## -FINAL DRAFT-

C OST OF 

## C OMPLIANCE WITH 

## W ATER 

## Q UALITY 

## C RITERIA FOR 

## T OXIC 

## P OLLUTANTS FOR 

## O REGON 

## W ATERS



### June 2008

Prepared for: Oregon Department of Environmental Quality 811 SW 6th Avenue Portland, OR 97204

and

United States Environmental Protection Agency Office of Water Office of Science and Technology 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460

Prepared by: Science Applications In ternational Corporation 11251 Roger Bacon Drive Reston, VA 20190

GSA Contract Number: GS-10F-0076J SAIC Contract Number: 06-6336-04-0347June 2008 i 

### Table of Contents

Executive Summary .................................................................................................................. ES-1 1. Introduction .............................................................................................................................. 1 -1 1.1 Background .................................................................................................................. 1-1 1.2 Purpose and Scope of the Analysis .............................................................................. 1-1 1.3 Organization of Report ................................................................................................ 1-2 2. Baseline for the Analysis ......................................................................................................... 2-1 2.1 Water Quality Criteria .................................................................................................. 2-1 2.2 Sources of Toxic Polluta nts to Surface Waters ............................................................ 2-4 2.2.1 Municipal and Industrial Dischargers.................................................................. 2-5
2.2.2 Storm Water ......................................................................................................... 2-6 2.2.3 Agriculture ........................................................................................................... 2-6 2.2.4 Forestry ................................................................................................................ 2-7 2.2.5 Mines .................................................................................................................... 2-8 2.2.6 Atmospheric Deposition ...................................................................................... 2-9
2.3 Water Quality ............................................................................................................... 2-9 3. Potential Revised Criteria ........................................................................................................ 3-1 4. Method for Estimating Potential Costs: Point Sources ............................................................ 4-1 4.1 Sample Selection .......................................................................................................... 4-1 4.2 Determining Reasonable Potential ............................................................................... 4-2 4.3 Projecting Effluent Limits ............................................................................................ 4-6 4.4 Identifying Compliance Scenarios ............................................................................... 4-9 4.4.1 Process Optimization ........................................................................................... 4-9 4.4.2 Source Controls .................................................................................................. 4-10 4.4.3 End-of-Pipe Treatment ....................................................................................... 4-16 4.4.4 Alternative Compliance Mechanisms ................................................................ 4-17 5. Method for Estimating Potent ial Costs: Nonpoint Sources ..................................................... 5-1 5.1 Available Data ............................................................................................................. 5-1 5.2 Identifying Exceedances .............................................................................................. 5-5 5.2.1 Antimony ............................................................................................................. 5-5 5.2.2 Beta-BHC ............................................................................................................. 5-6 5.2.3 Mercury ................................................................................................................ 5-6 5.3 Identifying Potential Compliance Actions and Costs .................................................. 5-7 6. Potential Compliance Costs ..................................................................................................... 6-1 6.1 Point Sources ............................................................................................................... 6-1 6.2 Nonpoint Sources and Storm Water ............................................................................ 6-4 6.3 Government Regulatory Costs ..................................................................................... 6-5 6.4 Uncertainties in the Analysis ....................................................................................... 6-6 6.3.1 Data Limitations ................................................................................................... 6-6 6.3.2 Load Reductions .................................................................................................. 6-7 6.3.3 Response to Revised Requirements ..................................................................... 6-7 7. References

............................................................................................................................... . 7-1 Appendix A. Facility Analyses ................................................................................................... A-1 Appendix B. Pollution Prevention Programs and Costs ............................................................. B-1 Appendix C. End-of-Pipe Treatment Controls and Costs ........................................................... C-1

### Appendix D. Variance Procedures Based on Adverse Economic Impacts ................................. D-1 Appendix E. BMPs and Unit Costs for Nonpoint Sources ..........................................................E-1 Appendix F. Sample Facility Resu lts and Statewide Extrapolation ............................................F-1

June 2008 ii

### List of Exhibits

Exhibit ES-1. Summary of Po tential Annual Compliance Costs ............................................. ES-5 Exhibit 2-1. Baseline Human Health Criteria for Pollutants of Concern ...................................2-1 Exhibit 2-2. NPDES Permitted Direct Dischargers in Oregon ................................................... 2-5 Exhibit 2-3. Summary of Oregon’s 2004 303(d) List of Impairments ....................................... 2-9 Exhibit 2-4. Summary of Toxi c Pollutant TMDLs in Oregon .................................................. 2-11 Exhibit 3-1. Human Health Crit eria for Select Consumption Rates: Consumption of Water and Fish

............................................................................................................................... ........3-1 Exhibit 3-2. Human Health Criter ia for Select Consumption Rates: Consumption of Fish Only

............................................................................................................................... .......3-4 Exhibit 4-1. Summary of Sample Facilities ................................................................................ 4-1 Exhibit 4-2. Baseline and Potent ial Revised AWQC for Mercury ............................................. 4-3 Exhibit 4-3. Summary of Reasonable Po tential Results for Sample Facilities ...........................4-5 Exhibit 4-4. Summary of Project ed AMELs for Sample Facilities ............................................ 4-6 Exhibit 4-5. Summary of Proj ected Baseline and Incremental Load Reductions for Sample Facilities

............................................................................................................................... 4-8 Exhibit 4-6. Average Annual Influent and E ffluent Mercury Concen trations, Mt. View SD ..4-13 Exhibit 4-7. Influent Mercury Concentr ations versus Per cent Removal, EBMUD ..................4-13 Exhibit 4-8. Inflow and Infilt ration Rehabilitation Unit Costs ................................................. 4-15 Exhibit 4-9. Summary of Potentia l End-of-Pipe Treatment Technologies ...............................4-16 Exhibit 4-10. Potential Level of Effort to Investigate Technological Feasibility .....................4-20 Exhibit 5-1. Summary of Se lect Ambient Monitoring Data ....................................................... 5-2 Exhibit 5-2. Potential Number of Ex ceedances and Impairments for Mercury ..........................5-6 Exhibit 6-1. Summary of Potential Annual Compliance Costs .................................................. 6-2

June 2008 iii

### Acronyms and Abbreviations

7Q10 Minimum 7-day average stream flow that occurs every 10 years 30Q5 Minimum 30-day average stream flow that occurs every 5 years ACWA Association of Clean Water Agencies ASB Aerated stabilization basin AMEL Average monthly effluent limit AWQC Ambient water quality criterion AWQP Agricultural Water Quality Program AWQMA Agricultural Water Quality Management Area AWQMAP Agricultural Water Quality Management Area Plan ATSDR Agency for Toxic Substances and Disease Registry ADWDF Average dry weather design flow BAF Bioaccumulation factor BBSM Boise Building Solutions Manufacturing, LLC BCF Bioconcentration factor BLS Bureau of Labor Statistics BMP Best management practice BW Human body weight
C b 

### Ambient background concentration
C ce 

### Calculated effluent con centration of the pollutant cfs Cubic feet per second CMZ Concentration of the pollutant at the edge of the mixing zone CAS Columbia Analytical Services CFR Code of Federal Regulations CWA Clean Water Act CCTV Closed circuit television CTUIR Confederated Tribes of the Umatilla Indian Reservation CV Coefficient of variance D Dilution factor DI Drinking water intake DDD Dichlorodiphenyldichloroethane DDE Dichlorodiphenyldichloroethylene DDT Dichlorodiphenyltrichloroethane DESP Dry electrostatic precipitator DHS Department of Health Services EBMUD East Bay Municipal Utility District EPA Environmental Protection Agency EQC Environmental Quality Commission f d 

### Translator to convert dissolved methylmercury into total mercury FI Human fish consumption FPA Forest Practices Act FPR Forest Practice Rules ft foot FTE Full time equivalent

June 2008 iv

### GSA General Services Agreement gpd grams per day IDEQ Idaho Department of Environmental Quality I&I Inflow and infiltration LAC Local Advisory Committee MCL Maximum Contaminant Level MDEL Maximum daily effluent limit MDL Method detection limit MEP Maximum extent practicable MPPA Minnesota Pollution Prevention Agency mgd million gallons per day MS4 Municipal separate storm sewer system MWRA Massachusetts Water Resources Authority MWMC Metropolitan Wastewat er Management Commission NRC Neilson Research Corporation ng/l nanograms per liter NPDES National Pollutant Discharge Elimination System NPL National Priorities List OAR Oregon Administrative Rules ODA Oregon Department of Agriculture ODEQ Oregon Department of Environmental Quality ODF Oregon Department of Forestry ODHS Oregon Department of Health Services OSA Orphan site account OTA Office of Technical Assistance PCBs Polychlorinated biphenyls PCS Permit compliance system PCE Tetrachloroethylene P2 Pollution prevention PAH Polycyclic aromatic hydrocarbons POTW Publicly owned wastewater treatment work QL Practical quantification level PSA Public service announcement PVC Polyvinylchloride PWB Portland Water Bureau PWSP Process water storage pond q1* Cancer potency factor Q b 

### Ambient flow Q e 

### Effluent flow RCO-1 Regenerative cat alytic/thermal oxidizer RfD Reference dose RP Reasonable potential RPA Reasonable potential analysis RSC Relative source contribution RWQCP Regional Water Quality Control Plant SD Sanitation district

June 2008 v

### SP/OWW Settling pond/open water wetland SWCP Storm water pollution control plan SWMP Storm water management program TMDL Total maximum daily load TRC Tissue residual concentration UCB University of California at Berkeley μg/L micrograms per liter WQBEL Water quality based effluent limit WQC Water quality criterion WQS Water quality standards

June 2008 viJune 2008 Executive Summary ES-1 

## ES. Executive Summary

The Oregon Department of Environmental Qualit y (ODEQ) is considering revising the fish consumption rate for calculating water quality criter ia applicable to waters in the state. This report provides estimates of the potential incremen tal compliance actions a nd costs that may be associated with such a change to the state’s water quality standards (WQS).

ES.1 Background

In May 2004, the Oregon Environmental Qua lity Commission (EQC) adopted revisions to Oregon Administrative Rules (OAR) covering wate r quality criteria fo r toxics (OAR 340-041 - 0033). The EQC revised the representative fish consumption rate for deriving human health criteria from 6.5 grams per day (gpd) to 17.5 gpd based on EPA (2000a) guidance. On July 8, 2004, ODEQ submitted the revised toxics criteria to EPA Region 10 for review and approval. The more stringent criteria took effect on February 15, 2005 before EPA Region 10 approval (those criteria that are less st ringent than the existing criteri a cannot be implemented without EPA approval). However, the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) and other tribes objected to the re vised criteria on the basis that the fish consumption rate does not account for higher fish consuming populations, wh ich include Tribal members. As a result, ODEQ is considering adopting a more protective fish consumption rate for calculating revised human health criteria.

ES.2 Scope of Analysis

The purpose of this analysis is to identify, usi ng available water quality and discharge data and information, the potential incremental complia nce actions and costs that publicly owned wastewater treatment works (POTWs) and industr ial point source dischargers may incur as a result of potential revised criteria. These im pacts may occur as a result of changes to the National Pollutant Discharge Elimination System (NPDES) permits for these facilities to incorporate revised water quality based effluent limits (WQBELs). Because ODEQ has yet to implement WQBELs reflecting existing criteria for toxic pollutants, we also identify the level of controls and costs that would be needed in the absence of any revisions to the fish consumption rate. Due to time and resource constraints, incl uding the large number of pollutants of concern and limited monitoring data, the es timates of statewide compliance costs reflect the extrapolation of results for a small sample of dischargers.

Although the focus of this analysis is compliance costs for wastewat er point sources, the revised standards may also result in a need for incr emental controls by municipal storm water and nonpoint sources discharging to surface waters. Ho wever, the data and information needed to evaluate potential control needs is more limited. Thus, we identify the types of controls and costs that may be incurred for these sources but do not develop stat ewide cost estimates.

For changes to water quality criteria within an existing water quality standards and NPDES permitting program, compliance costs likely repres ent the major component of total potential social costs. There may be some incremental regulatory program costs under the higher fish consumption rates associated with an increa sed number of impaired waters and TMDL

### development. However, for the most part, data are not sufficient to estimate these government

costs.

Social costs will be accompanied by the social benefits resulting from the control actions. Similarly, adverse economic impacts (municipa l and industrial expenditures financed through user fees and profits) will be accompanied by increased employment, in comes, revenues, and profits to sectors supplying co mpliance technologies and servi ces (which may be within or external to Oregon). The scope of this anal ysis is limited to an evaluation of potential compliance costs; this report does not provide estimates of potentia l benefits of revised standards or an economic impact analysis.

ES.3 Baseline for the Analysis

OAR 340-041-0033, Table 33A and Table 20 provide existing water qual ity criteria for the protection of human health based on consump tion of water and organisms (e.g., fish) and organisms only. ODEQ established the crit eria in Table 33A in 2004 based on EPA’s recommended national fish consumption rate of 17.5 gpd. Only those criteria in Table 33A more stringent than the previous criter ia in Table 20 are applicable; those less stringent are not to be implemented in NPDES permits until ODEQ receives EPA approval.

Toxic pollutants can be introduced to surface water through point sources (e.g., municipal and industrial effluents), storm water discharges , and nonpoint sources (e.g., agricultural runoff, forestry, mines, and atmospheric deposition). Point source and storm water discharges are regulated under the NPDES permit program. However, in Oregon, these permits do not currently include WQBELs reflect ing the baseline human health cr iteria. Nonpoint sources are primarily controlled through vari ous management plans and policies and TMDL load allocations, although these baseline requireme nts to attain existing criter ia (including TMDLs for nontoxic pollutants that could result in re duced levels of toxics) have not been fully implemented. Thus, even in the absence of revised fish consumption rates for calculating human health criteria, some dischargers will need to take actions to comply with existing criteria.

ES.4 Potential Revised Criteria

ODEQ is considering several revised fish c onsumption rates for calculating human health criteria, including 63.2 gpd, 113 gpd, 175 gpd, 389 gpd, and 620 gpd. For most pollutants, revising the fish consumption rate would result in criteria more stringent than the existing baseline criteria (exceptions in clude nickel, benzene, and chloro form, among others). For some pollutants, the change in fish consumption rate will not have an incremental impact on projected effluent limits compared to baseline criteria b ecause both baseline and revised criteria are below applicable quantification limits (QLs; the levels to which dischargers have to reduce effluent concentrations). Nevertheless, there are 91 pol lutants with baseline a nd revised human health criteria more stringent than the ex isting aquatic life criteria.

June 2008 Executive Summary ES-2

### ES.5 Method for Evaluating Effect on Point Sources

Compliance costs for municipal and industrial poin t sources may result from changes to NPDES permit requirements. To evaluate the potential e ffect of the potential re vised criteria on NPDES permit conditions and compliance actions for wastew ater point sources, we evaluated available effluent and ambient data for a sample of facili ties. We first evaluated compliance with baseline criteria by conducting a reasonabl e potential analysis (RPA), estimating load reductions, and determining controls (or alternative compliance measures) and costs needed for compliance. Then, we evaluated the incremental reductions th at would be needed under the revised criteria, and estimated incremental compliance actions and costs.

ODEQ (2005) procedures provide permit write rs instructions for determining whether dischargers have RP to cause or contribute to an exceedance of WQS, and how to calculate effluent limits for those pollutants with RP. We used these procedures in determining RP and effluent limits under the baseline as well as th e revised criteria, alt hough there is uncertainty regarding implementation procedures that may acco mpany a revised fish consumption rate. For mercury, we used EPA procedures and default valu es for translating the fish tissue criterion into a water column number for implementa tion into permits (U.S. EPA, 2001).

To identify potential compliance actions, we eval uated likely sources of the pollutants in the effluent and the effectiveness of different methods to reduce effluent concentrations. Analysis of the available data for a small sample of facilities indicates that there are likely to be exceedances of projected effluent limits for 4,4’-DDT, alpha -BHC, arsenic, bis(2-et hylhexyl) phthalate, dioxin, and mercury. There are a nu mber of potential alternatives for compliance with effluent limits for these pollutants, including:

• 

### Optimizing treatment processes (e.g., adding chemicals to increase flocculation or filtration efficiency) to increase pollutant removal efficiencies

• 

### Source control (e.g., pollution prevention program, inflow and infiltration reductions, more stringent pretre atment standards)

• 

### Installing end-of-pipe treatment technology (e .g., reverse osmosis, granular activated carbon, or chemical precipitation)

• 

### Alternative compliance mechanisms (e.g., site -specific criterion, TM DL, or variance).

Dischargers will pursue the lowest cost means of compliance with effluent limits. However, for the potential revised criteria, technical feasibility is also an issue. For many pollutants, the lowest levels achievable through end-of-pipe treatm ent are highly uncertain due to the fact that no other dischargers have been requ ired to treat to such low levels and performance data are notavailable. Thus, due to the uncertainty of achievable effluent levels, we did not identify any endof-pipe treatment technologies cap able of producing the necessary effluent concentrations on a consistent and reliable basis. In addition, even for technologies that c ould in theory result in compliance, other factors such as disposal of re sidual streams and very high costs per pound of pollutant removed may render such solutions infeasible, especial ly at municipal facilities. Hence, there may be a need for alternative compliance mechanisms.

For example, mercury and arsenic are the two main pollutants of concern for the sample facilities we evaluated. There are currently no proven end- of-pipe treatment technol ogies that can achieve

June 2008 Executive Summary ES-3

### low mercury levels (e.g., <10 ng/L) on a consistent basis. Pollution prevention (P2) or source control is a cost-effective means of reducing merc ury in wastewater effluents. However, there could be some maximum level of effort beyond which a P2 program would not provide additional reductions and a discha rger may need to pursue alte rnative compliance mechanisms such as a variance.

For arsenic, we estimated a range of actions and costs that included intake credits, best management practices, inflow and infiltration (I &I) reduction programs, and variances. Since the source in municipal wastew ater may be from contaminated groundwater leaking into the sewer system, I&I controls might enable compliance with baseline and re vised criteria. We estimated the potential cost of such actions based on unit costs from a consulting firm specializing in I&I redu ction programs. However, such a scenario may be unlikely for compliance with WQBELs for arsenic alone due to the fact that I&I reduction may be needed for other reasons (reduce flow to treatment plant, which reduces treatment costs, and to reduce sewer overflows). Indeed, state infrastructure needs include I&I reduction at a number of municipal systems (OECDC, 2007).

Thus, due to the uncertainties associated with estimating compliance act ions and costs, we included a range of costs based on the most likely compliance scenarios.

ES.6 Method for Evaluating Effect on Nonpoint Sources

Unlike point sources, ODEQ typically does not require nonpoint sources and municipal storm water dischargers to achieve numeric WQBELs fo r human health pollutants. The regulatory baseline for evaluating the potenti al impact of the revised criter ia includes some requirements for nonpoint sources and storm water dischargers to impl ement BMPs and load allocations as part of TMDLs. ODEQ has developed TMDLs for a num ber of toxic pollutants already and will be developing TMDLs for others. However, the pollutant loading reductions and discharge concentrations that will be achieved through base line BMPs is uncertain. Thus, there is also uncertainty in the extent of incremental contro ls that could be requi red under the potential revised criteria.

Instream monitoring data can be used to assess th e impact that a change in the fish consumption rate may have on attainment of water quality cr iteria and thus, control of potential nonpoint sources. Although not representative of all su rface waters, ODEQ’s Laboratory Analytical Storage and Retrieval (LASAR) database contai ns water quality monitoring data for the pollutants of concern. LASAR contains 3,889 water column and 676 fish tissue observations (for mercury) collected between 1997 and 2007 from locations other than point source outfalls for which there is either a reported value or detection limit.

The LASAR data indicate that most of the polluta nts with detected values have concentrations that exceed the baseline criteria (the exception is nickel, for which potential revised criteria are less stringent than baseline criter ia). Thus, source controls ar e necessary in the absence of revisions to the fish consumption rate. For antimony, beta-BHC, and merc ury, the percent of the data that exceeds the criteria in creases with increasing consump tion rates (e.g., by a factor of 3 for antimony between baseline crite ria and criteria based on the hi ghest consumption rate). In

June 2008 Executive Summary ES-4

### addition, there may be other pollutants exceeding baseline and revised water quality standards for which detection levels are too high or da ta are unavailable. N onpoint sources and storm water may be at least partially responsible for these potential impairments.

ES.7 Results

Costs for compliance with baseline criteria incl ude costs associated with implementation of existing permit limits, plans, and policies that reflect existing criteria. Incremental costs associated with compliance with the potential revi sed criteria represent th e costs of any actions or controls above and beyond those need ed to meet baseline requirements.

Point Source Costs



### Exhibit ES-1 provides a summary of the potential tota l and incremental (i.e., above and beyond those needed for compliance with baseline standa rds) annual statewide costs, both with and without the costs for I&I controls to reduce arse nic in municipal sewer systems. In addition, one-time expenditures associated with variance applications could range from $1.43 million to $7.05 million under the baseline; incremental vari ance-related expenditures could range from $0.59 million to $2.68 million under revised criteria.

Exhibit ES-1. Summary of Potential A nnual Compliance Costs (millions of $2007)

Total Incremental 1 Scenario With I&I Costs 2 No I&I Costs With I&I Costs 2 No I&I Costs Baseline $3.62 - $29.7 $3.62 - $3.92 NA NA 63.2 gpd $3.69 - $29.8 $3.69 - $4.04 $0.075 - $0.13 $0.075 - $0.13 113 gpd $3.96 - $30.1 $3.96 - $4.31 $0.35 - $0.40 $0.35 - $0.40 175 gpd $3.96 - $31.0 $3.96 - $4.36 $0.35 - $1.32 $0.35 - $0.45 389 gpd $4.46 - $31.6 $4.46 - $4.86 $0.85 - $1.82 $0.85 - $0.95 620 gpd $4.46 - $31.6 $4.46 - $4.86 $0.85 - $1.82 $0.85 - $0.95 NA = Not applicable 1. Represents the difference between total annual cost and bas eline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria). 2. High estimate includes cost of I&I to reduce arsenic in municipal sewer systems.



### The costs for minor dischargers ar e highly uncertain because there is a lack of data to evaluate effluent quality. For municipal minors, ODEQ ( 2005) indicates that only domestic sources with a dry weather design flow greater than 1 mgd must sample for toxic pollutants. Thus, unless this requirement changes, it is unlikely that minor municipal dischargers would incur costs for compliance with the baseline or revised criteria . For minor industrial dischargers, ODEQ (2005) indicates that industrial discharg ers subject to effluent limitati on guidelines would be required to monitor for toxic pollutants. However, effluent toxics data from one of the sample facilities (Oregon Steel Mills) indicates that most toxics are not likely to be presen t at levels of concern, and those that may be (e.g., ar senic) may not contribute si gnificantly to receiving water concentrations, resulting in BMP requirements rather than numeric WQBELs. Thus, costs to minor industrial facilities for compliance with baseline or revised criteria could be minimal depending on state implementation procedures.

June 2008 Executive Summary ES-5

### Nonetheless, one potential pollutant of concern for minor municipal dischargers is mercury. Under the 620 gpd alternative fish consumption rate, the revised mercury criterion could be below the detection level of 0.005 μg/L. Due to its ubiquitous nature in the environment (e.g., mercury is found in many household products and can be excreted in human waste because of mercury in dental fillings), it may be unlikely that any municipal discharger would be able to consistently achieve nondetect e ffluent levels without implementation of controls. Thus, if ODEQ were to require monitoring by minor municipals under such a scenario, these facilities might need to implement P2 for compliance. Annual P2 costs might range from 10% to 50% of the P2 cost for small major f acilities, with the range reflec ting the potential for piggybacking on the efforts of other nearby facilities. Thus , total annual costs for all 157 minor municipal dischargers for compliance with mercury criteria based on consumption of 620 gpd of fish could range from $0.8 million to $3.9 million. This may be a conservative estimate given the current lack of monitoring requirements for toxic pollutant s for municipal dischargers less than 1 mgd.

Indirect dischargers to municipa l wastewater treatment plants c ould also incur costs associated with the baseline and revised criteria if the m unicipality imposes more stringent pretreatment standards or requirements on these dischargers in an effort to re duce effluent loads. However, indirect dischargers of pollutants for which a municipal wastewater tr eatment plant would not have RP or need to reduce effluent loads would not be affected. To account for these potential costs, we estimated costs to indirect discharger s to municipal wastewater treatment plants under a mercury P2 program (discussed in Appendix B) . For other pollutants, identifying groups of indirect dischargers likely to be contributing to the influent lo ad at the treatment plant is more difficult because the pollutants are no longer activ ely used (e.g., legacy pesticides), could be formed as a byproduct of numerous processes (e.g., dioxin), or there is a lack of site-specific information available for each discharger to id entify where the pollutant is originating [e.g., arsenic, bis(2-ethylhexyl) phthalate ]. Thus, it is not possible to es timate pretreatment or P2 costs to indirect dischargers for po llutants other than mercury with out specific information on the types of industrial discharg ers in each service area.

