,000 nationally

, but can typicall y range from about $6,000 to $154,000. The lower end of the range ($6,000) reflects the typical cost associated with TMDLs that are the easiest to develop and also have the benefit of maximum efficiencies ( e.g. , a TMDL for another pollutant in the same wat erbody ). The higher end of the range represents the cost associated with TMDLs that are most difficult to develop, and for which there is no benefit of related work done on other TMDLs for the waterbody or the watershed . Although theJanuary 2012 10

. Government Expenditures **Draft for Internal Review Only**

**- Do Not Quote or Ci**  **te** 10

- 2 establishment of nume ric nutrient criteria may reduce these higher end TMDL costs, EPA did not account for these reductions in this analysis.

Because more than half of the WBIDs EPA identified as not attaining the proposed criteria exceed more than one criterion, EPA assumed that FDEP would address both pollutants in TMDL analyses for each set of WBIDs. Thus EPA estimated the cost of developing TMDLs as the cost of a TMDL for one pollutant plus the cost of a second TMDL for an additional related pollutant, or approximately $34 ,000 ( the average

TMDL cost of $28,000 for the first nutrient, plus the low end TMDL cost of $6,000 for the second

nutrient ). Escalating this cost to June 2010 dollars, 11 average per TMDL costs could be approximately $47,000. Multiplying the average cost pe r TMDL ($47,000) by an additional 58 TMDLs results in an

estimated total cost of approximately $ 2.7 million

. Currently, FDEP operates its TMDL schedule based on a five

- phase cycle that rotates through the five

basins over five years (FDEP, 2003). Under th is schedule, completion of TMDLs for high priority waters will take 9 years; it will take an additional 5 years to complete the process for medium priority waters. Thus, assuming all the incremental impairments are high priority and FDEP develops the new T MDLs

over a 9

- year period, annual costs could be approximately $0.3 million.



### Exhibit 10

- 1 : Summary of Estimated Government Expenditures

Estimated TMDLs Needed 58 Average Cost of TMDL $47,000

Total Costs (millions) $2.70

Annual Costs over 9 Years (millions) $0.30



### 10.2 Site Specific Alternative Criteria

As part of FDEP’s 2009 proposed nutrient criteria revisions, FDEP proposed to adopt many nitrogen and phosphorus TMDLs as SSAC. Under EPA’s proposed rule, th e state could adopt TMDL targets as SSAC as part of its triennial review process for minimal costs. Furthermore, costs to develop SSAC under EPA’s proposed rule are likely to be similar to what SSAC development costs have been under the

current narrative n utrient criteria in Florida, such that this proposed rule causes no additional costs. Thus, EPA assumed that incremental costs associated with SSAC, if any, would be minimal.



### 10.3 Ambient Monitoring

Existing TMDLs and information on the current 303(d) list indi cate that state and local agencies are regularly monitoring TN and TP in ambient waters. These agencies monitor TN and TP levels even though the existing criterion is narrative because FDEP’s nutrient impairment listing method uses a trophic state index (T SI) that is calculated based on TN, TP, and chlorophyll

- a concentrations. These nutrient criteria data are the basis of the extensive IWR database FDEP maintains, and which provides baseline water quality data for the analyses in this report.

Because FDEP is currently monitoring TN, TP, and chlorophyll

- a concentrations in many waters, the proposed rule is unlikely to have a significant cost impact on monitoring activities throughout the state.

11 Escalated using the Bureau of Labor Statistics Employment Cost Index for state and local government workers (2001 Index = 83.6; 2010 Index = 115.4).January 2012 11. Summary of Potential Costs

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  11

- 1 

## 11 Summary of Potential Costs

The potential costs that may be ass ociated with state implementation of t he proposed criteria for estuaries

, coast al water s , and south Florida inland waters in Florida may include incremental compliance and government resource costs. This section provides a summary of EPA’s estima tes of the se potential costs.



### Exhibit 11

- 1 : Summary of Potential Annual Costs Associated with Numeric Nutrient Criteria (2010 dollars)

Source Sector Type of Expenditure Annual Cost (millions) Municipal Wastewater 1 BNR to reduce TN and/or TP $94.2

- $117.5

Industrial Dischargers 2 BNR to reduce TN and TP; chemical precipitation to reduce
TP $7.6

Urban Stormwater 3 Stormwater controls $55.2

- $86.0
Agriculture 4 Owner/typical BMP program $0.3

- $0.3

Septic Systems 5 U pgrade to advanced nutrient
treatment $5.9

- $9.5

Government/Program Implementation 6 TMDL development $0.3

Total

-- $163.5

- $ 221.2

Note: Detail may not add to total due to independent rounding. BNR = biological nutrient removal; TMDL = total maximum da ily load; TN = total nitrogen; TP = total phosphorus 1. Based on upgrading existing treatment processes to advanced BNR. 2. Based on average annual costs per flow for dischargers stratified by industrial category. 3. Based on median stormwater control cost s from FDEP (2010a), and scenario of need for structural controls on land developed before 1982. 4. Based on implementing nutrient management on all crop land outside of incrementally and baseline impaired watersheds and scenarios in which all agricultural land not enrolled in the FDACS BMP program in incrementally impaired watersheds incurs owner/typica l program costs from SWET (2008 ) or all agricultural land in incrementally impaired watersheds incurs owner/ty pical costs based on SWET (2008 ). 5. Based on upgrading to advanced nutrient removal active septic systems within 500 feet of water (based on GIS land use data) in the watersheds surrounding potential incrementally impaired WBIDs. 6. Based on average costs to complete TMDLs for incrementally impaired waters under a 9

- year schedule.

The estimates of potential incremental costs associated with state implementation of EPA’s nume ric

nutrient criteria for estuaries, coastal waters , and south Florida inland waters in Florida are based on

several assumption s that may over

- (+) or underestimate (

- ) actual costs

. Exhibit 11

- 2 provides a summary of the key uncertainties.January 2012 11

. Summary of Potential Costs

**Draft for Internal Revie w Only** 

**- Do Not Quote or Cite**  11

- 1 

### Exhibit 11

- 2 : Uncertainties of the Analysis

Unce rtainty/Assumption Potential Impact on Cost Estimates Comment

Several assumptions in estimating costs

to municipal wastewater dischargers;

e.g., all dischargers would need to achieve TN and TP effluent

c oncentrations less than 3 mg/L and 0.1 mg/L, respect ively. ? EPA did not conduct facility

- specific analyses, so needed to make these

assumptions for general analysis.

For municipal wastewater dischargers, used same unit costs for capital and O&M regardles s of the reductions needed. ? EPA did not consider e xisting effluent quality in estimating potential incremental costs.

Industrial dischargers in the Electric Services and Other categories would not incur incremental compliance costs. - Estimate is based on a representative sample of dischargers. Could be an

underestimate if any of the other dischargers in the universe would incur
costs. Uncertainty with regard to the TN and TP concentrations achievable with available treatment technologies ? Estimate is based on assumption that variance demonstrations can be made.

Implementing controls on all urban land that is not low density residential developed after 1982 would be sufficient for compliance with the pro posed criteria. ? EPA did not have the data to perform watershed modeling to determine the

appropriat e mix of controls for each urban area that would result in attainment of the proposed criteria. Does not account for the existing level of BMP implementat ion resulting from NPDES stormwater permit requirements. + Costs are likely overestimated without

acc ounting for existing levels of BMP implementation.

Median unit costs used for urban stormwater controls to represent a scenario in which the range of stor mwater control costs are equally distributed throughout each watershed. ? Stormwater control costs ar e highly variable, with unit costs from FDEP (2010a) ranging over three orders of magnitude.January 2012 11

. Summary of Potential Costs

**Draft for Internal Revie w Only** 

**- Do Not Quote or Cite**  11

- 2 

### Exhibit 11

- 2 : Uncertainties of the Analysis

Unce rtainty/Assumption Potential Impact on Cost Estimates Comment

Agricultural costs estimates assume that

farmers would implem ent owner and typical BMP programs on all acres in incrementally impaired watersheds. ? EPA did not c onduct a watershed

specific analysis of potential agricultural controls needed to attain EPA’s proposed criteria. In some watersheds, point source or urban source controls may be sufficient, while in other watersheds a more aggressive level of BMP implemen tation may be necessary.

Septic systems located within 500 feet of

waterbodies in the potentially affected watersheds may need to reduce nutrient loads. ? Without site

- specific modeling of watershed characteristics and soil properties it is highly uncerta in whether septic systems within 500 feet of water in the potentially affected watersheds are contributing to nutrient loads and whether such contributions would need to be reduced.

Costs to attain proposed criteria attributed to proposed rule. + Some of these waters may be currently in nonattainment of the existing narrative nutrient criterion but not yet unidentified
as such.

EPA considered nutrient source categories separately, and assumed controls on all categories are needed in

all instances of crit eria exceedances. + In some watersheds, controls on a subset of potential sources may result in attainment of WQS.

BMPs = best management practices FDEP = Florida Department of Environmental Protection NPDES = National Pollutant Discharge Elimination Sys tem O&M = Operation and Maintenance TN = total nitrogen TP = total phosphorus Key: “+” = impacts likely overstated

“

– “ = impacts like understated “?” = direction of impact is uncertainJanuary 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  12

- 1 

## 12 Description of Benefits of Reducing Nutrient Loads to Florida
Estuar ies

Elevated concentrations of nutrients in e stuar ies, coast al water s , and south Florida inland waters in Florida may result in adverse ecological effects, and, as a result, decrease provision of environmental goods and services and impair designated water uses. Conversely, reduction in nutrient concentrations to meet numeric standards will improve ecological function and enhance provision of environmental goods

and services

, and help to attain or maintain designated uses. The following sections discuss the general

effects of nutrients in estuari ne , coast al waters

, and south Florida inland waters, and provide qualitative

assess ment of the potential for benefits from nutrient reductions that may result from implementation of the proposed rule.



### 12.1 Effect of Nutr ients on Bays, Estuaries and Coasts

The influence of growth

- limiting chemical s or nutrients, particularly nitrogen and phosphorus, on water quality, biota, and habitats of estuarine and coastal aquatic ecosystems is profound. When supplied in

excess amoun ts by man’s activities, elevated nutrient concentrations can lead to a series of predictable changes in the chemical and physical environment with resultant shifts in water quality and aquatic communities, a process which is commonly referred to as anthrop ogenic eutrophication (Bricker et al., 2007). The following sections provide general information on the ecological impacts of nutrients and the eutrophication process.

12.1.1 Ecological Effects

Eutrophication is the increase in organic carbon to an aquatic ecosys tem caused by primary production stimulated by excess nutrients, typically compounds containing nitroge n or phosphorus (U.S. EPA,

2010 d ). Eutrophication is a major concern for many waters within the United States, and is particularly severe for many waters in Florida

. The 2008 Integrated Report for Florida indicates that 94 estuaries encompassing approximately 900 square miles of water are impaired for nutrients, with nutrients ranked as the second most common source of impairment. 12 One additional coastal b ody representing 102 square miles is also impaired for c hlorophyll, typically considered an indicator of algal growth associated with eutrophication (FDEP, 2008 a ).

For most estuaries and coast al water s, the growth

- limiting nutrient (i.e., the chemical whic h largely controls the rate of primary production) is nitrogen, such that it is the reduction in the supply of nitrogen that is the primary focus of most estuarine nutrient TMDLs. Phosphorus can be growth

- limiting under certain circumstances, particularly near an estuary’s freshwater boundary, but phosphorus is generally more important in inland waters. EPA (2010 c ) provides a detailed description of adverse ecological effects of nutrients focusing on inland waters.

Eutrophication can lead to a predictable s equence of ecological effects and ultimately to environmental degradation, including increases in the occurrence and intensity of water column phytoplankton, including harmful algal blooms (e.g., nuisance and/or toxic species), loss of critical submerged a quatic vegetation (i.e., SAV), and reduced and/or diurnally variable dissolved oxygen (DO). In turn, ecological degradation can lead to significant losses in environmental goods and services provided by the affected waterbodies (e.g., reduced commercial an d recreational fishing opportunities and reduced swimming, diving, and

12 The 2010 report indicates cause of impairment as Trophic Status Index (TSI), which measures t he potential for algal or aquatic weed growth, the components of which include total nitrogen, total phosphorus, and chlorophyll.January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  12

- 2 snorkeling opportunities). Exhibit 12

- 1 provides a conceptual model of the potential ecosystem response to nutrients and how the resulting ecol ogical effects translate into impacts to ecological s ervices.



### Exhibit 12

- 1 : Eutrophication Impacts and Responses for Estuaries and Coast al Water s

External Nutrient Inputs Mitigating Natural
Factors Primary Responses Secondary Responses Impacts
Human / Aquatic Life

Nitrogen and Phosphorus Color Flushing
Residence

Depth Turbidity Grazing Algal Dominance Changes

Decreased Light

Availability

Increased Organic

Decomposition Harmful Algae

Loss of SAV

Low Dissolved

Oxygen Increase of Algal Toxins

Loss of Habitat

Fish Kills Diatoms to Flagellates

Benthic Dominance to Pelagic
Dominance

Extreme Chl

- a Concentrations

Excess Epiphytic Growth

Excess Macroalgal Growth Nuisance Blooms

Toxic Blooms

Reduced SAV Spatial Coverage

Negative SAV Spatial Coverage Trends

Extreme Chl

- a Concentrations

Bacterial Respiration Anoxia

Hypoxia

Biological Stress Commercial and Recreational Fishing Aquaculture

Tourism
Human Health

Swimming

Commercial and Recreational Fishing Aquaculture

Tourism Diversity Organism Condition Ecosystem Function

Nursery Areas

Diversity Organism Condition Ecosystem Function

Commercial and Recreational Fishing Aquaculture
Aesthetic Values
Tourism Diversity Organism Condition Ecosystem Function

Source: Adapted from Weaver (2010).

As illustrated in Exhibit 12

- 1

, external nutrient loads are the driving factor in the ecological impacts, but the relative impact can be significantly affected by the mitigating factors of light (color, tu rbidity), estuary hydrodynamics (tidal flushing, hydraulic residence time, depth), and biotic interactions (e.g., zooplankton grazing). It is typically the interplay between nutrients and the mitigating factors that produces a site specific response for a particular estuary, such that equal amounts of nitrogen may have quite variable growth responses in different environmental settings.

Exhibit 12

- 1 shows the primary responses of eutrophication, categorized as algal dominance changes, decreased light availability, and increased organic decomposition. As nutrients increase, the primary responses can lead to more severe and problematic secondary responses, which are typically the more readily observable manifestations of ecosystem degradation. These secondary responses include harmful algal blooms, loss of submerged aquatic vegetation, and low DO. In shallow waters, nutrient enrichment can lead to increases of attached benthic algae (i.e., epiphytes) or loose macroalgae ; whereas deeper waters will develop phytoplankton blooms. The sections below discuss primary and secondary responses to eutrophication and describe the quantitative relationship between nutrients and some of the primary and secondary responses.January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

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**- Do Not Quote or Cite**  12

- 3 12.1.2 Primary an d Secondary Eutrophication Responses

Increases in the supply of n utrients can lead to increased amounts of primary production in the form of phytoplankton in the water column. The strong positive relationship between nutrient supply and increased algal gr owth (often measured as concentrations of the primary photopigment chlorophyll

- a ) has been modeled for bays, estuaries, and coasts (e.g., Nielsen et al., 2002; Lewitus et al., 1998; Valiela et al., 1997), including Florida estuaries (Janicki et al., 2001; Morrison et al., 1996; Glibert et al., 2004). As nutrient loading increases, the trophic state of a waterbody can change from a poorly

- fertilized and low productivity state (termed oligotrophic) or moderately

- fertilized and moderately productive state (mes otrophic) to a well

- fertilized and highly productive state (eutrophic) (Pinckney et al., 2001).

Eutrophic coastal systems typically maintain high levels of primary productivity (i.e., phytoplankton, SAV, periphyton) during the growing season, which for Fl orida is essentially year

- round. In low salinity estuaries (i.e., less than 10

- 12 parts per thousand)

, eutrophication can shift the water column phytoplankton community to one dominated by blue

- green algae species which often have physiological advantages over other phytoplankton taxa under conditions of low light, high grazing, warm temperatures, and low nitrogen to phosphorus supply ratios (Smith et al., 1999). High concentrations of blue

- green algae (cyanobacteria) constitute harmful algal blooms (HABs) due to their potential to form nuisance surface scums, sharply reduce light penetration into the water, provide poor grazing material for zooplankton and young

- of

- year fish, and produce irritating or toxic compounds (e.g., cyanotoxins).

High concentration s of cyanotoxins have been found to cause health problems in humans and fatal poisoning in other animals, fish, and birds, and some cyanotoxins may bioaccumulate in the food chain (Miller et al., 2010). Recent research found the cyanobacter Lyngbya spp. in 16 different coastal areas throughout Florida, with persistent blooms in the Indian River Lagoon and Broward County reefs on the Atlantic Coast, as well as Sanibel Island on the Gulf Coast (Paerl et al., 2009). In higher salinity estuaries (i.e., greater than 10

- 12 parts per thousand), the physiological and biogeochemical

- based competitive advantages of blue

- green algae are reduced, such that blue

- green algal blooms are much less prevalent in these waters (Howarth and Marino, 2006).

The reduction of ligh t levels (i.e., decreased depth to which light penetrates or eutrophic zone) due to water column algal blooms and turbidity also can adversely affect SAV biomass in bays, estuaries, and coasts, reducing their spatial coverage, species diversity, and amount of primary production. In Floridian waters as elsewhere, the maximum depth of SAV colonization is highly dependent on the water clarity, as indicated by Secchi disk transparency (SDT) depth (Greening and Janicki, 2006; Krause

- Jensen et al., 2008). High nu trients can also lead to the direct growth of epiphytic algae on the SAV which also reduces

its light harvesting abilit y

. Overall, eutrophication can cause a shift in bays, estuaries, and coastal waters from aquatic vegetation domination (i.e., most of pr imary production coming from rooted aquatic plants) or coral domination to highly turbid and phytoplankton

- dominated systems, with little or no submerged aquatic vegetation or corals (Hauxwell et al., 2001; Lapointe et al., 2004). In addition to the loss i n primary production and reduced food for herbivorous wildlife (e.g., sea turtles, manatees), the loss of the aquatic vegetation has the additional ecosystem effect of reducing refuge habitat for zooplankton against fish predators. This condition may exace rbate the turbidity of the water, as the reduced herbivorous zooplankton population can no longer reduce or control phytoplankton biomass by grazing.

Eutrophication can lead to increased levels of organic carbon accumulations in the water column (Pinckney et al., 2001). When the algal blooms die, sink, and decay, the decomposition of the excess organic carbon leads to increased bacterial respiration, particularly in lower depths or in the sediments.January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  12

- 4 This increased oxygen demand can greatly reduce DO result ing in hypoxia (reduced DO)

, or even anoxia (lack of DO)

, in the deep or overlying waters. Shallow eutrophic waters may also be subject to large diurnal swings in DO because highly productive waters produce excess oxygen via photosynthesis during daylight hours but also result in low levels at night due to elevated dark respiratory demand. These diurnally variable conditions can lead to biological stress of aquatic biota resulting in impaired biotic conditions or even mortality (e.g., fish kills).

Water qu ality degradation caused by nutrients can also have significant adverse impacts on coral reef ecosystems. Lapointe (1997) found that blooms of macroalgae in reefs are correlated with concentrations of nitrogen and phosphorus, and that increases in nutrient loadings can shift the relative dominance of reefs from corals toward algae, drastically altering habitat and trophic structure. Nutrient

- related blooms of the green alga Codium isthmocladum in southeast Florida resulted in an emigration of reef fish and die

offs of sponges and corals (Lapointe et al., 2005).

In addition to the biological stress it produces, reduced or absent DO can also lead to altered reduction

oxidation (redox) chemistry. Low redox conditions can result in increased ammonia concentrati ons in the

water column

, and internal recycling of phosphorus from the sediment. The former can be toxic to aquatic life under certain temperature and pH conditions

, and the latter can be problematic for reduc ing phosphorus loadings.

12.1.3 Mitigating Factors

As indicated in Exhibit 12

- 1 , there are several mitigating factors that will potentially influence the degree or magnitude of response of a waterbody to eutrophication. The amount of color in the water (i.e., the tin t due to dissolved substances, independent of suspended material) influences the potential nutrient

- based productivity. Highly colored waters will not be as susceptible to nutrient addition as the depth of light penetration will be attenuated and primary p roductivity lessened. Turbidity due to suspended inorganic particles (silts and clays) will also tend to reduce productivity due to both light limitation and the adsorption of nutrients to the clay particles.

Hydraulic residence time (sometimes expressed as its reciprocal, the flushing rate) can mitigate the effect of nutrients. If the residence time is sufficiently short, algal blooms will not develop as the growing cells are quickly washed away and do not accumulate in the water column. Where such nutrie nt

- laden waters flush more slowly, significant algal blooms may develop. Depending on the physical configuration of the waterbody, tidal flushing may reduce or incre ase impacts of eutrophication. In the case of an open coastal system, tidal flushing and lo ngshore currents may act to dilute or sweep away algal accumulations. Conversely, in the case of complex and/or constricted coastal embayments, tidal action may serve to concentrate algal concentrations in interior portions.