Nonpoint Source and Storm Water Costs



### Under the baseline, control costs for nonpoint so urces (e.g., agricultural and forest operations; contamination from historic mining sites) and municipal storm water include those needed to reduce instream pollutant levels to baseline criteria or TMDL targets. Existing regulatory programs have not been fully implemented, and the extent of implementation efforts is uncertain. Thus, the additional controls needed for comp liance under the baseline cannot be estimated. There are, however, indications that baseline compliance costs for nonp oint sources and storm water discharges could be substantial. For ex ample, given the impairment status of waters throughout the state for mercury based on existing data and the fact that poi nt source dischargers are not likely to be significant sources of mercury to those wate rs, it is possible that nonpoint source controls are needed to improve wate r quality to meet baseline criteria.

There could also be incremental costs to nonpoi nt and storm water sources associated with meeting new or revised load allocations. However, because baseline programs have not yet been fully implemented, it is uncertain whether some in cremental level of cont rol would be necessary for compliance with the revised criteria. For any s ituation in which controls beyond those required under the baseline are neces sary, controls could include:

June 2008 Executive Summary ES-6• 

### Agricultural and forest lands – sediment and erosion controls beyond those specified under existing state and fede ral regulations and plans

• 

### Mining – cleanup and remediation includi ng excavation and onsite capping of contaminated soils, capping of onsite solid waste mining debris, regrading of tailings to mitigate mass wasting and off-site migration, and abatement and mitigation of physical hazards

• 

### Storm water discharges – incr eased or additional nonstructura l BMPs (e.g., institutional, education, or pollution prevention practices de signed to limit generation of runoff or reduce the pollutants load of runoff); and structural controls (e.g., engineered and constructed systems designed to provide water quantity or quality control).

Government Regulatory Costs



### Identifying the full scope of regulatory program costs associated with implementing existing criteria and programs is outside th e scope of this analysis. There is also substantial uncertainty associated with identifying any incremental impact of revised criteria, since the baseline is not fully implemented. Finally, there is uncertainty regarding the attributi on of regulatory program expenditures to criteria revisions. However, as the fish consumption rate increases, the applicable human health criteria decrease, which could result in more stringent and infeasible permit limits for point sources, and incremental impairments and need for TMDL development under the revised criteria.

If dischargers pursue variances for compliance wi th permit limits for mercury, arsenic, bis(2- ethylhexyl) phthalate, DDT, alpha-BHC, and di oxin, ODEQ costs associated with application review may range from $159,000 under the baseline to $65,000 under the revised criteria. For the most part, data are too limited to identify incremental impairments. For one pollutant, mercury, available ambient monitoring data indi cate a potential increase of 9 TMDLs at a consumption rate of 63.2 gpd and 21 TMDLs at a c onsumption rate of 620 gpd. If, for example, TMDL development costs range from approximately $26,000 to $500,000 (EPA, 2001b), this implies an increased level of expenditure of between $0.23 million and $4.5 million for mercury at a consumption rate of 63.2 gpd, and $0.55 million to $10.5 million for mercury at a consumption rate of 620 gpd. Note that the va riance application review and TMDL development costs would not be incurred in any single year; ra ther, the cost would be spread out over several years (e.g., 5 or 10 year time period).

ES.8 Uncertainties in the Analysis

There are a number of uncertainties in the analys is associated with data limitations, potential pollutant load reductions achievable, and how dischargers would respond to potential revised requirements and permit conditions that affect the estimated costs.

The lack of available data for both point and nonpoint sources adds uncerta inties to the analysis of potential costs associated with compliance with the revised criteria, including:

• 

### Data are not available for all pollutants or are extremely limited for some of the sample facilities making it difficult to determine whet her the facility is in compliance with baseline standards and whethe r incremental controls woul d be needed for compliance with revised criteria. Thus, costs could be higher or lower than shown.

June 2008 Executive Summary ES-7• 

### Lack of effluent flow data from which to calculate appropriate human health dilution factors which could result in lower dilution ratios than actually available, and thus, potentially higher costs.

• 

### In estimating baseline control costs, facility permits and ev aluation reports do not provide detailed information on the extent of cont rols and activities al ready underway. Thus, baseline costs could be overestimated because facilities may already be implementing controls to address issues such as I&I and P2 programs.

• 

### Lack of available instream m onitoring data prevents the es timation of potential statewide costs associated with reduc tions in pollutant loads fr om nonpoint sources.

• 

### Lack of data regarding pollutant reductions that have already been or are being achieved with the implementation of BMPs to addr ess existing impairments for conventional pollutants such as temperature and dissolved oxygen. Attainment of standards for these types of pollutants could also re sult in attainment of the baseline and revised criteria for toxic pollutants, negating the need for additional controls on nonpoint sources.

There is also uncertainty regarding the polluta nt loading reductions that would result from compliance with baseline and revi sed criteria. As the criteria become more stringent under increasing consumption rates, the feasibility of compliance with revised effluent limitations may decrease for some pollutants (e.g., mercury) that are ubiquitous in the environment and for which end-of-pipe treatment to very low levels is unp roven. If compliance is not feasible, pollutant load reductions may be minimal.

For point sources, we assumed that facilities wo uld pursue the lowest cost option for compliance with either baseline or revised criteria. However, without site-s pecific data and analysis, it is uncertain whether any particular contro l option would guarantee compliance.

In addition, there is uncertainty as sociated with the levels achievabl e with baseline controls. For both point and nonpoint sour ces, we assumed that in some cases baseline controls would result in compliance with revised criteria. It is not clear at which consumption ra tes the criteria would become low enough to warrant additional c ontrols above and beyond those needed for compliance under the baseline, or whether additional reductions are feasible.

June 2008 Executive Summary ES-8June 2008 1. Introduction 1-1 

## 1. Introduction

The Oregon Department of Environmental Qualit y (ODEQ) is considering revising the fish consumption rate for calculating water quality criter ia applicable to waters in the state. This report provides estimates of the potential incremen tal compliance actions a nd costs that may be associated with such a change to the st ate’s water quality standards (WQS).

1.1 Background

The Clean Water Act (CWA) directs states, with oversight by the U.S. E nvironmental Protection Agency (EPA), to adopt WQS to protect the public health and welfare, enhance the quality of water, and serve the purposes of the CWA. Un der Section 303, state WQ S must include: (1) designated uses for all water bodies within their jurisdictions, (2) water quality criteria sufficient to protect the most sensitive of the uses, and (3 ) an antidegradation policy consistent with the regulations at 40 CFR 131.12. The CWA also require s states to hold public hearings once every three years for the purpose of reviewing appli cable WQS and, as appropriate, modifying and adopting standards. The results of this triennial review must be submitted to EPA, and EPA must approve or disapprove a ny new or revised standards.

In May 2004, the Oregon Environmental Qua lity Commission (EQC) adopted revisions to Oregon Administrative Rules (OAR) covering wate r quality criteria fo r toxics (OAR 340-041 - 0033). The EQC revised the representative fish consumption rate for deriving human health criteria from 6.5 grams per day (gpd) to 17.5 gpd based on EPA (2000a) guidance. On July 8, 2004, ODEQ submitted the revised toxics criteria to EPA Region 10 for review and approval. The more stringent criteria took effect on February 15, 2005 before EPA Region 10 approval (those criteria that are less st ringent than the existing criteri a cannot be implemented without EPA approval). However, the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) and other tribes objected to the re vised criteria on the basis that the fish consumption rate does not account for higher fish consuming populations, wh ich include Tribal members. As a result, ODEQ is considering adopting a more protective fish consumption rate for calculating revised human health criteria.

1.2 Purpose and Scope of the Analysis

The purpose of this analysis is to identify, usi ng available water quality and discharge data and information, the potential incremental complia nce actions and costs that publicly owned wastewater treatment works (POTWs) and industr ial point source dischargers may incur as a result of potential revised criteria. These im pacts may occur as a result of changes to the National Pollutant Discharge Elimination System (NPDES) permits for these facilities to incorporate revised water quality based effluent limits (WQBELs). Because ODEQ has yet to implement WQBELs reflecting existing criteria for toxic pollutants, we also identify the level of controls and costs that would be needed in the absence of any revisions to the fish consumption rate. Due to time and resource constraints, incl uding the large number of pollutants of concern and limited monitoring data, the es timates of statewide compliance costs reflect the extrapolation of results for a small sample of dischargers.

### Although the focus of this analysis is compliance costs for wastewat er point sources, the revised standards may also result in a need for incr emental controls by municipal storm water and nonpoint sources discharging to surface waters. Ho wever, the data and information needed to evaluate potential control needs is more limited. Thus, we identify the types of controls and costs that may be incurred for these sources but do not develop stat ewide cost estimates.

For changes to water quality criteria within an existing water quality standards and NPDES permitting program, compliance costs likely repres ent the major component of total potential social costs. There may be some incremental regulatory program costs under the higher fish consumption rates associated with an increa sed number of impaired waters and TMDL development. However, for the most part, data are not sufficient to estimate these government

costs.

Social costs will be accompanied by the social benefits resulting from the control actions. Similarly, adverse economic impacts (municipa l and industrial expenditures financed through user fees and profits) will be accompanied by increased employment, in comes, revenues, and profits to sectors supplying co mpliance technologies and servi ces (which may be within or external to Oregon). The scope of this anal ysis is limited to an evaluation of potential compliance costs; this report does not provide estimates of potentia l benefits of revised standards or an economic impact analysis.

1.3 Organization of Report

This remainder of this report is organized as follows:

Section 2: Baseline for the Analysis – describes the current app licable toxic criteria and ODEQ procedures for implementing th e criteria in NPDES permits, s ources of toxic pollutants to surface waters, water quality impairments from toxic pollutants, and ongoing efforts to reduce and eliminate these impairments.

Section 3: Potential Revised Criteria – outlines the changes to ex isting water qua lity standards based on alternative fish consumption rates.

Section 4: Method for Estimating Potential Costs: Point Sources – describes the method for estimating compliance costs associated with base line and revised criteria for point sources in terms of revisions to NPDES permits.

Section 5: Method for Estimating Potential Costs: Nonpoint Sources – describes the method for identifying compliance costs a ssociated with baseline and revised criteria for nonpoint

sources.

Section 6: Potential Compliance Costs – provides estimates of pot ential costs to comply with the revised water quality standards, and discusses the uncertainties a ssociated with the estimates.

Section 7: References – provides the references used in the analysis.

June 2008 1. Introduction 1-2

### The appendices provide detailed analyses and additional information:

Appendix A: provides data and information on individu al sample facilities, and analyses of potential impacts under th e different scenarios.

Appendix B: describes pollution prevention programs and estimated costs.

Appendix C: provides details for various end-of-p ipe treatment technologies, including estimated costs, where available.

Appendix D: describes the applicable analyses for obtaining a temporary variance from WQBELs based on economic factors.

Appendix E: provides descriptions and costs for best management practices for nonpoint sources and storm water discharges.

Appendix F: summarizes the sample facility results and shows calculations for the extrapolation of statewide costs.

June 2008 1. Introduction 1-3June 2008 2. Baseline for the Analysis 2-1 

## 2. Baseline for the Analysis

This section describes the appli cable baseline for evaluating th e incremental costs associated with potential revised fish consumption rate s for calculating water qua lity criteria, including current water quality criteria, potential sources of the pollutants of concer n, and the current level of impairment in Oregon waters.

2.1 Water Quality Criteria

OAR 340-041-0033, Table 33A, provides existing wa ter quality criteria for the protection of human health based on consumption of water and organisms (e.g., fish) and organisms only. ODEQ proposed the criteria, wh ich are based on EPA’s recomme nded national fish consumption rate of 17.5 gpd, on May 20, 2004. Those criteria th at are more stringent than the previous criteria became effective February 15, 2005. The re maining criteria are not to be implemented in NPDES permits until EPA approves the criteria becau se they are less stringent than the previous criteria. Thus, the previous criteria (OAR 340-041-0033, Table 20) are the applicable baseline criteria for these pollutants.

Exhibit 2-1 shows the applicable baseline criteria fo r toxic pollutants. ODEQ designates all waters (except Bull Run River which has no discha rgers) for the protectio n of both aquatic life and human health. Thus, pollutants for which the a quatic life criteria are more stringent than the human health criteria are not of concern for the analysis because compliance costs will be driven by the more stringent aquatic life criteria.

Exhibit 2-1. Baseline Human Health Criteria for Pollutants of Concern 1 Freshwater Aquatic Life (μg/L) Saltwater Aquatic Life (μg/L) Human Health (μg/L) Pollutant Acute Chronic Acute Chronic Water and Fish Fish Only 1,1,1-Trichloroethane - - - - 18,400 a 1,030,000 a 1,1,2,2-Tetrachloroethane - - - - 0.17 4 1,1,2-Trichloroethane - - - - 0.59 16 1,1-Dichloroethylene - - - - 330 7,100 1,2,4,5-Tetrachlorobenzene - - - - 0.97 1.1 1,2,4-Trichlorobenzene - - - - 35 70 1,2-Dichlorobenzene - - - - 420 1,300 1,2-Dichloroethane - - - - 0.38 37 1,2-Dichloropropane - - - - 0.5 15 1,2-Diphenylhydrazine - - - - 0.036 0.2 1,2-Trans-Dichloroethylene - - - - 140 10,000 1,3-Dichlorobenzene - - - - 320 960 1,3-Dichloropropene - - - - 0.34 21 1,4-Dichlorobenzene - - - - 63 190 2,3,7,8-TCDD (Dioxin)
- - - - 0.000000005 5.1E-09 2,4,5-Trichlorophenol 1,800 3,600 2,4,6-Trichlorophenol - - - - 1.2 a 2.4 2,4-Dichlorophenol - - - - 77 290 2,4-Dimethylphenol - - - - 380 850June 2008 2. Baseline for the Analysis 2-2 

### Exhibit 2-1. Baseline Human Health Criteria for Pollutants of Concern 1 Freshwater Aquatic Life (μg/L) Saltwater Aquatic Life (μg/L) Human Health (μg/L) Pollutant
Acute Chronic Acute Chronic Water and Fish Fish Only 2,4-Dinitrophenol - - - - 69 5,300 2,4-Dinitrotoluene - - - - 0.11 3.4 2,4-Dinitro-o-Cresol - - - - 13.4 765 2-Chloronaphthalene - - - - 1,000 1,600 2-Chlorophenol - - - - 81 150 2-Methyl-4,6-Dinitrophenol - - - - 13 280 3,3’-Dichlorobenzidine - - - - 0.021 0.028 4,4’-DDD - - - - 0.00031 0.00031 4,4’-DDE - - - - 0.00022 0.00022 4,4’-DDT - - - - 0.000024 a 0.000024 a Acenaphthene - - - - 670 990 Acrolein - - - 190 290 Acrylonitrile - - - - 0.051 0.25 Aldrin 3 - 1.3 - 0.000049 0.00005 alpha-BHC - - - - 0.0026 0.0049 Anthracene - - - - 8,300 40,000 Antimony - - - - 5.6 640 Arsenic - - - - 0.0022 a 0.0175 a Arsenic (III) 360 190 69 36 - - Barium - - - - 1,000 - Benzene - - - - 0.66 a 40 a Benzidine - - - - 0.000086 0.0002 Benzo(a) Anthracene
- - - - 0.0038 0.018 Benzo(a) Pyrene
- - - - 0.0038 0.018 Benzo(b) Fluoranthene
- - - - 0.0038 0.018 Benzo(k) Fluoranthene
- - - - 0.0038 0.018 Beryllium - - - - 0.0068 a 0.117 beta-BHC - - - - 0.0091 0.017 Bis(2-Chloroethyl) Ether
- - - - 0.03 a 0.53 a Bis(2-Chloroisopropyl) Ether
- - - - 34.7 a 4,360 a Bis (Chloromethyl) Ether
- - - - 3.7E-09 a 0.00184 a Bis(2-Ethylhexyl) Phthalate
- - - - 1.2 2.2 Bromoform - - - - 4.3 140 Butylbenzyl Phthalate - - - - 1,500 1,900 Cadmium 3.9 a,b 1.1 a,b 43 a 9.3 a 10 - Carbon Tetrachloride - - - - 0.23 1.6 Chlordane 2.4 0.0043 0.09 0.004 0.00046 a 0.00048 a Chloride 860,000 230,000 - - - - Chlorine 19 11 13 7.5 - - Chlorobenzene - - - - 130 1,600 Chlorodibromomethane - - - - 0.4 13 Chloroform - - - - 0.19 a 15.7 a Chlorpyrifos 0.083 0.041 0.011 0.0056 - - Chromium (III) 1,700 a,b 21 0 a,b - - 170, 000 3,433,000June 2008 2. Baseline for the Analysis 2-3 

### Exhibit 2-1. Baseline Human Health Criteria for Pollutants of Concern 1 Freshwater Aquatic Life (μg/L) Saltwater Aquatic Life (μg/L) Human Health (μg/L) Pollutant
Acute Chronic Acute Chronic Water and Fish Fish Only Chromium (VI) 16 11 1,100 50 50 - Chrysene - - - - 0.0038 0.018 Copper 18 a,b 12 a,b 2.9 a 2.9 a - - Cyanide 22 5.2 1 1 140 140 Demeton - 0.1 - 0.1 - - Dibenzo(a,h)Anthracene
- - - - 0.0038 0.018 Dibutylphthalate - - - - 35,000 154,000 Dichlorobromomethane - - - - 0.55 17 Dieldrin 0.24 0.0019 0.71 0.0019 0.000052 0.000054 Diethyl Phthalate - - - - 17,000 44,000 Dimethyl Phthalate - - - - 270,000 1,100,000 Di-n-Butyl Phthalate - - - - 2,000 4,500 Endosulfan 0.22 0.056 0.034 0.0087 62 89 Endosulfan Sulfate - - - - 62 89 Endrin 0.086 0.0023 0.037 0.0023 0.059 0.06 Endrin Aldehyde - - - - 0.29 0.3 Ethylbenzene - - - - 530 2,100 Fluoranthene - - - - 42 a 54 a Fluorene - - - - 1,100 5,300 gamma-BHC (Lindane) 0.95 0.08 0.16 - 0.0186 a 0.0625 a Heptachlor 0.52 0.0038 0.0 53 0.0036 0.000079 0.000079 Heptachlor Epoxide - - - - 0.000039 0.000039 Hexachlorobenzene - - - - 0.00028 0.00029 Hexachlorobutadiene - - - - 0.44 18 Hexachlorocyclohexane - - - - 0.0123 0.0414 Hexachlorocyclopentadiene - - - - 40 1,100 Hexachloroethane - - - - 1.4 3.3 Ideno(1,2,3-cd)Pyrene
- - - - 0.0038 0.018 Iron - 1,000 - - 300 - Isophorone - - - - 35 960 Lead 82 a,b 3.2 a,b 140 a 5.6 a 50 a - Malathion 0.1 - 0.1 - - - Manganese - - - - 50 a 100 a Methyl Bromide - - - - 47 1,500 Methylene Chloride - - - - 4.6 590 Mercury 2.4 0.012 2.1 0.025 0.144 0.146 Methoxychlor - 0.03 - 0.03 100 - Methylene Chloride - - - - 4.6 590 Methylmercury - - - - - 300 μg/kg 2 Mirex - 0.001 - 0.001 - - Monochlorobenzene - - - - 488 a - Nickel 1,400 a,b 160 a,b 75 a 8.3 a 13.4 a 100 a Nitrates - - - - 10,000 - Nitrobenzene - - - - 17 690

### Exhibit 2-1. Baseline Human Health Criteria for Pollutants of Concern 1 Freshwater Aquatic Life Saltwater Aquatic Human Health (μg/L) (μg/L) Life (μg/L) Pollutant
Acute Chronic Acute Chronic Water and Fish Fish Only Nitronsamines - - - - 0.0008 1.24 N-Nitronsodibutylamine - - - - 0.0063 0.22 N-Nitrosodiethylamine - - - - 0.0008 1.24 N-Nitrosodimethylamine - - - - 0.00069 3 N-Nitrosodi-n-Propylamine - - - - 0.005 0.51 N-Nitrosodiphenylamine - - - - 3.3 6 N-Nitrosopyrrolidine - - - - 0.016 34 N-Nitrosodi-n-Propylamine - - - - 0.0050 0.51 Parathion 0.065 0.013 - - - - Pentachlorobenzene - - - - 1.4 1.5 Pentachlorophenol 20 a 13 a 13 7.9 0.27 3 Phenol - - - - 3,500 a 1,700,000 Phosphorus Elemental - - - 0.1 - - PAHs - - - - 0.0028 a 0.0311 a PCBs 2 0.014 10 0.03 0.000064 0.000064 Pyrene - - - - 830 4,000 Selenium 260 a 35 a 410 a 54 a 10 a 4,200 Silver 4.1 a,b 0.12 a 2.3 a - 50* - Sulfide-Hydrogen Sulfide - 2 - 2 - - Tetrachloroethylene - - - - 0.69 3.3 Thallium - - - - 0.24 0.47 Toluene - - - - 1,300 15,000 Toxaphene - - - - 0.00028 0.00028 Trichloroethylene - - - - 2.5 30 Vinyl Chloride - - - - 0.025 2.4 Zinc 120 a,b 110 a,b 95 a 86 a 7,400 26,000 Source: OAR 340-041-0033, Table 20 (denoted with an “a”) and Table 33A. a = indicates Table 20 criteria. b = criteria calculated based on 100 mg/L hardness. 1. Effective human health criteria include criteria from OAR 2340-041-0033 Table 33A that became effective February 2005 (revised criteria that became effective without EPA approv al) and Table 20 (original criteria since ODEQ’s 2004 proposed criteria are not effective pending EPA approval). 2. Criterion based on concentration of pollutant in fish tissue.



### Note that for Section 303(d) listings, the revise d criteria based on a fish consumption rate of 17.5 gpd cannot be used until ODEQ receives EP A Region 10 approval for the revisions.

2.2 Sources of Toxic Pollutants to Surface Waters

Toxic pollutants can be introduced to surface water through natural and human activities, including municipal and industrial effluents, storm water discharges , agricultural runoff, forestry (chemical application), mines, and atmospheric deposition.

June 2008 2. Baseline for the Analysis 2-4

### 2.2.1 Municipal and Industrial Dischargers



### EPA’s Permit Compliance System (PCS) database indicates that there are 390 municipal and industrial NPDES permitted dischargers in Oregon. Exhibit 2-2 shows the number of facilities by type (major/minor) and industria l category specified in PCS.

Exhibit 2-2. NPDES Permitted Direct Dischargers in Oregon Category 1 Majors Minors Agricultural Production – Crops - 1 Fishing, Hunting, and Trapping - 5 Metal Mining - 1 Nonmetallic Minerals - 5 Food and Kindred Products 2 11 Lumber and Wood Products 1 29 Paper and Allied Products 11 1 Chemicals and Allied Products 2 5 Stone, Clay, and Glass Products - 4 Primary Metal Industries 4 2 Fabricated Metal Products - 2 Industrial Machinery and Equipment - 1 Electronic and Other Electronic Equipment 1 3 Transportation Equipment - 2 Measuring, Analyzing, and Controlling Instruments - 1 Water Transportation - 1 Transportation by Air - 2 Electric, Gas, and Sanitary Services; except 4952 - 17 Sewerage Services (Municipal Wastewater) 49 157 Wholesale Trade - 8 Real Estate - 4 Hotels and Other Lodging Places - 3 Miscellaneous Repair Services - 1 Educational and Social Services - 6 Museums, Botanical, Zoological Gardens - 1 Engineering, Accounting, Research, Management, and Related Services - 1 Public Administration - 2 Nonclassifiable Establishments - 1 Not specified in PCS - 36 Total 70 313
“-“ = None. 1. Based on 2-digit standard industrial classification (SIC) code. Source: U.S. EPA (2007); Accessed June 8, 2007.



### ODEQ issues general NPDES permits for 15 different discharger categories, including cooling water/heat pumps, filter backwash, fish hatcheries, log ponds, boiler blowdown, seafood processing, storm water from gravel mining, c onstruction that distur bs one acre or more, industrial storm water, oily stor m water runoff, oil/water separators, tanks cleanup and treatment of groundwater, washwater, and noncontact geotherm al water. Currently there are no effluent limits or monitoring requirements for any of the pollutants of concern in these permits.

June 2008 2. Baseline for the Analysis 2-5

### 2.2.2 Storm Water



### Storm water discharges are gene rated by precipitation and runoff from land, pavements, building rooftops, and other surfaces. Storm water from municipal and industrial areas may contribute toxic pollutants to surface waters. ODEQ regul ates storm water discharges from municipal separate storm sewer systems (MS4s) through ge neral permits. The MS4 permits require the discharger to develop and implement a storm water management program (SWMP), with the goal of controlling pollutant discharges to th e maximum extent practicable (MEP). ODEQ interprets the MEP requirement to require all co ntrols that are reasonable and available. The management programs specify the best management practices (BMPs) that will be used in the following areas: public education and outreach; public participat ion and involvement; illicit discharge detection and elimin ation; construction runoff c ontrol; post-construction runoff control; and pollution prevention and good housekeeping. Permittees implement BMPs through an adaptive management or iterative approach.

ODEQ has issued 6 area-wide “Phase I” MS4 perm its. Phase I MS4s are those systems serving populations greater than 100,000. “Phase II” (or “small”) MS4s are those systems serving municipalities with populations less than 100,000 located within Census Bureau-defined urbanized areas. There are 18 cities and countie s in Oregon required to obtain “Phase II” MS4 permits. Federal regulations also provide states the discretion to requir e other MS4s outside of urbanized areas to apply for a permit.

Industrial dischargers, includi ng those engaged in manufactur ing, transportation, mining, and steam electric power industries, scrap yards, landfills, certain sewage treatment plants, and hazardous waste management facilities may have storm water requirements in their NPDES permits. ODEQ requires industrial storm water dischargers to develop a Storm Water Pollution Control Plan (SWPCP) that includes a monitoring plan and discussion of the site controls that the discharger will implement to prevent storm water pollution (ODEQ, 2004).

2.2.3 Agriculture



### Pesticides applied to agricultural lands can re ach surface waters through irrigation return flow, storm water runoff, and erosion of soils. Or egon’s Department of Agriculture’s (ODA) Agricultural Water Quality Program (AWQP) is charged with assisting the agriculture industry in reducing pollution from agri cultural sources. The legal foundation of the AWQP is the Agricultural Water Quality Management Ac t (SB1010) created in 1993 (ODA, 2007). SB1010 provides the department with enforcement author ity to deal with situations where corrective action is needed, but is not volunt arily being taken by an operator. In those cases where a farmer or rancher refuses to take action, the law aut horizes the department to require corrective measures or use civil penalties to address the issue.

The ODA has identified 39 watershed-based agri cultural water quality management areas (AWQMA). Within each AWQMA is a local advisory committ ee (LAC) consisting of water quality specialists, local farmers, ranchers, and community leaders. All 39 LACs have approved Agricultural Water Quality Management Ar ea Plans (AWQMAP) along with enforceable administrative rules to ensure all landowners do their part to avoid a nd resolve water quality

June 2008 2. Baseline for the Analysis 2-6

### problems. AWQMAPs must describe a program to achieve water qualit y standards. AWQMA rules must be sufficient to assure that landowne rs will prevent and cont rol water pollution from agricultural activities and soil erosion.

Agricultural sediment and erosion controls may be required to meet total maximum daily loads (TMDLs) for several toxic pollutants. For exampl e, elevated fish tissue concentrations of DDT and dieldrin, now banned pesticides, exist in the Snake River. In developing the Snake River – Hells Canyon TMDL, ODEQ assumed that existi ng loadings of these compounds occur solely from legacy application or contamination ( ODEQ and IDEQ, 2003). The implementation plan for the TMDL recommends sediment/erosion control practices to meet the load allocation defined in the TMDL. These controls will be outlined and enforced in AWQMAPs for Owyhee, Malheur, Burnt, Powder, and Wallowa basins (ODEQ and IDEQ, 2003).

Elevated fish tissue concentrations of mercur y exist in the Willamette Basin. The Willamette Basin Mercury TMDL states that relative contribution of mercury to the basin from erosion of native mercury-containing soils is approximate ly 48% (ODEQ, 2006b). ODEQ is implementing an incremental phased approach for this TMDL with plans to update current recommendations in 2011. As part of the update, ODEQ plans to furt her investigate the rela tive contributions of mercury from various sources (ODEQ, 2006c). Th e current implementation plan offers sector level, general recommendations to reduce the leve l of mercury in the Willamette River system. ODEQ recommends updating appli cable AWQMAPs to include strategies for minimizing soil erosion and controlling the use of mercury containing products.

2.2.4 Forestry



### Forest pesticides, which include herbicides, f ungicides, insecticides, and rodenticides, are commonly used to aid in the reestablishment, growth, and survival of forest tree species throughout Oregon (ODF, 2000). The Oregon Department of Forestry (ODF) regulates forest operations on nonfederal forestland through the Forest Practice Rules (FPR). The legal foundation for the FPRs is the Oregon Forest Practices Act (FPA). ODF administers forest practice chemical rules to ensure that chemicals used on forestland do not en ter surface waters in quantities that would degrade wate r quality or be harmful to the overall maintenance of terrestrial wildlife or aquatic lif e (ODF, 2007a). FPRs related to chemical applications require:

• 

### Written notification to ODF at least 15 days before conducting a chemical application

• 

### Operators (landowners, loggers, and pesticid e applicators) must maintain chemical handling equipment in a leak proof condition

• 

### Whenever water is taken from any stream or water impoundment for use in mixing chemicals, the operator must prevent chemicals from entering the water

• 

### Operator must conduct mixing, transfer, and stag ing of chemical applications in locations where the site does not provide a route fo r any chemical spill to run into water

• 

### Chemical label requirements must be followed

• 

### Operators must obey buffer requirements for chem ical application in the vicinity of water bodies (e.g., 10 feet for ground applications; 60 f eet for aerial applications of herbicides, rodenticides, and biological insecticides; and 100 feet for aer ial applications of fungicides and nonbiological insecticides) (ODF, 2007b).

June 2008 2. Baseline for the Analysis 2-7

### As described above, the Willamette Basin Mercur y TMDL states that relative contribution of mercury to the basin from erosion of mercur y containing soils is approximately 48%. ODEQ recommends implementing BMPs required by th e FPA that minimize soil erosion to reduce mercury loads from erosion from forestland (ODEQ, 2006c).

2.2.5 Mines



### Abandoned and inactive mines exist throughout Ore gon, including historic mining districts in eastern Oregon, southwest Oregon, and the Willamette Basin. Over the last century, minerals and metals such as gold, silver, copper, zinc, and mercury have been extracted from these mines. State and federal agencies ha ve identified over 1 40 mines in Oregon for possible further investigation or cleanup, and have initiated assessment of about 95 (ODEQ, 2006a).

ODEQ relies on the Orphan Site Account (OSA) to pay for clean up of contaminated sites, including abandoned mines, where the responsib le party is unknown, unable, or unwilling to perform cleanup. However, state OSA funds have decreased significantly over the past several years (ODEQ, 2006a). Faced with monetary cons traints, ODEQ prioritizes sites based on risks to human health and the environment. The ODEQ al so works closely with federal agencies (U.S. EPA, U.S. Forest Service, and federal Bureau of Land Management) to try to secure cleanup funds for abandoned mines that are located on both public and private land (ODEQ, 2006a).

Controls at mine sites may be required to m eet existing TMDLs for toxic pollutants including mercury. For example, the Willamette Basin Merc ury TMDL (ODEQ, 2006b) states that relative contribution of mercury to the basin from le gacy mining operations is only 0.6%. However, ODEQ indicates that mercury resi duals from old mining operations represent a significant source of mercury (approximately 75%) in the Cottage Grove Watershed within the Willamette Basin. ODEQ is implementing an incremental phased appro ach for this TMDL with plans to update the current recommendation in 2011. The current imp lementation strategy includes a continuation of ODEQ efforts to remediate abandoned mine sites to minimize the flow of mercury into adjacent water bodies (ODEQ, 2006c).

Elevated concentrations of mercury in fish tissu es also exist in the Snake and Owyhee Rivers. ODEQ and IDEQ (2003) analyzed the mercury loading in the Snake River – Hells Canyon drainage and concluded that leg acy gold, silver, and mercury mini ng in the drainage area may be a moderate to substantial contributor of the total mercury loading. Most of this legacy mining was located in the watershed of the Owyhee Rive r, a tributary to the Snake River (ODEQ and IDEQ, 2003). ODEQ and IDEQ did not develop a TMDL for mercury due to limited data; however, both have plans to deve lop a TMDL in the future.

In its Mercury Reduction Strategy, ODEQ identified planned activities at mercury contaminated mines (ODEQ, 2007a):

• 

### Black Butte Mine: Interim soil removal

• 

### Horse Heaven Mine: Second phase of remedial action

• 

### Opalite and Bretz Mines: Exploring joint fundi ng options with the Vale District of the Bureau of Land Management

• 

### Ochoco Mercury District: Phase 2 Abandoned Mine Lands study.

June 2008 2. Baseline for the Analysis 2-8

### 2.2.6 Atmospheric Deposition



### Atmospheric deposition may be a potential nonp oint source to surface waters through either direct or indirect depos ition. Direct deposition occurs wh en pollutants deposited directly on surface waters from the atmosphere. Indirect de position reflects the process by which metals and other pollutants such as pesticides deposited on the land surface are washed off during storm events and enter surface water through storm wa ter runoff. Atmospheric deposition is not directly addressed through any existing regulation, but is indi rectly addressed through TMDLs.

Atmospheric deposition is identified as a major source of mercury in both the Willamette Basin and the Snake River – Hells Canyon reach. ODEQ es timated the relative contribution of direct and indirect atmospheric depositi on of mercury in the Willamette Basin to be approximately 6% and 42%, respectively (ODEQ, 2006b). The Wi llamette Basin mercury TMDL implementation strategy includes a combination of voluntary BMPs to reduce emissions from air mobile, area, and industrial sources. The adoption of BMPs to control mercury movement on the landscape in urban, agriculture, and forestry environments, such as through erosion control practices, will help control mercury (ODEQ, 2006c).

ODEQ and IDEQ’s initial analysis of the Sn ake River – Hells Canyon drainage identified atmospheric deposition as a potentially substant ial source of mercury - primarily from the combustion of fossil fuels (ODEQ and IDEQ, 2003) . ODEQ plans to develop a TMDL to further investigate mercury in this drainage.

2.3 Water Quality

There are approximately 58,000 miles and 5,000 acres of surface water on Oregon’s 2004 303(d) list that are impaired. Exhibit 2-3 summarizes the number of water bodies impaired for each pollutant.

Exhibit 2-3. Summary of Oregon’ s 2004 303(d) List of Impairments
Pollutant Number of Water Bodies Number of River Miles Number of Lake Acres Aldrin 1 72.0 NA Ammonia 16 279.0 * Aquatic Weeds or Algae 23 276.2 169 Arsenic 14 501.8* NA Arsenic (tri) 7 135.9 NA Beryllium 12 144.6 NA Biological Criteria 32 479.1* NA Cadmium 3 33.1 NA Chlordane 1 7.8 NA Chlorine 3 55.3 NA Chlorophyll a 30 621.6 * Chlorpyrifos 4 20.1 NA Chromium (hex) 2 * * Copper 13 107.1* *
DDT 5 240.9 NA DDT Metabolite (DDE) 3 222.5 NA

June 2008 2. Baseline for the Analysis 2-9

### Exhibit 2-3. Summary of Oregon’ s 2004 303(d) List of Impairments
Pollutant Number of Water Bodies Number of River Miles Number of Lake Acres Dichloroethylenes 2 22.6* NA Dieldrin 8 216.1 NA Dioxin (2,3,7,8-TCDD) 3 802.7 NA Dissolved Oxygen 131 3,279* 706* E Coli 94 1,906* NA Enterococcus 1 2.6 NA Fecal Coliform 136 2,514 NA Flow Modification 530 11,295 NA Guthion 1 5.6 NA Habitat Modification 615 10,546* 3,017* Heptachlor 1 2.8 NA Iron 43 1,060* NA Lead 9 59.9* * Manganese 27 605.0* NA Mercury 15 667.9 780 Nickel 1 12.8 NA Nitrates 4 53.3 NA PCB 4 292.8 NA Pentachlorophenol 1 24.8 NA pH 64 1,660 134 Phosphorus 48 667.5* 184 PAHs 3 92.5 NA Sedimentation 90 1,273.2 NA Silver 4 52.8 * Temperature 840 16,841* NA Tetrachloroethylene 2 22.6* NA Total Dissolved Gas 3 326.4 NA Trichloroethylene 1 22.6 NA Turbidity 4 96.4 NA Zinc 6 25.7* * Total** 2,860 57,648 4,990 Source: ODEQ (2006d). NA = not applicable *Missing acreage or river miles for one or more water bodies. **Some water bodies are listed for more than one pollutant.



### The Oregon Department of Health has also issued fish consumption advisories for mercury (7 lakes/reservoirs and 4 rivers), PCBs (3 rivers), and pesticides (2 rivers).

Exhibit 2-4 summarizes the targets, load allocations , and implementation plans in completed TMDLs for the toxic pollutants of concern. TMDLs for other pollutants that result in a need for controls that reduce a variety of pollutants (e.g., forest buffers that increase shade and reduce temperature but also reduce runoff of toxics) will also impact th e baseline relevant to estimating the incremental impacts of the revised standards.

June 2008 2. Baseline for the Analysis 2-10

### Exhibit 2-4. Summary of Tox ic Pollutant TMDLs in Oregon Water Body Pollutant/Trigger Load Allocations Implementation Columbia River (ODEQ, 1991) Dioxin – high fish tissue concentrations Watershed Allocations: No implementation strategies identified to meet allocations. Columbia R. above WA/Canada border = 2.31 mg/day; Snake R. Basin above Ice Harbor Dam = 1.18 mg/day; Willamette R. Basin above Columbia R. = 0.54 mg/day Pulp and Paper Mills: Potlatch = 0.39 mg/day; Pope and Talbot = 0.19 mg/day; Boise Cascade, Wallula = 0.25 mg/day; James River, Camas = 0.42 mg/day; Longview Fibre = 0.08 mg/day; Weyerhaeuser = 0.26 mg/day; Boise Cascade, St. Helens = 0.27 mg/day; James River, Wauna = 0.21 mg/day Columbia Slough (ODEQ, 1998) DDT: DDT – fish tissue exceed 1.29 μ g/kg Dieldrin – fish tissue exceed 3.5 μ g/kg PCBs – fish tissue exceed 2.46 μ g/kg Dioxin – fish tissue exceed 0.07 ng/kg Sediments = 4.88×10 -4

mg/day; Storm Water = 3.24 mg/day; Future Growth = 1.62 mg/day Phase I implementation strategies include:

• Implement BMPs to reduce erosion and

sedimentation. Dieldrin: Sediments = 0.0108 mg/day; Storm Water = 9.6 mg/day; Future Growth = 4.8 mg/day • Monitor effectiveness of BMPs.

• Monitor contribution of contaminated

sediment sites. PCBs: Sediments = 0.161 mg/day; Storm Water = 5.3 mg/day; Future Growth = 10.6 mg/day; NuWay Oil = 1.82×10 -4

mg/day • Develop allocations for contaminated sediment sites.

• Remediate contaminated sediment in

Buffalo Slough. Dioxin: Sediments = 1.31×10 -3

mg/day; Storm Water = 1.31×10 -3

mg/day; Future Growth = 1.31×10 -3

mg/day Snake River (ODEQ and IDEQ, 2003) DDT: DDT – high fish tissue concentrations and exceeds water quality criterion Dieldrin – exceeds water quality criterion New applications = 0 kg/yr Implementation strategies include:

• Implement waste load allocations for

point sources though NPDES permits. Legacy application and transport (RM 409 to 335) = 0.31 kg/yr

• Implement numeric effluent limits or specific management measures into general permits. Brownlee and Oxbow Reservoirs = 0.33 kg/yr Dieldrin: New applications = 0 kg/yr

• Designated management agencies will select management measures to be included in implementation plans, determine if the source and/or management measure is applicable within their jurisdiction; monitor the frequency and extent of application measures for each identified source. Legacy application and transport (RM 409 to 335) = 0.88 kg/yr Brownlee and Oxbow Reservoirs = 1.0 kg/yr

Willamette Basin (ODEQ, 2006b; 2006c) Interim Mercury Allocations: Mercury – exceeds fish advisory screening level Implementation strategies include:

• Require selected NPDES permittees to

monitor for mercury and develop and implement mercury reduction plans as interim implementation measures. Runoff of atmospherically deposited mercury = 39.2 kg/yr; Direct deposition to open water = 5.5 kg/yr; Erosion of mercury containing soils = 44.8 kg/yr; Legacy mine discharges = 0.6 kg/yr; Sediment resuspension = 0 kg/yr; POTW discharges = 2.6 kg/yr; Industrial discharges = 1.1 kg/yr • Ensure MS4s are addressing mercury through their permits and require Phase I permittees to collect data on mercury in runoff so they may be appropriately

June 2008 2. Baseline for the Analysis 2-11

### Exhibit 2-4. Summary of Tox ic Pollutant TMDLs in Oregon Water Body Pollutant/Trigger Load Allocations Implementation considered in the 2011 TMDL update.

• Require implementation of BMPs for

the 1200Z general permit.

• Incorporate mercury reduction

strategies into implementation plans for Non-MS4 areas, Agricultural Water Quality Management Area Plans, Forest Practices Act, plans from the federal land managers, and air sectors.

• Support ongoing efforts between the

ODEQ Land Quality Program, BLM, and other stakeholders who are working to address mercury runoff from abandoned mines.

June 2008 2. Baseline for the Analysis 2-12

## 3. Potential Revised Criteria

ODEQ is considering revising the fish consumpti on rate for calculating hu man health criteria. The criteria can be calculated based on the pol lutant reference dose (for noncarcinogens) or cancer potency factor (for carcinogens), biocon centration factor, and fish consumption rate (EPA, 1980):

AWQC (RfD RSC) BW

DI FI BCF = + ⎡ ⎣ ⎢ ⎤ ⎦ ⎥ * * (* )

AWQC ( q ) BW

DI FI BCF = + ⎡ ⎣ ⎢ ⎤ ⎦ ⎥ − 

### 10

1 6



### * * (* ) 

### where, AWQC = ambient water qual ity criterion in mg/L BW = human body weight default value of 70 kg RfD = reference dose based on noncancer hu man health effects in mg/kg body weight-day RSC = relative source contribution (%) DI = drinking water intake default value of 2 L/day FI = human fish consumption in kg fish/day BCF = bioconcentration factor in L/kg fish q1* = cancer potency factor in kg body weight-day/mg.

U.S. EPA (2002) provides the applicable RfD, RS C, BCF, and q1* values for each pollutant of

concern.

In 2001, EPA published a revised methylmercury criterion based on the concentration of methylmercury in fish tissue, calculate d using the following equation (EPA, 2001a):

TRC BW RfD RSC

FI i i 

### = ∗

−

= 

# ∑

( )

2 4



### where, TRC = tissue residual concentrati on in mg methylmercury/kg fish

1 

### FI i 

### = human fish consumption of trophic level i (kg fish/day) RSC = relative source contribution in mg methylmercury/kg body weight-day.

Exhibits 3-1 and 3-2 summarize the human health criteria for the pollutants of concern (i.e., those pollutants with baseline and revised human h ealth criteria more stringent than the existing aquatic life criteria and for which reference do se/cancer potency factor and bioconcentration factor are available) for select fish consum ption rates and ODEQ’s quantification limits (QLs)

1 Trophic levels are defined by the food relationship of fish in the food chain. There are four trophic levels that make up the aquatic food chain: primary producers such phytoplankton and other plants; zooplankton, benthic filter feeders, grazers, and herbivorous fish; small predacious fish; and large, predator fish.

June 2008 3. Potential Revised Criteria 3-1

### which represent the minimum level to which dischargers need to measure each pollutant. Note that for some pollutants, the baseline criteria are more stringent than the revised criteria based on alternative fish consumption rates (e.g., benzen e, chloroform, and nickel, among others).