Depth is an important factor since deeper waters tend to be less productive than shallow waters. This is due to the euphotic zone occupying a greater proportion of the volume of shallow waters, as well as the greater probability for thermal stratification to occur in deeper waters. In addition, where estuaries enter the marine environment, the fresher, less dense water flows over the salty, denser marine waters, a salinity

- based stratification can occur; further compartmentalizing the water column. In either case, algae sinking in dee per, dark waters are much less likely to be re

- suspended.

Grazing refers to the ingestion of the phytoplankton by herbivorous zooplankton. Zooplankton and macroinvertebrates can be an important controlling mechanism for preventing algal blooms from develop ing. The size and composition of the fish community can also influence the biomass and effectiveness of the zooplankton grazers in controlling the primary producers.January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  12

- 5 

### 12.2 Impacts of Nutrients on Environmental Goods and Services

Eutrophication of estuaries, coa st al water s , and south Florida inland waters may have a significant impact on the value of environmental goods and services provided by the se waters.

12.2.1 Impacts of Harmful Algal Blooms ( HABs )

Exhibit 12

- 1 shows the l ink between eutrophication in bays, estuaries, and coasts and the provision of environmental goods and services. For example, the occurrence of nuisance or toxic HABs adversely affects a number of designated water uses including: contact recreational activ ities and recreational and commercial fishing, and may also pose human health risks. Reductions in recreational opportunities (e.g., decrease in catch rates), decline in aesthetic value, adverse public perceptions of the safety of polluted water, and poten tial exposure to health risks may also adversely affect tourism, both locally and at the

state level.

A large body of research on HABs in coastal waters in Florida focuses on “red tide” blooms, which are caused by dinoflagellate species (Kirkpatrick et al ., 2002). Although increased nutrient levels are correlated with red tide blooms, numerous other factors also contribute, and it is not possible to directly link nutrient reductions with reduced duration and frequency of red tide events (Alcock, 2007). For this reason, this analysis does not specifically consider benefits stemming from avoided red tide blooms.

One major HAB group of concern for bays, estuaries, and coasts are the blue

- green algae which pose a

toxic risk to mammals including wildlife and hu mans due to the presence of cyanotoxins and other toxic compounds released when the algae decay (Fleming and Stephan, 2001). Blue

- green algae toxins are classified according to mode of action and include hepatotoxins (e.g., microcystins), neurotoxins (e.g.

, anatoxins), skin irritants, and others (WHO, 2003a). The cyanobacterium Lyngbya , which is found in

coastal waters in Florida , is associated with skin irritation and may promote skin tumors (WHO, 2003b).

Contact recreation includes swimming and other act ivities (e.g., jet

- skiing, kayaking) where direct dermal exposure to water is likely. Swimmers’ direct contact with water makes them susceptible to irritants or toxins associated with certain types of HABs that may occur with nutrient pollution (Fleming an d Stephan 2001). Although HAB

- related beach closures in coastal and estuarine waters in Florida are typically associated with red tide events, which may not be linked as directly to nutrient loadings, evidence from Maryland demonstrates that cyanobacteria toxins can constitute a sufficient human health risk to warrant

beach closures in estuarine environ ments (Fristachi et al. 2008).

Phlips et al. (2002) examined the distribution of potentially toxic cyanobacteria in waters in Florida . The study noted bloom s of the cyanobacterium Synechococcus in two large Florida estuaries

– Florida Bay and the Indian River Lagoon. Paerl et al. (2009) found Lyngbya at sixteen sites along the Florida coast, with persistent blooms occurring in three locations. Decreased level s of nutrients associated with the

numeric nutrient criteria would reduce the number of HABs and thus reduce toxin levels and health risk

to swimmers, also potentially curtailing more substantial HABs outbreaks such as the one in Grand Lake St. Mary ’ s

.
12.2.2 Im pacts of Submerged Aquatic Vegetation Loss

Seagrasses often are a major determinant of the trophic structure of coastal ecosystems, providing food, habitat, and shelter for a wide range of fish species and provide feeding grounds for marine mammals, reptil es, and birds (Zieman, 1982). Increased nutrient loadings are frequently associated with the loss of SAV, especially seagrasses, and can be devastating for estuarine ecosystems, leading to reduction in

recruitment for coastal commercial fisheries and shell fisheries. Some seagrass habitats also serve asJanuary 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

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**- Do Not Quote or Cite**  12

- 6 nurseries for juveniles of species that spend their adulthoods in other habitats (Beck et al., 2001). Seagrasses also improve water quality by increasing DO and absorbing excess nutrients (US EPA, 2006).

In Florida, seagrass habitat is a highly valuable ecological and societal resource. Florida DEP has estimated that each acre of seagrass is worth $20,255 per year, which would translate to a benefit of $44.6 billion statewide (Carlson and Yarbro, 2008). In 20 09, Florida seagrass communities supported an estimated harvest of $23 million for six species of commercial fish and shellfish dependent upon seagrass habitat (Crist, 2010). Some commercially fished species that rely upon seagrass habitat include pink

shr imp, stone crab, spiny lobster, and snapper. SAV in the Florida Keys also provides habitat for over 30 species of tropical invertebrates that are harvested by the marine collection industry (Florida DEP, undated).

Seagrasses also provide forage for threate ned and endangered species including manatees and sea turtles (Orth et al., 2006; Beck et al., 2001). Nutrient

- induced reductions in seagrass habitat could have adverse implications for the populations of these species.

12.2.3 Impacts of Degraded Water Quality

Lo w ambient DO concentrations or anoxia adversely affects fish growth and reproductive success and can result in shifts in a fish community to low DO tolerant species, reduced growth rates, and more frequent fishkills. In waters with an anoxic bottom layer, the available volume of open water habitat for fish and zooplankton is reduced. Excess, decaying organic material and low DO often lead to unsightly or aesthetically

- unpleasing shorelines (sight and/or odor) that discourage beach recreational activities an d

tourism (Bricker et al., 2007) . Unsightly or aesthetically

- unpleasing shorelines may also affect waterfront property values (U.S. EPA, 2010 e )

. Additionally, degradation caused by nutrients can have significant adverse impacts on coral reef ecosystems. A s noted earlier, Lapointe (1997) found that blooms of macroalgae in reefs are correlated with concentrations of nutrients, and that increases in nutrient loadings can shift the reefs from coral dominance toward algae dominance, with significant impacts on habitat and trophic structure. This degradation diminishes the value of reefs as tourist destinations.

As noted in Exhibit 12

- 1 , the combination of the presence of HABs, loss of SAV, and low DO conditions will impa ct ecological services such as biodiversity (i.e., the number of species and habitats present), organism health (i.e., population viability and reproduction), and ecosystem function (e.g., carbon sequestration, nutrient cycling, waste assimilation). The ef fects of eutrophication in altering these types of ecological functions are well

- documented (e.g., Smith et al., 1999; Hauxwell et al., 2001).



### 12.3 Types of Benefits Associated with Nutrient Reductions

Implementing nutrient criteria and reducing nutrient concen trations in bays, estuaries, and coasts should reduce or prevent the adverse effects of eutrophication and, as a result, enhance the environmental goods and services that these waters provide. For impaired bays, estuaries, and coasts, the restoration goal is to

move these waters from a nutrient

- rich, eutrophic state to a lower nutrient state closer to the natural condition of the waterbody. For unimpaired waters, the criteria establish benchmarks for limiting loads and preventing a loss of designated uses i n the future, thus maintaining beneficial uses.

As shown in Exhibit 12

- 2 , EPA has identified the types of benefits often associated with environmental policies, including improvements in water quality, and the type s of methods that can be used to assign value to such benefits. Categories that may be applicable to nutrient reductions in Florida include humanJanuary 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

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- 7 health, ecological, and other benefits. The sections below discuss the potential for benefits in these
categor ies.



### Exhibit 12

- 2 : Types of Benefits Associated with Environmental Policies Category Examples Valuation Methods Human Health Improvements

Mortality risk reductions Reduced risk of fatality from
acute heal th risks Averting behavior, hedonics, stated preference

Morbidity risk reductions Reduced risk of nonfatal illness (e.g. gastrointestinal issues) Averting behavior, hedonics, stated preference Ecological Improvements

Market products Harvests or extracti on of food and other naturally

- occurring products and raw materials Production function

Recreation activities and aesthetics Wildlife viewing, fishing, boating, swimming, hiking, scenic views Production function, averting behaviors, hedonics, recreation

d emand, stated preference

Valued ecosystem functions S ediment trapping, soil retention, nutrient cycling, biodiversity, water filtration, soil fertilization, pest control Production function, averting behaviors, stated preference

Nonuse values Relevant sp ecies populations, communities, or ecosystem health Stated preference

Other Benefits

Aesthetic improvements Visibility, taste, odor Averting behaviors, hedonics, stated preference

Reduced materials damage Reduced soiling and corrosion Averting behavior s, production function, cost function
Source: U.S. EPA (2010a )

Note that there may be a lag between nutrient reductions and associated benefits in estuaries and coast al

water s. In some estuaries, groundwater is a significant source of nutrient loadings, and in these estuaries, there may be significant lag periods, as long as decades, between reductions in anthropogenic nutrient loadings to groundwater and observed improvements in the estuaries (Glibert et al., 2010).

12.3.1 Human Health Improvements

High concen trations of HABs can pose potential health risk associated with irritants, gastrointestinal diseases, and other concerns. As noted above, several Florida estuarine areas have documented chronic cyanobacteria blooms, including Florida Bay, Indian River Lago on, Broward County reefs, and the coastal waters of Sanibel Island (Phlips et al., 2002; Paerl et al., 2009). Exposure to contaminated water

may cause dermal , gastrointestinal, or other symptoms (Phlips et al., 2002).

To the extent that the criteria and a ssociated nutrient reductions reduce current exposures and illness and prevent future exposures and illness, society values these types of reduced health risks. The cost of illness (COI), including treatment costs and lost wages, can provide a lower bound on societal value as a measure of avoided costs (rather than the preferred willingness

- to

- pay measure of benefits that includes the value of avoided pain and suffering as well as out

- of

- pocket costs). COI values represent a lower

bound value because these costs do not include the value of avoiding pain and suffering.January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

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- 8 12.3.2 Ecological Improvements

The goods and services provided by estuaries and coastal waters in Florida are particularly valuable commercially, due to the large fishing and tourism industries, and e cologically, due to the wide range of biodiversity they support

. Ecological benefits that may arise from nutrient reductions include market benefits, such as those associated with commercial fisheries and shellfisheries, and benefits to other

markets such as ecotourism; recreational uses, such as boating, fishing, and swimming; ecosystem functions, such as nutrient cycling and biodiversity; and benefits that are not associated with use of the resources (nonuse benefits), such as preservation of species for future generations (existence and bequest values).

**Commercial Fisheries and Shellfisheries**

Hypoxic events in a single water body can cause millions of dollars in economic losses from recreational and commercial fishing alone (CENR, 2010). Numerous species of commercial fish and shellfish rely on Florida bays, estuaries, and coasts during at least one life stage. SAV in coastal and estuarine waters serve

as important habitat to several major commercial species, including pink shrimp, stone crab, spiny lobste r and snapper (Florida DEP, undated). As described above, anthropogenic nutrient loadings can have substantial adverse impacts on availability of SAV, which in turn reduces available habitat for these species.

The reduction in nutrients associated with th e adoption of numeric criteria would reduce the probability of further habitat loss and could allow for the reestablishment of SAV habitat in areas where it has already been lost. The fisheries industries related to the aforementioned commercial species br ing in tens of millions of dollars to Monroe County alone on an annual basis (Florida DEP, undated). However, since multiple factors other than nutrient criteria can determine the presence and abundance of SAV and its suitability as habitat, the magnitude of the benefit directly attributable to the criteria would be difficult to

estimate.

**Tourism**
The tourism industry in nearshore counties in Florida contributes approximately $12.35 billion (2004 dollars) to the state economy annually 13 (NOEP, 2006). HABs ca n lead to public health department posting of water quality advisories due to potential health risk associated with irritants, gastrointestinal diseases, and other concerns. Reductions in the magnitude and duration of HABs linked to excess nutrients will p revent losses to local economies. As noted earlier, recent research funded by NOAA found Lyngbya spp. cyanobacteria in sixteen different coastal areas throughout Florida (Paerl et al., 2009).

Although an analysis of economic impacts on Florida beaches cau sed by a cyanobacteria bloom is not available, studies of tourism impacts resulting from red tide events find substantial adverse effects. 14 Lack

of information on locations and frequencies of cyanobacterial HABs and lost recreational value from

beach closu re s in Florida make it difficult to quantify the economic benefits to the tourism sector that may

be associated with reductions in nutrient loadings and HAB s in Florida waters.

Coastal saltwater fishing is a major attraction for both native Floridians and tourists and is a substantial boon to the Florida economy. Saltwater anglers averaged 10.8 million fishing trips per year within

13 Tourism data is for 2004, the most recent year for which data is available. Except where otherwise noted, dollar values

pre sented in this chapter are in 2010 dollars, inflated from original year dollars using CPI.

14 For example, Larkin and Adams (2006) found that red tide

- related HABs reduced restaurant and lodging revenues in the Ft.

Walton Beach and Destin areas of Northwes t Florida by $3 million and $4 million per month, respectively.January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

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- 9 territorial sea in Florida from 2005 to 2009 (NOAA, 2011). Recreational saltwater fishing in Florida has an annual impact of $ 5.4 billion dollars ( F FWC, 2010).

Ecotourism is an important sector in the economy of Florida and one which is highly vulnerable to the adverse impacts of eutrophication. Water quality aesthetics are directly linked to ecotourism, since

tourists are drawn by the untouched natural beauty or uniqueness of a particular ecosystem. Florida has many unique environments and species

, including coral reefs and manatees , that attract visitors . Thus, the principal benefits of ecotourism are avoiding loss of tourist d ollar s arising from declining attendance at

natural attractions due to water quality degradation

, or maintaining growth in income generated by increased tourism to natural attractions where water quality has been restored.

These natural attractions are vul nerable to increased nutrients as documented in studies of reefs in southeast Florida where blooms of the green alga Codium isthmocladum resulted in an emigration of reef

fish and die

- offs of sponges and corals (Lapointe et al., 2005). Lapointe et al. (200 5) found that anthropogenic nutrient pollution was likely a contributing factor to these blooms. Controls that reduce nutrient levels in surface waters and applied to the watershed (e.g., fertilizer reductions, septic system upgrades) may reduce nutrients that runoff directly or indirectly into reefs (see Section s 8 and 9 ).

R eef

- related recreational expenditures on activities such as snorkeling, scuba diving, fishing, and glass

bottom boating in four counties in southeastern Florida for a one year period in 2000

- 2001 totaled $5.37 billion (Johns et al., 2001). Preventing deterioration of water quality will avoid the costs associated with a

loss of tourism dollars associated with reef d amage. For example, Johns et al. (2001) estimated total economic contribution of reef related expenditures to income in four Florida counties at nearly $2.5 billion between June 2000 and May 2001, of which $1.5 billion stemmed from natural reefs. Tourist

a ctivities primarily included fishing, diving and snorkeling. Natural reefs supported 45,000 full

- time and
part

- time jobs during that period (Johns et al., 2001).

**Property Value s** 
Due to population growth, there has been significant development of coastal p roperties in Florida. Previous studies suggest that waterfront property is more desirable when located near unpolluted water, and therefore property values increase with improved water quality and vice versa. Improvement of water quality following implemen tation of the numeric nutrient criteria may increase waterfront property

values.

H edonic property models can be used to quantify the difference in property value for a given change in water quality in a particular locale. Hedonic models allow estimation o f the impact of a unit change in water quality (i.e., implicit price) on property prices.

For example, Czajkowski and Bin (2010) estimated the property price impacts of changes of several water quality measures in coastal Martin County, South Florida, inc luding temperature, pH, water visibility (clarity), salinity, DO, and the general indicator location grade, which is compiled by combining relative quality of four of the aforementioned indicators, excluding temperature. The results indicate that even

smal l improvements in water quality could be worth thousands of dollars to individual properties. It is important to note, however, that this method does not account for nonuse values and that there may be some overlap with other values such as recreational us e

. The authors found that the impact of all indicators except for DO on sale price was significant. Of the measures given, water visibility is the one most directly related to nutrient loadings. The mean marginal value of a one percent improvement in water visibility, all other things equal, was $5,263 (Czajkowski

and Bin

, 2010).January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

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- 10 **Recreation and Aesthetics**
The degradation of water resources resulting from high nutrient concentrations may negatively affect recreational opportunities. As stated above, high lev els of HABs could lead to beach closures, because of potential health risk, reducing the occurrence or quality of recreational activities. In addition to health and safety concerns, eutrophication may lead to the aesthetic degradation of water resources. A lgal and cyanobacterial blooms, and particularly surface scums

, are unsightly and can have unpleasant odors, causing beachgoers to go elsewhere even when a beach is not closed, diminishing recreational values. The color, clarity, and taste of water adverse ly affect many recreational activities, including recreational fishing, boating, diving, snorkeling, and swimming.

Eutrophication reduces the amount of DO in a waterbody, leading to fish kills. This in turn leads to fewer and smaller fish, and a reduction of the game fish population. Reductions in SAV also have adverse impacts on fishery stocks. Florida ranks number one nationwide in economic impacts from saltwater fishing ( F FWC, 2010). Between 2005 and 2009, anglers took an average of 10.8 million saltwat er fishing trips in the territorial sea of Florida (NOAA, 2011).

Activities that take place near water, such as hiking, jogging, picnicking, wildlife watching, and camping may also be adversely affected by nutrient discharges into the water. While these a ctivities do not involve

water contact, visually unpleasant water and odors may greatly detract from the enjoyment gained through these activities. Decreases in fish populations may cause a reduction in wildlife near the resource, affecting wildlife viewin g. Additionally, toxic cyanobacteria may poison birds and other wildlife through bioaccumulation, reducing the wildlife population near a waterbody (Landsberg and Shumway, 1998).

Improved water quality from reducing nutrient discharges will enhance the r ecreational uses of water resources, thereby resulting in welfare gain to recreational users of these resources. Improved water quality from reducing nutrient concentrations may translate into three components of recreational benefits: (1) an increase in t he value of a recreational trip resulting from a more enjoyable experience, (2) an increase in recreational participation, and (3) and increase in the number of available recreational sites.

**Valued Ecosystem Functions**

Attainment of the nutrient criteria s hould improve ecological functions such as biodiversity and protection of sensitive species. Since eutrophication tends to drive ecosystems to physical and chemical conditions (turbidity, low DO, highly organic sediments) which are tolerated by a smaller s uite of biota, reduction in

nutrients will allow the re

- establishment of SAV and pollution

- intolerant species (Greening and Janicki, 2006).

The ability of SAV to re

- establish in Florida estuaries under conditions of reduced nutrient loading is already doc umented . For example, Tampa Bay recovered nearly 8,000 acres of seagrass between 1982 and 2008 following reductions in nutrient loadings due to more stringent wastewater and stormwater standards enacted in the 1980s and nitrogen management measures introdu ced in the watershed in the early 1990s (Tampa Bay NMC, 2010). Increased species diversity is often linked to ecological capacity to

resist disturbance.

Estuarine and coastal waters provide habitat for numerous endangered and threatened species (Smith,

200 3). Florida is home to 53 federally listed endangered or threatened animal species and 54 endangered or threatened plant species, several of which are coastal aquatic species (U.S. FWS, 2011). The value of these species is indicated by f ederal and state ex penditures on conservation efforts to protect and restore them. Expenditures for the West Indian manatee alone totaled nearly $10 million for fiscal year 2003

, although this spending is not solely in Florida ( U.S. GAO, 2005).January 2012 12

. Description of Benefits of Reducing Nutrient Loads to Florida Estuar ies

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- 11 Attempting to isolate the eff ects of nutrients from other stressors of special concern in Florida and elsewhere is difficult. Symbolic threatened and endangered species such as the Florida manatee and several sea turtle species are affected somewhat by water quality and nutrient condi tions through the food

chain (e.g., effects on aquatic macrophytes), although other factors (e.g., water temperature, hydrological variation, direct human interference) are also important.

In the case of the Florida manatee, preferred manatee habitat is c haracterized by the availability of good quality SAV (Smith, 1993). In coastal waters, manatees feed primarily on submerged aquatic macrophytes such as Thalassia hemprichii and Syringodium filiforme (U

. S

. FWS, 200 1 ) . Nutrient loading to estuaries promotes the growth of epiphytic algae and decreased light transparency, thus reducing available SAV forage (Nelson, 2009). Reduced watershed loadings to meet nutrient criteria will improve the quality of the preferred habitat for this keystone species.

Losses of s ensitive species are generally linked to loss of their habitat, either by outright modification or elimination or by the alteration of the highly specific combination of physical, chemical or biological factors that provide the specialized niche. These cha nges can be attributed to a variety of causes but eutrophication can be a major factor since changes in the nutrient regime can lead to differences in the way competitive interactions occur between species and lead to major shifts in community composition. This is particularly relevant in the case of seagrasses and other SAV, which provides habitat for a wide range of bio ta but which is sensitive to anthropogenic nutrient loadings.