June 2008 3. Potential Revised Criteria 3-2June 20083. Potential Revised Criteria3-1Exhibit 3-1. Human Health Criteria for Select Consumption Rates:Consumption of Water and FishRevised Criteria based on Select Consumption Rates (μg/L)PollutantQL (μg/L)BaselineCriteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpd1,1,2,2-Tetrachloroethane0.50.170.150.140.120.0890.0691,1,2-Trichloroethane0.50.590.540.490.440.330.261,1-Dichloroethylene0.53303002702301701301,2,4,5-Tetrachlorobenzene1.00.970.290.160.110.0480.0301,2,4-Trichlorobenzene0.535159.46.43.01.91,2-Dichlorobenzene0.542023015011053351,2-Dichloroethane0.50.380.370.360.350.310.281,2-Dichloropropane0.50.50.460.420.380.290.231,2-Diphenylhydrazine5.00.0360.0240.0180.0140.00750.00501,2-Trans-Dichloroethylene0.5140130130120110941,3-Dichlorobenzene0.53201701108040261,3-Dichloropropene0.50.340.330.320.300.260.221,4-Dichlorobenzene0.5633423167.95.12,3,7,8-TCDD (Dioxin)5.0E-065.0E-091.4E-097.9E-105.1E-102.3E-101.4E-102,4,5-Trichlorophenol2.01,8007804903301601002,4,6-Trichlorophenol1.01.20.550.340.230.110.0672,4-Dichlorophenol1.077463223127.72,4-Dimethylphenol2.03801801107636232,4-Dinitrophenol5.06967656254482,4-Dinitrotoluene1.00.110.100.0930.0840.0650.0522-Chloronaphthalene1.01,00038023015069442-Chlorophenol1.0813320146.54.12-Methyl-4,6-Dinitrophenol2.01312109.26.65.03,3'-Dichlorobenzidine1.00.0210.00720.00420.00270.00130.00084,4'-DDD0.010.000310.0000860.0000480.0000310.0000140.00000884,4'-DDE0.010.000220.0000610.0000340.0000220.00000990.00000624,4'-DDT0.010.0000240.0000610.0000340.0000220.00000980.0000062Acenaphthene1.0670240140954428Acrolein5.0190704228138.1Acrylonitrile5.00.0510.0330.0240.0180.00950.0063June 20083. Potential Revised Criteria3-2Exhibit 3-1. Human Health Criteria for Select Consumption Rates:Consumption of Water and FishRevised Criteria based on Select Consumption Rates (μg/L)PollutantQL (μg/L)BaselineCriteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpdAldrin0.010.0000490.0000140.00000780.00000500.00000230.0000014alpha-BHC0.010.00260.00110.000670.000450.000210.00013Anthracene1.08,3005,4003,9002,9001,5001,000Antimony0.15.65.45.35.14.74.3Arsenic0.050.00220.00830.00570.00410.00210.0014Benzene0.50.662.01.81.61.20.89Benzidine10.00.0000860.0000400.0000260.0000180.00000840.0000054Benzo(a) Anthracene1.00.00380.00250.00180.00130.000700.00047Benzo(a) Pyrene1.00.00380.00250.00180.00130.000700.00047Benzo(b) Fluoranthene1.00.00380.00250.00180.00130.000700.00047Benzo(k) Fluoranthene1.00.00380.00250.00180.00130.000700.00047Beryllium0.10.00680.00510.00390.00310.00170.0012beta-BHC0.010.00910.00380.00230.00160.000740.00047Bis(2-Chloroethyl) Ether1.00.030.0260.0230.0200.0140.010Bis(2-Chloroisopropyl) Ether2.034.71,3001,2001,200950790Bis(Chloromethyl) Ethera3.7E-095.3E-053.5E-052.4E-051.2E-057.7E-06Bis(2-Ethylhexyl) Phthalate1.01.20.490.300.200.0950.061Bromoform0.54.34.03.73.32.62.0Butylbenzyl Phthalate1.01,5005002901908654Carbon Tetrachloride0.50.230.170.130.100.0580.040Chlordane0.10.000460.000220.000130.0000810.0000360.000023Chlorobenzene0.513011088744733Chlorodibromomethane0.50.40.370.340.310.240.19Chloroform0.50.195.14.74.33.32.7Chrysene1.00.00380.00250.00180.00130.000700.00047Dibenzo(a,h)Anthracene1.00.00380.00250.00180.00130.000700.00047Dichlorobromomethane0.50.550.500.470.430.330.26Dieldrin0.010.0000520.0000150.00000830.00000530.00000240.0000015Diethyl Phthalate1.017,0008,5005,5003,8001,8001,200Dimethyl Phthalate1.0270,000160,000120,00084,00044,00029,000Di-n-Butyl Phthalate1.02,000920580400190120Endosulfan Sulfate0.016222138.53.92.5June 20083. Potential Revised Criteria3-3Exhibit 3-1. Human Health Criteria for Select Consumption Rates:Consumption of Water and FishRevised Criteria based on Select Consumption Rates (μg/L)PollutantQL (μg/L)BaselineCriteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpdEndrin0.010.0590.0170.00930.00600.00270.0017Endrin Aldehyde0.010.290.0830.0470.0300.0140.0085Ethylbenzene0.55303202201608455Fluoranthene2.0423721146.23.9Fluorene1.01,100720520390200140gamma-BHC (Lindane)0.010.01860.00530.00320.00220.00100.00065Heptachlor0.010.0000790.0000220.0000120.00000790.00000360.0000022Heptachlor Epoxide0.010.0000390.0000110.00000610.00000390.00000180.0000011Hexachlorobenzene1.00.000280.0000790.0000440.0000290.0000130.0000081Hexachlorobutadiene2.00.440.410.390.360.290.24Hexachlorocyclopentadiene2.0403734302318Hexachloroethane2.01.40.670.420.290.140.089Ideno(1,2,3-cd)Pyrene1.00.00380.00250.00180.00130.000700.00047Isophorone10.0353230272016Methyl Bromide0.5474440372823Methylene Chloride0.54.64.54.44.34.03.6Methylmercury0.00005-0.081 mg/kg10.045 mg/kg10.029 mg/kg10.013 mg/kg10.0082 mg/kg1Nickel10.013.42801901406945Nitrobenzene1.017161514119.2N-Nitrosodibutylamine10.00.00630.00580.00540.00500.00390.0031N-Nitrosodiethylamine10.00.000800.000800.000800.000790.000780.00076N-Nitrosodimethylamine1.00.000690.000690.000690.000680.000680.00068N-Nitrosodi-n-Propylamine2.00.0050.00480.00470.00460.00410.0037N-Nitrosodiphenylamine1.03.31.30.820.550.260.17N-Nitrosopyrrolidine10.00.0160.0160.0160.0160.0160.016Pentachlorobenzene10.01.40.150.0870.0560.0250.016Pentachlorophenol2.00.270.220.180.150.090.066Phenol1.03,50020,00019,00019,00017,00015,000PCBs0.50.0000640.0000180.00000990.00000640.00000290.0000018Pyrene1.0830540390290150100Selenium2.0101501401209170Tetrachloroethylene0.50.690.450.320.240.130.084Exhibit 3-1. Human Health Criteria for Select Consumption Rates:Consumption of Water and FishRevised Criteria based on Select Consumption Rates (μg/L)PollutantBaselineQL (μg/L)Criteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpdThallium0.240.100.0630.0430.0200.0130.1Toluene1,3001,0008707204503200.5Toxaphene0.000280.0000770.0000430.0000280.0000120.00000780.5Trichloroethylene2.52.11.71.40.910.650.5Vinyl Chloride0.0250.0240.0230.0230.0200.0180.5a = Contact DEQ laboratory1. Represents a fish tissue criterion, and would be applicable to all waters (fresh and marine).Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish OnlyRevised Criteria based on Select Consumption Rates (μg/L)PollutantBaselineQL (μg/L)Criteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpd1,1,2,2-Tetrachloroethane0.541.10.620.400.180.111,1,2-Trichloroethane0.5164.32.41.60.700.441,1-Dichloroethylene0.57,1002,0001,1007103202001,2,4,5-Tetrachlorobenzene1.10.300.170.110.0480.0301.01,2,4-Trichlorobenzene0.57019117.03.22.01,2-Dichlorobenzene0.51,30036020013058371,2-Dichloroethane0.537105.73.71.61.01,2-Dichloropropane0.5154.02.31.50.660.411,2-Diphenylhydrazine5.00.20.0560.0310.0200.00900.00571,2-Trans-Dichloroethylene0.510,0002,8001,6001,0004602901,3-Dichlorobenzene0.59602701509643271,3-Dichloropropene0.5215.83.32.10.950.591,4-Dichlorobenzene0.51905330198.75.42,3,7,8-TCDD (Dioxin)5.0E-065.1E-091.4E-097.9E-105.1E-102.3E-101.4E-102,4,5-Trichlorophenol3,6001,0005603601601002.02,4,6-Trichlorophenol1.02.40.670.380.240.110.0682,4-Dichlorophenol1.0290824629138.32,4-Dimethylphenol2.08502401308538242,4-Dinitrophenol5.05,3001,5008305302401502,4-Dinitrotoluene1.03.40.940.520.340.150.0962-Chloronaphthalene1.01,6004402501607145June 20083. Potential Revised Criteria3-4June 20083. Potential Revised Criteria3-5Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish OnlyRevised Criteria based on Select Consumption Rates (μg/L)PollutantQL (μg/L)BaselineCriteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpd2-Chlorophenol1.01504123156.74.22-Methyl-4,6-Dinitrophenol2.0280794428138.03,3'-Dichlorobenzidine1.00.0280.00790.00440.00280.00130.000804,4'-DDD0.010.000310.0000860.0000480.0000310.0000140.00000884,4'-DDE0.010.000220.0000610.0000340.0000220.00000990.00000624,4'-DDT0.010.0000240.0000610.0000340.0000220.00000980.0000062Acenaphthene1.0990270150994528Acrolein5.0290804529138.2Acrylonitrile5.00.250.0680.0380.0250.0110.0070Aldrin0.010.000050.0000140.00000780.00000500.00000230.0000014alpha-BHC0.010.00490.00140.000760.000490.000220.00014Anthracene1.040,00011,0006,2004,0001,8001,100Antimony0.164018099642918Arsenic0.050.01750.0140.00800.00520.00230.0015Benzene0.540147.95.12.31.4Benzidine10.00.00020.0000550.0000310.0000200.00000890.0000056Benzo(a) Anthracene1.00.0180.00510.00280.00180.000820.00052Benzo(a) Pyrene1.00.0180.00510.00280.00180.000820.00052Benzo(b) Fluoranthene1.00.0180.00510.00280.00180.000820.00052Benzo(k) Fluoranthene1.00.0180.00510.00280.00180.000820.00052Beryllium0.10.1170.01400.00760.00490.00220.0014beta-BHC0.010.0170.00470.00260.00170.000770.00048Bis(2-Chloroethyl) Ether1.00.530.1500.0820.0530.0240.015Bis(2-Chloroisopropyl) Ether2.04,36018,00010,0006,5002,9001,800Bis(2-Ethylhexyl) Phthalate1.02.20.610.340.220.0990.062Bis(Chloromethyl) Ethera0.001840.0000800.0000450.0000290.0000130.0000081Bromoform0.51403721146.13.8Butylbenzyl Phthalate1.01,9005403001908755Carbon Tetrachloride0.51.60.450.250.160.0740.046Chlordane0.10.000480.000220.000130.0000810.0000360.000023Chlorobenzene0.51,6004302401607044Chlorodibromomethane0.5133.52.01.30.570.36June 20083. Potential Revised Criteria3-6Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish OnlyRevised Criteria based on Select Consumption Rates (μg/L)PollutantQL (μg/L)BaselineCriteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpdChloroform0.515.74827177.94.9Chrysene1.00.0180.00510.00280.00180.000820.00052Dibenzo(a,h) Anthracene1.00.0180.00510.00280.00180.000820.00052Dichlorobromomethane0.5174.82.71.70.770.49Dieldrin0.010.0000540.0000150.00000830.00000540.00000240.0000015Diethyl Phthalate1.044,00012,0006,8004,4002,0001,200Dimethyl Phthalate1.01,100,000310,000170,000110,00050,00031,000Di-n-ButylPhthalate1.04,5001,200700450200130Endosulfan Sulfate0.018925148.94.02.5Endrin0.010.060.0170.00940.00600.00270.0017Endrin Aldehyde0.010.30.0840.0470.0300.0140.0085Ethylbenzene0.52,1005903302109660Fluoranthene2.0543922146.33.9Fluorene1.05,3001,500830530240150gamma-BHC (Lindane)0.010.06250.00660.00370.00240.00110.00067Heptachlor0.010.0000790.0000220.0000120.00000790.00000360.0000022Heptachlor Epoxide0.010.0000390.0000110.00000610.00000390.00000180.0000011Hexachlorobenzene1.00.000290.0000800.0000450.0000290.0000130.0000081Hexachlorobutadiene2.0185.12.91.80.830.52Hexachlorocyclopentadiene2.01,1003101701105031Hexachloroethane2.03.30.910.510.330.150.093Ideno(1,2,3-cd)Pyrene1.00.0180.00510.00280.00180.000820.00052Isophorone10.0960270150964327Methyl Bromide0.51,5004102301506742Methylene Chloride0.559016092.059.027.017.0Methylmercury0.00005300μg/kg10.081 mg/kg10.045 mg/kg10.029 mg/kg10.013 mg/kg10.0082 mg/kg1Nickel10.01004702601707748Nitrobenzene1.0690190110693120.0N-Nitrosodibutylamine10.00.220.0600.0340.0220.00980.0062N-Nitrosodiethylamine10.01.240.130.0710.0460.0210.013N-Nitrosodimethylamine1.030.840.470.300.140.085N-Nitrosodi-n-Propylamine2.00.510.140.0780.0510.0230.014Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish OnlyRevised Criteria based on Select Consumption Rates (μg/L)PollutantBaselineQL (μg/L)Criteria (μg/L)63.2 gpd113 gpd175 gpd389 gpd620 gpdN-Nitrosodiphenylamine1.061.70.930.600.270.17N-Nitrosopyrrolidine349.55.33.41.50.9610.0Pentachlorobenzene1.50.160.0870.0560.0250.01610.0Pentachlorophenol2.030.840.470.300.140.086Phenol1.01,700,000470,000270,000170,00077,00048,000PCBs0.50.0000640.0000180.00000990.00000640.00000290.0000018Pyrene1.04,0001,100620400180110Selenium2.04,2001,200650420190120Tetrachloroethylene0.53.30.910.510.330.150.093Thallium0.10.470.130.0730.0470.0210.013Toluene0.515,0004,1002,3001,500670420Toxaphene0.50.000280.0000770.0000430.0000280.0000120.0000078Trichloroethylene0.5308.34.63.01.30.85Vinyl Chloride0.52.40.680.380.240.110.069a = Contact DEQ laboratory.1. Represents a fish tissue criterion.June 20083. Potential Revised Criteria3-7June 2008 4. Method for Estimating Potential Costs: Point Sources 4-1 

## 4. Method for Estimating Potential Costs: Point Sources

This section describes the method for estimating th e potential costs to po int sources associated with compliance with both baseline criteria and re vised criteria that incorporate the alternative fish consumption values. Compliance costs for municipal and industrial point sources may result from changes to NPDES permit requirements.

4.1 Sample Selection

Factors that may affect the poten tial magnitude of compliance costs include flow and facility type. Larger flows are typically associated w ith the largest treatment costs, although per-unit costs may decrease due to economies of scale. A cer tainty sample of the la rgest facilities ensures that this high potential for cost is captured in the analysis. Industrial category may also be indicative of the potential to incur costs. Tr eatment requirements differ for municipal and industrial discharges, and effluent quality may be similar across categories of facilities. Minor dischargers typically do not ha ve monitoring requirements for toxic pollutants and, may not contribute significantly to instream loads even if such pollutants were pr esent in the effluent from these facilities. Thus, the potential for mino r facilities to incur costs as a result of an increased fish consumption rate is low.

As shown in Exhibit 2-2, ther e are 77 major (49 municipal a nd 28 industrials) and 313 minor (157 municipal and 156 industrials) individually permitted wastewater discharges to waters for which the potential revised human health criter ia would apply. EPA uses the designation of “major” for municipal discharges of 1 million ga llons per day (mgd) or more, and industrial discharges with a major rating code (based on th e presence of toxics and size of discharge flow) over a specified value (e.g., 80) (U.S. EPA, 2008).

To incorporate the facilities with highest poten tial for cost, we evaluated the four largest facilities based on the facility information sectio n of EPA’s PCS database (four municipals, one of which is dominated by flow from a pulp and paper plant). 2 

### ODEQ also selected one minor industrial to represent a potentia l worse case based on industrial process (steel mill). To evaluate potential for costs at the remaining municipa l and industrial facilities, we selected a representative random sample of 13 major facilities and 2 minor facilities (one municipal and one industrial).

Exhibit 4-1 provides a summary of the sample for evaluation. Appendix A provides additional information on these facilities.

Exhibit 4-1. Summary of Sample Facilities
NPDES Number Name Major/ Minor Type Flow (mgd)

Certainty Sample

2 PCS does not contain flow data for the industrial facilities in Oregon.

### Exhibit 4-1. Summary of Sample Facilities
NPDES Number Major/ Name Type Flow (mgd) Minor OR0026905 City of Portland, Columbia Blvd WWTP Major Municipal 108.3 OR0031224 Metro Wastewater Management, Eugene-Springfield WPCF Major Municipal 49 OR0020834 St. Helens-Boise Cascade WWTP Major Municipal 1 40 OR0026409 City of Salem, Willow Lake WWTP Major Municipal 35 OR0000451 Oregon Steel Mills Minor Industrial 0.79** Random Sample OR0029777 Clean Water Services, Rock Creek WWTP Major Industrial 15 OR0031259 Tri-City Service District Major Municipal 8.4 OR0034002 McMinnville WRF Major Municipal 5.6 OR0027561 Astoria WWTP Major Municipal 4.2 OR0020001 Woodburn WWTP Major Municipal 3.1 OR0026221 Clackamas City, Kellogg Creek WWTP Major Municipal 2.7 OR0023361 North Bend WWTP Major Municipal 2.2 OR0023582 Coos Bay WWTP #2 Major Municipal 2 OR0020354 Brookings WWTP Major Municipal 1.3 OR0001074 Pope & Talbot Inc., Halsey Bleach-Kraft Pulp Mill Major Industrial 10.3* OR0000566 Blue Heron Paper Company Major Industrial 9.7** OR0002402 Heinz Food Company Major Industrial 3.4** OR0000060 Reynolds Metals Company Major Industrial 1.95* OR0030660 Shady Cove WWTP Minor Municipal 0.45 OR0002411 Boise Cascade, Elgin Sawmill Minor Industrial NA Source: EPA (2007). NA = Not available. *Represents the average of average monthly e ffluent flows reported in the Effluent M easurements/Violations section of EPA’s PCS database. **Flow as reported in permit. 1. Dominated by industrial flow.



### Note that the flows reported in PCS for St . Helens-Boise Cascade WWTP and Rock Creek WWTP do not match the average flows specified in their permits (the exhibit shows flows reported in PCS).

4.2 Determining Reasonable Potential

ODEQ (2005) procedures provide permit write rs instructions for determining whether dischargers have reasonable potential (RP) to cause or contribute to an exceedance of WQS. These procedures apply to:

• 

### All industrial sources ODEQ requires to perf orm effluent monito ring (see Table 4)

• 

### All industrial sources ODEQ does not require to mon itor, but has identified a concern for toxic pollutants (e.g., a facility that stores ha zardous chemicals on site and has a recorded history of spills into to the wastewater st ream that could potentially pass through the treatment system into the receiving water)

• 

### All domestic sources greater than 1 mgd average dry weather design flow (ADWDF)

• 

### All domestic sources less than 1 mgd ADWDF w ith a significant indus trial user that may be a potential source of pollutants, discha rging to a receiving water body providing less

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-2

### than 10:1 dilution, with a treatment system that is based on biological treatment, as opposed to a lagoon system, or where the indivi dual permit writer feels conditions exist that warrant an analysis.

The first step in determining RP is to identify the applicable criteria. For freshwater, permit writers should use human health criteria for cons umption of water and organisms. Human health criteria for consumption of organisms only apply to marine and estuarine waters. For mercury, the criterion represents the concen tration of methylmercury in fish tissue. It is uncertain how ODEQ will implement this fish tissue-based criterion in NPDES permit. However, for this analysis, we converted the criterion into an am bient water quality criterion (AWQC) for total mercury using bioaccumulation factors (BAFs):



### AWQC (RfD RSC) BW

DI (FI BAF ) f THg

i i i d 

### = −
+ ∗ ⎡

⎣ ⎢ ⎢ ⎢ ⎤

⎦ ⎥ ⎥ ⎥ ÷

= 

# ∑
2 4



### where, AWQC = ambient water qual ity criterion in mg/L BW = human body weight default value of 70 kg RfD = reference dose based on noncancer hu man health effects in mg/kg body weight-day RSC = relative source contribu tion in mg/kg body weight-day DI = drinking water intake default value of 2 L/day FI = human fish consumption in kg fish/day
BAF i 

### = bioaccumulation factor for trophic level i (L/kg fish) f d 

### = translator to convert dissolved methylmercury into total mercury .

For this analysis, we assumed that ODEQ woul d use EPA’s default values to convert the methylmercury fish tissue criterion into a total mercury water column criterion:

• 

### National BAFs: BAF 2 

### = 120,000 L/kg; BAF 3 

### = 680,000 L/kg; BAF 4 

### = 2,700,000 L/kg

• 

### Trophic level specific consum ption rate percentages: FI 2 

### = 22%; FI 3 

### = 46%; FI 4 

### = 33%

• 

### Dissolved methylmercury to total mercury tran slator: 0.014 for river; 0.032 for lakes.

Exhibit 4-2 shows the AWQC for mercury for rivers a nd lakes at alternative fish consumption rates calculated using EPA’s default values.

Exhibit 4-2. Baseline and Pote ntial Revised AWQC for Mercury Alternative Fish Consumption Rate Criteria (μg/L) Water Body Baseline Criteria Type (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Rivers 0.017 0.0047 0.0026 0.0017 0.00076 0.00048 Lakes 0.0075 0.0021 0.0011 0.00075 0.00033 0.00021 AWQC = ambient water quality criterion



### Note that ODEQ’s applicable QL for mercur y is 0.01 μg/L based on using either Method 245.7 or Method 1631; ODEQ specifies the QL for methylmercury at 0.00005 μg/L using Method 1630. Thus, converting the methylmercury fish tissue criterion into a total mercury water column value would result in less stringent requ irements for dischargers (because dischargers would only need to reduce total mercury to th e QL of 0.01 μg/L under existing implementation procedures). To be conservative (i.e., erri ng on the side of higher costs), we assumed that

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-3June 2008 4. Method for Estimating Potential Costs: Point Sources 4-4 

### dischargers would only use clea n methods (i.e., Method 1631) to monitoring for total mercury with a QL of 0.0005 μg/L.

The next step in the reasonable potential analysis (RPA) is to calculate the concentration of pollutants in the discharge. For noncarcinogens, this value is the maximum observed effluent value times a multiplying factor for the 95% c onfidence level and 95% probability basis (EPA, 1991; Tables 3-1 and 3-2). For carcinogens, th is value is the geometric mean effluent concentration times the multiplying factor. The fe wer number of data points available for the analysis, the larger the multiplying factor. For example, if only one effluent value is available, the multiplying factor would be 6.2 [using a coeffi cient of variance (CV) of 0.6], and the RPA would be based on an effluent concentration th at is over six times greater than the actual measured value.

If all effluent observations ar e nondetect and the criterion is greater than QL (ODEQ, 2005; Appendix B), the calculated effluent concentra tion should be set equal to the lowest method detection limit (MDL) or QL, whichever is lower and/or available. If the QL is lower than the criterion, there is no RP, and if th e criterion is less than the QL and all values are nondetect, there would only be monitoring requirements to ensure that effluent levels remain below specified QLs.

If the calculated effluent concentration (or lowest QL if all observati ons are nondetect) is less than the applicable criterion, ther e is no RP. If the concentration is greater than the criterion, the permit writer must determine whether a mixing zone is appropriate. For this analysis, where the ambient concentration is greater than the applicable criterion or a pollutant is on the 303(d) list as impaired in the water body, we considered a s cenario in which a mixing zone would not be appropriate. If a mixing zone is not appropriate, there is RP. With mixing, RP is based on comparison of the concentration of the pollutant at the edge of the mixing zone boundary to the criterion:

where,
C MZ 

### = Concentration of the pollutant at the edge of the mixing zone
C ce 

### = Calculated effluent concentration of the pollutant
C b 

### = Ambient background concentration (set to ze ro where all observat ions are nondetect or data are not available) D = Dilution factor.

The dilution factor is calculated as:

where, Q e 

### = Effluent flow Q b 

### = Ambient flow (harmonic mean for carcinogens and 30Q5 for noncarcinogens). 

### C MZ ce 

### = CCD

D b 

### + − *( ) 1



### D Q Q
Q e b

e 

### = +June 2008 4. Method for Estimating Potential Costs: Point Sources 4-5 

### If the concentration at the edge of the mixing zone is less than th e applicable crite rion, there is no RP; if the mixing zone concentration is greate r than the criterion, the permit writer must determine whether the point source is a signi ficant contributor to the receiving water concentration of the pollutant. ODEQ (2005) in dicates that a point source is a significant contributor to a rece iving water load if:

• 

### For persistent bioaccumulative and toxi c pollutants (PBTs) (e.g., mercury, aldrin, dieldrin, benzo(a)pyrene, chlo rdane, DDT, dioxins and furans , hexachlorobenzene, alkyllead, mirex, octachlorostyrene, PCBs, and toxaphene), downstream receiving water concentrations are at least 1% gr eater than upstream concentrations

• 

### For non-PBTs (e.g., arsenic), downstream receivi ng water concentrations are at least 10% greater than upstream concentrations.

However, without upstream and downstream measur ements, it is difficult to determine whether any dischargers would be consid ered significant contri butors. Thus, we assumed that if the concentration at the edge of the mixing zone exceeds the app licable criterion there is RP. 3



### Exhibit 4-3 summarizes the RPA for the sample facili ties; Appendix A provides the details of the analyses. As shown in the exhibit, under cu rrent procedures (ODEQ, 2005), dischargers in the sample have RP and thus need WQBELs fo r the following pollutants: 4,4’-DDT, alpha-BHC, arsenic, bis(2-ethylhexyl) phthalate, dioxin, mercury, and tetrachloroethylene.

Exhibit 4-3. Summary of Reasonable Potential Resu lts for Sample Facilities Facility Name Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Astoria WWTP As As As As, Hg As, Hg As, Hg Brookings WWTP None None None None None None Coos Bay WWTP None As, BEHP As, BEHP As, BEHP As, BEHP As, BEHP, Hg Eugene-Springfield WPCF 4,4’-DDT, alpha-BHC 4,4’-DDT, alpha-BHC 4,4’-DDT, alpha-BHC 4,4’-DDT, alpha-BHC 4,4’-DDT, alpha-BHC 4,4’-DDT, alpha-BHC Kellogg Creek WWTP As, Hg As, Hg As, Hg As, Hg As, Hg As, Hg McMinnville WRF As As, Hg As, Hg As, Hg As, Hg As, Hg North Bend WWTP As As As As As As Portland, Columbia Blvd WWTP - 001 Dioxin, As Dioxin, As Dioxin, As Di oxin, As Dioxin, As Dioxin, As, Hg

Portland, Columbia Blvd WWTP - 003 As As As, Hg As, BEHP, Hg As, BEHP, Hg As, BEHP, Hg, PCE Rock Creek WWTP None Hg Hg Hg Hg Hg Salem, Willow Lake WWTP As, Hg As, BEHP, Hg As, BEHP, Hg As, BEHP, Hg As, BEHP, Hg As, BEHP, Hg

St. Helens WWTP As As, Hg As, Hg As, Hg As, Hg As, Hg Tri-City S.D. As, Hg As, Hg As, Hg As, Hg As, Hg As, Hg

3 Ultimately, attaining WQS in a water body, which affects the ambient concentr ation for calculating the size of the mixing zone or results in removal of a 303(d) listing, coul d make effluent limits less stringent for point sources to waters in which ODEQ allows mixing zones. However, these potential benefits (avoided costs) will not be realized until standards are attained, which for many pollutants of concern will require controls on a variety of sources.

### Exhibit 4-3. Summary of Reasonable Potential Resu lts for Sample Facilities Facility Name Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Woodburn WWTP As, BEHP As, BEHP As, BEHP As, BEHP As, BEHP As, BEHP Shady Cove WWTP None None None None None None Blue Heron Paper Hg Hg Hg Hg Hg Hg Collins Products None None None None None None Pope & Talbot As, Hg As, Hg As, Hg As, Hg As, Hg As, Hg Reynolds Metals Co None None None None None None Boise Cascade None None None None None None Oregon Steel Mills As As As As As As
As = arsenic BEHP = bis(2-ethylhexyl) phthalate Hg = mercury TCE = tetrachloroethylene



### 4.3 Projecting Effluent Limits

If there is RP, the permit writer should calcula te average monthly and maximum daily effluent limits using the following equation:

AMEL D WQC C C b b 

### = ×

− + ( )

where, AMEL = Average monthly effluent limit D = Dilution factor WQC = Water quality criterion
C b 

### = Ambient background concentration.

The maximum daily effluent limit (MDEL) is calculated by multiplying the AMEL by a factor determined based on effluent variability and the number of samples per month using (EPA, 1991; Table 5-3).

We compared the maximum observed effluent c oncentration (MEC) to the AMEL to determine compliance. This method ensures that discha rgers only monitoring pollutants once per month are discharging below applicable limits. Thus, if the MEC is below the projected AMEL, or there is no RP for a pollutant, there are unlikely to be any compliance costs. However, if effluent concentrations exceed the projected limits, comp liance actions and associated costs are likely.

Exhibit 4-4 provides a comparison of obs erved MECs with projected average monthly effluent limits and QLs for the dischargers in the sample th at have RP for a partic ular pollutant. Limits shown in bold represent scenarios in which effluent reductions are likely needed for compliance.