**Nonuse Values**
Even if no human activities or uses are affected by environmen tal changes caused by nutrient runoff, such environmental changes may still affect social welfare. For a variety of reasons, including bequest, altruism, and existence motivations, individuals may value the knowledge that water quality is being maintained, that ecosystems are being protected, and that populations of individual species are healthy independent of any use. It is difficult to quantify the relationship between changes in pollutant discharges and the improvements in societal well

- being that are n ot associated with current use of the affected ecosystem or habitat.

That nonuse values exist is indisputable, as evidenced, for example, by society’s willingness to contribute to organizations whose mission is to purchase and preserve lands or habitats t o avert development (although some portion of these donations may be motivated by use values). Notwithstanding challenges involved in estimation of nonuse values, there is a substantial literature devoted to such issues (Bateman et al., 2006). These studie s use stated preference methods, which are the only option for elicit ing

estimates of individuals’ willingness to pay for resources they do not directly use. This literature provides insight into analysts’ ability to estimate nonuse values within various t ypes of policy contexts, and for various types of resources

. Various studies have found that individuals are willing to pay for water quality improvements, including nutrient reductions affecting wildlife habitat regardless of whether or not they are direc t uses (e.g., anglers). Hazen and Sawyer (2008) report that the average non

- use value, expressed in terms of a one

time tax to be put into a trust fund to maintain the Indian River Lagoon estuary in Florida , was $13.75 among visitors who had not engaged on recreational activities on the lagoon in the past year, and $38.38 among visitors who had. For local residents, willingness to pay the one

- time tax was $106.22 per respondent. Another study by Bendle and Bell (1995) found that Florida households valued pr otection of

the West Indian Manatee population in Florida at an average of $22.34 per year per household.January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 1 

## 13 Potential Incremental Benefits of the Numeric Nutrient Criteria

As discussed in Section 12

, excessive nutrient concentrat ions may have a wide range of effects on estuaries, coastal waters , and south Florida inland waters in Florida , impacting environmental services valued by humans, such as recreational uses of the waters. This section provides estimates of the potential

mag nitude of the benefits of r educing nutrient concentrations to meet the proposed numeric water quality

criteria

, based on existing literature. EPA quantified t he potential magnitude of the potential benefits by comparison to an index of water quality, and v aluing improvements in water quality based on a meta

analysis of valuation studies for the types of uses supported by different water quality levels.

These benefits are attributable to all the nutrient pollution control actions that will be implemented,

in cluding those to meet baseline requirements to the extent that they will affe ct future water quality in the
estuary, coastal waters , and south Florida inland waters currently not in attainment of the proposed

criteria.



### 13.1 W ater Quality Index

Researchers have developed the concept of a water quality index ( WQI ) to translate measurements of multiple parameters of water quality into a single numerical indicator that can be easily interpreted by policy makers and the general public. Once an overall WQI value is c alculated, it can be related to suitability for potential uses. For example, Vaughan (1986) developed a conceptual water quality ladder to indicate whether water quality is suitable for various anthropogenic uses of freshwater systems , and

identified “mini mally acceptable parameter concentration levels” for each of the five potential uses (i.e., boating, rough fishing, game fishing, swimming, and drinking without treatment). Vaughan (1986)

deemed w ater quality acceptable for each use if all of the parameter s met the identified threshold

concentration levels.

Water quality is measured differently in freshwater and marine contexts. The nature of anthropogenic and ecological uses for estuaries and coastal marine differs significantly from those of freshwater aq uatic
system s with many water uses not relevant to a marine setting (e.g., drinking water, irrigation, coldwater fishery). For purposes of the W Q I , water quality attainment should be linked to appropriate marine uses. Under the Florida Surface Water Qualit y Standards (62

- 302.400 F.A.C.), the designated Florida water

uses include:

 Potable Water Supplies (Class I)

 Shellfish Propagation or Harvesting (Class II)

 Fish Consumption; Recreation, Propagation and Maintenance of a Healthy, Well

- Balanced Population

of Fish and Wildlife (Class III)

 Fish Consumption; Recreation or Limited Recreation; and/or Propagation and Maintenance of a Limited Population of Fish and Wildlife (Class III

- Limited)

 Agricultural Water Supplies (Class IV)

 Navigation, Utility and Industrial Use (Class V)

These water quality classifications are arranged in order of the degree of protection required, with Class I water generally having the most stringent water quality criteria and Class V the least.January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 2 For Florida marine waters, potable and agri cultural water supplies are not relevant. In addition, Class III

Limited waterbodies are restricted to those with human

- induced physical or habitat conditions that prevent attainment of Class III uses. Since this designated use is not linked to attainment of chemical water quality, it is also not relevant for application to a WQI.

In contrast, Outstanding Resource Waters (i.e., waters so designated under Special Protection, Outstanding Florida Waters, Outstanding National Resource Waters (62

- 302.700 F.A.C) ) represent an additional designation for coastal waters

. Outstanding resource waters are based on state or federal recognition (e.g., State Aquatic Preserves, National Estuary Program).

The following are the anthropogenic and ecological uses in coastal an d marine setting s, listed in approximate order of decreasing water quality requirements:

1. Outstanding resource waters

2. Shellfish Propagation or Harvesting

3. Fish Consumption; Recreation, Propagation and Maintenance of a Healthy, Well

- Balanced Population of F ish and Wildlife

4. Navigation, Utility and Industrial Use

WQI are synthetic summations of water quality parameters of interest, and researchers may include or delete pa rameters for various purposes. For example, B rown et al. ( 1970) incorporated nine water qu ality parameters relevant to evaluation of riverine systems in which water quality was heavily influenced by point source discharges (e.g., wastewater treatment plants). In modifying the WQI for previous analyses (U.S. EPA 2009 b)

, EPA removed pH and temper ature from the calculations, and included chlorophyll

- a only for water quality as sessments of estuarine waters. For the waters affected by the proposed rule, parameters in these indices other than those for which EPA is proposing criteria (TN, TP, chloroph yll

- a ) are either implicitly accounted for under the proposed cri teria (DO, BOD, TSS) because of the related effects of control actions, or are less relev ant to the marine setting (FC). Therefore, for this analysis, EPA used only TN, TP, and chlorophyll

- a in the WQI.

For this analysis, EPA developed a WQI based on five threshold values mark ing boundaries of freshwater quality use classifications (U

. S

. EPA

, 2002; U

. S

. EPA

, 2009 b ). Several researchers (e.g., Cude

, 2001,

CCME

, 2001, BISF

, 2003, Wazniak et al.

, 2007) have employed WQI scoring system s with five increments of water quality, with each step corresponding to a numeric range, qualitative descriptor, and/or a letter grade

, including several for estuaries and coastal waters.

These five levels of water q uality are generally equated to qualitative narrative classifications (“Excellent”, “Good”, “Fair”, “Poor”, and “Highly Degraded”) that are easily recognized by the public. These qualitative classifications have also been interpreted with descriptive condi tions of the degree of water quality standard violations (CCME

, 2001, BISF

, 2003), such that:

 Excellent = virtual absence of threat or impairment, close to pristine or natural conditions.

 Good = minor threat or impairment, rarely departs from natural condi tions.

 Fair = occasionally impaired or threatened. Sometimes departs from natural conditions.

 Poor or Degraded = frequently threatened or impaired. Often departs from natural levels.

 Very Poor or Very Degraded = almost always threatened or impaired. Usuall y departs from natural

levels.January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 3 These qualitative water quality descriptors correspond to numerical thresholds within a range between 100 and 0, but the exact value of those thresholds are dependent on the WQI method used ( Exhibit 13

- 1 ).

For example, the Bay Institute of San Francisco index has five ranges 15 : a narrow upper range (100

- 95), three wide middle ranges (94

- 80, 79

- 65, 64

- 45), and a broad lower range (<45) (BISF

, 2003). The narrow upper range applies stringe nt criteria to the most sensitive beneficial uses higher on the ladder (i.e., outstanding resource waters). The wide middle ranges acknowledge that most parameter values will fall

somewhere around the median of the distribution. Finally, the broad lowest r ange represents those situations for which the majority of water quality parameters do not meet criteria and the water is acknowledged to be highly degraded.

The WQI used by the State of Maryland to compare water quality and ecological health in coastal ba y segments compares the median values for TN, TP, Chl a, and DO to established threshold values deemed protective of several ecological endpoints, including maintenance of seagrasses, avoidance of phytoplankton bloom conditions and maintenance of DO values for fish and benthic communities (Wazniak et al.

, 2007). The i ndex joins these together into one number between zero and one (normalized

to 0 to 100 in Exhibit 13

- 1 ) and categorizes results into five ranges of wat er quality. A score of 100 indicates habitat suitable for fish and aquatic grass survival, while a value of zero indicates unsuitable habitat for either fish or aquatic grasses. Intermediate values indicate that the system is variable and that
some ecosyst em functions (grass beds or fish) may be expected to be absent some of the time.



### Exhibit 13

- 1 : Comparison of Ranges of Numerical Scores Associated with Narrative Classes in Two WQI Systems
WSI type Numerica l Score Narrative Scale

San Francisco Bay WQI 1 95

- 100 Excellent

80

- 94 Good

65

- 79 Fair

45

- 64 Poor

<44 Very Poor

Maryland WQI 2 80

- 100 Excellent

60

- 80 Good

40

- 60 Poor

20

- 40 Degraded

<20 Very Degraded
1. BISF (2003) 2. Wazniak et al. (2007)

For this analysis, EPA use d the two WQI systems above to develop estimates of baseline and post

compliance WQI levels for WBIDs that are identified as potentially incrementally impaired under the proposed rule.

13.1.1 Estimated Baseline Water Quality

Estimating the potential change in water quality from attainment of the proposed criteria along an index of water quality requires estimation of the baseline water quality condition. The waters that EPA

15 CCME defines five WQI rankings: excellent, good, fair, marginal, and poor.January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 4 identified for this analysis as potentially incrementally affec ted are not among those currently listed by FDEP as impaired for nutrient or nutrient

- related causes (see Section 4 for the method EPA used to identify incrementally affected waters)

. These potentially incrementally affected wa ters are shown in

Exhibit 4

- 2

. As discussed above, EPA assumed that waters attaining the proposed criteria meet the definition of

“ good” water quality. Further, EPA assume d that waters which have been previously investigated by an d identified under prior CWA Section 303(d) lists as “impaired” (due to violations of water quality standards, narrative criteria, presence of nuisance algal blooms, etc.) and thus requiring a TMDL reflect “poor” water quality conditions, indicative of wat ers that are “f req uently threatened or impaired and o ften depart from natural levels .” As indicated in Exhibit 13

- 1 , there is agreement that a score of 60 signals the
lower threshold below which water is of poor qu ality. For th is analysis, EPA assume d that none of the waters it identified as potentially incrementally impaired under the proposed rule meet the definition of poor water quality . EPA assumed that these waters are of better than poor water quality becaus e they are not already listed as impaired under the existing narrative nutrient criterion, or under a nutrient

- related

TMDL.

Waters that FDEP has not yet identified as impaired but that exceed one or more proposed criteria may fall into the “fair” category , representing waters that are “ occasi onally impaired or threatened; s ometimes depart ing from natural conditions .” EPA assum ed that such waters have WQI scores ranging between 60 and 80 (between poor and good). However, rather than treat all waters that ar e not listed as impacted but that exceed proposed criteria identically (e.g., WQI score = 70), EPA used available water quality data to develop a gradient of water quality conditions within the “fair” category such that waterbody WQI scores may be identifi ed as closer to the “good” or to the “poor” threshold values.

For this analysis, EPA use d the relative magnitude of exceedence as indication of rel ative water quality

within the “fair” interval (60 ≤ WQI < 80) . While relatively higher exceedence of water quality standards usually indicate s poorer water quality for most parameters (e.g., toxics

, total dissolved solids), the response to nutrients is not as easily interpreted. However, for th is analysis, EPA use d this method (mapping magnitude of percent exce edence of nutrient criteria to the WQI) to focus on the improvements due to meeting the proposed criteria, as these waters are not identified for any wate r quality violation other than with respect to the proposed criteria [based on comparison to the exist ing 303(d) list)]

.

EPA estimate d WQI score s for individual WBIDs by compari ng the average annual geometric mean for each parameter to the proposed crit erion , and estimating the ma gnitude of criteria exceedence (e.g., 0.02

indicates that the a verage of the annual geometric mean s is 2 % above the criterion). EPA rank ed and distributed the values along a range of 60 to 80 WQI scores such that waterbodies with poorer water quality (i.e., higher magnitude of exceedence) are just above a WQI score of 60

, and the w ater s with better scores (lower magnitude of exceedence) approximate a WQI score of 80.

As waterbodies may be evaluated for one to three criteria, a given WBID may be associated with multiple WQI estimates under this method. EPA develop ed baseline WQI est imates for each WBID using three scenarios: 1) baseline WQI estimated from exceedences of TN criteria (a scenario in which nitrogen is the limiting nutrient of concern) ; 2) baseline WQI estimated from exceedences of TP criteria (a scenario in which phospho rus is the limiting nutrient of concern) ; and 3) baseline WQI estimated from exceedences

of Chl

- a criteria (a scenario in which Ch l

- a is the primary concern) . If data for a WBID are unavailable for one or more pollutant s , EPA substitute d average criteria e xceedence for another pollutant for the same WBID, with the following order of preference: TN, TP, Chl

- a . With this method , the estimated WQI is not a composite index across all parameters

. If EPA were to instead estimate such a composite index, itJanuary 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 5 would b e unclear how to weight each parameter in calculating the index. Lacking information to prefer one baseline method over the others, EPA used all three descriptions of baseline water quality to calculate a range of benefits

EPA used the three scenarios for this analysis since each parameter can be potentially growth

- limiting to primary production due to nutrient or light requirements. Scientists consider p rimary production in estuarine and coastal marine systems to be limited primarily by nitrogen. However, the nature of the limiting factor can change spatially or temporally due to fluctuation in the nitrogen to phosphorus delivery rates shifting the relative abundance of these nutrients. Estuaries and coastal systems subject to high nutrient loads may, at va rious times, display nitrogen limitation, phosphorus limitation, or co

limitation by both nutrients (Conley, 2000). In very turbid waters, light availability may be the limiting factor. Accordingly, EPA consider ed the potential water quality improvement re alized under these scenarios to estimate the range of benefits.

Exhibit 13

- 2

,

Exhibit 13

- 3

, and

Exhibit 13

- 4 show the relatio nship between the percent exceedence and estimated Baseline WQI scores for each pollutant , with WBIDs on the horizontal axis, ranked and arrayed from lower to higher water quality according to each parameter

.


### Exhibit 13

- 2 : Percent Exceedence and Estimated Baseline WQI, TN

Exhibit 13

- 3 : Percent Exceedence and Estimated Baseline WQI, TPJanuary 2012 13

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- 6 

### Exhibit 13

- 4 : Percent Exceedence and Estimated Baseline WQI, Chl

- a

Exhibit 13

- 5 shows the distribution of incrementally impaired WBID miles by WQI value for each of the

three baseline scenarios

. When baseline WQI is estimated based on exceedence of TN criteria, 16 % of incrementally impaired waters have baseline WQI values between 60 and 65, 5 % have baseline WQI values between 65 and 70, 17 % have WQI values bet ween 70 and 75, and 62 % have baseline values

between 75 and 80. When baseli ne WQI is estimated based on exceedence of TP criteria, 2 % of incrementally impaired waters have baseline WQI values between 60 and 65, 1 % have baseline WQI

values between 65 and 70 , 26 % have WQI values bet ween 70 and 75, and 71 % have baseline values

betwe en 75 and 80. When baseline WQI is estimated based on exceedence of Chl

- a criteria, 3 % of incrementally impaired waters have baseline WQI values between 60 and 65, 1 % have baseline WQI

values between 65 and 70 , 20 % have WQI values bet ween 70 and 75, and 77 % have baseline values

between 75 and 80.January 2012 13

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- 7 

### Exhibit 13

- 5 : Estimated Percentage of Incrementally Impaired Coastal and Estuary Miles in FL by WQI Classifications

Baseline WQ I Baseline WQI Based on % of TN Exce edance Baseline WQI Based on % of TP Exceedance Baseline WQI Based on % of Ch

- **a** Exceedance

Total Miles Percent of Total Total Miles Percent of Total Total Miles Percent of Total 60 ≤ WQI < 65 860 16% 114 2% 142 3% 65 ≤ WQI <70 270 5% 36 1% 36 1%
70 ≤ WQI < 75 944 17% 1,446 26% 1,081 20% 75 ≤ WQI ≤ 80 3,455 62% 3,933 71% 4,270 77%
Total Miles 1 5,530 100% 5,530 100% 5,530 100% 1. Includes miles for all incrementally impaired estuarine, coastal, and south Florida marine WBIDs

. Ch

- a = chlorophyll a TN = total nitrogen TP = total phosphorus WBID = water body identification WQI = water quality index

13.1.2 Estimated Water Quality from Attaining Criteria

Although the numerical ranges of the two WQI methods listed in Exhibit 13

- 1 di ffer, there appears to be some agreement that “good” water quality is associated with a score of > 80; which is also true for many other WQIs, including those used in freshwaters (Brown et al. , 1970; Cude, 2001; CCME, 2001)

. Based on the description that g ood water has “a minor threat of impairment and rarely departs from national conditions,” EPA assume d that “good” water quality status is associated with attainment of all water quality standards and support of all designated uses. This condition and numer ical score is also consistent with the expected water quality and ecological conditions for Florida marine waters which

meet their site

- specific criteria. [In comparison, meeting the proposed criteria does not elevate marine waters to an “excellent” catego ry since that category is likely a function of other factors independent of water chemistry (e.g.,, an undeveloped watershed, no nearby discharges).] EPA assumed that attaining the proposed criteria is representative of ‘good’ water quality, or a WQI scor e of 80.

13.1.3 Estimated Incremental Change in Water Quality due to the Proposed Rule

To estimate benefits of water quality improvements associated with the criteria, EPA assumed that all incrementally waterbodies will improve from the estimated baseline water quality (a s represented by the

estimated WQI value) to “good” (as represented by a WQI value of 80 )

. The difference in WQI (hereafter denoted as Δ WQI) between baseline conditions and compliance with the numeric criteria is a measure of the change in wate r quality that may be attributable to attaining the proposed criteria . To monetize benefits of the regulation, EPA calculated the improvement in water quality for all incrementally impaired waterbodies for which it estimated a ΔWQI of greater than de minim is (0.01 WQI units). EPA did not monetize w ater quality improvements below 0.01 WQI units because it does not expect any value to be placed on such small improvements as the water quality is essentially unchanged

.
As shown in Exhibit 13

- 6

, a total of 5,530 estuarine and coastal miles are potentially incrementally impaired under the proposed criteria and thus may attain higher water quality by coming into compliance

with the proposed criteria for the scenario in wh ich baseline WQI is estimated based on exceedence of TN

criteria . This mileage accounts for improvements in 100% of t he impaired waterbodies and 26 % of theJanuary 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 8 estuarine and coastal miles in the state. In the other two scenarios

, 4 WBIDs ( 56 miles) have baseli ne water quality values that are only slightly below 80 and therefore have de minimis improvements. Thus, a total of 5, 474 miles (99% of impaired miles and 26% of all miles in the state) are expected to improve in

these scenarios

. Larger improvements in wa ter quality are expected when baseline WQI is estimated using exceedence of TN criteria. For example, in this scenario, 20% of the incrementally impaired miles (5% of state miles) are expected to have WQI improvements greater than 10 points. Conversely, in the other two scenarios, only 3% of the incrementally impaired miles (1% of state miles) are expected to have WQI improvements greater than 10 points.



### Exhibit 13

- 6 : Total Potential Improved Coastal and Est uary WBIDs and Miles

Change in WQ I Total number of WBID s Improved Total Miles Improved Percent of Total Miles in Analysis Percent of Total Miles in State

Baseline WQ I Based on % of TN Exceedance
0.01 ≤ ΔWQI < 1.0 42 569 10% 3% 1.0 ≤ ΔWQI < 5.0 102 2,88 7 52% 14% 5.0 ≤ ΔWQI <10 43 944 17% 4% 10 ≤ ΔWQI 43 1,130 20% 5%
Total 230 5,530 100% 26%
Baseline WQ I Based on % of TP Exceedance
0.01 ≤ ΔWQI < 1.0 33 395 7% 2% 1.0 ≤ ΔWQI < 5.0 129 3,482 63% 16% 5.0 ≤ ΔWQI <10 54 1,446 26% 7% 10 ≤ ΔWQI 10 151 3% 1%
Total 226 5,474 99% 26%
Baseline WQ I Based on % of Ch

- **a** Exceedance
0.01 ≤ ΔWQI < 1.0 59 779 14% 4% 1.0 ≤ ΔWQI < 5.0 125 3,435 62% 16% 5.0 ≤ ΔWQI <10 33 1,081 20% 5% 10 ≤ ΔWQI 9 178 3% 1%
Total 226 5,474 99% 26%
Ch

- a = chlorophyll a TN = to tal nitrogen TP = total phosphorus WBID = waterbody identification WQI = water quality index



### 13.2 Estimating Value of Water Quality Improvements

To estimate nonmarket benefits of water quality improvements resulting from the rule , EPA used a

benefits transfer approach. Benefit s transfer involves adapting existing research to evaluate a proposed policy impacting similar environmental goods and services in a different place and/or time (Desvousges et

al.

, 1998; VandenBerg et al.

, 2001) , and may involve the trans fer of unit value s or valuation function s , the latter of which may include techniques of meta

- analysis. Benefit transfer techniques are often the only feasible option for providing information to inform environmental policy decisions due to resource

constr aints.January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 9 Comprehensive estimates of the total value of environmental goods and services include both use and

nonu se values. Stated preference methods, or benefit transfers based on stated preference studies, are generally accepted techn iques for estimating these values (Desvousges et al.

, 1998). Stated preference methods rely on surveys that assess respondents’ stated willingness to pay (WTP) for water quality improvements.

To est imate the benefits associated with the proposed rule, EPA used a meta

- analysis approach as opposed to a unit value based approach or to borrowing a specific benefits function from literature. Transferring the mean or median values from the original studies may lead to a significant error, because

the likelihood of finding a good fit between a single (or multiple) study site and a policy site is usually low (Boyle and Bergstrom 1992; Spash and Vatn 2006). 16 However, if these mean or median values contribute to a body of WTP estimates and if these estimates are syst ematically related to variations in resource, study, and site characteristics, then meta

- regression analysis may provide a viable tool for estimating a more universal transfer function with distinct advantages over unit value or other function

based transf er methods (Rosenberger and Johnston, 2007)

. In addition, the u se of meta

- analysis allows the WTP function to be adjusted to reflect resource and population characteristics as well as the expected magnitude of environmental improvement at the policy sites.

13.2.1 Meta Analysis of Valuation Studies

To estimate the potential nonmarket benefits associated with attaining the proposed criteria , EPA used a

benefits transfer function based on a meta

- analysis presented in EPA (2009 b ). EPA identified 45
valuation studies t hat use stated preference techniques to elicit benefit values for water quality improvements. To examine the relative influence of study, economic, and resource characteristics on WTP for improving surface water quality, the Agency conducted a regression

- b ased meta

- analysis of 115 estimates of WTP for water quality improvements, provided by the 45 original studies.

The general approach to the meta

- analysis including analytic methods and model specifications follow

standard methods used by Johnston et al. ( 2005) and Shrestha et al. (2007), among many others ( e.g. , Rosenberger and Phipps

, 2007). Th e estimated regression equation provides a means of forecasting WTP

based on variables that represent potential water quality improvem ents :

(Eq. 13

- 1 )

In this function

, ln( WTP ) , the natural log of WTP for water quality improvements

, is the dependent

variable in the meta

- analysis. The metadata include independent variables characterizing specific details

of the r esources valued, such as :

 geographic region and scale (e.g., the number of waterbodies)

 resource characteristics (e.g., baseline conditions, the extent of water quality change, and ecological services affected by resource improvements)

 characteristics of s urveyed populations (e.g., users, nonusers)

16 Within a benefit transfer context, transfer error is often inversely related to the correspondence between a stud y site and a policy site among various dimensions (Rosenberger and Phipps, 2007).January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 10  other details specific to each study.

Exhibit 13

- 7 , later in this section, provides a summary of the estimated regression equation. EPA (2009b) provides detail on the met adata, model specification, and justifi cation for the functional form.

13.2.2 Function Transfer to Proposed Rule

EPA assign ed a value to each model variable corresponding with theory, characteristics of the water resources, and sites affected by the regulation a nd the policy context.

EPA follow ed Johnston et al. (2006) in assigning values for methodological attributes (i.e., variables characterizing the study methodology used in the original source studies), which are set at mean values from the metadata except in cases where theoretical considerations dictate alternative specifications. This approach follows general guidance from Bergstrom and Taylor (2006) that meta

- analysis benefit transfer should incorporate theoreti cal expectations and structures. As such, E PA assigned thr ee of the methodology variables

– discrete

, WQI_study , and outlier_bids

– values of one. Year_index is 9.68, which corresponds to the mean year that the stu dies were conducted, 2002, and Nonparam is zero because

most studies included in meta data used parametric methods to estimate WTP values. Other study and methodology variables ( volunt, mail, lump_sum, non_reviewed, median_WTP) are also zero (See Exhibit

13

- 7 for an explanation of the variable assig nments)

.
EPA use d Florida

- sp ecific median household income data from the U.S. Census Bureau ( 2010 ) to assign

the income variable for all full time residents in Florida, and income data from Smith and House (2006) to assign an income value for seasonal re sidents

. 17 EPA set the nonusers variable to zero, because water quality improvements resulting from nutrient reductions would benefit both users and nonusers of the

affected resources

. The dummy variable s denoting multiple regions ( mr ) and the Mountain Plai n ( mp ) regional dummy are zero because the water q uality improvement will be restricted to waterbodies in

Florida.

The default model value is a resource change taking place in saltwater bodies. Therefore, EPA set all waterbody type variables (i.e. region al_fresh, single_lake, single_river, salt_pond, multiple_river, num_riv_pond ) to zero because the only expected water quality improvements in estuaries and coastal

reaches

. Water quality improvements resulting from the proposed nutrient criteria are likely to enhance a variety of water resource uses, including fishing, swimming, and boating. Therefore, variables denoting multiple uses ( allmult ) and recreational fishing ( fish_use ) have a value of one, while the variable denoting nonspecified uses ( nonspec ) i s zero. EPA assign ed b aseline water quality ( baseline ) and change in water quality ( quality_ch ) WBID

- specific values (s ee Section 13.1 .1 ).

For a broader discussion of issues involved in the specification of variable levels for meta

- analysis benefit

tran sfer, see EPA (2009b) and Johnston et al. (2005; 2006)

.

17 EPA used the Consumer Price Index to adjust the value from the 2006 survey and study to 20 10 dollars. Inflation

- adjusted income for seasonal residents is $67,364. Income fo r full

- time Florida residents is $47,450.January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 11 

### Exhibit 13

- 7 : Independent Variable Assignments

Variable Coefficient Assigned Value Explanation

Study and Methodology Vari ables intercept 5.7109 N/A N/A

year_index

- 0.08043 9.68 Set to 9.68 to reflect the mean year that the studies in the
data set were conducted.

discrete

- 0.1248 1 Set to one to reflect survey efforts that employed discrete choice elicitation methods, whi ch are preferred over other approaches, such as open

- ended and payment card methods.

volunt

- 1.3233 0 Set to zero because hypothetical voluntary payment mechanisms are not even potentially incentive compatible (Mitchell and Carson 1989).

mail

- 0.2013 0 Set to zero because mail surveys may be of less quality
than in

- person interviews.

lump_sum 0.5569 0 Set to zero because the policy option will be paid for over a period of years.

WQI

- 0.3275 1 Set to one because of the methodological use of the WQI in
the meta

- analysis.

nonparam

- 0.6698 0 Set to zero because most studies used in the meta analysis used regression analysis to calculate willingness to pay values.

non_reviewed

- 0.2718 0 Set to zero to reflect a preference for studies published in

peer

- re viewed journals.

median_WTP

- 0.5358 0 Set to zero because only average or mean WTP values in combination with the number of affected households will mathematically yield total benefits if the distribution of WTP is not perfectly symmetrical.

outlier_bids

- 0.8837 1 Set to one because survey data that exclude such responses are preferable; outlier bids are often excluded from the analysis of stated preference data because these bids (often identified as greater than a certain percentage of a respondent’s i ncome) may indicate that a respondent did not consider his or her budget constraints and or supplementary goods. Surveyed Population

income 0.0000027 Varies Median annual household income data from the 200 5

- 2009 American Communities Survey and Smith e t al (2006); median household income values assigned separately for full time state residents and part time seasonal residents (U.S. Census Bureau 20 10 and Smith ea al. 2006).

nonusers

- 0.4036 0 Set to zero in order to estimate the total value for a quatic habitat improvements, including both use and nonuse values; for nonuser population, the total value of water

resource improvements includes nonuse values only (Freeman 2003). Waterbody Type Variables single_river

- 0.4279 0 The criteria are only for salt waterbodies, therefore all waterbody type variables are set to zero because the default value in the model is a resource change taking place in estuaries. single_lake

- 0.06316 0 multiple_river

- 1.4752 0 regional_fresh 0. 1588 0

salt_pond 0.9849 0January 2012 13

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- 12 

### Exhibit 13

- 7 : Independent Variable Assignments

Variable Coefficient Assigned Value Explanation

Geographic Region and Scale Variables

num_riv_

pond 0.1173 0 Indicates the number of rivers or salt ponds affected by a policy, and is set to zero because the criteria affect the entire state; this variable assignment is con stant across study regions.

mr

- 0.8846 0 Regional variables are omitted from the predictive portion of the analysis (i.e., set to zero) because they are not relevant to FL

. mp 1.6337 0

Resource Improvement Variables

allmult

- 0.3728 1 Set to one becau se multiple species may benefit from water quality improvements

nonspec

- 0.4042 0 Set to zero because multiple species may benefit from water quality improvements.

lnquality_ch 0.4065 Varies Set to the natural log of the change in the WQI for a given
WB ID.

fish_use

- 0.3317 1 Set to one because a variety of aquatic species may benefit

, therefore enhancing recreational fishing opportunities.

fishplus 0.4432 0 Set to zero because a fish population change of 50% or greater is unlikely.
lnbase 0.02610 Vari es Set to the natural log of the base WQI for a given WBID N/A means not applicable

13.2.3 Estimating Annual Household WTP for Water Quality Improvements

Using this regression function, EPA calculated the estimated economic values of water quality improvement s by WBID . For each WBID, coefficient estimates for each variable, taken from meta

analysis results ( Exhibit 13

- 7

, column 2) are multiplied by the variable levels provided above ( Exhibit

13

- 7 , column 3). The sum of these products represents the predicted natural log of WTP ( ln_WTP ) for a given WBID, as indicated by WTP = exp(ln_WTP + σ

e 2 /2) ( Equation 13

- 2 ) . The final step uses a

standard formula to transform this predicted natural log into the desired WTP estimate. This formula is given by:

WTP = exp(ln_WTP + σ

e 2 /2) ( Equation 13

- 2 )

Where:

exp(·) = the exponential operator

ln_WTP = the predicted natural log of WTP for WQ improvements in a given WBID

σ e 2

= the model residual variance ( 0.1876 ) taken from EPA (2009 b ) 18

.

18 EPA estimate d the meta

- analysis regression using a multilevel, random

- effects specification. The fundamental distinction
between these models and classical linear models is the two

- part modeling of the equation e rror to account for hierarchical data. Here, the meta

- data are comprised of multiple observations per study, and there is a corresponding possibility of correlated errors among observations that share a common study or author. The common approach to model ing such potential correlation is to divide the residual variance of estimates into two parts, a random error that is independently and identically distributed ac ross all studies and for each observation, and a random effect that represents systematic vari ation related to each study. The model isJanuary 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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**- Do Not Quote or Cite**  13

- 13 However , estimates derived from regression models are subject to some degree of error and uncertainty.

To better characterize the u ncertainty or error bounds around predicted WTP, EPA used a procedure described by Krinsky and Robb (1986). This involves sampling the variance

– covariance matrix of the estimated coefficients, which is a standard output of the statistical package used to e stimate the meta

analysis model. WTP values are then calculated for each drawing from the variance

– covariance matrix and an empirical distribution of WTP values is constructed. By varying the number of drawings, it is possible to generate an empirical dist ribution with a desired degree of accuracy (Krinsky and Robb

, 1986). The low and high estimate of WTP values are then identified based on the 5 th and 9 5 th percentile of WTP values from the empirical distribution. These bounds may help decision

- makers under stand the uncertainty associated with the benefit results.

EPA used the Krinsky and Robb (1986) procedure to estimate the 5 th, 50th, and 95 th percentiles of total

WTP (reflecting the 90 percent confidence interval of estimates) for both full time and part time seasonal residents, based on the results of the total WTP regression model. EPA esti mate d that seasonal residents

will live in the state for app roximately four months of the year; therefore EPA weighted household WTP

value s for seasonal residents by 3 3.3 %. Error! Reference source not found. presents the results of these

calculations , for each of the three scenarios.

Although the confidence limits for WTP estimates related to the covariance matrix of meta

- analysi s parameter estimates can be estimated, these limits do not assess the sensitivity of results to changes in

meta

- regression model assumptions or specifications (cf. Johnston et al.

, 2005 ; 2006) or assumptions implied in benefit aggregation (cf. Loomis

, 199 6; Loomis et al.

, 2000; Bateman et al.

, 2006). As noted above, however, a number of assumptions and specifications lead to conservative benefit estimates. These assumptions and uncertainties are also discussed further in Section 13.3

.
As shown in Exhibit 13

- 8 , a verage annual household WTP for full time residents for these water quality improvements may be approximately $12

- $14

, depending on the exceedence data used to est imate baseline water quality. Part time residents have lower average annual household WTP, with estimates of approximately $4

- $5, depending on the scenario.



### Exhibit 13

- 8 : Average Annual Household Willingnes s to Pay for Water Quality Improvement in Florida Estuaries and Co a stal Waters (2010$) Across all WBIDs

State Resident Type Baseline WQ I Based on % of TN Exceedance Baseline WQ I Based on % of TP Exceedance Baseline WQ I Based on % of Ch

- **a** Exceedance

Full Time FL Resident $13.78 $11.95 $11.53
Part Time Winter Resident $4.91 $4.26 $4.11

Ch

- a = chlorophyll a TN = total nitrogen TP = total phosphorus WBID = water body identification WQ I = water quality index

estimated as a two

- level hierarchy, with level one corresponding to non

- use value estimates (individual observations), and level two corresponding to individual studies. The random

- effect may be interpreted as a devia tion from the mean equation intercept associated with individual studies (Bateman and Jones, 2003).January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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- 14 13.2.4 Estimating Total WTP for Water Quality Improvem ents

To calculate total WTP at the WBID level , EPA use d the mean per

- household WTP for both full

- time and
part

- time residents (under all three scenarios ) by WBID shown above , and then multiplie d by the number of households in each category in 20 10 and the percentage of miles or area that comprise a given WBID.

EP A calculated the number of full

- time households in the state by dividing the population estimates by the average number of people per household (U.S. Census Bureau, 2010 ), and the number of part

- tim e households by dividing the number of seasonal residents from Smith and House (2006) by the average number of people per household (U.S. Census Bureau, 2010 ). To account for the growth in the number of seasonal households between 2006 and 2010, EPA calcul ate d an annual growth rate for the population of the state of Florida, and applie d this growth rate to the population estimates from Smith and House (2006)

. The total WTP equation for each reach is provided below ( Equation 12

- 3 )



### ) )

, ( WBID baseline WBID WBID 

### es PercentMil StateHH WQI WQI WTP TWTP × × ∆ = ( Eq uation 13

- 3 ) )

Where:

TWTP WBID = the WBID

- level welfare change from improved water quality

WTP WBID = the estimated WTP for water quality improvement for a given WBID based on baseline WQI (WQI baseline) and the expected change in water quality under the
post

- compliance scenario ( Δ WQI)

StateHH = the number of full

- time or seasonal households in Florida

PercentMiles WBID = the percentage of total miles ( co a stal and estuary miles ) in the state of Florida that are comprised of a given WBID.

Finally, EPA aggregated WBID

- level benefits t o the state level for full time and part time households. As presented in Exhibit 13

- 9

, full time resident annual benefits range from $ 82.4 million ( mean estimate) for improvements in estuaries and coastal waters t o $ 98.5 million ( mean estimate) , depending on the assumed

baseline water quality . Seasonal resident annual benefits are much smaller, with mean estimates of $1.3

between $ 1.6 million for the three scenarios . Total benefits may range from $ 83.7 million to $ 100.1

million per year

.



### Exhibit 13

- 9 : Total Annual State Benefits Associated with the Proposed Criteria (Millions of 2010$)

State Resident Type Baseline WQ I Based on % of TN Exceedance Baseline WQ I Based on % of TP Exceedance Baseline WQ I Based on % of Ch

- **a** Exceedance

Lower

5% Bound Mean Upper 95% Bound Lower 5% Bound Mean Upper 95% Bound Lower 5% Bound Mean Upper 95% Bound

Full Time FL

Resident $42.9 $98.5 $185.7 $35.7 $85.4 $165.2 $33.9 $82.4 $160.8

Part Time Winter Resident $0.7 $1.6 $3.1 $0.5 $1.4 $2.8 $0.5 $1.3 $2.7

Total $43.6 $100.1 $188.8 $36.3 $86.8 $167.9 $34.5 $83.7 $163.5
Ch

- a = chlorophyll a TN = total nitrogen TP = total phosphorus WBID = water body identification WQ I = water qu ality indexJanuary 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

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**- Do Not Quote or Cite**  13

- 15 Note that a portion of these benefits would be a ttributable to controls that are not yet fully implemented

but would result in reductions in nutrient concentrations in estuaries, coastal waters , and south Florida

inland waters . It is not poss ible to identify the water quality that would result after full implementation of such controls. Thus, the portion of benefits attributable to controls beyond the cost analysis (because the se controls are part of the baseline and requir ed in the absence of the rule) is uncertain

. There is substantial uncertainty regarding the baseline water quality of the waters that may be incrementally impaired under the proposed rule. Since these waters are currently unlisted for impairment, water quality may be represen tative of better than “fair”/WQI = 60. To investigate the sensitivity of the benefits estimates to the assumption regarding baseline water quality, EPA estimated the three scenarios assuming that the baseline WQI values fall between 70 and 80 (i.e., baseli ne water quality is substantially better than “fair”), compared to between 60 and 80. Benefits to Florida residents under this alternative assumption are smaller than under the base assumption, as the potential improvement for incrementally impaired waters is smaller. Exhibit 13

- 10 presents the results of this alternative analysis. Total annual state benefits may range from $65 to $67.3 in this scenario.



### Exhibit 13

- 10 : Total Annual State Be nefits Associated with the Proposed Criteria, Higher Baseline Water Quality Scenario (Millions of 2010$)

State Resident Type Baseline WQ I Based on % of TN Exceedance Baseline WQ I Based on % of TP Exceedance Baseline WQ I Based on % of Ch

- **a** Exceedance
Lower

5% Bound Mean Upper 95% Bound Lower 5% Bound Mean Upper 95% Bound Lower 5% Bound Mean Upper 95% Bound
Full Time FL

Resident $23.5 $64.3 $134.2 $24.7 $66.2 $136.7 $23.4 $63.9 $133.3

Part Time Winter Resident $0.4 $1.0 $ 2.2 $0.4 $1.1 $2.3 $0.4 $1.0 $2.2

Total $23.9 $65.3 $136.4 $25.1 $67.3 $138.9 $23.8 $65.0 $135.6
Ch

- a = chlorophyll a TN = total nitrogen TP = total phosphorus WBID = water body identification WQ I = water quality



### 13.3 Uncertainty and Limitations

There are a number of uncertainties and limitations associated with the analysis of benefits, including the extent to which the monetized estimates can be attributed to the proposed rule. For this preliminary analysis, EPA estimated the potential magnitude of benefit s associated with attaining the proposed criteria. These benefits will be attributable to the range of nutrient pollution controls needed to achieve the necessary pollutant reductions, including those associated with baseline requirements. However, the

cos ts of these actions are appropriately not part of this analysis.

Another source of substantial uncertainty relates to the estimation of the potential change in water quality represented by attaining the proposed criteria in incrementally affected waters. E PA estimated baseline

W QIs for each WBID based on historical observations of exceedances of the proposed criteria. To the extent that this relationship is imperfect, estimates of baseline WQI may be biased. Additionally, baseline WQI for each WBID is estim ated independently for each pollutant (with either the lowest or highest WQIJanuary 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  13

- 16 value for each WBID selected to estimate benefits). This method does not address the simultaneous effect that multiple pollutants may have on water quality. Additionally, paramete rs other than TN, TP and Chl

- a (e.g., pathogens) may impair designated use and be influenced by nutrients (e.g., DO)

. F uture analysis should incorporate the estimated baseline water quality scores with data for other parameters of importance for attaining designated uses. However, none of the WBIDs identified here as incrementally impaired are listed as impaired for other pollutants in the 303(d) list in Florida

. Finally, a number of issues and uncertainties are common to all benefit transfers , which invol ve adapting research conducted for another purpose in the available literature to address the policy questions at hand. Because benefits analysis of environmental regulations rarely affords enough time to develop original stated preference surveys that are specific to the policy effects, benefit transfer is often the only option to inform a policy decision. As a result, they are well represented in benefit

- cost analyses (Smith et al.

, 2002).

Benefit transfers are by definition characterized by a difference between the context in which resource values are estimated and that in which benefit estimates are desired (Rosenberger and Phipps

, 2007). The ability of meta

- analysis to adjust for the influence of study, economic, and resource characteristics on

WTP can minimize, but not eliminate, potential biases (Smith et al.

, 2002; Rosenberger and Stanley

, 2006; Rosenberger and Phipps

, 2007). As is typical in applied benefit transfers, the original studies underlying the meta

- analysis model used in this analysis prov ides an imperfect match to the context in which values are desired. Therefore, some beneficial effects may not be accounted for while others may

be overestimated.