Exhibit 4-4. Summary of Projected AMELs for Sample Facilities Projected AMELs 2 (μg/L) Name MEC QL 1 (μg/L) (μg/L) Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 4,4’-DDTEugeneSpringfield WPCF 0.08 0.01 0.00025 0.00065 0.00035 0.00023 0.00010 0.000066

Alpha-BHC

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-6June 2008 4. Method for Estimating Potential Costs: Point Sources 4-7 

### Exhibit 4-4. Summary of Projected AMELs for Sample Facilities Projected AMELs 2 (μg/L) Name MEC (μg/L) QL 1 (μg/L) Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpdEugeneSpringfield WPCF 0.068 0.01 0.028 0.012 0.0071 0.0048 0.0022 0.0014

Arsenic Astoria WWTP 1.05 0.05 0.61 0.49 0.28 0.18 0.081 0.053 Coos Bay WWTP 0.25 0.05 NA NA NA 0.21 0.094 0.062 Kellogg Creek WWTP 1.3 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014

McMinnville WRF 1.3 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014 North Bend WWTP 0.72 0.05 1.8 1.5 0.84 0.55 0.24 0.16

Portland, Col. Blvd Outfall 1 4.08 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014

Portland, Col. Blvd Outfall 3 1.71 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014

Salem, Willow Lake WWTP 11 0.05 0.026 0.10 0.068 0.049 0.025 0.017

St. Helens WWTP 2.28 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014 Tri-City S.D. 1.0 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014 Woodburn WWTP 6.78 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014 Pope & Talbot 1.80 0.05 0.31 1.2 0.82 0.59 0.30 0.20 Oregon Steel Mills 2.04 0.05 0.0022 0.0083 0.0057 0.0041 0.0021 0.0014 Bis(2-ethylhexyl) phthalate Coos Bay WWTP 55.4 0.05 NA 25 14 9.0 4.1 2.5 Portland, Col. Blvd Outfall 3 24.8 0.05 NA NA NA 18 8.7 5.6

Salem, Willow Lake WWTP 13 0.05 NA 5.9 3.6 2.4 1.1 0.73

Woodburn WWTP 17.9 0.05 1.9 0.78 0.48 0.32 0.15 0.098 Dioxin Portland, Col. Blvd Outfall 1 5.5E-06 1.0E-07 1.3E-08 1.4E-09 7.9E-10 5.1E-10 2.3E-10 1.4E-10

Mercury Astoria WWTP 0.042 0.0005 NA NA NA 0.059 0.027 0.017 Coos Bay WWTP 0.0069 0.0005 NA NA NA NA NA 0.02 Kellogg Creek WWTP 0.013 0.0005 0.017 0.0047 0.0026 0.0017 0.00076 0.00048

McMinnville WRF 0.011 0.0005 NA 0.0047 0.0026 0.0017 0.00076 0.00048 Portland, Col. Blvd Outfall 1 0.075 0.0005 NA NA NA NA NA 0.04

Portland, Col. Blvd Outfall 3 0.38 0.0005 NA NA 0.24 0.16 0.07 0.04

Rock Creek WWTP 0.0051 0.0005 NA 0.0047 0.0026 0.0017 0.00076 0.00048

Salem, Willow Lake WWTP 0.07 0.0005 0.017 0.0047 0.0026 0.0017 0.00076 0.00048

### Exhibit 4-4. Summary of Projected AMELs for Sample Facilities Projected AMELs 2 (μg/L) Name MEC QL 1 (μg/L) (μg/L) Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd St. Helens WWTP 0.0047 0.0026 0.0017 0.00076 0.00048 0.037 0.0005 NA

0.017 0.0047 0.0026 0.0017 0.00076 0.00048 Tri-City S.D. 0.020 0.0005
0.017 0.0047 0.0026 0.0017 0.00076 0.00048 Blue Heron Paper 0.20 0.0005
0.0047 0.0026 0.0017 0.00076 0.00048 Pope & Talbot 0.0073 0.0005 0.017 Tetrachloroethylene Portland, Col. Blvd Outfall 3 4.9 0.5 NA NA NA NA NA 7.7

1. QL for mercury represents level achievable using Method 1631. 2. Limits shown in bold represent scenarios in whic h effluent reductions are likely needed for compliance. AMEL = Average monthly effluent limit gpd = grams per day MEC = Maximum effluent concentration NA = Not applicable (no RP) QL = Quantification limit



### Exhibit 4-5 shows the pollutant load reductions (in pounds per year) needed for compliance with the baseline and revised criteria . Load reductions are based on reducing the MEC to the AMEL, except for pollutants with limits less than the app licable QL, the load reductions represent the amount needed to reduce effluent levels to the QL.

Exhibit 4-5. Summary of Pr ojected Baseline and Incremental Load Reductions for Sample Facilities (lbs/yr) Incremental (over baseline) Reduction Baseline Facility Name Reduction 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 4,4’-DDT Eugene Springfield 10.4 - - - - - Alpha-BHC Eugene Springfield 6.0 2.4 2.7* 2.7* 2.7* 2.7* Arsenic Astoria WWTP 5.6*

- - - - - Coos Bay WWTP NA NA NA 0.25 0.96 1.16 Kellogg Creek WWTP 27*

- - - - - McMinnville WRF 21*

- - - - - North Bend WWTP NA NA NA 1.14 3.21 3.75 Portland, Col. Blvd Outfall 1 354*

- - - - - Portland, Col. Blvd Outfall 3 196*

- - - - - Salem, Willow Lake WWTP 1167*

- - - - - St Helens WWTP 204*

- - - - - Tri-City Service District 24*

- - - - - Woodburn WWTP 68* - - - - - Pope & Talbot 73 - - - 0.5 5.4 Oregon Steel Mills 4.8 - - - - - Bis(2-ethylhexyl) Phthalate Coos Bay WWTP NA 187 255 285 315 325 Portland, Col. Blvd Outfall 3 NA NA NA 331 784 935

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-8

### Exhibit 4-5. Summary of Pr ojected Baseline and Incremental Load Reductions for Sample Facilities (lbs/yr) Incremental (over baseline) Reduction Baseline Facility Name Reduction 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Salem, Willow Lake WWTP NA 756 1,002 1,129 1,268 1,307 Woodburn WWTP 162 11.4 14.4 16.0 17.7 18.3 Dioxin Portland, Col. Blvd. 1.2E-03* - - - - - Mercury Astoria WWTP NA NA NA NA 0.19 0.32 Kellogg Cr. WWTP NA 0.18 0.22 0.24 0.26 0.27* Portland, Col. Blvd Outfall 1 NA NA NA NA NA 7.5 Portland, Col. Blvd Outfall 3 NA NA 6.8 10.7 15.1 16.6 McMinnville WWTP NA 0.11 0.14 0.16 0.17 0.18* Rock Creek WWTP NA 0.047 0.30 0.40 0.52 0.55* Salem WWTP NA 1.31 1.53 1.63 1.73 1.76* St Helens WWTP NA 2.95 3.14 3.22 3.31 3.33* Tri-City SD NA 0.31 0.37 0.39 0.42 0.42* Blue Heron Paper NA 0.36 0.43 0.45 0.48 0.49* Pope & Talbot, Hasley Mill NA 0.13 0.23 0.28 0.32 0.34*
“-” = No incremental load reduction because baseline and revised lim its are below the QL or baseline limit is more stringent. gpd = grams per day NA = Not applicable (no load reductions needed) *Represents reductions to the QL, not projected effluent limit. 1. Load reduction calculated based on maximum observed effluen t concentration and average dry weather design flow. For pollutants with limits less than the applicable QL, load reducti ons represent the amount needed to reduce effluent levels to th e QL. For the revised criteria, load reductions repres ent incremental reductions needed above and beyond those needed for compliance with baseline criteria



### 4.4 Identifying Compliance Scenarios

Analysis of the available data for a small sample of facilities indicates that there are likely to be exceedances of projected effluent limits for 4,4 ’-DDT, alpha-BHC, arsenic, bis(2-ethylhexyl) phthalate, dioxin, and mercury. There are a number of potential alternatives for compliance with effluent limits for these pollutants, including:

• 

### Optimizing treatment processes (e.g., adding chemicals to increase flocculation or filtration efficiency) to increase pollutant removal efficiencies

• 

### Source control (e.g., pollution prevention program, inflow and infiltration reductions, more stringent pretre atment standards)

• 

### Installing end-of-pipe treatment technology (e .g., reverse osmosis, granular activated carbon, or chemical precipitation)

• 

### Alternative compliance mechanisms (e.g., site -specific criterion, TM DL, or variance).

Dischargers will pursue the lowest cost means of compliance with effluent limits. However, for the potential revised criteria, technical feasibility is also an issue. Hence, there may be a need for alternative compliance mechanisms.

4.4.1 Process Optimization

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-9

### The lowest cost option is likely the adjustment of existing treatment (process optimization). This option would be most feasible where relatively low pollutant reductions are needed or monitoring data indicate that po llutant loads increase throughout the treatmen t process as a result of chemical additions or treatment techniques.

Process optimization usually i nvolves process analysis and pr ocess modifications. Process analysis is an investigation of the performance-li miting factors of the treatment process and is a key factor in achieving optimum treatment effi ciency. Performance-limiting factors for common wastewater treatment processe s (e.g., sedimentation, activated sludge, filtration) may include operator training, response to changes in wastew ater quality, maintenan ce activities, automation, and process control testing. The cost of process analysis includes the cost of additional or continuous monitoring throughout the treatmen t process, and a treatment performance evaluation. These costs vary based on the num ber of treatment proces ses analyzed and the magnitude of the reductions needed.

Process modifications include activities short of adding new treatment technology units (conventional or unconventional) to the treatm ent train. For increasing pollutant removal efficiencies, process modifications could include adjusting coagul ant doses to increase settling, equalizing flow if pollutant concentrations spike during wet weather events, increasing filter maintenance activities or backwash cycles, training operators, and installing automation equipment including necessary hardware and softwa re. Several months of adjustments may be needed to achieve a desired level of process optim ization. In practice, th e process modifications necessary would be determined by the process analysis study.

Process optimization costs depend on the polluta nt needing reductions and existing treatment processes and operations. For ex ample, a facility could add a flocculant aid to secondary treatment to increase solids removal, and thus , the removal of any pollu tants that adhere to particulates [e.g., mercury and bi s(2-ethylhexyl) phthala te]. In addition, chemicals used in wastewater treatment could contai n contaminants (e.g., chlorine cont aminated with low levels of mercury), and for certain pollutants (e.g., mercury) the use of such chemicals could result in exceedances. Thus, switching chemicals or the source of chemicals could be another low cost process optimization control option.

The effectiveness of process optimization la rgely depends on the efficiency of current operations, the existing treatment processes, and the fate and transport of the pollutant through the treatment train. For example, if a facili ty is already well maintained and operated, implementing process optimization may not result in additional pollutant reductions because the existing treatment processes are already performing at their feasible limits. Also, because most conventional treatment technologies are designe d to maximize removal of suspended solids, process optimization aimed at increasing those rem oval efficiencies may not result in significant reductions for pollutants existing primarily in di ssolved form. Given the available information for the sample facilities, it is generally not possi ble to determine the reductions achievable with process optimization; rather, a detailed, site-specific study would be necessary.

4.4.2 Source Controls

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-10

### If adjusting existing operations w ould not be feasible or would not be sufficient to achieve the necessary reductions, source controls would likely be the next most cost-eff ective control option. Source control could be used alone , or in conjunction with proce ss optimization. The feasibility of source control efforts depends on the makeup of the influent and potential sources of the pollutant. For example, certain toxic pollutants are primarily used in industrial processes. Thus, for a municipal facility, a feasib le source control option would be regulating indirect industrial dischargers through pretreatment permits. However, for pollutants in which the main sources are commercial and residential wastewater (e.g., me rcury), a facility would likely have to concentrate efforts on public outreach and educati on or a sewer use ordinance. Other pollutants, such as arsenic, may be due to natural s ources (e.g., groundwater), and reducing inflow and infiltration (I&I) or treating source water may be necessary.

Costs for source control activities depend on th e pollutant and the measures or controls implemented. For this analysis, we estimated th at the sample faciliti es would pursue pollution prevention (P2) programs (for mercury, DDT, BHC, dioxin, and bis(2-ethyl hexyl) phthalate) or I&I reduction projects (for arsenic) to reduce toxic pollutant concentrations in effluents.

Pollution Prevention Program

Successful P2 programs will likely include at least some of the following steps:

• 

### Identify sources – particularly sources that contribute the greatest load to the influent

• 

### Form a workgroup – preferably composed of representatives from government, industry, community, and environmental organizations that are either familiar with P2 strategies or familiar with the pollutant

• 

### Define program goals – including a statement of how the municipality intends to reduce pollutant levels in its effl uent, the purpose for doing so, and a time line for completion

• 

### Develop an approach – including selecting sectors for P2 effort s, the criteria for targeting efforts (e.g., size of the sour ce loading, authority available to control the source, time required to produce desired results), whether e fforts will be voluntary or regulatory, and who will execute each program effort

• 

### Estimate program costs – develop estimates and identify entities that will bear the costs

• 

### Implement Program – starting with the most cost-effective measures and modifying activities and approach based on measured results

• 

### Assess progress – including both successes and failures (i.e., lessons learned) throughout the duration of the program

• 

### Provide follow-up – necessary to ensure P2 measures continue to be implemented

• 

### Develop a contingency plan – including a descrip tion of actions to be taken if plan efforts are unsuccessful.

The focus and approach of the program will be different for each community and sector targeted. As such, plans vary in complexity and in the re sources necessary to achi eve the goals set forth.

The reductions in mercury achievable through P2, and thus the ability to achieve compliance with numeric effluent limits using P2 alone, wi ll vary based on existing tr eatment processes, the makeup and size of the service area (e.g., number of potential mercury sources ), and the level of P2 already being implemented in the communit y. Large municipal facilities with numerous

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-11

### potential mercury sources may see significant redu ctions after implementation of a measure that targets a major influent mercury source, such as a sewer use ordinanc e requiring all dental offices to install amalgam separators. However, facilities with much smaller service areas may not be able to achieve the same reductions in th eir effluent with P2 due to a lower percent of easily identifiable and controllable sources co ntributing to the influe nt mercury load. For example, sources from the residential sector are not as easy to identify as those from industrial and commercial sectors since they may originat e from a wide range of products and smaller municipalities are likely to receive most of th eir inflow from the residential sector.

The Western Lake Superior San itation District (WLSSD) in Mi nnesota was one of the first municipalities to implement P2 for mercury, with efforts dating back to 1989. As a result of inhouse process changes and an ongoing public awar eness program, WLSSD reduced mercury in dry sludge from 4.5 ppm in 1990 to 0.9 ppm in 2001 (80% reduction). During the same period, effluent levels decreased from 0.58 μg/L to 0.005 μg/L (99% reducti on) (WLSSD, 2002).

A number of communities in California have also demonstrated results. The Mt. View Sanitary District has three dental offices, two hospita ls, and one laboratory th at discharge to the wastewater treatment plant. During an audit of the hospitals and labor atory, the District found they had all already replaced mercury containing -equipment and chemicals. In 2002, the District held onsite inspection audits at each dental office in its service area to encourage implementation of a list of BMPs. During the audits, they disc overed that two of the offices were disposing of wastes from their vacuum systems in the sink or storm drain, and advised the offending offices on the proper disposal methods. As shown in Exhibit 4-6 , after a spike in average influent concentrations between fiscal year (FY) 2001-2002 and FY 2002-2003, influent concentrations decreased by about 55% in FY 2003-2004; effluentconcentrations conti nued to decrease each year (this trend could be due to improvements in treatment performance or an increase of influent particulate mercury which is more easil y removed with conventional treatment processes and so would not significantly a ffect effluent concentrations). However, since that time, the District has not been able to identify any additional likely sources of mercury (Engler Environmental Associates, 2005). Thus, future re ductions from P2 may be more difficult to achieve, especially as the residential population in the service area increases.

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-12

### Exhibit 4-6. Average Annual Influent and Effluent Mercury Concentrations, Mt. View SD

1 10 100 1000

FY 00-01 FY 01-02 FY 02-03 FY 03-04 FY 04-05Total Mercury (ng/L) Influent

Effluent



### There are a number of known a nd controllable source of mercury. However, the effectiveness for other pollutants such as 4,4’-DDT, alpha-BHC, bis(2-ethylhexyl) phthalate, and dioxin will vary based on whether there are any existing sources in the service area or if the presence of the pollutant is due to legacy use.

Other limiting factors of P2 effectiveness could be treatment performance capability and the percent of dissolved mercury in the effluent. For traditional wastewater treatment plants (i.e., plants without advanced end-of-pipe treatment), the particulate fraction of a pollutant is more easily removed than the dissolved fraction. Ther efore, if P2 primarily reduces particulate mercury in the influent, the treatment removal efficiency may decrease because there is less particulate mercury to remove. A decrease in ef fluent removal rates associated with decreased influent loads could also be due to the mech anisms by which the pollutant is removed (e.g., settling and adsorption) reaching equilibrium (i.e., there is some minimum pollutant level that a particular treatment pro cess cannot go below).

Exhibit 4-7 shows how removal efficiencies for me rcury at EBMUD vary with influent concentrations (Mena, 2005). The data shows that, for the most part, as influent mercury concentrations decrease, the per cent of mercury removed also d ecreases. Thus, while P2 may effectively reduce influent mercury loads and the total load of mercury to the environment, the total benefits of P2 (e.g., reductions in sludge concentrations, which ma y be released to air through incineration) may not be predicted or meas ured through changes in effluent levels alone (or compliance with applicable effluent limits).

Exhibit 4-7. Influent Mercury Concen trations versus Percent Removal, EBMUD

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-1382.0% 84.0% 86.0% 88.0% 90.0% 92.0% 94.0% 96.0% 98.0% 100.0%

0 200 400 600 800 1000 1200 1400 1600 Influent Mercury (ng/L)Percent Removal



### There is little information available on the cost of P2 programs for individual pollutants because facilities typically do not account for pollutant-sp ecific P2 costs as a budget item that can be verified apart from other base program costs. However, the experiences of facilities that have already developed P2 programs for pollutants such as mercury provide some information on likely program components and costs.

Community size is likely to be a factor affecting P2 program costs. For example, it is unlikely that a minor facility would need the same am ount of resources for program development and outreach efforts as a large major municipal faci lity because the service area is smaller and contains fewer households and commercial/industri al dischargers to targ et. Smaller facilities may also pool their resources together and devel op a joint P2 program to save time and money on program development and outreach materials. Fo r this analysis, we assumed that P2 program costs for mercury may be approximately $50,000 per year for a small munici pal facility (1 mgd to 5 mgd), $100,000 for a medium-sized municipal facility ( ≥ 5 mgd to 20 mgd), and to $150,000 per year for a large municipal facility (> 20 m gd). P2 program costs for pollutants with fewer potential sources would likel y be lower ($25,000 to $50,000). Appendix B discusses the basis for these estimates.

We also estimated costs to indirect dischargers to municipal wastewater treatment plants under a mercury P2 program (see Appendix B). For othe r pollutants, identifying groups of indirect dischargers likely to be contribu ting to the influent load at the treatment plant is more difficult because the pollutants are no longer actively used (e .g., legacy pesticides), could be formed as a byproduct of numerous processes (e. g., dioxin), or there is a lack of information available. Thus, it is not possible to estimate pret reatment or P2 costs to indirect dischargers for pollutants other than mercury without specific information on the t ypes of industrial discha rgers in each service

area.

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-14June 2008 4. Method for Estimating Potential Costs: Point Sources 4-15 

### I&I Reduction Projects

The main components of an I&I reduction pr ogram are identifying sources through field investigations, designing and constructing re habilitation improvements, and monitoring postconstruction flows to determine the effectiven ess of the rehabilitati on (King County, 2005).

Identifying I&I sources can involve a wide range of field inspectio ns and testing procedures. For most collection systems, I&I is the result of defe cts in pipelines and manh ole structures or entry from connected storm sewers (Wade, 2002). Source identification ac tivities include smoke testing, manhole inspections, pipe line cleaning, closed circuit television (CCTV) inspections, dyed-water testing, building inspections, and privat e lateral inspections (Wade, 2002). The exact combination of actions depends on the size and makeup of the system and extent of the I&I problem. Wade (2007) estimates that a compre hensive study to identify I&I problems would cost approximately $2.50/ft of sewer system pipe.

The results of the source identification study dict ate the selection of re habilitation and control projects. Thirty years ago, I&I reduction projects were mainly limited to pipe replacement or construction of a parallel sewer, making repair costs prohibitive (Wade, 2002). However, today there are no-dig or trenchless construction practic es available to reduce I&I as well as project

costs. Exhibit 4-8 provides unit costs for vari ous rehabilitation options.

Exhibit 4-8. Inflow and Infilt ration Rehabilitation Unit Costs Activity Units Unit Cost Comments Pipeline Rehabilitation Linear Feet $30 - $100 Full trenchless or replacement Partial Pipeline Rehabilitation Each $1,000 - $2,500 Point repairs, partial renewal Manhole Replacement Each $2,000 - $5,000 Manhole Rehabilitation Vertical Feet $20 - $200 Grouting, coating, lining Capacity Improvements Linear Feet $50 - $150 Relief sewers (8”-15”) Wet-Weather Storage/Treatment Gallons $0.50 - $1.00 Source: Wade and Cate (2004)



### Wade and Cate (2004) indicate that basic control costs for sewer rehabilitation could be as much as $7 per linear foot of se wer pipe (2004 dollars). Escal ated to 2007 dollars, using the Engineering News Record Construction Cost In dex, unit costs would be approximately $8 per linear foot. 4 

### The useful life of sewer pipes in Or egon may range from 20 year to 50+ years (OECD, 2007). For an estimate of annual costs, we annualized total costs by 7% over 20 years.

4 Wade (2004) also estimates that the costs for a compre hensive control program that includes sewer rehabilitation and controls to handle wet weather flows (e.g., relief sewers, detention basins, and treatment plant improvements) could be three times greater than basic program costs. However, this additional level of infrastructure upgrade to accommodate increased flow for storm water control is not necessary for controlling infiltration which reduces flows.

### There are no data available evaluating the eff ectiveness of an I&I reduction program on effluent arsenic concentrations at a wast ewater treatment plant. The effectiveness of the program to reduce groundwater infiltration depends on the co mpleteness of the source identification study and the funds available to rehabilitate the system . Wade (2002) estimates that most cities should be able to reduce peak flows to the treatment plant by 30% to 50% for programs specifically designed to reduce wet-weather ove rflows and bypasses. Similar estimates are not available for reducing infiltration only, primarily because estimating the volume of flow from infiltration is difficult because it is not directly correlated with rain events; groundwater infiltration tends to be higher in winter when water usage is lower due to a higher groundwater table and vice versa in the summer (Santa Rosa, 2006).

4.4.3 End-of-Pipe Treatment



### If process optimization or s ource control would not be suffi cient for compliance with the baseline or revised criteria, al ternative discharge op tions or end-of-pipe treatment technologies may be necessary. However, at the higher altern ative fish consumption rates many of the criteria approach extremely low levels (e.g., mercury) or fall below QLs [e.g., bis(2-ethylhexyl) phthalate]. In addition, for many pollutants, th e lowest levels achievable through end-of-pipe treatment are highly uncertain due to the fact that no other discharger s have been required to treat to such low levels and performa nce data are not available.

For metals such as mercury and arsenic, technologi es that primarily target the dissolved fraction of the pollutant are most likely to achieve low effluent levels because most of the particulate fraction will already be removed with existing treat ment controls designed to remove solids (see discussion of Process Optimization). For orga nic pollutants such as 4,4;-DDT, alpha-BHC, and dioxin, similar treatment technologies can be us ed, although operating parameters may have to be adjusted to achieve optimal removal rates. Bis(2-ethylhexyl) phthala te is a semi-volatile organic pollutant that is primarily attached to particulates larger than 0.1 μm (Marttinen, et al., 2003). With such a high percentage of the pollu tant sorbed to partic ulates, the potential for biological degradation is low. Thus, treatment technologies that target removal of solids should also remove bis(2-ethy lhexyl) phthalate.

Exhibit 4-9 summarizes some of the end- of-pipe treatment technologies that could be used to remove the pollutants of concern. Note that although these technologies should theoretically be able to achieve the levels needed for compliance with the baseline and revised criteria, there is no evidence that any point source discharger to surface waters has actually implemented such controls for compliance with toxic effluent limits . Thus, there are no performance data available on which to base design criteria or to substantiate theoretical claims.

Exhibit 4-9. Summary of Potentia l End-of-Pipe Treatment Technologies Technology Pollutants Removed Comments Inorganics (e.g., arsenic and mercury), radium, pesticides, and microbial contaminants Pretreatment (e.g., microfiltration) to prevent fouling; may need multiple units in series to achieve low effluent levels. Reverse Osmosis

Metals (e.g., arsenic and mercury), nitrate, and radionuclides System would have to be optimized for removal of a specific pollutant to achieve low effluent levels. Selective Sorbents

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-16

### Exhibit 4-9. Summary of Potentia l End-of-Pipe Treatment Technologies Technology Pollutants Removed Comments Preoxidation likely necessary to achieve low effluent levels; removal rates may be highly dependent on pH and other wastewater characteristics Metals (e.g., arsenic and mercury) and phosphorus Chemical Precipitation

Refractory organics (DDT, BHC, dioxin), and volatile organics (bis(2-ethylhexyl) phthalate) Pretreatment to remove solids and prevent fouling; disposal of spent media could be costly. Granular Activated Carbon

Refractory organics (e.g., DDT, BHC, and dioxin) Destroys pollutants so that residuals management is not an issue; may result in formation of harmful byproducts. Advanced Oxidation



### Appendix C provides detailed information on each treat ment technology as well as available unit costs. Due to the uncertainty of achievable effluent levels, we did not identify any end-ofpipe treatment technologies cap able of producing the necessary effluent concentrations on a consistent and reliable basis.