Some related and additional limitations inherent to the meta

- analysis model and the subseque nt benefit

transfer include the numerous uncertainties and associated assumptions required to aggregate WTP across spatial jurisdictions, as detailed by Loomis (1996), Loomis et al. (2000) and Bateman et al. (2006), among

others. While these uncertainties are well known, the literature does not agree on appropriate, standardized guidance for benefit aggregations, and applied benefit

- cost analysis almost universally requires simplifying assumptions in order to generate defensible welfare aggregations. In an ideal context, analysts would have information necessary to estimate spatially referenced distance decay relationships for all changes resulting from policies under consideration (cf. Bateman et al.

, 2006). However, even the most advanced literature provid es only simple illustrations of such issues, and none methodologically sufficient to support regulatory analysis.

In analyzing benefits of the ru le, EPA estimated nutrient loading reduction benefit s to Florida residents (both full

- and part

- time) only. Al though residents of other states may hold values for water resources

outside of their home state s if such resources have personal, regional, or national significance

, EPA did

not have sufficient information to estimate WTP for Florida water quality improve ments as valued by out

of

- state residents. As a result, the population considered in the benefits analysis of the rule does not represent all the households that are likely to hold values for water resources in the state of Florida. Even if per household W TP for out

- of

- state residents are small, they may be substantial in the aggregate if these values are held by a substantial fraction of the population.

Some resource valuation studies have found that respondents in the typical contingent market situation

m ay overstate their WTP compared to their likely behavior in a real

- world situation. However, the magnitude of hypothetical bias on the estimated WTP is uncertain. Following standard benefit transfer approaches, including m eta

- analysis transfers, this analy sis reflects the assumption that each source study provides a valid, unbiased estimate of the welfare measure under consideration (cf. Moeltner et al., 2007;January 2012 13

. Potential Incremental Benefits of the Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  13

- 17 Rosenberger and Phipps, 2007). To minimize potential hypothetical bias, EPA set independent variab le

values to reflect best benefit transfer practices

. The estimation of WTP may be sensitive to differences in the environmental water quality measures. Studies that did not use the WQI were mapped to the WQI so a comparison could be made across studies.

T he dummy variable ( WQI ) captures the effect of a study using ( WQI =1) or not using the WQI ( WQI =0).
This showed that studies that did not use the WQI had lower WTP values, which indicate s that there may have been some systematic biases in the mapping of stu dies that did not use the WQI. In analyzing the benefits of this regulation, EPA set the WQI variable to one to reduce uncertainty in WTP estimates associated with studies that did not include WQI as a native survey instrument. EPA (2009b) provides a

detai led discussion of water quality measures used in the original studies included in the meta

- analysis

. Transfer error may occur when benefit estimates from a study site are adopted to forecast the benefits of a policy site. Rosenberger and Stanley (2006) def ine transfer error as the difference between the transferred

and actual

– generally unknown

– value . While meta

- analysis is fairly accurate when estimating benefit

function s , transfer error may be a problem in cases where the sample size is small. While me ta

- analyses have been shown to outperform other function

- based transfer methods in many cases, this result is not universal (Shrestha et al.

, 2007). However , results reviewed by Rosenberger and Phipps (2007) are “very promising” regarding the performance o f meta

- analytic benefit transfers relative to alternative transfer

methods.

Finally, t here may be a lag between nutrient reductions and associated benefits in estuaries and coastal

waters. The length of this lag, however, varies considerably depending on t he source of nutrient loadings

to estuaries. In some estuaries, for example, groundwater is a significant source of nutrient loadings, and there may be significant lag periods, as long as decades, between reductions in anthropogenic nutrient loadings to gr oundwater and observed improvements in the estuaries (Glibert et al., 2010). Given this variability, EPA does not estimate a constant lag period for the attainment of benefits from water quality improvements. Instead, the estimate presented above represent the potential benefits of full attainment of the proposed criteria.January 2012 14

. References

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  14

- 1 

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. Proposed Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  A

- 1 

## Appendix A. Proposed Numeric Nutrient Criteria

Error! Reference source not found.

, Error! Reference source not found.

, and Exhibit A

- 3 show the applicable numeric nutrient criteria for each segment or WBID.



### Exhibit A

- 1 : Proposed Chlorophyll

- a Criteria for Coastal
Waters

WBID CHLA_Criteri a WBID CHLA_Criteri a 8001 2.54 8092 0.27
8002 2.24 8093 0.26
8003 1.32 8094 0.23
8004 1.11 8095 0.21
8005 1.03 8096 0.20
8006 0.87 8097 0.19
8007 0.96 8098 0.18
8008 1.09 8099 0.19
8009 0.89 8100 0.24
8010 0.88 8101 0.51
8011 0.89 8102 0.89
8012 0.94 8103 1.11
8 013 1.25 8104 1.51
8014 1.45 8105 1.41
8015 2.38 8106 1.38
8016 2.22 8107 1.39
8017 3.16 8108 1.30 8045C 4.87 8109 1.33
8046 4.34 8110 1.78
8047 4.15 8111 2.62
8048 4.12 8112 2.29
8049 4.48 8113 2.07
8050 3.44 8114 1.94
8051 3.12 8115 1.82
8052 2.87 8116 2.06
8053 2.81 8117 2.02
8054 2.77 8118 2.04
8055 3.09 8119 1.78
8056 4.39 8120 1.88
8057 3.96 8121 2.03
8058 3.77 8122 2.43
8059 4.19 8123 2.80
8060 5.03 8124 2.90
8061 3.97 8125 2.90

8062 3.97 8126 3.70
8063 3.88 8127 3.76
8064 4.4 1 8128 3.92
8091 0.64 8129 4.24January 2012 Appendix A

. Proposed Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  A

- 2 

### Exhibit A

- 2 : Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment
ID TN (mg/L) TP (mg/L) chl_a (ug/L) Perdido Bay (Includes Big Lagoon) Upp er Perdido Bay 0101 0.59 0.042 5.23 Big Lagoon 0102 0.26 0.019 4.85 Central Perdido Bay 0103 0.47 0.031 5.81 Lower Perdido Bay 0104 0.34 0.023 5.76 Pensacola Bay (Includes

Escambia, Blackwater, East Bay and Santa Rosa Sound) Blackwater Bay 0201 0.55 0.022 3.89 Upper Escambia Bay 0202 0.43 0.025 3.70 East Bay 0203 0.50 0.021 4.24

Santa Rosa Sound 0204 0.31 0.018 4.09 Lower Escambaa Bay 0205 0.42 0.024 3.93 Upper Pensacola Bay 0206 0.40 0.021 3.92 Lower Pensacola Bay 0207 0.34 0.020 3.62
Santa Rosa Sound 0208 0.33 0.020 4.08

Santa Rosa Sound 0209 0.36 0.020 5.17 Choctawhatchee Bay Eastern Choctawhatchee Bay 0301 0.61 0.035 4.14

Central Choctawhatchee Bay 0302 0.48 0.017 3.86

Western Choctawhatchee Bay 0303 0.41 0.015 3.49

St. Andre ws Bay (includes West, East, and North Bay,

and St. Andrews Sound) East Bay 0401 0.31 0.014 4.65
St. Andrew Sound 0402 0.14 0.009 2.28 Eastern St. Andrews Bay 0403 0.24 0.021 3.93 Western St. Andrews Bay 0404 0.19 0.016 3.12
Southern St. Andrews
Ba y 0405 0.15 0.013 2.58

North Bay 1 0406 0.22 0.012 3.67 North Bay 2 0407 0.22 0.014 3.65 North Bay 3 0408 0.21 0.016 3.42 West Bay 0409 0.23 0.022 3.83 St. Joe Bay St. Josephs Bay 0501 0.43 0.020 3.00 Apalachicola Bay (includes

St. Vincent, East Bay, St. George Sound) St. George's Sound 0601 0.53 0.019 3.62 Apalachicola Bay 0602 0.51 0.019 2.66 East Bay 0603 0.76 0.034 1.65

St. Vincent Sound 0605 0.52 0.016 11.91 Apalachicola / Offshore 0606 0.30 0.008 2.32 Alligator Harbor Aligator Harbo r 0701 0.36 0.011 2.79 Aligator / Offshore (WBID 8024) 0702 0.33 0.009 3.07

Aligator / Offshore (WBID 8023) 0703 0.33 0.009 2.86

Ochlockonee Bay St. Marks River (793A) 0828 0.55 0.030 1.19
Ochlocknee Offshore (8025 & 8026) 0829 0.47 0.019 1.87

Och locknee Bay (1248*) 0830 0.66 0.037 1.84 Econfina (3402A) 0824 0.59 0.028 4.57 Big Bend/Apalachee Bay (Panacea to Shired Island) Steinhatchee Offshore (8035) 0818 0.39 0.032 4.78January 2012 Appendix A

. Proposed Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  A

- 3 

### Exhibit A

- 2 : Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment
ID TN (mg/L) TP (mg/L) chl_a (ug/L)
Steinhatchee River (3573C 0819 0.67 0.077 0.97

Steinhatchee Offshore ( 8033 & 8034) 0820 0.34 0.018 3.46

Steinhatchee

Fenholloway Offshore (8031 & 8032) 0821 0.40 0.023 4.07

Fenholloway (3473A) 0822 1.15 0.444 1.93 Fenholloway Offshore (8030) 0823 0.48 0.034 10.27

Econfina Offshore (8029) 0824 0.59 0.028 4.57
Ochloc knee

- St. Marks Offshore (8028) 0825 0.79 0.033 2.72

St. Marks River Offshore (8027) 0827 0.51 0.022 1.66

Suwannee Sound/Cedar Keys Suwannee Offshore (3422D) 0817 1.10 0.090 3.70

Spring Coast (Waccasassa to Anclote) Anclote River (1440) 0804 0.48 0.037 4.74 Anclote Offshore (8045C) 0805 0.31 0.011 3.15

Pithlachascotee River (1409C) 0806 0.50 0.022 2.40

Pithlachascotee Offshore (8044) 0807 0.32 0.011 2.50

Weeki Wachee River (1382*) 0808 0.32 0.010 1.64

Weeki Wachee Offshore (8042 & 8043) 0809 0. 30 0.010 2.06

Chassahowitzka River (1361) 0810 0.32 0.010 0.70

Chassahowitzka River Offshore (8041) 0811 0.29 0.010 1.73

Crystal River (1341) 0812 0.35 0.013 1.35 Crystal

- Homosassa Offshore (8039 & 8040) 0813 0.36 0.013 2.10

Waccasassa River Offs hore (8038) 0814 0.38 0.019 3.92

Waccasassa River Offshore (8037) 0815 0.32 0.019 4.12

Homosassa River (1345) 0833 0.47 0.032 1.89
Clearwater Harbor/St. Joseph Sound Clearwater Harbor (1528 & 1528C) 0801 0.47 0.029 5.67

St. Joseph Sound (8045D) 0802 0.46 0.029 5.51

Clearwater

- St. Joseph Offshore (8046 & 8047) 0803 0.29 0.008 2.60

Tampa Bay Estuary Program (Boca Ciega, Hillsborough, Upper, Mid,

Lower, Old, Terra Ceia, Manatee River) Hillsborough Bay 0901 0.49 0.175 7.74 Old Tampa Bay 0902 0.44 0. 172 12.90 Upper Tampa Bay 0903 0.44 0.152 7.85 Middle Tampa Bay 0904 0.37 0.116 6.27 Lower Tampa Bay 0905 0.31 0.074 4.91January 2012 Appendix A

. Proposed Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  A

- 4 

### Exhibit A

- 2 : Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment
ID TN (mg/L) TP (mg/L) chl_a (ug/L)
Manatee River 0906 0.62 0.115 7.41 Boga Ceia 0907 0.30 0.086 5.30 Sarasota NEP (Sarasota, Palma Sola, Roberts, Little Saras ota Bay) Sarasota Bay 1001 0.28 0.119 7.72 Palm Sola Bay 1002 0.34 0.141 7.18 Roberts Bay 1003 0.34 0.131 8.61 Little Sarasota Bay 1004 0.30 0.123 8.31 BlackBurn bay 1005 0.28 0.118 7.03 Dona Bay 1006 0.24 0.115 4.16
Charlotte Harbor NEP (Lemon Bay, Caloosahatchee, Pine Island Sound, San Carlos Bay, Estero Bay) Upper Caloosahatchee 1101 1.11 0.110 9.88

Lower Caloosahatchee 1102 0.61 0.083 3.48 Estero Bay 1103 0.65 0.072 2.34

Matiacha Pass 1104 0.57 0.076 1.63 San Carlos Bay 1105 0.57 0.06 0 2.39 Peace Estuary 1106 0.79 0.303 3.52 Myakka Estuary 1107 0.71 0.176 3.79 Upper Charlotte Harbor 1108 0.71 0.177 2.88

Lower Charlotte Harbor 1109 0.61 0.105 2.11

Pine Island Sound 1110 0.56 0.062 2.05
Lake Worth Lagoon/Loxahatchee North Lake worth Lagoon 1201 0.55 0.067 4.67
Central Lakeworth Lagoon 1202 0.57 0.089 5.30

South Lakeworth Lagoon 1203 0.48 0.034 3.55

Lower Loxahatchee 1301 0.64 0.027 2.88

Middle Loxahatchee 1302 0.90 0.041 3.83 Upper Loxahatchee 1303 1.15 0.068 2.75
St. Lucie Lower St.Lucie 1401 0.58 0.045 5.27

Middle St.Lucie 1402 0.90 0.120 8.43 Upper St.Lucie 1403 1.22 0.197 8.94 Indian River Lagoon (Banana River, Mosquito Lagoon) Upper Mosquito Lagoon 1501 1.10 0.050 3.60 Lower Mosquito Lagoon 1502 1.30 0.060 7.00

Banana River 1503 1.60 0.060 9.90 Upper Indian River Lagoon 1504 1.40 0.060 10.00

Upper Central Indian River Lagoon 1505 1.30 0.060 11.00

Lower Central Indian River Lagoon 1506 0.80 0.080 8.00

Lower Indian River Lagoon 1507 0.80 0.070 5.60

Halifax River (includes Smith Creek) Upper Halifax River 1601 1.10 0.180 8.80

Lower Halifax River 1602 0.85 0.200 9.70 Guano, Tolomato, Matanzas, Pellicer Pablo Creek 1701 0.60 0.090 6.60 Cabbage Creek 1702 0.60 0.090 6.60

Guana River 1703 0.60 0.0 90 6.60 Upper Tolomato River 1704 0.60 0.090 6.60

Lower Tolomato River 1705 0.60 0.090 6.60January 2012 Appendix A

. Proposed Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  A

- 5 

### Exhibit A

- 2 : Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment
ID TN (mg/L) TP (mg/L) chl_a (ug/L) Upper Matanzas River 1706 0.60 0.090 6.60
Central Matanzas River 1707 0.60 0.090 6.60

Lower Matanzas River 1708 0.60 0.090 6.60 St. Johns River Estuary L ower St. John River 1801 0.75 0.095 2.50

Trout River 1802 1.09 0.108 3.60

Trout River 1803 1.15 0.074 7.70 Nassau River/Big Talbot/St. Marys River/Amelia River Lower Nassau 1901 0.33 0.113 3.17

Middle Nassau 1902 0.40 0.120 2.41 Upper Nassau 1903 0.75 0.125 3.45 Lower St.Mary's 2002 0.27 0.045 3.01 Middle St.Mary's 2003 0.44 0.036 2.65January 2012 Appendix A

. Proposed Numeric Nutrient Criteria

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  A

- 6 

### Exhibit A

- 3 : Proposed Nutrient Criteria for South Florida Marine Waters Waterbody Segment TN, mg/L TP, m g/L Chl

- a, μg/L Biscayne Bay CS 0.37 0.007 0.38 Biscayne Bay NCI 0.33 0.008 0.46 Biscayne Bay NNB 0.33 0.012 1.79 Biscayne Bay SCI 0.52 0.008 0.4 Biscayne Bay SCM 0.39 0.008 0.36 Biscayne Bay SCO 0.26 0.007 0.27 Biscayne Bay SNB 0.32 0.01 1.01

Flor ida Bay CFB 1.45 0.025 3.11 Florida Bay CL 1.59 0.049 10.06 Florida Bay ECFB 0.88 0.009 0.68 Florida Bay MBS 0.73 0.01 0.76 Florida Bay NFB 0.85 0.015 1.04 Florida Bay SFB 0.88 0.011 1.32 Florida Bay WFBC 0.63 0.02 2.01 Florida Bay WFBN 0.45 0.024 2 .95 Florida Bay WFBS 0.34 0.012 1.02 Florida Keys BKB 0.28 0.009 0.38 Florida Keys BKS 0.26 0.011 0.73 Florida Keys DT 0.21 0.008 0.42 Florida Keys FKN 0.2 0.007 0.27 Florida Keys FKS 0.22 0.008 0.36 Florida Keys FKT 0.21 0.008 0.33 Florida Keys KW OS 0.21 0.008 0.38 Florida Keys MAR 0.23 0.009 0.63 Rookery Bay CI 0.3 0.033 3.56 Rookery Bay COCO 0.54 0.059 6.25 Rookery Bay EB 0.33 0.055 5.48 Rookery Bay MARC 0.36 0.048 5.86 Rookery Bay NPL 0.32 0.05 4.91 Rookery Bay PINE 0.33 0.049 4.87
Rooke ry Bay SCB 0.48 0.073 4.48

Gulf Shelf GS 0.39 0.021 2.84 Whitewater Bay BLK 0.46 0.056 4.24 Whitewater Bay CTHB 0.84 0.041 5.37 Whitewater Bay GI 0.54 0.041 3.69 Whitewater Bay IWW 0.76 0.037 4.98 Whitewater Bay LMB 0.89 0.027 3.98 Whitewater Bay PD 0.66 0.025 3.03 Whitewater Bay SRM 1.13 0.026 2.47 Whitewater Bay WWB 1.04 0.028 4.51January 2012 Appendix B

. Municipal WWTP Cost Estimates

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  B

- 1 

## Appendix B. Municipal WWTP Cost Estimates

Exhibit B

- 1 shows the cost estimates for municipal WWTP s discharging to affected waters in Florida.



### Exhibit B

- 1 : Potential Costs to Municipal WWTPs for Compliance with Numeric
Nutrient Criteria

NPDES

No. Discharger Name Flow (mgd) Reductions Needed Total Capital Costs (millions

2010$) Annual O& M Costs (millions

2010$) TN TP Majors

FL0000922 USN MAYPORT NAVAL STATION WWTF 2 No Yes $1.4 $0.2

FL0000957 USN NAS JACKSONVILLE STP 3 No Yes $2.2 $0.3

FL0002631 BAY COUNTY WASTE
TRTMNT

- PANAMA 37 Yes Yes $50.6 $5.5

FL0020206 PORT ST. JOE 3.1 No Yes $2.2 $0.3

FL0020231 JAX BEACH STP 4.5 No Yes $3.2 $0.4

FL0020401 PALMETTO STP 2.4 No No $0.0 $0.0

FL0020427 NEPTUNE BEACH WWTP 1.5 No Yes $1.1 $0.1

FL0020451 ST ANDREWS WWTF 5 No Yes $3.6 $0.5

FL0020532 ORMOND BEACH STP 6 No No $0.0 $0.0

FL002054 1 CAPE CANAVERAL 1.8 No No $0.0 $0.0

FL0020940 HOWARD F CURREN AWTP 96 No No $0.0 $0.0

FL0021105 COCOA BEACH WRF 6 No No $0.0 $0.0

FL0021261 FT MYERS

- CENTRAL STP 11 No Yes $7.9 $1.0

FL0021270 FT MYERS

- SOUTH STP 12 No Yes $8.6 $1.1

FL0021326 DUNEDIN

- MA INLAND STP 6 No Yes $4.3 $0.6

FL0021440 MAIN STREET WWTP 20 No No $0.0 $0.0

FL0021512 PANAMA CITY BEACH STP 7 Yes Yes $9.6 $1.0

FL0021661 VERO BEACH WWTP

INDIAN RIVER 4.5 No No $0.0 $0.0

FL0021857 CLEARWATER

- MARSHALL ST STP 10 Yes Yes $13.7 $1.5

FL002 1865 CLEARWATER

- EAST WWTF 4.3 No Yes $3.1 $0.4

FL0021938 ST AUGUSTINE STP NO 1 4.5 Yes Yes $6.2 $0.7

FL0023248 ATLANTIC BEACH

- BUCCANEER STP 1.3 No Yes $0.9 $0.1

FL0023604 JEA

- MONTEREY WWTF 3.6 No Yes $2.6 $0.3

FL0023663 SAN JOSE WWTF 2.25 No Yes $1 .6 $0.2

FL0023671 JEA

- JACKSONVILLE HEIGHTS WWT 2.5 No Yes $1.8 $0.2

FL0024007 SANTA ROSA ISL

- PENSCLA BCH STP 2.4 No No $0.0 $0.0

FL0024805 MIAMI

- VIRGINIA KEY WTP 121 No No $0.0 $0.0January 2012 Appendix B

. Municipal WWTP Cost Estimates

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  B

- 2 

### Exhibit B

- 1 : Potential Costs to Municipal WWTPs for Compliance with Numeric
Nutrient Criteria

NPDES

No. Discharger Name Flow (mgd) Reductions Needed Total Capital Costs (millions

2010$) Annual O& M Costs (millions

2010$) TN TP

FL0025755 SIESTA KEY UTILITIES AUTHORITY 2.7 No Yes $1.9 $0.3

FL002 5984 DAYTONA BCH/BETHUNE
PT WWTF 10 No No $0.0 $0.0

FL0026000 JEA

- BUCKMAN WWTF 52.5 No Yes $37.8 $4.9

FL0026255 HOLLYWOOD WTP 42 No No $0.0 $0.0

FL0026271 NAPLES

- MUNICIPAL PLANT 10 No Yes $7.2 $0.9

FL0026344 BOCA RATON WPC FAC 20 No No $0.0 $0.0

FL0 026441 JEA

- ARLINGTON WWTF 15 No Yes $10.8 $1.4

FL0026450 JEA

- NORTHEAST WWTF (FKA DIST 10 No Yes $7.2 $0.9

FL0026468 JEA

- SOUTHWEST WWTF 10 No Yes $7.2 $0.9

FL0026603 LARGO CITY OF 15 No Yes $10.8 $1.4

FL0026611 FLAGLER BEACH WTP 1 Yes Yes $1.4 $0 .1
FL0026751 JEA

- ROYAL LAKES WWTF 3.25 No Yes $2.3 $0.3

FL0026778 BEACON HILLS SUBDIVISION WWTF 1.3 No Yes $0.9 $0.1

FL0027260 FERNANDINA BEACH

MUNICIPAL STP 3.5 Yes Yes $4.8 $0.5

FL0027278 FT PIERCE UTIL AUTHORITY

- WTP 9 No No $0.0 $0.0

FL0027651 CI TY OF OLDSMAR 2.25 No Yes $1.6 $0.2

FL0027677 HOLLY HILL ADVANCED
WWTF 2.4 No No $0.0 $0.0

FL0030007 CITY OF CAPE CORAL 15.1 No No $0.0 $0.0

FL0030325 FL CITIES WATER

WATERWAY EST 1.25 No Yes $0.9 $0.1

FL0030406 TARPON SPRINGS STP 4 No No $0.0 $0.0

FL 0031771 BROWARD CO NORTH REGIONAL WWTP 80 No No $0.0 $0.0

FL0031801 ESCAMBIA CTY

- BAYOU MARCUS 8.2 No Yes $5.9 $0.8

FL0032182 MIAMI

- DADE NO DIST WTF 112.5 No No $0.0 $0.0

FL0034649 LOXAHATCHEE RV REG WWTP&RECL 11 No No $0.0 $0.0

FL0035980 SO. CENTRAL

- WW DISP.
BD. 24 No No $0.0 $0.0

FL0038776 ATLANTIC BEACH WWTP 3 No Yes $2.2 $0.3

FL0038831 ANASTASIA ISLAND WWTP 4 Yes Yes $5.5 $0.6

FL0039829 LEE COUNTY UTIL

- FIESTA VILLAGE 5 No No $0.0 $0.0

FL0040398 COOPER CITY UTILITY 2.5 No No $0.0 $0.0January 2012 Appendix B

. Municipal WWTP Cost Estimates

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  B

- 3 

### Exhibit B

- 1 : Potential Costs to Municipal WWTPs for Compliance with Numeric
Nutrient Criteria

NPDES

No. Discharger Name Flow (mgd) Reductions Needed Total Capital Costs (millions

2010$) Annual O& M Costs (millions

2010$) TN TP

DEPT

FL0 040541 DAVIE STP 3 No No $0.0 $0.0

FL0040614 HILLSBORO CO

- FALKENBURG RD A 6 No Yes $4.3 $0.6

FL0040665 CLEWISTON CITY OF
WWTP 1.5 No No $0.0 $0.0

FL0040771 SARASOTA CITY OF WWTP 10 No No $0.0 $0.0

FL0041122 MELBOURNE CTY OF GRANT ST WWTP 5.5 No No $ 0.0 $0.0

FL0041360 EAST CENTRAL REGIONAL
WWTP 64 Yes Yes $87.6 $9.5

FL0041637 INDIAN RIV CTY

- WEST REGIONAL 4 No No $0.0 $0.0

FL0041670 NORTHWEST REGIONAL
WRF 5 No Yes $3.6 $0.5

FL0139475 SLCU SOUTH HUTCHINSON ISLAND 1.6 No No $0.0 $0.0

FL0167959 MILIT ARY PT REGIONAL
WWTF 7 No No $0.0 $0.0

FL0169978 CITY OF LYNN HAVEN 2.5 No Yes $1.8 $0.2

FL0170909 MILLVILLE WWT FACILITY 5 Yes Yes $6.8 $0.7

FL0173371 SPENCER WWTF 0.499 No Yes $0.4 $0.0

Minors

FL0003174 HURLBURT FIELD AIR FORCE BASE 1 No No $0.0 $0. 0

FL0020559 PORT ORANGE WWTP 12 No No $0.0 $0.0

FL0021431 EDGEWATER CITY OF 0.83 No No $0.0 $0.0

FL0021521 COCOA WATER RECLAMATION FACILI 4.5 No No $0.0 $0.0

FL0021571 ROCKLEDGE WWTP 0 No No $0.0 $0.0

FL0023396 WELLINGTON ARMS CONDO WWTP 0.015 Yes Ye s $0.0 $0.0

FL0023981 SANTA ROSA ISL

- NAVARRE BCH STP 0.9 No No $0.0 $0.0

FL0027618 EVERGLADES CITY STP 0.115 Yes Yes $0.2 $0.0

FL0028380 OCEAN MAISONETTES 0.01 Yes Yes $0.0 $0.0

FL0031216 CEDAR KEY SEWER & WATER DIST 0.166 Yes Yes $0.2 $0.0

FL0032468 CENTURY TOWN OF 0.45 No No $0.0 $0.0

FL0032654 MARSH COVE WWTF 0.05 Yes Yes $0.1 $0.0

FL0036862 POINCIANA UTIL

KISSIMMEE 0.35 Yes Yes $0.5 $0.1January 2012 Appendix B

. Municipal WWTP Cost Estimates

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  B

- 4 

### Exhibit B

- 1 : Potential Costs to Municipal WWTPs for Compliance with Numeric
Nutrient Criteria

NPDES

No. Discharger Name Flow (mgd) Reductions Needed Total Capital Costs (millions

2010$) Annual O& M Costs (millions

2010$) TN TP

FL0038768 SEACOAST UTIL

- PGA
WWTP 12 Yes Yes $16.4 $1.8

FL0039756 BEVERLY BEACH SURFSIDE UTILITY 0.099 Yes Y es $0.1 $0.0

FL0040592 ATLANTIC DRY DOCK CORP STP 0.06 Yes Yes $0.1 $0.0

FL0040622 BREVARD COUNTY

- S. BEACHES 0.017 No No $0.0 $0.0

FL0041424 PALM BCH CTY

- REGIONAL
PLANT 30 Yes Yes $41.0 $4.4

FL0042242 WALDO WWTP CITY OF 0.085 Yes Yes $0.1 $0.0

FL0 042293 BAREFOOT BAY 0.9 No No $0.0 $0.0

FL0044237 INNLET BEACH WWTF 0.5 Yes Yes $0.7 $0.1

FL0044245 PLAYERS CLUB SOUTH
WWTF 0.5 Yes Yes $0.7 $0.1

FL0044253 MARSH LANDING WWTF 0.6 Yes Yes $0.8 $0.1

FL0102482 SOUTH WALTON UTILITY COMPANY 2.5 No Yes $1.8 $0.2

FL0102920 CCAFS/REGIONAL (DW) 0.8 Yes Yes $1.1 $0.1

FL0103268 TITUSVILLE NORTH

- OSPREY 0.54 No No $0.0 $0.0

FL0116009 PALM COAST UTILITY CORPORATION 3.35 Yes Yes $4.6 $0.5

FL0116793 NASSAU REGIONAL WWTF 2 Yes Yes $2.7 $0.3

FL0116921 NASSAU HOST INC. 0.03 Yes Yes $0.0 $0.0

FL0117897 SAWGRASS STP 0.8 Yes Yes $1.1 $0.1

FL0128775 WILLIAM E DUNN WRF 9 No No $0.0 $0.0

FL0141356 COLLIER CO S REGIONAL 8 Yes Yes $10.9 $1.2

FL0141399 COLLIER COUNTY NORTH REGIONAL 13.5 Yes Yes $18.5 $2.0

FL0141704 PO RT OF THE ISLANDS SOUTH WWTP 0.2 Yes No $0.1 $0.0

FL0147141 FLAMINGO SEWAGE
TREATMENT PLAN 0.09 Yes No $0.1 $0.0

FL0170224 SEMINOLE IMPROVEMENT DISTRICT 0.06 Yes Yes $0.1 $0.0

FL0174441 BLACKS FORD WRF 0.49 Yes Yes $0.7 $0.1

FL0177008 SARASOTA COUNTY U TILITIES

- NO 5.937 Yes Yes $8.1 $0.9January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 1 

## Appendix C. Sample Industrial Discharger Analyses

Kinder Morgan Tampaplex Bulk Terminal

NPDES permit number: FL0321486 Major/minor: Minor
SIC code: 5169 ( Chemicals and Allied Products, Not Elsewhere Classified )
Industrial Cate gory: Chemicals and Allied Products Design Flow: Not reported Average Flow: Intermittent (range: 0.23 mgd to 2.88 mgd from 2006 through 2010). Receiving Water: Port Sutton Channel (WBID 1637)

Description
The facility consists of bulk material handling , warehousing, and a shipping terminal. The company transports aggregates, fertilizer products, and other dry bulk materials to and from the facility via ship, truck, or rail. These materials are temporarily stored at the facility in enclosed structures an d outdoors. The facility collects contact storm water runoff from the product unloading, storage, and loading areas in the Western and Central detention ponds where it is pumped through a series of treatment ponds prior to overflowing into the Eastern dete ntion pond. The facility routes contact and noncontact storm water from the eastern outdoor storage areas and scrubber underflow water to two dust suppression ponds. In the event of excess accumulation of wastewater and storm water, the facility may discha rge via Outfalls 001

and 004 to Port Sutton Channel.

Summary of Effluent Data and Limits
The facility does not discharge every month. In fact, effluent concentration data for TN and TP are only available for 5 months and effluent load data are only availab le for 10 months from 2006 through 2010, as

shown in Exhibit C

- 1

.


### Exhibit C

- 1 : Effluent Data Summary, Kinder Morgan Tampaplex Bulk Terminal 1

Pollutant Concentratio n Data Load Data

Observations Avg. Effluent (mg/L) Permit Limit (mg/L) Observations Avg. Effluent (lb/day) Permit Limit (lb/day)

TN 5 27.1 None 10 50.4 None
TP 5 41.6 None 10 96.8 None Source: EPA (2011 ) 1. TN and TP effluent data from 2006 through 20 10. Concentration data represent average of maximum monthly values; Load data represent average of maximum monthly values. The permit specifies a 5

- year rolling annual average TP target of 4.1 tons per year for both the Kinder Morgan Tampaplex Terminal an d Ammonia Terminal (FL0000264), and a cumulative 5

- year average of monthly TN loads target of 75 tons per year for 4 facilities total (FL0321486, FL0000264, FL0001643, and FL0122904). Thus, compliance with these limits depends on nutrient loads at other fa cilities.

Incremental Controls
The facility discharges to the Hillsborough Bay segment (Segment ID 0901) of the Tampa Bay estuary
with annual geometric mean criteria for TN and TP of 0. 49 mg/L and 0. 175 mg/L, respectively. The discharger is currently cove red under the Tampa Bay Reasonable Assurance Plan, and has a TN effluent loading limit reflecting the target levels for the bay. However, the plan does not include targets for TP. Thus, given current effluent TP concentrations, and the uncertainty as to wh ether dilution would beJanuary 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 2 considered in the calculations of potential effluent limits, this facility may need to implement a level of incremental control to reduce TP concentrations under the proposed rule.

Effluent monitoring data indicate that the facilit y discharges intermittently (there are only 5 monthly maximum/average flow values reported in PCS over 5 years of data) with extremely variable flows (ranging an order of magnitude). Without site

- specific facility information or knowledge of how FDEP

would permit such a discharge, the compliance mechanisms that would be necessary under the proposed rule are uncertain. For example, the discharger may be able to implement pollution prevention or waste

minimization measures to reduce stormwater contact with ma terials or reduce wastewater volume. The discharge r could also expand or construct new detention ponds to reduce or eliminate the discharge. However, due to the uncertainty related to the likely compliance mechanism, EPA conservatively (i.e., erring on the side of higher costs) assumed that the discharger would need to meet effluent limits based on

criteria end

- of

- pipe.

To meet the potential TP levels, EPA estimated costs based on chemical precipitation followed by

filtration . Capital and O&M unit costs co uld be $ 0

. 32 /gpd and $ 238 /MG, respectively. Based on a design

flow of 2.88 mgd, total capital costs could be a pproximately $ 0. 93 million. During the last 5 years, the facility has only discharged 2 consecutive months. Thus, to estimate O&M costs

, EPA assum ed that the facility would operate the treatment units for 60 days per year at a flow of 2.88 mgd for a cost of $0. 041

million. Total annual costs would be $ 0. 13 million based on annualizing capital costs at 7% over 20 years and adding annual O&M

. Exhibit C

- 2 summarizes these costs.



### Exhibit C

- 2 : Potential Incremental Costs, Kinder Morgan Tampaplex Bulk Terminal

Treatment Controls Capital Costs ($ million) 1 O&M Cost ($ million/yea r) 2 Annual Costs ($ million/year) 3
Chemical precipitation with filtration $0.93 $0.041 $0.13

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration. 2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of operating days per year (60 days). 3. Capital costs annualized at 7% over 20 years plus annual O&M.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 3 

### Mosaic Fertilizer

– Riverview Chemical Complex

NPDES permit number : FL000 0761 Major/minor : Major
SIC code : 2874 ( Phosphatic Fertilizers ) Industrial Category : Chemicals and Allied Products Design Flow : Not reported Average Flow : 0.79 mgd for Outfall 005B and 0.33 mgd for Outfall 021 (2006

- 2010) Receiving Water : Alafia River (Outfall 001, 0 05A, 005B, 021); Hillsborough Bay (Outfall 022); Archie Creek (Outfall 025)
Description

The facility manufactures sulfuric acid, phosphoric acid, fluoride products, ammoniated phosphates and micronutrient added fertilizers, and animal feed phosphates. At f ull capacity, the facility produces approximately 1,500,000 tons of phosphoric acid per year (with 7,500,000 tons per year of phosphogypsum as a byproduct of the manufacturing process). Other operations at the site include electric cogeneration, phosphogyp sum storage, raw material storage and handling, wastewater storage and handling, process material handling, product shipping facilities, and a 0.0175 mgd domestic wastewater treatment plant.

The facility discharges nonprocess wastewater, treated process w astewater, and storm water through Outfalls 001 and 005A to the Alafia River and through Outfall 005B to a barge basin off the Alafia River. In its 2005 permit, the facility proposed to change its operations to reduce the discharge from Outfall 001

and red irect the discharge to Outfall 005B. The facility sends storm water runoff from nonprocess area to detention ponds where filtration and nutrient removal take place prior to discharging through Outfall s 021 and 022. The north storm water management system f or Outfall 025 is designed to contain a storm event resulting in 7 inches of rain within a 24

- hour period. Effluent from the wastewater plant is routed to the process cooling pond water system.

Summary of Effluent Data and Limits

Exhibit C

- 3 summarizes average monthly effluent data for TN and TP for Outfall 005B and TP data for Outfall 021 from 2006 through 2010; there are no data for the other outfalls.



### Exhibit C

- 3 : Effluent Data Summary, Mosaic Fertilizer

– Riverview Chemical Complex 1

Pollutant Concentration Data Load Data

Observations Avg. Effluent (mg/L) Permit Limit (mg/L) Observations Avg. Effluent (lb/day) Permit Limit (lb/day) 2

Outfall 005B
TN 60 8.5 Non e 59 8.8 55
TP 5 41.6 None 59 23.8 55 Outfall 021
TN 57 1.8 None 0

-- None Source: EPA (2011 ) 1. TN and TP effluent data from 2006 through 2010. Concentration data represent average of maximum monthly values; Load data represent average of average mont hly values (which were consistently higher than the maximum monthly values reported). 2. Represents average monthly loading limits. The maximum daily load limit is 100 lbs/day for TN and 120 lbs/day for TP. The facility also has cumulative target values fo r Outfalls 001, 005A, and 005B of 1,452,331 lb/yr for TN and 2,358,657 lb/yr for TP.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 4 Incremental Controls

The facility discharges to the estuarine portion of the Alafia River (Segment ID 0901) of the Tampa Bay
estuary with annual geometric mean criteria for TN and TP of 0. 4 9 mg/L and 0. 175 mg/L, respectively. The facility is already covered under the Alafia River Nutrient TMDL. FDEP considers the discharger an insignificant source of nutrients (Petrus and Laskis, 2009):

“Th e one point source with outfal ls discharging to the Alafia River, the Mosaic Fertilizer, L.L.C. Riverview Chemical Complex, NPDES No. FL0000761, was considered not to be a significant load to the lower Alafia River relative to the total nonpoint source load, as the current TN load

bein g discharged is less than one percent of the total load entering the lower Alafia River. The facility’s current load to the river, for the 2001

- 2007 period, was applied as the WLA. Since the facility load is small relative to the total load entering the es tuary, the reductions will be focused on MS4 facilities and nonpoint sources. ”

However, because FDEP determined TN to be the limiting pollutant in the receiving water, it established a TMDL for TN only. Thus, under the rule the discharger may need to imple ment controls to reduce TP

concentrations. Given the lack of site

- specific facility treatment or process information and the uncertainty regarding how FDEP will establish effluent limits for the facility, the compliance mechanisms the facility would implem ent under the rule are uncertain. For example, the permit indicates that the discharge has filtration and nutrient removal prior to discharge through Outfall 021. However, it does not specify the type of nutrient removal processes to give indication as to whether modifications could be made to the existing treatment to enhance TP removal. It is also not clear whether FDEP would treat TP similar to how it treats TN under the Alafia River TMDL and set effluent limits based on existing loads

because the discha rger accounts for such a small percentage of the load. Due to these uncertainties, EPA conservatively (i.e., erring on the side of higher costs) assumed that the discharger would need to meet

effluent limits based on criteria end

- of

- pipe.

To meet the pote ntial TP levels, EPA estimated costs based on chemical precipitation followed by

filtration . Capital and O&M unit costs could be $ 0

. 32 /gpd and $ 238 /MG, respectively. The facility’s permit does not report design flows from which to estimate total capital co sts. Therefore, to estimate capital costs, we used the 90 th percentile maximum monthly flow from 2006 through 2010 to approximate the necessary design flow (1.7 mgd for Outfall 005B and 0.8 mgd for Outfall 021). Based on these flows, total capital costs co uld be approximately $ 0.80 million

. During the last 5 years, average maximum monthly flows for Outfall 005B and Outfall 021 have been 0.79 mgd and 0.33 mgd, respectively. Thus, to estimate O&M costs we used these average flows assuming operation of the tre atment units 365 days per year at a cost of $ 0.097 million. Total annual costs would be $ 0.17 million based on annualizing capital costs at 7% over 20 years and adding annual O&M

. Exhibit C

- 4 summarizes these costs

.


### Exhibit C

- 4 : Potential Incremental Costs, Mosaic Fertilizer

– Riverview Chemical Complex

Treatment Controls Capital Costs ($ million) 1 O&M Cost ($ million/year) 2 Annual Costs ($ million/year) 3

Chemic al precipitation with filtration $0.80 $0.097 $0.17

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration. 2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the numbe r of operating days per year (365 days). 3. Capital costs annualized at 7% over 20 years plus annual O&M.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 5 

### Trademark Nitrogen Corporation

NPDES permit number: FL0000647 Major/minor: Minor
SIC code: 2873 (Nitrogenous Fertilizers) Industrial Category: Chem icals and Allied Products Design Flow: 25 mgd Average Flow: 0.11 mgd (average of monthly maximum flows) Receiving Water: Unnamed ditch to Palm River to McKay Bay

Description

The facility is a fertilizer production plant, consisting of a 125 ton per da y nitric acid plant, a 150 ton per day ammonium nitrate plant, a fertilizer solution plant, a magnesium nitrate plant, a nitrogen

- phosphorus

potassium blend plant (liquid fertilizer), and a small boiler plant

. Wastewater consists of boiler blowdown, boiler water softener backwash, cooling tower blowdown, once

- through noncontact cooling water, and storm water runoff. All wastewater except the cooling water is treated in an unlined, hyacinths vegetated detention ditch. The ditch system provides for uptake of nutrients and settling of solids. Noncontact cooling water is piped directly to a basin downstream of the vegetated ditch.

Summary of Effluent Data and Limits

Exhibit C

- 5 summarizes average monthly effluent data fo r TN and TP from 2005 to 2010.



### Exhibit C

- 5 : Effluent Data Summary, Trademark Nitrogen Corporation

Pollutant Number of Observations Average Effluent (mg/L) 1 Permit Limit 2

Total nitrogen 60 0.76 3.0
Total phosphorus 1 0.048 None
Sour ce: EPA (2011 ) for nitrogen data; 2008 Effluent Quality Assessment Report for phosphorus. 1. TN effluent data from 2006 through 2010. Represents average of maximum monthly values. TP effluent data from March 2008. 2. Represents monthly average limit; permit also contains a daily maximum limit of 5.0 mg/L. In addition, the 5

- year rolling average for TN may not exceed 200 lbs/yr.