4.4.4 Alternative Compliance Mechanisms



### If none of the control options discussed above would result in complia nce with baseline or revised effluent limitations, or if the costs of available treatment would be prohibitive, dischargers would likely need some form of relief from the requirements.

Site-Specific Criteria

If dischargers suspect that the ch aracteristics in the vicinity of their discharge warrant alternative criteria values (e.g., resulting in less stringent effl uent limitations in their permit), they may work to collect data for consideration by permitting authorities. ODEQ may also implement sitespecific criteria as part of a TMDL process (i.e., identifying the appropriate target value). ODEQ (2007b) indicates that site-speci fic criteria are justif iable if one of the following is true:

• 

### Species at the site are more or less sensitive than those used by EPA to develop the national recommended criteria

• 

### Physical and/or chemical char acteristics of the site alter the biological availability or toxicity of the chemical (e.g., alkalinity, pH , hardness, suspended solids, and salinity influence the concentration of the toxic form s of some heavy metals, ammonia, and other chemicals)

• 

### EPA may not have criteria recommendation for a pollutant adversely affecting the designated use of a particular water body.

The site-specific criteria must be based on sound scientific ra tionale and not affect the existing designated use (ODEQ, 2007b). EP A must also review and appr ove the criteria prior to implementation.

Because additional data are likely required to as sess the appropriateness of site-specific criteria at a particular location, the extent of use of this mechanism by dischargers is uncertain. However, consideration by ODEQ w ithin the context of a TMDL is likely, and may or may not

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-17

### reflect an incremental in crease in effort above that associated with current TMDLs (this type of data collection and evaluation may already be a part of TMDL development efforts).

Intake Credits

Under 40 CFR 122.45(g), EPA allows dischargers to re quest that effluent limits be adjusted to reflect credit for pollutants in the discharger’s intake water if either:

• 

### The applicable effluent limitations and st andards contained in 40 CFR subchapter N specifically provide that they shall be applied on a net basis

• 

### The discharger demonstrates that the cont rol system it proposes or uses to meet applicable technology-based limits and standards would, if properly installed and operated, meet the limits and sta ndards in the absence of pollu tants in the intake waters.

Intake credits will only be grante d to the extent necessary to m eet the applicable limit, up to a maximum value equal to the influent value. In most cases, intake credits will only be granted to dischargers that can demonstrate that the intake water is drawn from the same body of water into which the discharge is made. However, EPA ma y waive this requirement if no environmental degradation will result. Thus, depending on the how the water is used/altered in the treatment process and the location of intakes and outfalls, di schargers in Oregon may be eligible for intake credits.

Variances

OAR 340-041-0061(2) allows the st ate’s EQC to grant point source dischargers variances from meeting water quality standards if attaining the wa ter quality standard is not feasible for one of the following reasons:
1. Naturally occurring pollutant concentrations prevent the attainment of the use.
2. Natural, ephemeral, intermittent, or low fl ow conditions or water levels prevent the attainment of the use, unle ss these conditions may be comp ensated for by the discharge of sufficient volume of effluent discharges to enable uses to be met without violating state water conservation requirements.
3. Human-caused conditions or sources of polluti on prevent the attainment of the use and cannot be remedied or would cau se more environmental damage to correct than to leave in place.
4. Dams, diversions, or other types of hydrologi c modifications preclud e the attainment of the use, and it is not feasible to restore the water body to it s original condition or to operate such modification in a way which w ould result in the attainment of the use.
5. Physical conditions related to the natural feat ures of the water body, such as the lack of a proper substrate, cover, flow, depth, pools, riffles, and unrelated to water quality preclude attainment of aquatic life protection uses.
6. Controls more stringent than those require d by sections 301(b) a nd 306 of the federal Clean Water Act would result in substantial and widespread economic and social impact.

Note that these are the same considerations that EPA has established for changing a use that is not an existing use in a use attainability analysis.

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-18

### To demonstrate that any of the first five conditi ons above apply as part of an application for a variance, dischargers would likely prepare doc umentation of the conditions warranting the variance. For example, New Jersey Departme nt of Environmental Protection (NJDEP) was considering adopting more stringent water qua lity criteria for mercury, PCBs, and DDT. However, because the proposed criteria reflect ed extremely low concentration levels, and available analytical methods for DDT and PCBs cannot detect at such low levels, NJDEP evaluated the technologi cal feasibility of ava ilable treatment technologies for reducing these pollutants in wastewater (U.S. EPA, 2005).

Such an evaluation may require a comprehensive literature search and analysis of the data compiled from the search. The literature search may encompass general information identifying the treatment technologies capable of removing the pollutants of concern, background on the processes driving the removal or reduction of pollutants, and performance data showing the effluent levels demonstrated at pilot-, demonstration-, and full-scale wastewater treatment plants. Dischargers seeking a variance based on the thir d factor would also n eed to evaluate the feasibility of each technology as it relates to its own effluent ch aracteristics and treatment train (e.g., through a comparison of performance data a nd theoretical effluent levels cited in the literature to their own tr eatment operations).

Unfortunately, given the fact that few, if any, wa stewater treatment plants discharging to surface waters have installed advanced end-of-pipe tr eatment technologies for compliance with toxics standards, performance data will be extremely li mited. Thus, it may not be possible to determine whether any of the identified technologies could in fact achieve the desired effluent levels without collecting additional da ta or conducting studi es designed to measure the limits of performance of each technology. For this reason, dischargers may evaluate whether installing any of the identified trea tment technologies would result in a dverse economic and social impacts before conducting any pilot tests or studies.

To evaluate the potential for control costs to cause substantial and widespread economic and social impacts (the sixth condi tion above), dischargers are likel y to follow EPA’s (1995) Interim Economic Guidance for Water Quality Standa rds Workbook which provides worksheets and instructions for public and priv ate sector entities. Following EPA (1995), dischargers conduct a two-step analysis, first 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. Appendix D provides a discussion of the analysis.

Often times, permitting authorities require facilities to implement a P2 or source control program as part of the conditions for gr anting a variance. It is not cl ear whether ODEQ would require such actions when granting a variance. Ho wever, OAR 340-041-0061(2)(C) states that ODEQ may condition the variance on the performance of additional studies, monitoring, management practices, and other controls deemed necessary. T hus, to be conservative (i.e., err on the side of overestimating costs), we assumed that facilities would need to implement a P2 program as part of a variance.

Potential Costs

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-19

### The potential costs associated with pursuing a lternative compliance mechanisms will depend to some extent on the implementation procedures accompanying the final revised criteria (e.g., some states have sought to mini mize individual discharger demons trations of applicable variance factors by establishing multidischarger variance proce dures). There is also uncertainty regarding the relief mechanism and specific factors that a discharger will address. However, legal costs (often incurred by private companies) must be at tributed to discharger preferences and not the regulation, because legal services are not necessa ry to prepare the analyses or applications related to any of the a lternative compliance mechanisms discussed above.

For temporary variances from WQBELs, discharg ers are most likely to base applications on technical (factor 3) and economic (factor 6) infeasibility. Exhibit 4-10 provides estimates of levels of effort that may be associated with tech nological feasibility analyses. Note that initial efforts regarding technological f easibility may serve to reduce co sts of subsequent applications (e.g., dischargers may rely on prev iously developed materials), since the pollutants for which achieving compliance may not be technologically feasible are likely to be common across dischargers (e.g., arsenic and me rcury). Indeed, reducing cost s of individual discharger applications is the motive behind some current state procedures establishing provisions for granting multidischarger variances from WQBELs for mercury. Thus, cost may decrease over time. There is also uncertainty regarding th e extent to which such efforts represent an incremental effect attributable to revising the fish consumption rate versus efforts that dischargers will undertake routinely as part of maintaining wastewat er treatment facilities absent any regulatory changes.

Exhibit 4-10. Potential Level of Effort to Investigate Technological Feasibility Component Hours Cost 1 Literature search 180 $19,800 Write up and evaluation of theory and performance data from search 100 $11,000 Evaluation of existing treatment performance 40 $4,400 Total 320 $35,000 1. Based on a labor rate of $100/hr, reflecting the average wage rage for an environmental engineer in Oregon escalated to May 2007 dollars ($35.86; BLS, 2006; 2007a) and multiplied by a fact or of 3.03 to account for overhead, benefits, and profit (PSMJ, 2007).



### The cost associated with indi vidual applications demonstrat ing adverse economic and social impacts would likely include the cost of a preliminary engineer ing analysis (preconceptual design; detailed design work is not necessary) an d subsequent financial analysis for which EPA (1995) provides guidance and worksheets. This level of engineering analysis, in conjunction with the financial impact analyses (described in Appendix D) may vary based on facility size (larger facilities may have more alternatives a nd issues to evaluate, and more capabilities compared to smaller facilities). To provide so me indication of the potential magnitude of such costs, we assumed that dischargers will likely complete the studies and variance application within a relatively short time period (e.g., 4 mont hs) with contract labor. Assuming that the scope of a study for large faciliti es (>20 mgd) could warrant a level of effort equivalent to approximately 4 full time consultants over this amount of time (e.g., 680 hours per consultant), costs would be approximately $300,000 (at an average hourly wage rate of $110, including benefits, overhead, and fee). We assumed that the level of effort involved in completing studies and applications would be one-thi rd less for medium-sized faciliti es (>5 mgd and <20 mgd) (i.e.,

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-20June 2008 4. Method for Estimating Potential Costs: Point Sources 4-21 

### approximately $200,000), and two-thirds less (i.e., approximately $100,000) for small-sized facilities (>1 mgd to 5 mgd).

ODEQ would also have to review any requests for variances. As for dischargers, there is uncertainty regarding the extent to which variance-related efforts represent incremental effects attributable to either baselin e or revised criteria versus basic discharge-related program components. Nonetheless, assuming the State’s review of the engineer ing cost and financial impact analysis could require up to 100 hours 5 

### and the average hourly wage rate for an environmental engineer at ODEQ is $39.20 in cluding benefits ( ODEQ, 2008; BLS, 2007b) 6 

### , perreview cost to ODEQ could be approximately $3,900.

OAR 340-041-0061(2) indicates that variances only last for three years or the life of a permit, whichever is less. Costs for variance renewals for both dischargers and ODEQ are likely to be minimal.

Costs to develop analyses for site-specific crite ria would likely fall within the range for variance applications for the different factors, and inta ke credit justificati on costs would likely be minimal.

5 We assumed that the review process could take 32 hours, including validating source data, checking calculations, and evaluating the engineering design and the conclusions regarding potential financial and community impacts. ODEQ’s variance procedures also require a notification and public comment period. Based on time estimates to review and respond to comments on an individual permit issue to a single concentrat ed animal feeding operation (U.S. EPA, 2000b), we assumed that, on average, the notif ication and response to comments activities would require an average of 68 hours. T hus, the total time requirement for each request is 100 hours.

6 The average hourly rate across salary levels for an envi ronmental engineer is $26.83. The benefits multiplier from BLS (2007b) is 1.46.June 2008 5. Me thod for Estimating Potential Costs: Nonpoint Sources 5-1 

## 5. Method for Estimating Potential Costs: Nonpoint Sources

Unlike point sources, ODEQ typically does not require nonpoint sources and municipal storm water dischargers to achieve numeric WQBELs fo r human health pollutants. The regulatory baseline for evaluating the potenti al impact of the revised criter ia includes some requirements for nonpoint sources and storm water dischargers to implement BMPs and wasteload allocations as part of TMDLs (see Section 2). ODEQ has deve loped TMDLs for a number of toxic pollutants already (Exhibit 2-5) and will be developing TMDLs for others (Exhibit 2-4). However, the pollutant loading reductions and discharge concentrations that will be achieved through baseline BMPs is uncertain. Thus, there is also uncertain ty in the extent of incremental controls that could be required under the pot ential revised criteria.

5.1 Available Data

Instream monitoring data can be used to assess th e impact that a change in the fish consumption rate may have on attainment of water quality cr iteria and thus, control of potential nonpoint sources. Although not representative of all su rface waters, ODEQ’s Laboratory Analytical Storage and Retrieval (LASAR) database contai ns water quality monitoring data for the pollutants of concern. LASAR contains 3,889 water column and 676 fish tissue observations (for mercury) collected between 1997 and 2007 from locations other than point source outfalls for which there is either a reported value or detection limit. Exhibit 5-1 provides a summary of these data.

ODEQ’s 303(d) listing policy requi res at least two exceedances of water quality standards for a water to be classified as impaired and needing a TMDL (Category 5). If da ta are insufficient, but there is one exceedance, ODEQ (200 6e) indicates that the water s hould be classified as one of potential concern (Category 3B).June 20085. Method for Estimating Potential Costs: Nonpoint Sources5-2Exhibit 5-1. Summary of Select Ambient Monitoring Data1Number of ObservationsPercent of Detected Values Exceeding Criteria2PollutantNumber ofStationsTotalDetectBaseline362.3 gpd113 gpd175 gpd389 gpd620 gpd1,1,2,2-Tetrachloroethane110NANANANANANA1,1,2,2-Tetrachloroethylene110NANANANANANA1,1,2-Trichloroethane110NANANANANANA1,1-Dichloroethylene110NANANANANANA1,2,4-Trichlorobenzene220NANANANANANA1,2-Dichlorobenzene220NANANANANANA1,2-Dichloroethane110NANANANANANA1,2-Dichloropropane110NANANANANANA1,3-Dichlorobenzene220NANANANANANA1,4-Dichlorobenzene220NANANANANANA2,4,6-Trichlorophenol110NANANANANANA2,4-Dichlorophenol110NANANANANANA2,4-Dimethylphenol110NANANANANANA2,4-Dinitrophenol110NANANANANANA2,4-Dinitrotoluene110NANANANANANA2-Chloronaphthalene110NANANANANANA2-Chlorophenol110NANANANANANA4,4`-DDD2381111001001001001001004,4`-DDE2583121001001001001001004,4`-DDT2381151001001001001001004,6-Dinitro-2-methylphenol110NANANANANANAAcenaphthene220NANANANANANAAcenaphthylene220NANANANANANAAcrolein (2-Propenal)110NANANANANANAAldrin23691100100100100100100alpha-BHC291260NANANANANANAAnthracene220NANANANANANAAntimony15346829101417172831Arsenic20953468100100100100100100Benzene110NANANANANANABenzo(a)pyrene110NANANANANANABenzo[a]Anthracene220NANANANANANAJune 20085. Method for Estimating Potential Costs: Nonpoint Sources5-3Exhibit 5-1. Summary of Select Ambient Monitoring Data1Number of ObservationsPercent of Detected Values Exceeding Criteria2PollutantNumber ofStationsTotalDetectBaseline362.3 gpd113 gpd175 gpd389 gpd620 gpdBenzo[a]pyrene110NANANANANANABenzo[b]Fluoranthene220NANANANANANABenzo[k]Fluoranthene220NANANANANANABeryllium9918382100100100100100100beta-BHC23811000100100100Bis(2-chloroethyl)ether110NANANANANANABis(2-chloroisopropyl)ether110NANANANANANABis(2-ethylhexyl)phthalate110NANANANANANABromodichloromethane110NANANANANANABromoform110NANANANANANAButylbenzylphthalate110NANANANANANACarbon Tetrachloride110NANANANANANAChlordane23560NANANANANANAChlorobenzene110NANANANANANAChloroform110NANANANANANAChrysene220NANANANANANADibenzo[a,h]Anthracene220NANANANANANADibromochloromethane110NANANANANANADieldrin291387100100100100100100Diethylphthalate110NANANANANANADimethylphthalate110NANANANANANAdi-n-Butylphthalate110NANANANANANAEndosulfan sulfate110NANANANANANAEndrin18760NANANANANANAEndrin Aldehyde23740NANANANANANAEthyl Benzene110NANANANANANAFluoranthene220NANANANANANAFluorene220NANANANANANAHeptachlor23695100100100100100100Heptachlor Epoxide23815100100100100100100Hexachlorobenzene23692100100100100100100Hexachlorocyclopentadiene12320NANANANANANAExhibit 5-1. Summary of Select Ambient Monitoring Data1Number of ObservationsPercent of Detected Values Exceeding Criteria2Number ofPollutantStationsTotalDetectBaseline362.3 gpd113 gpd175 gpd389 gpd620 gpdHexachloroethane110NANANANANANAIdeno[1,2,3-cd]pyrene220NANANANANANAIsophorone110NANANANANANAMercury47730424211928407494Mercury (fish tissue)5108676648468797100100100Methylene Chloride110NANANANANANANickel206526340100000Nitrobenzene110NANANANANANAN-Nitrosodiphenylamine110NANANANANANAPentachlorophenol110NANANANANANAPyrene220NANANANANANASelenium15346735000000Thallium15346738100100100100100100Toluene110NANANANANANAToxaphene23560NANANANANANAtrans-1,2-Dichloroethylene110NANANANANANATrichloroethylene110NANANANANANAVinyl Chloride110NANANANANANANA = not applicable1. Source: ODEQ (2007c); data from 1997 and 2007. Does notinclude stations directly downstream of point sources.2. Human health criteria for consumption of water and organisms.3. Compared to existing criteria [i.e., effective human healthcriteria include criteria from OAR 2340-041-0033 Table 33A thatbecame effective February 2005 (revised criteria that becameeffective without EPA approval) and Table 20 (original criteriasince ODEQ’s 2004 proposed criteria are not effective pending EPA approval)].4. Water column data compared to potential water column criteriabased on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, andwater column translator.5. Wet weight fish tissue concentrations compared to revised fish tissue criteria.June 20085. Method for Estimating Potential Costs: Nonpoint Sources5-4June 2008 5. Method for Estimating Potential Costs: Nonpoint Sources 5-5 

### 5.2 Identifying Exceedances

Based on the data in Exhibit 5-1, most of the pollu tants with detected values have concentrations that exceed the baseline criteria 7 

### (the exception is nickel, for wh ich potential revised criteria are less stringent than baseline criter ia). Thus, source controls ar e necessary in the absence of revisions to the fish consumption rate. If such controls do not also result in compliance with the potential revised criteria, nonpoint sources could be impacted in terms of additional controls (e.g., increased rate of BMP implementation). For antimony, beta-BHC, and mercury, the percent of the data that exceeds the criteria in creases with increasing consumption rates (e.g., by a factor of 3 for antimony between baseline criteria and criteria based on the highest consumption rate). Again, higher rates of cont rol could be required if controls to achieve baseline criteria are not sufficient for compliance with potential revised criteria. However, most BMPs are not designed to achieve a specific perc ent reduction in pollutants in a manner similar to how point source controls are typically im plemented (e.g., specific treatment units in a treatment train can be operated to achieve mo re or less pollutant reductions depending on permit requirements). Thus, without more detailed da ta on the sources of the pollutants, and the instream concentrations that would be achieved from baseline levels of controls, the potential magnitude of incremental impact is uncertain.

5.2.1 Antimony



### There are 3 samples (of 29 detects) that exceed the baseline criteria , and no water bodies currently listed as impaired fo r antimony. Each of the baseline criteria exceedances are on different water bodies. Thus, based on the ex isting listing policy these waters would be of potential concern but not impaired.

There are 9 exceedances of the most stringent revised criterion (bas ed on a fish consumption rate of 620 gpd), representing 8 different water bodies . Based on the existing listing policy, only one new water body would be considered impaired fo r the revised criterion based on a consumption rate of 620 gpd; the remaining wa ter bodies would be of potential concern due to a lack of data. In addition, there would be no new listings for th e other criteria based on consumption rates of 63.2 gpd, 113 gpd, 175 gpd, and 389 gpd, only additional waters of potential concern. Thus, the data indicate that there could be an incremental impact associated with the revised criteria for antimony at a consumption rate of 620 gpd.

Antimony can enter surface waters through atmos pheric deposition (e.g., antimony released into the air by volcanoes and forest fires), soil erosion and weathe ring of antimony-containing ores and soil, and commercial or industrial processes, such as metal smelting and refining, coal-fired power plants, and refuse incineration (ATSDR, 1992). Much of the antimony found in sediment, soil, and rock is so strongly attached to dust and dirt or buried in minerals that it is unlikely to

7 Effective human health criteria in clude criteria from OAR 2340-041-0033 Table 33A that became effective February 2005 (revised criteria that became effective wit hout EPA approval) and Table 20 (original criteria since ODEQ’s 2004 proposed criteria are not effective pending EPA approval).

### enter surface waters (ATSDR, 1992). Thus, likely sources of antimony include runoff from agricultural and forest lands, storm wate r, and industrial point sources.

It is uncertain whether additional data would indi cate impairments or the need for an increase in the level of control above and beyond those needed for compliance wi th baseline standards. For example, BMPs for agricultural and forest lands required as part of the existing regulatory framework or to achieve load allocations for other pollutants could also reduce antimony loads.

5.2.2 Beta-BHC



### There is one detected concentration of beta-B HC, which exceeds the criteria for consumption rates of 175 gpd and greater. The detected value is located on Zollner Creek, which is already on the existing 303(d) list for a number of pollutants including arsenic, chlo rdane, and dieldrin. Chlordane and dieldrin are similar to BHC in th at both were found in pesticides/insecticides and are no longer used or produced (ATSDR, 2005). Thus, the potential sour ces would likely be the same and controls implemented to reduce chlo rdane and dieldrin to address the existing impairments would also likely reduce concentrations of beta-BHC. However, if additional data indicate new impairments for beta-BHC, some level of incremental controls may be needed.

5.2.3 Mercury



### Fish tissue concentrations of mercury exceed the baseline criterion of 0.3 mg/kg in 296 of 648 samples, and 3 of 242 detected samples exceed the baseline water co lumn criterion of 0.144 μg/L. These exceedances represent data from 24 water bodies, only 5 of which are on the current 303(d) list for mercury. The number of water bodies impaired based on the current listing policy would increas e with increasing fish consumption rates. Exhibit 5-2 summarizes the number of exceedances and impairments for each scenario.

Exhibit 5-2. Potential Number of Exceedances and Impairments for Mercury 1

Number of Exceedances Water Bodies of Potential Impaired Water Bodies Concern (Category 3A) (Category 5) Scenario Total Incremental 2 Total Incremental 2 Total Incremental 2 Baseline 299 NA 3 NA 21 NA 63.2 gpd 610 311 4 1 30 9 113 gpd 693 394 2 -1 3 33 12 175 gpd 744 445 5 2 36 15 389 gpd 827 528 5 2 42 21 620 gpd 827 528 5 2 42 21 NA = Not applicable 1. Includes both potential fish tissue and water column exceedances and impairments. 2. Represents the difference between total number for each scenario and baseline (i.e., incremental number above and beyond the baseline). 3. There are a greater number of exceedances for certain wa ter bodies, moving them from being of potential concern to impaired, thus, resulting in a negative incremental number of water bodies potentially of concern.



### As shown in the exhibit, the number of impair ed water bodies doubles at consumption rates of 389 gpd and 620 gpd over baseline impairments. Thus , controls above and beyond those needed for compliance with the baseline cr iteria could be needed under the revised criteria alternatives.

June 2008 5. Method for Estimating Potential Costs: Nonpoint Sources 5-6June 2008 5. Method for Estimating Potential Costs: Nonpoint Sources 5-7 

### Mercury occurs naturally as a mineral and is distributed throughout the environment by both natural and anthropogenic processes (ATSDR, 1999). Natural sources include volcanoes, geothermal springs, geologic deposits, and the oc ean. Human-related sources primarily include coal combustion, waste incineration, industrial uses, and mining (USGS, 2003). The Willamette Basin Mercury TMDL identifies runoff and erosi on from agricultural and forest lands, storm water, legacy mining, and munici pal and industrial dischargers as potential sources of mercury. Natural sources and atmospheric deposition are ge nerally difficult to control. Thus, future mercury TMDLs are likely to focus on sources similar to those identified in the Willamette Basin TMDL. Once point sources are in compliance with the revised st andards and BMPs for all other TMDLs have been implemented (see Exhibit 2-4), there may or may not be some incremental level of control above and beyond what is al ready required under ba seline conditions for compliance with the revised criteria.

5.3 Identifying Potential Comp liance Actions and Costs

Data are too limited to reliably estimate the ex tent of nonpoint source and storm water controls needed to achieve the baseline water quality stan dards and the incremental controls necessary to comply with potentially revised criteria. In addition to antimony, beta-BHC, and mercury, discussed above, there may be other pollutant s exceeding baseline and revised water quality standards for which detection leve ls are too high or da ta are unavailable. Nonpoint sources and storm water may be at least partially res ponsible for these poten tial impairments.