Incremental Controls

The facility discharges to McKay Bay (Segment ID 0901) of the Tampa Bay estuar y with annu al geometric mean criteria for TN and TP of 0. 4 9 mg/L and 0. 175 mg/L, respectively. However, the facility is already covered under the McKay Bay TMDL and has a WLA for TN of 3.0 mg/L, which it is currently meeting. Therefore, EPA assumed that th e TMDL TN targets would be adopted as SSAC and the facility

would not incur incremental costs associated with TN reductions.

The only TP observation indicates that the discharger is likely discharging below the applicable TP criterion. Thus, EPA assumed t hat an incremental level of control would not be necessary for compliance with effluent limits under the proposed rule and costs would be zero

.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 6 

### Anheuser Busch Inc., Main Street Sod Farm

NPDES permit number: FL 0041530 Major/minor: Minor
SIC code: 2082 (M alt Beverages) Industrial Category: Food Design Flow: 2.4 mgd Average Flow: 1.02 mgd (average of annual average values from 2006 through 2010) Receiving Water: Little Cedar Creek to Broward River

Description

Anheuser Busch operates a land application system that receives untreated and/or pretreated brewery liquor as a nutrient enrichment to grow turf and forage crops on a 320

- acre site

. The land application site drains to an interconnected pond system comprised of two ponds: North Borrow Pit (NBP) and South Borrow Pit (SBP). NBP drains to SBP which discharges via Outfall 001 to Little Cedar Creek.

Summary of Effluent Data and Limits

Exhibit C

- 6 summarizes average monthly effluent data for TN and TP from 2005 to 2010.



### Exhibit C

- 6 : Effluent Data Summary, Anheuser Busch Inc., Main Street Sod Farm

Pollutant Number of Observations Average Effluent (mg/L) 1 Permit Limit 2

Total nitrogen 55 3.0 None Total phosphorus 20 1.3 None Source: EPA (2011) 1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values. 2. Permit contains an annual loading limit for TN of 27,000 lbs/year.

Incremental Controls

The facility discharges to the Saint Johns River estuary (Segment ID 1802) with draft annual average

criteria for TN and TP of 1.09 mg/L and 0. 1 0 8 mg/L, respectively. However, for TN the discharger is covered under the Lower Saint Johns River TMDL and BMAP. FDEP gave the discharger a TN WLA that represented a 49% decrease in TN. To reduce effluent nutrient loads, in 2006, Anheuser Busch improved/modified the site nutrient management plan and increased the crop area to which they land applied a portion of the wastewater to reduce the nutrient load per acre (Busby

, 2009). Thus, EPA assumed that the discharger would not be required to implement additional controls for compliance with TN limits under the proposed rule.

However, for TP the discharger may need to reduce effluent levels under the pr oposed rule. Due to a lack

of site

- specific facility operations and treatment data, it is uncertain whether additional improvements or

modifications similar to those made to reduce TN concentrations could be made to reduce TP

concentrations. It is also unc ertain how FDEP would permit the facility under the proposed rule (e.g.,

limits based on criteria end

- of

- pipe, existing loads, or factoring in some degree of available dilution). As such, EPA conservatively (i.e., erring on the side of higher costs) assume d that the discharger would need

to meet effluent limits based on criteria end

- of

- pipe for TP.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 7 To meet the potential TP levels, EPA assumed that the facility would likely install chemical precipitation followed by filtration . Capital and O&M unit costs co uld be $ 0

. 32 /gpd and $ 238 /MG, respectively. Based on a design flow of 2.4 mgd, total capital costs could be a pproximately $ 0.77 million. During the last 5 years, average maximum monthly flows have been approximately 1.02 mgd. Thus, assuming operation of

th e treatment units 365 days per year , O&M costs could be approximately $0. 089 million. Total annual costs would be $ 0. 16 million based on annualizing capital costs at 7% over 20 years and adding annual

O&M

. Exhibit C

- 7 summarizes these costs.



### Exhibit C

- 7 : Potential Incremental Costs, Anheuser Busch

– Main Street Sod Farm

Treatment Controls Capital Costs ($ million) 1 O&M Cost ($ million/year) 2 Annual Costs ($ mill ion/year) 3
Chemical precipitation with filtration $0.77 $0.089 $0.16

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration. 2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtra tion and the number of operating days per year (365 days). 3. Capital costs annualized at 7% over 20 years plus annual O&M.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 8 

### Coca

- Cola North America, Dunedin

NPDES permit number: FL0 000477 Major/minor: Major
SIC code: 2033 ( Canned Fruits, Vegetables, P reserves, Jams, and Jellies ) Industrial Category: Food Design Flow: 0.45 mgd Average Flow: 0.22 mgd (average monthly maximum values from 2006 through 2010) Receiving Water: Saint Joseph’s Sound

Description

Coca

- Cola North America operates a fruit juice bl ending, packaging, and shipping operation for various fruit juice based concentrates for sale to food service organizations. The facility has an activated sludge industrial wastewater treatment system designed to collect and treat industrial process wastew ater through flow equalization, aeration, clarification, and filtration. The process wastewater consists of process blending, tank cleaning, boiler blowdown, cleaning from truck unloading area, noncontact defrost water, storm water runoff from parking lots and paved areas, well water used for cleaning and maintenance of the activated sludge treatment plant, and reverse osmosis concentrated from the water treatment plant onsite (the facility uses drinking water as an ingredient in its products).

Summary of E ffluent Data and Limits

Exhibit C

- 8 summarizes average monthly effluent data for TN and TP from 2005 to 2010.



### Exhibit C

- 8 : Effluent Data Summary, Coca

- Cola North America, Dunedin

Pollutant Number of Observations Average Effluent (mg/L) 1 Permit Limit (mg/L) 2

Total nitrogen 60 1.4 3.0 Total phosphorus 20 0.53 1.0 Source: EPA (2011) 1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values.
2. Permit contains an annual loading limit for TN of 27,000 lbs/year.
Incremental Controls

The facility discharges to the Saint Joseph’s Sound (Segment ID 0802) with annual geometric mean

criteria for TN and TP of 0. 46 mg/L and 0. 0 29 mg/L, respectively. The facility is currently discharging above the applicable criteria , and b ecause water quality data indicate that the segment could be impaired

for nutrients , it is not likely to receive dilution in the calculations of effluent limits. Thus, EPA assumed

that potential effluent limits for TN and TP would reflect criteria end

- of

- pipe.

However, d ue to the extremely low TN and TP levels, there is significant uncertainty as to whether the projected effluent limits are technologically or economically feasible to at tain . Thus, EPA assumed that the facility would likely pursue a variance from meeting effluent limits based on criteria end

- of

- pipe.

While e xisting TN concentrations are already relatively low

, additional reductions in TP could be achieved through cost

- eff ective treatment controls. Thus, EPA estimated incremental compliance costs based on installation of chemical precipitation (the facility already has filtration) as a condition of the variance (e.g., lowest levels feasible).

Capital and O&M unit costs coul d be $ 0

. 03 /gpd and $ 101/MG , respectively. Based on a design flow of

0.45 mgd, total capital costs could be a pproximately $ 0.015 million. During the last 5 years, averageJanuary 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 9 maximum monthly flows have been approximately 0.22 mgd. Thus, assuming operation of th e treatment units 365 days per year , O&M costs could be approximately $0. 008 million. Total annual costs would be $ 0. 01 million based on annualizing capital costs at 7% over 20 years and adding annual O&M

. Exhibit
C

- 9 summarizes these costs.



### Exhibit C

- 9 : Potential Incremental Costs, Coca Cola North America

- Dunedin

Treatment Controls Capital Costs ($ million) 1 O&M Cost ($ million/year) 2 Annual Costs ($ million/ year) 3
Chemical precipitation $0.015 $0.008 $0.01 1. Design flow multiplied by unit cost of $0.03/gpd for chemical precipitation. 2. Average flow multiplied by unit cost of $101/MG for chemical precipitation and the number of operating days per year (365 days). 3. Capital costs annualized at 7% over 20 years plus annual O&M.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 10 

### Tropicana Manufacturing Company, Inc.

NPDES permit number: FL0 000043 Major/minor: Major
SIC code: 0174 (Citrus Fruits) Industrial Category: Food Design Flow: 2.26 mgd Average Flow: No discharge since 2003 Receiving Water: Manatee River

Description

The facility operates a citrus juice processing plant with processes fresh fruit during the harvesting season (November through June) and packages the juice on a year

- round basis. The pro cess wastewater from the production facility is treated in an onsite, multi

- stage wastewater treatment plant which consists of equalization, dissolved air flotation, anaerobic bioreactors, pH adjustment, and 2 nd stage activated sludge (aeration and seconda ry clarification), and tertiary dissolved air flotation. Treated effluent is stored or discharged to to an underground injection well or Manatee River.

Summary of Effluent Data and Limits

The facility has not discharged in the last five years; thus, there are no effluent data for TN and TP. However, the discharge has an annual loading limit for TN of 9.125 tons/year based on a 5

- year rolling average with a 1

- year maximum load not to exceed 13.6875 tons.

Incremental Controls

The Manatee River (Segment ID 09 0 6) has TN and TP criteria of 0.62 mg/L and 0.1 15 mg/L, respectively. However, b ecause the facility has not discharged within the last five years, EPA assumes that it would not incur incremental control costs under the proposed rule.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 11 

### Tampa Phosphate Termi nal and Warehouse

NPDES permit number: FL0166057 Major/minor: Minor
SIC code: 1475 ( Phosphate Rock) Industrial Category: Mining Design Flow: Not reported Average Flow: 0.018 mgd Outfall D

- SW1; 0.31 mgd Outfall D

- SW3 (average of average monthly values for 2006 through 2010) Receiving Water: East Bay (sub

- bay of Hillsborough Bay)

Description

Facility operations consist of bulk fertilizer storage and material transfer for the shipping terminal at the Port of Tampa

. The facility is permitted to dischar ge contact and noncontact storm water via Outfall D

SW1 and D

- SW3 directly into East Bay, a sub

- bay of Tampa Bay. During normal rainfall events, Outfall

D

- SW1 does not discharge, and the sump pump transfers all storm water to the onsite storm water

retention pond which is designed to store a 25

- year, 24

- hour rainfall event of 8 inches. Storm water enters the retention pond where solids settle out and then flows over a berm to the secondary area containing hyacinths with uptake nutrients. Outfal l D

- SW3 is locat ed at the storm water retention pond. Fertilizer products are the only significant materials handled at the facility that have potential f or storm water

exposure.
Summary of Effluent Data and Limits

Exhibit C

- 10 summ arizes TN and TP effluent data from 2006 through 2010 for Outfalls D

- SW1 and D

SW3.



### Exhibit C

- 10 : Effluent Data Summary, Tampa Phosphate Terminal and Warehouse

Pollutant Number of Observations Average Effl uent (mg/L)

1 Permit Limit 2

Outfall D

- SW1 Total nitrogen 13 19.1 None Total phosphorus 13 22.6 None Outfall D

- SW3 Total nitrogen 5 17.4 None Total phosphorus 5 32.1 None Source: EPA (2011) 1. TN and TP effluent data from 2006 through 2010 representi ng average of maximum monthly values. 2. Permit contains 5

- year rolling average annual maximum target values for TN and TP of 1,104 lbs/year and 986 lbs/year, respectively.
Incremental Controls

The facility discharges to Hillsborough Bay (Segment ID 0901 ) in the Tampa Bay estuary with annual geometric mean criteria for TN and TP of 0. 4 9 mg/L and 0. 175 mg/L, respectively. The discharger is currently covered under the Tampa Bay Reasonable Assurance Plan, and has a TN effluent loading limit reflecting the ta rget levels for the bay. However, the plan does not include targets for TP. Thus, given current effluent TP concentrations, and the uncertainty as to whether the discharger would receive dilution in the calculations of potential effluent limits, this facil ity may need to implement a level of

incremental control to reduce TP concentrations under the proposed rule.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 12 Effluent monitoring data indicate that the facility discharges intermittently (there are only 13 monthly maximum/average flow values reported in PCS over 5 years of data for Outfall D

- SW1 and 5 for Outfall

D

- SW3) with extremely variable flows (ranging 2 orders of magnitude). Without site

- specific facility information or knowledge of how FDEP would permit such a discharge

, the compliance mechanisms that would be necessary under the proposed rule are uncertain. For example, the discharger may be able to implement pollution prevention or waste minimization measures to reduce stormwater contact with materials or reduce wastewater volume. The discharge c ould also expand or construct new stormwater detention ponds to reduce or eliminate the discharge. However, due to the uncertainty related to the likely compliance mechanism, EPA conservatively (i.e., erring on the side of higher costs) assumed that the

di scharger would need to install additional end

- of

- pipe treatment controls to meet effluent limits based on the criteria at the point of discharge (i.e., no dilution)

.

To meet the potential TP levels, EPA estimated costs based on chemical precipitation follo wed by

filtration . Capital and O&M unit costs could be $ 0

. 32 /gpd and $ 238 /MG, respectively. The facility’s permit does not report design flows from which to estimate total capital costs. Therefore, to estimate capital costs, we used the 90 th percentile max imum monthly flow for both outfalls from 2006 through 2010 to approximat e the necessary design flow (0.29 mgd for Outfall SW1 and 0.76 mgd for Outfall

SW3 ). Based on these flows, total capital costs could be approximately $ 0.34 million. During the last 5

y ears, average maximu m monthly flows for Outfall SW1 and Outfall SW3 have been 0. 018 mgd and 0.31 mgd, respectively. Thus, to estimate O&M costs we used these average flows assuming operation of the

treatment units 79 days per year (13 months of discharge o ver 5 years = 79 discharge days per year) at a cost of $ 0. 006 million. Total annual costs would be $ 0. 038 million based on annualizing capital costs at 7% over 20 years and adding annual O&M

. Exhibit C

- 11 summarize s these costs.



### Exhibit C

- 11 : Potential Incremental Costs, Tampa Phosphate Terminal and Warehouse

Treatment Controls Capital Costs ($ million) 1 O&M Cost ($ million/year) 2 Annual Costs ($ million/year) 3
Chemical precipitation with filtration $0.34 $0.006 $0.038

1. 90 th percentile flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration. 2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtrati on and the number of operating days per year (79 days). 3. Capital costs annualized at 7% over 20 years plus annual O&M.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 13 

### YARA North America, Inc.

NPDES permit number: FL00 38652 Major/minor: Major
SIC code: 1475 (Phosphate Rock) Industrial Category: M ining Design Flow: 2 mgd Average Flow: 1.8 mgd (average of maximum monthly values from 2006 through 2010) Receiving Water: Port Sutton Channel

Description

The facility is a bulk anhydrous ammonia storage and transfer facility that encompasses approxim ately 3.65 acres. The anhydrous ammonia arrives via ship and is stored in two onsite storage tanks where it is distributed by commercial pipeline and tanker trucks. The facility intakes sea water from the Tampa Bay Electric discharge

, and pumps the warmed w ater through two parallel shell and tube type heat exchangers. The facility has a 15,000 gallon holding tank to store contaminated seawater in case of an upset and to contain noncontact cooling water from the condensers prior to discharge. The condensers u se potable municipal water with addition of antiscalant, corrosion inhibitors, and biocides. The wastewater treatment system has a fully automatic differential pH detection and control system. The facility also collects storm water in a 50,000 gallon deten tion pond where it monitors and controls the water level using a sump pump system. Any pumped storm water mixes with the seawater cooling water upstream of Outfall D

- 001 prior to discharging to the Port Sutton Channel.

Summary of Effluent Data and Limits

Exhibit C

- 12 summarizes average monthly effluent data for TN and TP from 2005 to 2010.



### Exhibit C

- 12 : Effluent Data Summary, YARA North America, Inc.

Pollutant Numbe r of Observations Average Effluent (mg/L) 1 Permit Limit (mg/L) 2

Total nitrogen 59 1.1 3.0 Total phosphorus 53 0.23 None Source: EPA (2011) 1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values. 2. Permit also co ntains an annual loading target value for TN of 7,951 lbs/year representing only the load contributed by the facility (excludes any TN in the initial intake water).
Incremental Controls

The facility discharges to Port Sutton Channel (Segment ID 0901) in the Tampa Bay estuary with annual geometric mean criteria for TN and TP of 0. 4 9 mg/L and 0. 175 mg/L, respectively. The discharger is currently covered under the Black Point Channel TN TMDL and the Tampa Bay Reasonable Assurance Plan, and has a TN effluent loading limit reflecting the target levels for the bay. Thus, EPA assumed the discharger would not incur incremental control costs associated with TN reductions.

T he plan does not include targets for TP. C urrent average effluent TP concentrations indicate that the facility is likely discharging below the TP criterion. Thus

, EPA assumed that th e facility would not incur

incremental costs associated with TP reductions

.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 14 

### Coastal Terminals LLC

- Fisher Island Terminal

NPDES permit number: FL00 36064 Major/mino r: Minor
SIC code: 5171 (Petroleum Bulk S tations and Terminals ) Industrial Category: Other Design Flow: 0.5 mgd Average Flow: 0.42 mgd (only one maximum monthly value from 2006 through 2010) Receiving Water: Biscayne Bay

Description

The facility is a bulk petroleum products storage and distribution facility with a total of 17 aboveground storage tanks at the terminal site that store petroleum products including No. 6 fuel oil and diesel fuel.

There is no dedicated "off

- spec" tank as all petroleum conta ct water (PCW), including tank bottom water and contaminated stormwater are diverted to any one of the No. 6 fuel oil storage tanks for assimilation. Secondary containment for the tank farm is provided by earthen dikes that surround an unlined

containment basin area of about 150,000 square feet. This facility may discharge up to 0.5 MGD of hydrostatic tank test water through Outfall D

- 002, using either ambient sea water or municipal fresh water as the test water source. Hydrostatic test water is not normall y treated before disposal, but it must first be analyzed and shown to meet the effluent limitations specified in the permit before its release. If necessary, portable water treatment equipment (e.g., diatomaceous earth filter) may be utilized to reduce the particular pollutant(s) of concern. In the event municipal potable water is used as the source water, effluent total residual chlorine (TRC) level is typically reduced by exposure to atmosphere, during

overland flow in transit to Outfall D

- 002. Tank botto m water, loading rack runoff and other miscellaneous PCW’s, are returned to any one of the No. 6 fuel oil storage tanks for assimilation.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this disc harger.

Incremental Controls

The facility discharges wastewater to the Southern North Bay (Segment ID SNB) of the Biscayne Bay estuary with annual geometric mean criteria for TN and TP of 0.32 mg/L and 0.010 mg/L, respectively. The facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack of existing permit requirements, the nature of the wastewater (e.g

. , petroleum contact water and hydrostatic test water made up of ambient sea water or municipal potable water ), and the frequency of discharge (once in five years), it is unlikely that the facility would have reasonable potential under the proposed rule. Thus, incremental compliance costs are likely zero.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 15 

### F lorida A tlantic U niversity Sea Tech Facility

NPDES permi t number: FL0178870 Major/minor: Minor
SIC code: 8733 ( Noncommercial Research Organizations ) Industrial Category: Other Design Flow: 0.062 mgd Average Flow: 0.054 mgd (average of maximum monthly values from 2006 through 2010) Receiving Water: Whiskey Creek or New River Sound

Description

The facility is a university research institute that engages in various aspects of ocean engineering research activities. Part of the operation carried out at the facility involves the study of marine materials and

co rrosion effect as relating to offshore structures using natural sea water in holding tanks. Inside the tanks, sea water comes into contact with a variety of coupon

- sized test samples of metal (steel and aluminum), reinforced concrete, and carbon fiber comp osites structural materials that are in suspension and submerged under water. Researches renew the test water in the tanks is periodically with new sea water to maintain general freshness and to prevent bio

- growth inside the tanks. The facility periodicall y discharges "spent" test sea water through Outfall D

- 001 to the south end of the Whiskey Creek or New

River Sound . Note that only 5% to 10% of the total sea water withdrawn is actually routed into the two test tanks. The majority of the inflow bypasses th e tanks entirely, and flows directly to the outfall. The facility does not treat the spent sea water before discharge due to the historic low level of pollutants being introduced into the waste stream from the test processes, absence of foreign chemical ad ditives used in the study, high proportion of noncontact direct bypass flow, and the very well controlled environment of the laboratory. The test tanks are manually scrubbed down periodically to remove any larger settled and floating debris or excess bio

- g rowth.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls

The facility discharges coastal waters, for which EPA has proposed only chlorophyll

- a criteria. Howev er,

t he facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack of existing permit requirements and the nature of the wastewater (e.g

. , spent and noncontact sea water), it is unlikely that the facility would have reasonable potential under the proposed rule. Thus, incremental compliance costs are likely zero.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 16 

### Miami Seaquarium Tank Flow

- Through Water Discharge Facility

NPDES permit number: FL0169129 Major/minor: Minor
SIC code: 7996 (Amusement Parks)

Indust rial Category: Other Design Flow: 1 8.72 mgd Average Flow: Outfall D

- 001 = 2.88 mgd; Outfall D

- 003 = 3.024 mgd; Outfall D

- 004 = 1.44 mgd; Outfall D

- 005 = 1.44 mgd (average of average monthly values from 2006 through 2010) Receiving Water: Biscayne Bay

Description

Miami Seaquarium is a major marine life exhibition facility that presents a variety of marine wildlife exhibits, animal shows, and other marine ecosystem theme attractions. The facility discharges continuous,

once

- through, tank flow through wat ers from the various marine life habitats and tanks at the seaquarium facility. Intake water for the seaquarium is from Biscayne Bay continuously flows through the habitats and tanks in various sequences, before being returned to the Biscayne Bay through o ne of the seven ocean outfalls. Treatment of the raw supply water is minimal and limited to filtration at the intake to improve the purity of the water, and chlorination prior to the entrances to most of the tanks to control bacteria and algae growth. Ther e is also localized further conditioning of the supply water (e.g. chilling, aeration and additional filtration, etc.) at various tanks to accommodate the unique habitat environment required of

different animals.