The magnitude of impacts attributable to the po tential revisions depend on the extent to which additional practices, more costly practices, or regulation of a greater number of sources are needed for compliance with the potential revisi ons in comparison to compliance with existing baseline standards. Appendix E provides examples of appli cable BMPs and unit costs for nonpoint sources and storm water discharges.

If an additional number of TMDLs are needed under the revised criteria, there may be an increase in government regulatory costs. For example, the data for mercury in Exhibit 5-2 indicate a potential increase of between 9 and 21 impaired waters. EPA (2001b) estimates that TMDL development costs per water body t ypically range from under $26,000 to over $500,000 depending on the number of TMDLs, their level of difficulty and the extent to which impaired waters are clustered together for TMDL development. 8 

### If ODEQ expenditures are on a similar level and TMDLs are developed for each water, ODEQ costs would range from $0.23 million to $4.5 million for revised criteria based on a fish consumption rate of 63.2 gpd and $0.55 million to $10.5 million for revised criteria based on a fish consumption rate of 620 gpd (and less if it is feasible to conduct fewer TMDLs to address all of the segments).

8 EPA (2001) anticipates that in the future, states w ill increasingly adopt efficient practices when developing TMDLs, thus potentially reducing develop costs.June 2008 6. Results of the Analysis 6-1 

## 6. Potential Compliance Costs

This section summarizes the estimates of pot ential compliance costs, and discusses the limitations and uncertainties associated with the analysis.

6.1 Point Sources

Costs for compliance with baseline criteria includ e costs to point source dischargers associated with implementation of NPDES permit limits that reflect existing criteria. Incremental costs associated with compliance with the potential revi sed criteria represent th e costs of any actions or controls above and beyond those needed to meet baseline requirements.

NPDES permits for facilities in Oregon do not cu rrently include WQBELs reflecting the baseline criteria. Thus, even in the absence of revi sed fish consumption ra tes for calculating human health criteria, some facilities will need to take actions to comply with revised permit conditions based on the existing criteria. Analysis of a sma ll sample of dischargers suggests that reductions in effluent concentrations of at least six pollutants would be needed under the baseline criteria: 4,4’-DDT, alpha-BHC, arsenic, bis(2-ethylh exyl) phthalate, dioxin, and mercury.

DDT and alpha-BHC are legacy poll utants that are no longer used or manufactured in the United States. Many surface waters in Oregon have high natural background concentrations of arsenic, and most of the sample facilities do not use or generate arsenic during wastewater treatment. Bis(2-ethylhexyl) phthalate is found mainly in plastics and is used as a plasticizer for polyvinylchloride (PVC) and other polymers. The plasticizers can be released from plastics manufacturing wastes or through release from plastic goods (Environment Canada, 1994). Bis(2-ethylhexyl) phthalate in can also be associated with samp ling and/or laboratory analysis conditions (Fairfield-Suisun SD, 2003). Di oxin is primarily a byproduct formed during chlorination by wastewater treatment plants or in the manufacture of cer tain organic chemicals (ATSDR, 1999). Sources of dioxin to and within wastewater treatment plants are difficult to control without completely elimin ating the use of chlorine throughout the service area. In fact, one municipality predicted that implementation of all identified control strategies to reduce dioxin only had the potential to reduce the load to the treatment plant by a relatively small percentage (Palo Alto, 1997). T hus, it is likely that fo r these pollutants, s ource control would be the only cost-effective treatment option, although it would not necessarily result in compliance with baseline criteria and alternative complian ce mechanisms (such as intake credits or a variance) may be needed.

Mercury is the only pollutant for which reductions would be needed for the sample facilities to comply with baseline criteria that is activel y used in a number of industrial and commercial applications. Thus, controlling mercury though P2 or source controls programs would not only be cost-effective but could also result in the reductions needed for baseline compliance.

Thus, given these considerations , we identified the most likel y compliance scenarios under the baseline to include:

• 

### 4,4’-DDT – alternative compliance mechanis m (such as variance with P2 program)

• 

### Alpha-BHC – alternative compliance mechan ism (such as variance with P2 program)• 

### Arsenic – alternative compliance mechanism (such as intake credits or site specific criteria)

• 

### Bis(2-ethylhexyl) phthalate – cl eaner sampling or P2 program

• 

### Dioxin – alternative compliance mechanism (such as variance with P2 program)

• 

### Mercury – P2 program.

The analysis of the sample dischargers also indica ted that an incremental level of control may be needed to achieve criteria for the following pollutants under revised fish consumption rates: arsenic, bis(2-ethylhexyl) phtha late, and mercury. We identified the most likely compliance scenarios for the revised criteria to include:

• 

### Arsenic – alternative compliance mechanism (such as a variance)

• 

### Bis(2-ethylhexyl) phthalate – cl eaner sampling or P2 program

• 

### Mercury – P2 program with or without alternative compliance mechanism (such as a variance).

In addition, since the source of arsenic in municipal wastewater may be from contaminated groundwater leaking into the sewer system, I&I c ontrols might enable compliance with baseline and revised criteria. We estimated the potential cost of such actions based on unit costs from a consulting firm specializing in I&I reduction programs, although such a scenario may be unlikely for compliance with WQBELs alone. I&I reduc tion may be needed for other reasons (reduce flow to treatment plant, which reduces treatment costs, and to reduce sewer overflows). Indeed, state infrastructure needs include I&I reducti on at a number of municipal systems (OECDC, 2007).

The cost associated with pursuing alternative compliance mechanisms is uncertain because the particular mechanism is unknown. Implemen tation procedures accompanying the revised criteria may affect compliance scenarios. ODE Q (2005) also identifies a need to address the high natural background arsenic c oncentrations through various st rategies for performing RP analyses and setting WQBELs, such as allowing gr eater than 25% of the st ream flow for dilution calculations or basing requirements on the relative source contribution of a particular discharger. For this analysis, we estimated costs based on pursuing a variance as an individual discharger, which may represent the most costly of potentia l alternative compliance mechanisms that may ultimately be pursued.

Exhibit 6-1 provides a summary of the potential total and increm ental (i.e., above and beyond those needed for compliance with baseline standa rds) annual statewide costs, both with and without the costs for I&I controls to reduce arse nic in municipal sewer systems. In addition, one-time expenditures associated with variance applications could range from $1.43 million to $7.05 million under the baseline; incremental vari ance-related expenditures could range from $0.59 million to $2.68 million under revised criteria. Appendix F shows the derivation of these estimates from the sample facility results.

Exhibit 6-1. Summary of Potential A nnual Compliance Costs (millions of $2007)

Total Incremental 1 Scenario With I&I Costs 2 No I&I Costs With I&I Costs 2 No I&I Costs Baseline $3.62 - $29.7 $3.62 - $3.92 NA NA 63.2 gpd $3.69 - $29.8 $3.69 - $4.04 $0.075 - $0.13 $0.075 - $0.13

June 2008 6. Results of the Analysis 6-2

### Exhibit 6-1. Summary of Potential A nnual Compliance Costs (millions of $2007)

Total Incremental 1 Scenario With I&I Costs 2 No I&I Costs With I&I Costs 2 No I&I Costs 113 gpd $3.96 - $30.1 $3.96 - $4.31 $0.35 - $0.40 $0.35 - $0.40 175 gpd $3.96 - $31.0 $3.96 - $4.36 $0.35 - $1.32 $0.35 - $0.45 389 gpd $4.46 - $31.6 $4.46 - $4.86 $0.85 - $1.82 $0.85 - $0.95 620 gpd $4.46 - $31.6 $4.46 - $4.86 $0.85 - $1.82 $0.85 - $0.95 NA = Not applicable 1. Represents the difference between total annual cost and bas eline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria). 2. High estimate includes cost of I&I to reduce arsenic in municipal sewer systems.



### Under both the baseline and revise d criteria scenarios, there ar e no pollutant load reductions associated with alternative compliance mechanisms su ch as intake credits and variances. Even if ODEQ requires dischargers to implement P2 pr ograms as a condition of a variance, load reductions could still be minimal especially fo r legacy pollutants for which there may be no active, easily identifiable sources. Even for a pollutant such as mercury for which sources are relatively easy to identify and P2 can be a co st-effective control option, there is uncertainty regarding the load reductions ac hievable through such actions . At some point, additional individual facility P2 program activities and e xpenditures may not provide additional reductions. Because there are currently no proven end-of-pip e treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consistent basis, dischargers may pursue a variance (e.g., based on manmade conditions that cannot be reme died or economic fact ors). Thus, as the criteria become more stringent (due to higher fish consumption rates), potential load reductions may become constant because additional redu ctions may be infeasible at this time.

The compliance costs will be incurred as ODEQ renews discharger permits and updates TMDLs to reflect the revised criteria, which may occur at different times for different entities. NPDES permits are for five years, and compliance is upon permit adoption. The “annual” compliance costs in the report are rough order of magnitude es timates of the annual level of expenditures (the annual level of capital outlay or annualized capital cost s, and annual operations and maintenance) needed to maintain full complian ce. These costs do not drop to zero because the useful life of capital is limited and will continue to need replacement to maintain the level of pollution control. For example, I&I control may require continued capital outlays. For P2, there are likely to be continual ch allenges (e.g., changes in the comm unity discharging to the sewer system) in maintaining compliance. However, t echnological capabilities w ill also change in the future.

The costs for minor dischargers ar e highly uncertain because there is a lack of data to evaluate effluent quality. However, for municipal minor s, ODEQ (2005) indicates that only domestic sources with a dry weather design flow greater th an 1 mgd must sample for toxic pollutants. Thus, unless this requirement changes, it is unl ikely that minor munici pal dischargers would incur costs for compliance with the baseline or revi sed criteria.

For minor industrial dischargers, ODEQ (2005) indicates that industrial dischargers subject to effluent limitation guidelines would be required to monitor for toxic po llutants. However, effluent toxics data from one of the sample f acilities (Oregon Steel Mills) indicates that most

June 2008 6. Results of the Analysis 6-3

### toxics are not likely to be presen t at levels of concern, and thos e that may be (e.g., arsenic) may not contribute signifi cantly to receiving water concentra tions, resulting in BMP requirements rather than numeric WQBELs. Thus, costs to minor industrial facilities for compliance with baseline or revised criteria could be minimal depending on st ate implementation procedures.

Nonetheless, one potential pollutant of concer n for minor municipal dischargers however is mercury. Under the 620 gpd alternative fish c onsumption rate, the revised mercury criterion could be below the detection level of 0.005 μg/L . Due to its ubiquitous nature in the environment (e.g., mercury is found in many house hold products and can be excreted in human waste because of mercury in dental fillings), it may be unlikely that any municipal discharger would be able to consistently achieve nondetect effluent levels wit hout implementation of controls. Thus, if ODEQ were to require mon itoring by minor municipals under such a scenario, these facilities might need to implement P2 fo r compliance. Annual P2 costs might range from 10% to 50% of the P2 cost for small major facilit ies, with the range reflecting the potential for piggybacking on the efforts of other nearby facilities. Thus, total annual costs for all 157 minor municipal dischargers for compliance with merc ury criteria based on consumption of 620 gpd of fish could range from $0.8 million to $3.9 million. This may be a conservative estimate given the current lack of monitoring requirements fo r toxic pollutants for municipal dischargers less than 1 mgd.

Indirect dischargers to municipa l wastewater treatment plants c ould also incur costs associated with the baseline and revised criteria if the m unicipality imposes more stringent pretreatment standards or requirements on these dischargers in an effort to re duce effluent loads. However, indirect dischargers of pollutants for which a municipal wastewater tr eatment plant would not have RP or need to reduce effluent loads would not be affected. To account for these potential costs, we estimated costs to indirect discharger s to municipal wastewater treatment plants under a mercury P2 program (discussed in Appendix B) . For other pollutants, identifying groups of indirect dischargers likely to be contributing to the influent lo ad at the treatment plant is more difficult because the pollutants are no longer activ ely used (e.g., legacy pesticides), could be formed as a byproduct of numerous processes (e.g., dioxin), or there is a lack of site-specific information available for each discharger to id entify where the pollutant is originating [e.g., arsenic, bis(2-ethylhexyl) phthalate ]. Thus, it is not possible to es timate pretreatment or P2 costs to indirect dischargers for po llutants other than mercury with out specific information on the types of industrial discharger s in each service area.

6.2 Nonpoint Sources and Storm Water

Costs for compliance with baseline criteria incl ude costs to nonpoint s ources (e.g., agricultural and forest operations; contamination from hist oric mining sites), and municipal storm water sources associated with implementation of ex isting programs and TMDLs. Incremental costs associated with compliance with the potential revi sed criteria represent th e costs of any actions or controls above and beyond those needed to meet baseline requirements.

Under the baseline, control costs for these includ e those needed to redu ce instream pollutant levels to baseline criteria or TMDL targets. Existing regulatory programs have not been fully implemented, and the extent of implementation effo rts is uncertain. Thus, the additional controls

June 2008 6. Results of the Analysis 6-4

### needed for compliance under the baseline cannot be estimated. There are, however, indications that baseline compliance costs for nonpoint s ources and storm water discharges could be substantial. For example, given the impairment status of waters throughout the state for mercury based on existing data and the fact that point sour ce dischargers are not likely to be significant sources of mercury to those waters, it is possi ble that nonpoint source controls are needed to improve water quality to m eet baseline criteria.

There could also be incremental costs to nonpoi nt and storm water sources associated with meeting new or revised load allocations. However, because baseline programs have not yet been fully implemented, it is uncertain whether some in cremental level of cont rol would be necessary for compliance with the revised criteria. For any s ituation in which controls beyond those required under the baseline are neces sary, controls could include:

• 

### Agricultural and forest lands – sediment and erosion controls beyond those specified under existing state and fede ral regulations and plans

• 

### Mining – cleanup and remediation includi ng excavation and onsite capping of contaminated soils, capping of onsite solid waste mining debris, regrading of tailings to mitigate mass wasting and off-site migration, and abatement and mitigation of physical hazards

• 

### Storm water discharges – incr eased or additional nonstructura l BMPs (e.g., institutional, education, or pollution prevention practices de signed to limit generation of runoff or reduce the pollutants load of runoff); and structural controls (e.g., engineered and constructed systems designed to provide water quantity or quality control).

6.3 Government Regulatory Costs

Identifying the full scope of regulatory program costs associated with implementing existing criteria and programs is outside th e scope of this analysis. There is also substantial uncertainty associated with identifying any incremental impact of revised criteria, since the baseline is not fully implemented. Finally, there is uncertainty regarding the attributi on of regulatory program expenditures to criteria revisions. However, as the fish consumption rate increases, the applicable human health criteria decrease, which could result in more stringent and infeasible permit limits for point sources, and incremental impairments and need for TMDL development under the revised criteria.

If dischargers pursue variances for compliance wi th permit limits for mercury, arsenic, bis(2- ethylhexyl) phthalate, DDT, alpha-BHC, and di oxin, ODEQ costs associated with application review may range from $159,000 under the baseline to $65,000 under the revised criteria. For the most part, data are too limited to identify incremental impairments. For one pollutant, mercury, available ambient monitoring data indi cate a potential increase of 9 TMDLs at a consumption rate of 63.2 gpd and 21 TMDLs at a c onsumption rate of 620 gpd. If, for example, TMDL development costs range from approximately $26,000 to $500,000, this implies an increased level of expenditure of between $0.23 million and $4.5 million for mercury at a consumption rate of 63.2 gpd, and $0.55 million to $10.5 million for mercury at a consumption rate of 620 gpd. Note that th e variance application review and TMDL development costs would not be incurred in any single year; rather, the co st would be spread out over several years (e.g., 5 or 10 year time period).

June 2008 6. Results of the Analysis 6-5

### 6.4 Uncertainties in the Analysis

There are a number of uncertainties in the analys is associated with data limitations, potential pollutant load reductions achievable, and how dischargers would respond to potential revised requirements and permit conditions that affect the estimated costs.

6.3.1 Data Limitations



### The lack of available data for both point and nonpoint sources adds uncerta inties to the analysis of potential costs associat ed with compliance with the revised criteria.

Point Sources

Data are not available for all pollu tants for all sample facilities. Without data, we are not able to determine whether the facility is in compliance with baseline standards and whether incremental controls would be needed for compliance with revised criteria. For example, the Eugene Springfield WWTP data does not contain effluent measurements for mercury and arsenic, the two pollutants for which other major municipal facilities would incur the greatest compliance costs. Thus, costs could be higher than shown if additional data indicates a need for pollutant reductions.

For several facilities with effluent data, the data available are limited. For example, there is only one data point for each pollutant for Oregon St eel Mills. Additional data could result in compliance cost estimates higher or lower than shown.

We are also lacking effl uent flow data from which to calculate appropriate human health dilution factors. In those instances we used chronic aq uatic life dilution factor s based on the 7Q10 flow, rather than the 30Q5 or harmonic mean stream fl ow. The 7Q10 flow is often less than the 30Q5 and harmonic mean flows; thus, more dilution ma y be available, which means estimated costs may be overstated.

In estimating baseline control costs, facility permits and ev aluation reports do not provide detailed information on the extent of controls and activities already underway. Thus, baseline costs could be overestimated because facilities may already be implementing controls to address issues such as I&I and P2 programs. For so me facilities, we had information on existing activities, and could reduce base line control costs accordingly. Facility permits and evaluation reports also lack sufficient information on the sour ces of pollutants in a f acility’s influent. For example, permits often state the number of signi ficant industrial users to a plant, but do not describe the types of industries. Without such in formation, it is difficult to determine whether P2 or stricter pretreatment controls would effectively reduce pollutant concentrations.

Nonpoint Sources

The lack of available instream monitoring data prevents the estimation of potential statewide costs associated with reductions in pollutant load s from nonpoint sources. Additional data could show that some incremental leve l of control on nonpoint sources and storm water discharges is

June 2008 6. Results of the Analysis 6-6

### needed to meet the revised standards. Howeve r, without more information, the magnitude of those costs cannot be estimated.

There is also a lack of data re garding pollutant reductions that have already been or are being achieved with the implementation of BMPs to address existing impairments for conventional pollutants such as temperature and dissolved oxyge n. Attainment of standards for these types of pollutants could also result in atta inment of the baseline and revise d criteria for t oxic pollutants, negating the need for additional controls on nonpoint sources.

6.3.2 Load Reductions



### There is uncertainty regardi ng the pollutant loading reducti ons that would result from compliance with baseline and revi sed criteria. As the criteria become more stringent under increasing consumption rates, the feasibility of compliance with revised effluent limitations may decrease for some pollutants (e.g., mercury) that are ubiquitous in the environment and for which end-of-pipe treatment to very low levels is unp roven. If compliance is not feasible, pollutant load reductions may be minimal.

Detection limits also add uncertainty to the estimated load reductions under more stringent criteria. If the revised criteria are below the QL , dischargers would only be required to treat to the QL (e.g., arsenic) because levels lower than that could not be measur ed. Thus, there may not be measurable or quantifiable incremental pollutant load redu ctions from wastewater point sources associated with more stri ngent human health criteria.

6.3.3 Response to Revised Requirements



### For point sources, we assumed that facilities wo uld pursue the lowest cost option for compliance with either baseline or revised criteria. However, it is uncertain whether any particular control option would guarantee compliance. For example, the effluent reductions achievable through P2 activities and the level of effort needed for compliance are highly site-specific and cannot be estimated without a detailed analysis of the f acility’s service area and existing plant processes and operations. In some cases, facilities may di scover than treatment chemicals are contributing to mercury effluent levels, and switching to another manufacturer or chemical results in compliance. In others, extensive P2 may not be sufficient and an alternative compliance mechanism (such as a variance) would be necessary.

In addition, the costs of controls are likely facility-specific a nd may be higher or lower than shown. For example, we assumed a single unit co st for pipe rehabilita tion for I&I reduction program costs. Results of source identification determine the control measures needed to reduce I&I to a sewer system. Thus, it is uncertain ho w much system rehabilitation will cost until the source identification study is complete.

Dischargers may also explore more holistic appr oaches that address pr oblems in addition to compliance with the revised criteria which mean s costs may be overstated. For example, to address an increasing demand in water supply (d ue to increases in population and changes in climate), the Orange County wate r and sanitation districts partne red together to implement an advanced water purification pr oject known as the Groundwater Re plenishment (GWR) System.

June 2008 6. Results of the Analysis 6-7

### The GWR system purifies highly treated sewer effl uent to replenish groundwater supplies. The system provides a new reliable, high-quality wa ter supply for north and central Orange County, eliminates any immediate need for another ocea n outfall pipe for wastewater, diversifies local water supplies, and over time, will help lower the mineral content in the groundwater basin (GWRS, 2008). Industrial dischargers may also make changes that could indirectly affect effluent quality to deal with issues such as energy usage and raw material suppliers.

For both point and nonpoint sources, we assumed th at in some cases base line controls would result in compliance with revised criteria. It is not clear at which consumption rates the criteria would become low enough to warrant additional controls above and beyond those needed for compliance under the baseline, or whether additional reductions are feasible.

June 2008 6. Results of the Analysis 6-8June 2008 7. References 7-1 

## 7. References

Agency for Toxic Substances and Disease Regist ry (ATSDR). 2005. Toxicological Profile for Alpha-, Beta-, Gamma-, and Delta -Hexachlorocyclohexane. August.

Agency for Toxic Substances and Disease Regi stry (ATSDR). 1999. Toxicological Profile for Mercury. April.

Agency for Toxic Substances and Disease Regi stry (ATSDR). 1992. Toxicological Profile for Antimony and Compounds. September.

Bureau of Labor Statistics (BLS). 2006. Stat e Occupational Employment and Wage Estimates Oregon. Online at http://www.bl s.gov/oes/current/oes_or.htm.

Bureau of Labor Statistics (BLS). 2007a. Empl oyment Cost Index Histor ical Listing Current. Employment Cost Index for Wages and Salaries, All Civilians, Profession and Related (not seasonally adjusted).

Bureau of Labor Statistics (BLS). 2007b. Em ployer Costs for Employee Compensation. Table 3. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: State and local government work ers, by major occupational and industry group, September 2007, Management, professi onal and related. Online at http://www.bls.gov/news.release/pdf/ecec.pdf.

Engler Environmental Associates. 2005. A nnual Pollution Prevention Report for July 2004 – June 2005. Prepared for the Mountain View Sanitation District.

Groundwater Replenishment Syst em (GWRS). 2008. Examining the Cost of Building and Operating a Water Purification Sy stem to Provide a New Source of Water for an Arid Region.

King County. 2005. Benefit/Cost Analysis Repor t: Regional Infiltration and Inflow Control Program King County, Washington. Prepar ed by Earth Tech Team. November.

Marttinen, S.K, A. Riitta, H. Kettunenb, and J.A. Rintalaa. 2003. Occurrence and Removal of Organic Pollutants in Sewages and Landfill Leacha tes. The Science of the Total Environment: Volume 301, Issues 1-3, pages 1-12.

Mena, Deirdre. 2005. East Bay Municipal Utilit ies District Wastewater Department. Personal communication. June.

Oregon Department of Agriculture (ODA). 2007. Water Quality and Agriculture. February.

Oregon Department of Environmental Quality (O DEQ). 2008. Salary Schedule. Online at http://www.deq.state.or.us/ msd/hr/salaryschedule.pdf

.

### Oregon Department of Environmental Qual ity (ODEQ). 2007a. 2007-2011 DEQ Mercury Reduction Strategy. March.

Oregon Department of Environmental Quality (O DEQ). 2007b. Use Attain ability Analysis and Site-Specific Criteria Internal Ma nagement Directive. April.

Oregon Department of Environmental Quality (O DEQ). 2007c. Laboratory Analytical Storage and Retrieval (LASAR): Web Application. Online at http://deq12.deq.state.or.us/lasar2/

.

Oregon Department of Environmental Quality (ODEQ). 2006a. Fact Sheet: Oregon’s Abandoned Mine Cleanups Complicated by High Cost and Lack of Funding. March.

Oregon Department of Environmental Quality (O DEQ). 2006b. Chapter 3: Willamette Basin Mercury TMDL. September.

Oregon Department of Environmental Quality (ODEQ). 2006c. Willamette Basin TMDL - Chapter 14: Water Quality Management Plan. September.

Oregon Department of Environmental Quality (ODEQ). 2006d. Water Quality Assessment – Oregon’s 2004/2006 Integrated Re port Database. Online at http://www.deq.state.or.us/wq /assessment/rpt0406/search.asp

.

Oregon Department of Environmental Quality (ODEQ). 2006e. Assessment Methodology for Oregon’s 2004/2006 Integrated Report on Water Quality Status.

Oregon Department of Environmental Quality (O DEQ). 2005. Reasonable Potential Analysis for Toxic Pollutants Internal Mana gement Directive. September.

Oregon Department of Environmental Qualit y (ODEQ). 2004. Guidance Document for Preparation of the NPDES Strom Wat er Pollution Control Plan. May.

Oregon Department of Environmental Qual ity (ODEQ). 1998. Columbia Slough Total Maximum Daily Loads (TMDLs) for Chloroph yll a, Dissolved Oxygen, pH, Phosphorus, Bacteria, DDE/DDT, PCBs, Pb, Dieldr in and 2,3,7,8 TCDD. September.