Tank flow

- through water normally only conta ins relatively low level of waste loads, that consist of mostly animal waste and by

- product, and other natural foreign matters including animal feed residue and decayed vegetation. As a result, treatment or reduction of waste loads is normally adequately a chieved by the natural dilution, mixing and breakdown effects, associated with the continuous high volume flow

through renewal process; and from nature degradation by exposure to atmosphere. The facility discharges through Outfalls D

- 001 through D

- 007 to B iscayne Bay.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls

The facility discharges wastewater from all of its outfalls to the Southern North Bay (Segment ID SNB) of the Biscayne Bay estuary with annual geometric mean criteria for TN and TP of 0.32 mg/L and 0.010 mg/L, respectively . However, there are no effluent data from which to assess compliance and the facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack of existing permit requirements and the nature of the wastewater (e.g

. , spent and noncontact sea water), it is unlikely that the facility would have reasonable potential under the proposed rule. Thus, i ncremental compliance costs are likely zero.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 17 

### Motiva Enterprises LLC, Port Tampa Terminal

NPDES permit number: FL0000591 Major/minor: Minor
SIC code: 5171 (Petroleum Bulk S tations and Terminals ) Industrial Category: Other Design Flow: Not reported
Avera ge Flow: Outfall D

- 001 = 0.15 mgd; Outfall D

- 002 = 0.08 mgd; (average of maximum monthly values from 2006 through 2010) Receiving Water: Tampa Bay

Description

The facility is a bulk petroleum storage facility that receives refined petroleum products f rom marine vessels and tank trucks. The facility stores the products in above ground storage tanks and distributes them to transport trucks and/or pipelines. The wastewater generated from the facility consists of hydrostatic test tank water and stormwater. The hydrostatic test water is potable city water that is used to fill a storage tank after completion of modifications or repairs to the tank. Tank drawdown will be collected and hauled offsite for treatment and disposal by a registered contractor in acco rdance with relevant regulations.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls

The facility discharges in the Upper Tampa Bay (Segment ID 0903) in the T ampa Bay estuary with annual geometric mean cri teria for TN and TP of 0.4 4 mg/L and 0. 152 mg/L, respectively. However, there are no effluent data from which to assess compliance and the facility does not have existing effluent limits or monitoring requirem ents for TN or TP. Given the lack of existing permit requirements and the nature of the wastewater (e.g

. , potable, hydrostatic test water, and stormwater), it is unlikely that the facility would have reasonable potential under the proposed rule. Thus, incr emental compliance costs are likely zero.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 18 

### Smurfit Stone, Fernandina Beach Containerboard Mill

NPDES permit number: FL0001104 Major/minor: Major
SIC code: 2631 (Paperboard Mills) Industrial Category: Pulp and Paper Design Flow: 37.5 mgd Average Flow: 1 7.1 mgd (average of maximum monthly values from 2006 through 2010) Receiving Water: Lower Amelia River

Description

The facility produces unbleached kraft linerboard through the following processes: wood preparation, pulping, pulp processing and chemic al recovery, and paper and paperboard manufacturing, all of which contribute to production of wastewater. Wastewater treatment consists of a grit chamber, bar screen, primary clarifier, heat exchanger, cooling tower (for noncontact cooling water), UNOX pur e oxygen activated sludge treatment system, and dual secondary clarifiers. The facility dewaters primary and secondary solids using screw presses and belt presses. The facility discharges to Amelia River.

Summary of Effluent Data and Limits

Exhibit C

- 13 summarizes average monthly effluent data for TP from 2006 to 2010.



### Exhibit C

- 13 : Effluent Data Summary, Smurfit Stone

- Fernandina Beach Mill

Pollutant Number of Obs ervations Average Effluent (mg/L) 1 Permit Limit (mg/L) 2

Total phosphorus 19 0.47 None Source: EPA (2011) 1. TP effluent data from 2006 through 2010. Represents average of maximum monthly values. TN data are not available from EPA’s PCS database, however , the average total K jeldahl nitrogen concentration from 2006 to 2010 is approximately 3.8 mg/L (based on 19 observations of the maximum monthly value). Total K jeldahl n itrogen is the s um of organic nitrogen, ammonia, and ammonium, and

can be used to estim ate TN by adding the concentrations of nitrate

- N and nitrite

- N. Lab reports for this facility indicate that nitrate and nitrite concentrations are extremely low. Thus, total K jeldahl nitrogen levels can be used as a proxy for TN for this analysis.

Incremen tal Controls

The facility discharges to the Lower Amelia River (Segment ID 2002) in the St. Mary’s estuary with annual geometric mean criteria for TN and TP 0.27 mg/L and 0.0 45 mg/L, respectively. The discharger has a mixing zone for the calculation of ef fluent limits for dissolved oxygen, copper, nickel, and
temperat ure. The dilution ratio is 32:1 and because the existing water quality data (see discussion in

Section 4 ) indicate that the segment is not likely to be impaired un der the proposed rule, EPA assumed the discharger would have a mixing zone for TN and TP under the proposed rule . P otential effluent limits

could be 8 .6 mg/L for TN and 1.4 mg/L for TP. Existing effluent data indicate that the facility would likely be in c om pliance with projected TN and TP effluent limits. Thus, incremental costs would be zero.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 19 

### Rayonier Performance Fibers, LLC

NPDES permit number: FL0000701 Major/minor: Major
SIC code: 26 1 1 (Pulp Mills) Industrial Category: Pulp and Paper Design Flow: 26.31 mgd Average Flow: 16.8 mgd (average of maximum monthly values from 2006 through 2010) Receiving Water: Amelia River

Description

The facility is a chemical cellulose pulp mill using the sulfite process. Wastewater treatment consists of a grit cha mber, neutralization, primary clarifier, and a 34

- acre mechanical aeration lagoon. The facility discharges treated process wastewater, treated stormwater, rinse water, and regenerate water from the water treatment plant zeolite softening units to Amelia Ri ver only during outgoing tides.

Summary of Effluent Data and Limits

TN and TP data are not available from EPA’s PCS database, however, a laboratory report indicates that in 2009 TN concentrations were approximately 42.2 mg/L and TP concentrations were appr oximately 1.6 mg/L. There are no effluent limits for TN and TP in the current permit.

Incremental Controls

The facility discharges to the Lower Amelia River (Segment ID 2002) in the St. Mary’s estuary with annual geometric mea n criteria for TN and TP of 0 .27 mg/L and 0.0 45 mg/L, respectively. The discharger has a mixing zone for the calculation of effluent limits for dissolved oxygen, copper, nickel, aluminum, iron, lead, and zinc. The dilution ratios range from 2:1 to 8:1 depending on the pollutant.

Thus

, because the existing water quality data (see discussion in Section 4 ) indicate that the segment is not likely to be impaired under the proposed rule, EPA assumed the discharger would have a mixing zone for

TN and TP under the proposed rule . P otential effluent limits could be 2 .2 mg/L for TN and 0. 36 mg/L for TP. Existing effluent data indicate that the facility would likely need to implement controls for compliance with such limits.

However, d ue to the low TN

, there is signif icant uncertainty as to whether the projected effluent limits are feasible to attain . Thus, EPA assumed that the discharger would likely pursue a variance from meeting the projected effluent limits. Because existing TN and TP concentrations are relatively high compared to

levels that can be achieved with cost

- effective treatment controls such as advanced BNR , EPA assumed that the facility would need to reduce TN and TP as a condition of the variance (e.g., lowest levels feasible). Thus, EPA estimated increm ental compliance costs based on installation of advanced BNR.

Capital and O&M unit costs could be $ 1 .3 0 /gpd and $ 385 /MG, respectively. Based on a design flow of 26.31 mgd, total capital costs could be approximately $ 36.0 million. During the last 5 years, a verage maximu m monthly flows h ave been 16.8 mgd . Thus, to estimate O&M costs we used these average flows assuming operation of the treatment units 365 days per year at a cost of $ 2. 5 million. Total annual costs would be $ 5

. 9 million based on annualizing ca pital costs at 7% over 20 years and adding annual O&M.
Exhibit C

- 14 summarizes these costs.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 20 

### Exhibit C

- 14 : Potential Incremental Costs, Rayonier Performance Fibers, LLC

Treatment Controls Capital Costs ($ million) 1 O&M Cost ($ million/year) 2 Annual Costs ($ million/year) 3

Advanced BNR $36.0 $2.5 $5.9 1. Design flow multiplied by unit cost of $1.30 /gpd for advanced BNR

. 2. Average flow multiplied by unit cost of $ 385 /MG for advanced BNR and the number of operating days per year ( 365 days). 3. Capital costs annualized at 7% over 20 years plus annual O&M.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 21 

### Smurfit Stone, Seminole Mill

NPDES permit number: FL0000400 Major/minor: Major
SIC code: 26 1 1 (Pulp Mills) Industrial Category: Pulp and Paper Design Flow: 20 mgd Average Flow: 7.4 mgd (average of maximum monthly values from 2006 through 2010) Receiving Water: Saint Johns River

Description

The facility generates pulp with an onsite OCC recycling pulp oper ation or the purchase of bleached pulp. The Saint John’s River BMAP indicates that the facility changed from a pulp and paper mill to a recycling mill in the 1990s, reducing the volume of effluent. Wastewater treatment consists of grit removal, primary cla rification, and aeration in two unlined holding ponds and an unlined aeration stabilization basin. The facility also includes an onsite landfill and sludge drying beds which process nonhazardous solid waste material from onsite operations and activities. T he facility discharges treated process wastewater and sanitary wastewater to the Saint John’s River.

Summary of Effluent Data and Limits

Exhibit C

- 15 summarizes average monthly effluent data for TN and TP from 2006 to 2010.



### Exhibit C

- 15 : Effluent Data Summary, Smurfit Stone

- Seminole Mill

Pollutant Number of Observations Average Effluent (mg/L) 1 Permit Limit (mg/L) 2

Total nitrogen 31 4.8 None Total phosphorus 14 0.41 None Source: EPA (2011) 1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values. 2. Permit contains an annual load based limit for TN of 74,305 kg/year.
Incremental Controls

The facility discharges to the Sai nt John’s River (Segment ID 1802) with annual geometric mean criteria

for TN and TP of 1.09 mg/L and 0. 1 08 mg/L, respectively. The Saint John’s River BMAP indicates that no additional reductions are needed for compliance with the facility’s WLA (it has alr eady achieved twice as many reductions as needed for the TMDL). Thus, assuming the existing TN TMDL target is adopted as SSAC, there would be no incremental costs associated with TN reductions under the proposed rule.

However, for TP the discharger may ne ed to reduce effluent levels under the proposed rule. Due to a lack

of site

- specific facility operations and treatment data, it is uncertain whether additional improvements or

modifications could be made to reduce TP concentrations. It is also uncertain ho w FDEP would permit the facility under the proposed rule (e.g., limits based on criteria end

- of

- pipe, existing loads, or factoring

in some degree of available dilution). As such, EPA conservatively (i.e., erring on the side of higher costs) assumed that th e discharger would need to meet effluent limits based on criteria end

- of

- pipe. To

meet the potential TP levels, the facility would likely need to install chemical precipitation followed by

filtration

. Capital and O&M unit costs could be $ 0

. 32 /gpd and $ 238 /MG, respectively. Based on a design flow of

20 mgd, total capital costs could be a pproximately $ 6.4 million. During the last 5 years, averageJanuary 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 22 maximum monthly flows have been approximately 7.4 mgd. Thus, assuming operation of the treatment units 365 days p er year , O&M costs could be approximately $0.64 million. Total annual costs would be $ 1.3 million based on annualizing capital costs at 7% over 20 years and adding annual O&M

. Exhibit
C

- 16 summarizes these costs.



### E xhibit C

- 16 : Potential Incremental Costs, Smurfit Stone

– Seminole Mill

Treatment Controls Capital Costs ($ million) 1 O&M Cost ($ million/year) 2 Annual Costs ($ million/year) 3
Chemical precipitation
wi th filtration $6.4 $0.64 $1.3

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration. 2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of operating days pe r year (365 days). 3. Capital costs annualized at 7% over 20 years plus annual O&M.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 23 

### Florida Power and Light, Cutler Plant

NPDES permit number: FL0001481 Major/minor: Major
SIC code: 4911 (Electric Services) Industrial Category: Electric Services Desig n Flow: 313 mgd Average Flow: 134.7 mgd; (average of maximum monthly values from 2006 through 2010) Receiving Water: Biscayne Bay

Description

The facility consists of two gas fired units (Units 5 & 6) with rated capacities 85 megawatts and 160
megawat ts , respectively. The units are normally used only during periods of peak power demand. Once

through condenser cooling water is withdrawn from Biscayne Bay through a common intake canal for the purpose of cooling the steam condensers. The facility does not add chemicals or provide treatment for the

once

- through condenser cooling water, auxiliary cooling water and intake screen wash water. Other wastewater streams generated at the plant including air heater wash, stack wash, dust collector wash, ash sluice, boiler chemical cleaning wastewater, boiler fireside wash, water treatment system wastewater, and boiler blowdown are treated and discharge to the evaporation/percolation pond. Treatment consists of solids settling, neutralization, and chemical precipitati on. The facility also treats wastewater from plant and equipment area floor drains by oil separation prior to discharge to the evaporation/percolation pond. The facility discharges the effluent from this system to the common cooling water discharge canal. The facility discharges intake screen backwash water and non

- equipment area uncontaminated stormwater to Biscayne Bay via a discharge canal; other wastewater streams generated at the plant are treated and discharged to an onsite evaporation/percolation pon d.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls

The facility discharges to the Northern Central Inshore (Segment ID NCI) of Biscayne Bay with TN and

TP annual geometric mean criteria of 0.33 mg/L and 0.008 mg/L, respectively. However, there are no effluent data from which to assess compliance and the facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack of existing permit requirements and the nature of the wastewater (e.g

. , mainly once

- through cooling water), it is unlikely that the facility would have reasonable potential under the proposed rule. Thus, incremental compliance costs are likely zero.January 2012 Appendix C

. Sample Industrial Discharger Analyses

**Draft for Internal Review Only**

**- Do Not Quote or Cite**  C

- 24 

### Progre ss Energy, Bartow Power Plant

NPDES permit number: FL0000132 Major/minor: Major
SIC code: 4911 (Electric Services) Industrial Category: Electric Services Design Flow: Not reported Average Flow: 524 mgd; (average of maximum monthly values from 2006 throug h 2010) Receiving Water: Old Tampa Bay

Description

This facility is a steam electric generating facility consisting of three units with a net rated capacity of 495

MW and uses natural gas and oil for plant fuel. The plant has a once

- through condenser cooling water system that uses water from Tampa Bay. Cooling water is intermittently chlorinated for biofouling control. Wastewater from the facility consists of once

- through cooling water, intake screen washwater, metal cleaning wastes, and low volume was tes which include boiler blowdown, surface and equipment wash down waste, demineralizer regeneration waste, and reverse osmosis reject. The facility dischargers stormwater from plant areas and diked petroleum storage areas; once

- through cooling water, inta ke screen washwater, and stormwater to Tampa Bay; and metal cleaning wastes and low volume wastes to ground water via the onsite evaporation/percolation pond system.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’ s PCS database for this discharger.

Incremental Controls

The facility discharges to Old Tampa Bay (Segment ID 0902) in the Tampa Bay estuary with annual geometric mea n criteria for TN and TP of 0.44 mg/L and 0. 172 mg/L, respectively. However, there are n o effluent data from which to assess compliance and the facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack of existing permit requirements and the nature of the wastewater (e.g

. , mainly once

- through cool ing water), it is unlikely that the facility would have reasonable potential under the proposed rule. Thus, incremental co mpliance costs are likely zero

.January 2012 Appendix D

. Analysis of Downstream Protection Values

**Draft for Internal Review Only**

**- Do Not Quote**  **or Cite** D

- 1 

## Appendix D. Analysis of Downstream Protection Values

As part of the proposed rule, EPA is establishing numeric nutrient criteria for specific locations that flow into estuary segments or coastal waters, referred to as pour points. However, EPA is not proposing implementation procedures associated with these pour points. In addition, FDEP has not proposed similar

cr iteria under its current (2011) proposed numeric nutrient criteria rule. Thus, it is uncertain how such criteria would be implemented in terms of listing impaired waters, TMDL development, and requirements on point and nonpoint sources.

This appendix provi des an analysis of whether the applicable numeric nutrient criteria are being attained at the pour points and the potential implications associated with nonattainment.

D.1. Estimating Attainment of Criteria for Pour Points

Using the same minimum data requi rements (e.g., four data points in one year with at least one data point in summer and winter seasons) and attainment criteria (no more than one exceedance in a three year period), EPA estimated whether the numeric nutrient criteria would be attained at ea ch pour point.

For estuary pour points not in South Florida, EPA used data from any station within 0.5 miles of and within the same WBID as the pour point. Of the 402 individual estuary pour points, EPA estimated that criterion for at least one pollutant is being exceeded at 50 points. However, the downstream estuary segment for only 16 of these 50 pour points is also exceeding the proposed criteria.

For South Florida pour points, EPA used data from the WBID in which the pour point is located because

it di d not have specific location data for the points. This analysis suggests that 12 out of 23 pour points are potentially exceeding the criterion for at least one pollutant. Of these 12, only 4 are associated with marine segments that are not also exceeding t he proposed criteria.

D.2. Potential Implementation Actions

EPA proposed criteria for pour points to protect the estuary and coastal waters downstream of these points. However, the actions that the state would take in cases where the criteria are exceeded at the pour point and not the downstream estuary are uncertain. For example, the state could use data from the pour point analysis to require additional monitoring or investigation of the downstream estuary. The state could also decide to include any WBID containing a pour point exceeding the criteria on its 303(d) list of impaired waters and develop a TMDL to prevent future degradation of the downstream water.

Scenario 1: Pour Point Exceedance Trigger Additional Monitoring

Under a scenario in which an exce edance of the criteria at a pour point results in the state requiring additional monitoring and studies for an estuary, incremental costs are likely minimal. Currently, FDEP

maintains a database of ambient water quality monitoring data for waters across t he stat e, segregating water quality monitoring into three tiers:

 Tier 1 includes regular monitoring, using a probabilistic monitoring design to estimate water quality across the state on the basis of a representative subsample of waterbodies.

 Tier 2 provid es more intensive monitoring of waterbodies identified as impaired or at risk; FDEP implements it through strategic monitoring plans (SMPs) at the state water management district level.

 Tier 3 monitoring is intensive monitoring for the development of TMDLs or the investigation of variances or site specific alternative criteria (SSAC).January 2012 Appendix D

. Analysis of Downstream Protection Values

**Draft for Internal Review Only**

**- Do Not Quote**  **or Cite** D

- 2 Thus, based on the outcome of the pour point attainment analyses, FDEP can shift water quality monitoring locations and resources to areas it deems most necessary or relevant.

Scenario 2: Pour Point Exceedance Result in Impairment Listing

Under a scenario in which exceedances of criteria at the pour points results in FDEP listing the entire WBID in which the pour point is located as impaired, incremental costs would be based on the extent of existing source controls. For example, none of the estuary pour points are in WBIDs located in watersheds for which EPA has not already estimated control costs either under this proposed rule or as part of its inland numeric nutrient criteri a rule. For the South Florida pour points, only one WBID is in a watershed for which EPA has not already estimated control costs. If incremental controls on urban, agriculture, and septic systems are needed in this watershed total annual costs could be app roximately $81,000 (based on the methods for estimating costs described in the report). Exhibit D

- 1 summarizes

these costs.



### Exhibit D

- 1 : Summary of Potential Incremental Costs Asso ciated with DPVs

Source Category Units in Watershed Annual Unit Cost Total Potential Incremental Annual Cost ($/year)
Urban 57.7 acres $ 990 1 $76,100 Agriculture 0 acres 1 NA $ 0 Septic Systems 3 systems $1,300 3 $4,700
Total NA NA $80,800

1. Based on ca pital cost of $6,800 annualized at 7% over 20 years plus O&M equal to 5% of capital. 2. Land use data for the watershed indicate that there are no agriculture acres. 3. Based on capital cost of $6,500 annualized at 7% over 20 years plus O&M equal to $650 p er year.