Oregon Department of Environmental Quality (ODEQ). 1991. Total Maximum Daily Loading to Limit Dischargers of 2,3,7,8-TCDD (Dioxin) to the Columbia River Basin. February.

Oregon Department of Environmental Quality (O DEQ) and Idaho Department of Environmental Quality (IDEQ). 2003. Snake River - Hells Ca nyon Total Maximum Daily Load (TMDL). July.

Oregon Department of Forestry (ODF). 2007a. Oregon Department of Forestry Forest Practice Administrative Rules and Fore st Practices Act. January.

Oregon Department of Forestry (ODF). 2007b. Forest Practice Notes: Chemicals and Other Petroleum Products. August.

June 2008 7. References 7-2

### Oregon Department of Forestry (ODF). 2000. Oregon Department of Forestry: Aerial Pesticide Application Monitoring - Final Report. March.

Oregon Economic and Community Development Commission (OECDE). 2007. Inventory of Infrastructure Needs in the State of Oregon. A ppendix J: Water, Sewer, Stormwater projects needed to address State/Federal Requirem ents or to Replace Antiquated Systems.

PSMJ Resources, Inc. 2007. 2007 PSMJ A/E Financial Performance Survey, 27th Edition: CEO Snapshot.

Santa Rosa. 2006. Inflow and Infiltration Study : City of Santa Rosa. January. Online at http://ci.santa-rosa.ca.us/ docLib/Documents/IIStudyJan06.pdf

.

United States Environmental Protection Agency (U.S. EPA). 2008. Enforcement & Compliance History Online (ECHO). Search Help: Facility Designation (Water Searches only). Online at http://www.epa-echo.gov/echo/help_all_programs.html

.

United States Environmental Protection Agency (U.S. EPA). 2007. Permit Compliance System (PCS) Database. Online at http://www.epa.gov/enviro/html/pcs/adhoc.html

.

United States Environmental Protection Agency (U.S. EPA). 2005. Technol ogical Feasibility of Proposed Water Quality Criteria for New Jersey. Prepared for U.S. EPA Region 2. Prepared by Science Applications Intern ational Corporation. March.

United States Environmental Protection Agen cy (U.S. EPA). 2002. National Recommended Water Quality Criteria: 2002. Human Health Cr iteria Calculation Ma trix. EPA 822-R-02-012. November.

United States Environmental Protection Agency (U.S. EPA). 2001a. Water Quality Criterion for the Protection of Human Health: Me thylmercury. EPA-823-R-01-001. January.

United States Environmental Protection Agency (U.S. EPA). 2001b. The National Costs of the Total Maximum Daily Load Program (Dra ft Report). EPA 841-D-01-003. August.

United States Environmental Protection Agency (U.S. EPA). 2000a. Methodology for Deriving Ambient Water Quality Criteria for the Prot ection of Human Health. EPA 822-B-00-004. October.

U.S. Environmental Protection Agency (EPA). 2000b. Supporting Statement for the Information Collection Request for the Proposed Regulatory Revisions to the National Pollutant Discharge Elimination System Regulations for Concentrated Animal Feeding Operations and Feedlot Effluent Limitations Guidelines.

United States Environmental Protection Agency (U.S. EPA). 1995. Interim Economic Guidance for Water Quality Standards Work book. EPA 823-B-95-002. March.

June 2008 7. References 7-3

### United States Environmental Protection Agen cy (U.S. EPA). 1991. Technical Support Document for Water Quality-based Toxi cs Control. EPA/505/2-90-001. March.

United States Environmental Protection Ag ency (U.S. EPA). 1980. Guidelines and Methodology Used in the Preparation of Health Effect Assessm ent Chapters of the Consent Decree Water Criteria Documents. Fe deral Register 45: 79347, Appendix 3.

U.S. Geological Survey (USGS) . 2003. Mercury in Stream Ecos ystems—New Studies Initiated by the U.S. Geological Survey. March.

Wade, Mark. G. 2007. Personal communication. November 11, 2007.

Wade, Mark G. 2002. Controlling Inflow and In filtration in Wastewater Collection Systems. Presented at Convergence 2000, Ju ly 23-26. Kansas City, MO.

Wade, Mark G. and Clifford K. Cate. 2004. Funding Dilemma: CMOM’s Evil Witch of the West. Presented at the Underground Infras tructure Advanced Technology Conference, December 6-7, 2004. Washington D.C.

Western Lake Superior Sanitary District (WLSSD). 2002. Blueprint for Mercury Elimination.

June 2008 7. References 7-4June 2008 Appendix A. Facility Analyses A-1 

## Appendix A. Facility Analyses

Facility Name Page # Major Municipals Astoria WWTP A-2 Brookings WWTP A-9 Coos Bay WWTP #2 A-10 Eugene Springfield WPCF A-17

Kellogg Creek WWTP A-22

McMinnville WRF A-31 North Bend WWTP A-39 Portland Columbia Boulevard WWTP A-45 Rock Creek WWTP A-57 Salem Willow Lake WWTP A-64 St. Helen-Boise Cascade WWTP A-75 Tri-City Service District A-83

Woodburn WWTP A-92 Minor Municipals City of Shady Cove WWTP A-99 Major Industrials Blue Heron Paper Company A-100 Heinz Food Company A-106 Pope and Talbot Inc. A-107 Reynolds Metals Company A-114 Minor Industrials Boise Cascade, Elgin Sawmill A-116 Oregon Steel Mills A-118

### City of Astoria Wastewater Treatment Plant

Facility Description

The City of Astoria Wastewater Treatment Plant (NPDES permit number OR0027561) was built in 1974 and serves a population under 10,000. The f acility was originally designed to treat wastes from canneries as well as domestic wast ewater, although the canne ries are no longer in service. ODEQ classifies this 4.2 mgd (ADWDF) f acility as a major discharger. The facility discharges treated effluent into the Columbia River at river mile 18.0. The facility does not treat effluent from any categoric al or significant industri al users, and therefore is not required to have a federal pretreatment program. However, ODEQ has requested th at the facility conduct an industrial waste survey from wh ich it may reevaluate the need for a pretreatment program.

Treatment Processes

The 2001 NPDES permit for the facility lists curr ent treatment processes as headworks, two aerated lagoons, a polishing lagoon, and chlorine cont act chamber. The headworks consists of a bar screen and a Parshall flume flow meter. The aerated lagoons are 6.8 acres (22 million gallons) and 5.8 acres (18.9 million gallons) each and ar e operated in series. There is also a 7.6 acre polishing lagoon. The permit indicates that the lagoons have not been dredged for sludge.

Effluent Data and Limits

Exhibit A-1 summarizes monitoring data from September 2003 to September 2006 for those pollutants of concern for which effl uent data are available. The f acility does not have effluent limits for any toxic pollutants.

Exhibit A-1. Effluent Data Summary, City of Astoria 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 3 3 0.003 - - - 1,1,2-Trichloroethane 3 3 0.002 - - - 1,1-Dichloroethylene 3 3 0.005 - - - 1,2,4-Trichlorobenzene 2 2 0.005 - - - 1,2-Dichlorobenzene 3 3 0.002 - - - 1,2-Dichloroethane 3 3 0.002 - - - 1,2-Dichloropropane 3 3 0.002 - - - 1,2-Trans-Dichloroethylene 3 3 0.003 - - - 1,3-Dichlorobenzene 3 3 0.002 - - - 1,4-Dichlorobenzene 3 3 0.002 - - - 2,4,6-Trichlorophenol 4 4 25 - - - 2,4-Dichlorophenol 4 4 25 - - - 2,4-Dimethylphenol 4 4 25 - - - 2,4-Dinitrophenol 4 4 62.5 - - - 2,4-Dinitrotoluene 2 2 0.005 - - - 2-Chloronaphthalene 2 2 0.005 - - -

June 2008 Appendix A. Facility Analyses A-2June 2008 Appendix A. Facility Analyses A-3 

### Exhibit A-1. Effluent Data Summary, City of Astoria 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2-Chlorophenol 2 2 0.005 - - - 2-Methyl-4,6-Dinitrophenol 3 3 62.5 - - - 3,3'-Dichlorobenzidine 3 3 0.005 - - - 4,4'-DDD 3 3 0.2 - - - 4,4'-DDE 3 3 0.5 - - - 4,4'-DDT 3 3 0.5 - - - Acenaphthene 3 3 0.005 - - - Acrolein 3 3 0.01 - - - Acrylonitrile 3 3 0.01 - - - Aldrin 3 3 0.5 - - - alpha-BHC 3 3 0.5 - - - Anthracene 3 3 0.005 - - - Antimony 3 0 - 0.61 0.33 0.19 Arsenic 10 1 5 1.05 0.61 0.32 Benzene 3 3 0.003 - - - Benzidine 3 3 0.06 - - - Benzo(a) Anthracene 3 3 0.005 - - - Benzo(a) Pyrene 3 3 0.005 - - - Benzo(b) Fluoranthene 3 3 0.005 - - - Benzo(k) Fluoranthene 3 3 0.005 - - - Beryllium 3 3 0.1 - - - beta-BHC 3 3 0.5 - - - Bis(2-Chloroethyl) Ether 3 3 0.005 - - - Bis(2-Chloroisopropyl) Ether 3 3 0.01 - - - Bis(2-Ethylhexyl) Phthalate 3 1 0.01 0.073 0.028 0.011 Bromoform 3 3 0.02 - - - Carbon Tetrachloride 3 3 0.003 - - - Chlordane 3 3 25 - - - Chloroform 3 3 0.002 - - - Chrysene 3 3 0.005 - - - Dibenzo(a,h)Anthracene 3 3 0.005 - - - Dichlorobromomethane 3 3 0.005 - - - Dieldrin 3 3 0.5 - - - Diethyl Phthalate 3 3 0.005 - - - Dimethyl Phthalate 3 3 0.005 - - - Di-n-Butyl Phthalate 3 3 0.01 - - - Endosulfan Sulfate 3 3 1 - - - Endrin 3 3 0.5 - - - Endrin Aldehyde 3 3 0.5 - - - Ethylbenzene 3 3 0.002 - - - Fluoranthene 3 3 0.005 - - - Fluorene 3 3 0.005 - - - Gamma-BHC (Lindane) 3 3 0.04 - - - Heptachlor 3 3 0.5 - - -

### Exhibit A-1. Effluent Data Summary, City of Astoria 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 Geometric Maximum Minimum (μg/L) Mean Heptachlor Epoxide 3 3 0.5 - - - Hexachlorobenzene 3 3 0.005 - - - Hexachlorobutadiene 3 3 0.01 - - - Hexachlorocyclopentadiene 3 3 0.01 - - - Hexachloroethane 3 3 0.01 - - - Ideno(1,2,3-cd)Pyrene 3 3 0.005 - - - Isophorone 3 3 0.005 - - - Mercury 9 0 - 0.042 0.016 0.006 Methylene Chloride 3 3 0.003 - - - Nickel 10 1 20 7.52 4.80 3.84 Nitrobenzene 3 3 0.005 - - - N-Nitrosodimethylamine 3 3 0.005 - - - N-Nitrosodi-n-Propylamine 3 3 0.01 - - - N-Nitrosodiphenylamine 3 3 0.005 - - - PCBs 3 3 3 0.5 - - - Pentachlorophenol 4 4 25 - - - Phenol 6 6 100 - - - Pyrene 3 3 0.005 - - - Selenium 3 1 0.5 1.13 0.90 0.72 Tetrachloroethylene 3 3 0.002 - - - Thallium 3 2 0.1 0.14 0.14 0.14 Toluene 3 1 0.002 0.019 0.0094 0.005 Toxaphene 3 3 25 - - - Trichloroethylene 3 3 0.02 - - - Vinyl Chloride 3 3 0.02 - - - QL = Quantification limit. 1. Represents effluent data from Sept 2003 to Sept 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

There are no upstream ambient receiving water data available for this facility.

Potential Impacts

Baseline Criteria



### Exhibit A-2 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Columbia River at river mile 18 is estuarine; thus, human health criteria for consumption of organisms only are applicable. Flow data from which to calculate the harmonic mean or 30Q5 flows are not available, however, based on the facility’s existing pe rmit, the dilution factor is 35.

June 2008 Appendix A. Facility Analyses A-4

### The Columbia River at river mile 18 is on the state’s 303(d) list as impaired for DDE, dioxin, and PCBs; thus, the discharger would not receive dilution for these pollutants.

Exhibit A-2. RPA for Base line Criteria, Astoria WWTP

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) Antimony 1.83 0 0.052 640 No Arsenic 0.89 0 0.026 0.0175 Yes Bis(2-Ethylhexyl) Phthalate 0.084 0 0.0024 2.2 No Mercury 4 0.074 0 0.0021 0.017 No Nickel 9.41 0 0.27 100 No Selenium 3.39 0 0.097 4200 No Thallium 0.42 0 0.012 0.47 No Toluene 0.057 0 0.0016 15000 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants except ar senic (CV = 0.39), mercury (CV = 0.57), and nickel (CV = 0.23) (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on facility’s existing permit (factor = 35). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger has RP to exceed baseline criteria for arsenic because the concentration at the edge of th e regulatory mixing zone is greate r than the applicable existing human health criterion. Under existing procedures, the applicable AMEL is 0.61 μg/L and the MDEL is 1.02 μg/L. Since the average arsenic concentration is 0.66 μg/L and the maximum effluent concentration is 1.05 μg/L, slightly above the projected limits, the discharger may need to reduce arsenic in its effluent.

Arsenic and arsenic-containing chemicals are not us ed in wastewater treatment, and the facility does not have any significant or categorical industrial users. However, drinking water and groundwater infiltration are two poten tial sources to the treatment pl ant. Astoria’s public water system draws water from three surface water intakes: Bear Creek, Cedar Creek, and Middle Lake. Most arsenic samples (organic plus inorganic) from the surface waters since 1986 are nondetect below the minimum reporting levels; th ere were 3 detected values ranging from 3 μg/L to 9 μg/L in the early 1990s (ODHS, 2007a ). The minimum reporting levels are not specified, and the drinking water maximum contam inant level is 10 μg/L, which is higher than current wastewater effluent concentrations and huma n health criteria. Ther efore, from these data it is not possible to determine with any certainty whether drinking water is contributing to high arsenic levels in the wastewater effluent. However, if the facility determines that drinking water is the source of high arsenic valu es in the wastewater, it is likely that the facility would pursue a variance or request that ODE Q consider granting the facility intake credits.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $100,000, with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be $4,270,000 for a comprehensive I&I reduction

June 2008 Appendix A. Facility Analyses A-5

### program that includes source identif ication and pipe rehabilitation for a system with 77 miles of sewer pipes (approximately $403,000 per year annualiz ed at 7% over 20 year s). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for comp liance and the discharg er would not likely undertake such a program for comp liance with toxic criteria alone.

Revised Criteria



### Exhibit A-3 summarizes the RPA for the revised huma n health criteria for consumption of organisms only for those pollutants detected in th e effluent (there will be no RP or monitoring requirements if all obser vations are nondetect).

Exhibit A-3. RPA for Revi sed Criteria, Astoria WWTP Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Antimony 0.052 180 99.0 64.0 29.0 18.0
Arsenic 0.026 0.014* 0.0080* 0.0052* 0.0023* 0.0015* Bis(2-Ethylhexyl) Phthalate 0.0024 0.61 0.34 0.22 0.099 0.062 Mercury 2 0.0021 0.0047 0.0026 0.0017* 0.00076* 0.00048*
Nickel 0.27 470 260 170 77.0 48.0
Selenium 0.097 1200 650 420 190 120 Thallium 0.012 0.13 0. 073 0.047 0.021 0.013 Toluene 0.0016 4100 2300 1500 670 420 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on facility’s existing permit (factor = 35). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger coul d have RP for arsenic and mercury based on the alternative fish consumption rates.

Arsenic

The discharger would have RP for arseni c at consumption rates of 63.2 gpd, 113 gpd, 175 gpd, 389 gpd, and 620 gpd. Exhibit A-4 shows the projected effluent limits for these consumption

rates.

Exhibit A-4. Projected Effluent Limits for Arsenic, Astoria WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.49 0.28 0.18 0.081 0.053 MDEL ( μ g/L) 0.81 0.47 0.30 0.13 0.087



### As described in the baseline analysis, the discharger may need to reduce effluent concentrations for compliance with baseline crit eria, or pursue alternative comp liance measures. These are the same compliance scenarios that would apply under all of the potential revised criteria. The

June 2008 Appendix A. Facility Analyses A-6

### baseline I&I reduction program includes a comp rehensive study to identify all potential infiltration sources and rehabilita tion of those sources. Thus, base line controls, or alternative actions, should also enable compliance with the revised criteria, and there would be no incremental compliance costs.

Mercury

The discharger would have RP for mercur y at consumption rates of 175 gpd, 389 gpd, and 620 gpd. Exhibit A-5 shows the projected AMELs and MDELs for each consumption rate based on the water column criteria in the RPA exhibit.

Exhibit A-5. Projected Effluent Limits for Mercury, Astoria WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) NA NA 0.059 0.027 0.017 MDEL ( μ g/L) NA NA 0.12 0.052 0.033



### The maximum effluent concentration at the fa cility is 0.042 μg/L, which is lower than both projected limits for a consumption rate of 175 gpd. Thus, the facility would not likely implement controls for compliance with the revised criterion.

The maximum effluent concentration is greate r than the AMEL for a consumption rate of 389 gpd and the AMEL and MDEL for a consumption rate of 620 gpd. Thus, the facility may need to implement controls to reduce effluent merc ury concentrations for compliance with these limits. Since the projected effluent levels are in the range achievable by municipal wastewater treatment plants that have implemented P2, the facility would likely implement a P2 program for compliance with the projected effluent limits. Annual P2 program costs for a 4.2 mgd municipal facility may be approximately $100,000 (see Appendi x B for details). As described in Appendix B, P2 costs also include expend itures by indirect dischargers to implement controls (see Exhibit B-2). Based on information on the discharger’s service area, incrementa l indirect discharger costs may be minimal (e.g., there are no uni versities in the service area).

Summary



### Exhibit A-6 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent the any costs above and beyond those that would be needed for compliance with baseline criteria. Under a vari ance scenario for arsenic, costs would likely fall within the range shown in the exhibit (e.g., a one-time e xpenditure of approximately $35,000 to $100,000).

Exhibit A-6. Summary of Po tential Costs, Astoria WWTP

Alternative Compliance Scenario Total Annual Costs Incremental ($/yr) Costs 1 Baseline • Intake credits, variance, or I&I reduction program (arsenic) $0 - $403,000 NA 63.2 gpd • Intake credits, variance, or I&I reduction program (arsenic) $0 - $403,000 $0 113 gpd • Intake credits, variance, or I&I reduction program (arsenic) $0 - $403,000 $0 175 gpd • Intake credits, variance, or I&I reduction program (arsenic) $0 - $403,000 $0

June 2008 Appendix A. Facility Analyses A-7

### Exhibit A-6. Summary of Po tential Costs, Astoria WWTP

Alternative Compliance Scenario Total Annual Costs Incremental ($/yr) Costs 1

• Intake credits, variance, or I&I reduction program (arsenic) $100,000 - $503,000 $100,000 389 gpd

• P2 program (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $100,000 - $503,000 $100,000 620 gpd

• P2 program (mercury) NA = Not applicable 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised cr iteria represent the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed fo r compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-8

### City of Brookings Wastewater Treatment Plant

Facility Description

The City of Brookings Wastew ater Treatment Plant (NPDES permit number OR0020354) is a secondary treatment facility that serves Brooking s and the Harbor Sanitary District. Based on 1995 estimates, the facility serv es a population of 9,700, and primar ily treats wastewater from domestic sources including residential and commerc ial sites. ODEQ classifies the facility as a major discharger. The ADWDF for the plant is 1.75 mgd. The facility di scharges all treated effluent into the Pacific Ocean through outfall 00 1. There are 10 other outfalls used only in emergency overflow situations.

Treatment Processes

The 2000 NPDES permit for the facility lists cu rrent treatment processes as screening, grit removal, primary sedimentation, tricking filter/ solids contact secondary treatment, secondary clarification, and disinfec tion with chlorine gas. Sludge is se nt to an anaerobic digester equipped with a sludge thickening system, and land a pplied to approved bene ficial use sites.

Effluent Data and Limits

There are no effluent data available for the pollu tants of concern, and the facility does not have effluent limits for any toxic pollutants in its current permit.

Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

The facility discharges less than 2 mgd of treated effluent 500 feet offshore into the Pacific Ocean. The facility’s acute dilu tion factor (which is generally lower than the human health dilution factors) is 70. Given su ch a large dilution fact or, it is unlikely th at the facility would have RP to cause or contribute to exceedances of the baseline criteria or th e revised criteria based on alternative fish consumption rates.

June 2008 Appendix A. Facility Analyses A-9

### City of Coos Bay Wastew ater Treatment Plant #2

Facility Description

The City of Coos Bay Wastewater Treatment Plant #2 (NPDES permit number OR0023582) is located in Coos Bay, Oregon and serves the Ci ty of Coos Bay and the Charleston Sanitary District. The treatment facility receives prim arily domestic wastewater from residential and commercial sources from a population of a pproximately 10,000. The average dry weather design flow to the facility equals 2.02 mgd. ODEQ classifies the facility as a major discharger. The facility discharges all treated effluent into Coos Ba y through outfall number 001. There are 4 other outfalls used only in emergency overflow situations.

Treatment Processes

The 2003 NPDES permit for the facility lists curren t treatment processes as activated sludge with effluent chlorination. Primary and secondary sludge is settled in the primary clarifier and pumped to anaerobic digesters. Digested sludge is trucked to the facultative sludge lagoon. The facility removes sludge from the la goon after a year or more with a floating dredge and applies it to private farmlands and forest sites as a beneficial supplement.

Effluent Data and Limits

Exhibit A-7 summarizes monitoring data from July 2006 for those pollutants of concern for which effluent data are available. The availabl e data represent maximum and average values of three samples. Because the raw data are not av ailable, the exhibit shows only the maximum and average concentrations for the detected values. Th e facility does not have effluent limits for any toxic pollutants.

Exhibit A-7. Effluent Da ta Summary, Coos Bay WWTP #2 1 Summary of Detected Values Number of Observations (μg/L) Pollutant
Total Nondetect MDL 2 (μg/L) Maximum Average 1,1,2,2-Tetrachloroethane 3 3 0.12 - - 1,1,2-Trichloroethane 3 3 0.11 - - 1,1-Dichloroethylene 3 3 0.07 - - 1,2,4-Trichlorobenzene 3 3 4.85 - - 1,2-Dichlorobenzene 3 3 4.85 - - 1,2-Dichloroethane 3 3 0.14 - - 1,2-Dichloropropane 3 3 0.012 - - 1,2-Diphenylhydrazine 3 3 4.85 - - 1,2-Trans-Dichloroethylene 3 3 0.05 - - 1,3-Dichlorobenzene 3 3 4.85 - - 1,4-Dichlorobenzene 3 3 4.85 - - 2,4,6-Trichlorophenol 3 3 4.85 - - 2,4-Dichlorophenol 3 3 4.85 - - 2,4-Dimethylphenol 3 3 9.71 - -

June 2008 Appendix A. Facility Analyses A-10June 2008 Appendix A. Facility Analyses A-11 

### Exhibit A-7. Effluent Da ta Summary, Coos Bay WWTP #2 1

Number of Observations Summary of Detected Values (μg/L) Pollutant
Total Nondetect MDL 2 (μg/L) Maximum Average 2,4-Dinitrophenol 3 3 4.85 - - 2,4-Dinitrotoluene 3 3 2.91 - - 2-Chloronaphthalene 3 3 2.91 - - 2-Chlorophenol 3 3 4.85 - - 3,3'-Dichlorobenzidine 3 3 4.85 - - 4,4'-DDD 1 1 0.0962 - - 4,4'-DDE 1 1 0.0962 - - 4,4'-DDT 1 1 0.0962 - - Acenaphthene 3 3 2.91 - - Acrolein 3 3 7.5 - - Acrylonitrile 3 3 2.1 - - Aldrin 1 1 0.0962 - - alpha-BHC 3 3 0.0962 - - Anthracene 3 3 2.91 - - Antimony 3 3 0.102 - - Arsenic 3 0 - 0.25 0.21 Benzene 3 3 0.03 - - Benzidine 3 3 58.3 - - Benzo(a) Anthracene 3 3 2.91 - - Benzo(a) Pyrene 3 3 2.91 - - Benzo(k) Fluoranthene 3 3 2.91 - - Beryllium 3 3 0.128 - - beta-BHC 1 1 0.0962 - - Bis(2-Chloroethyl) Ether 3 3 2.91 - - Bis(2-Chloroisopropyl) Ether 3 3 4.85 - - Bis(2-Ethylhexyl) Phthalate 3 0 - 55.4 24.9 Bromoform 3 3 0.08 - - Butylbenzyl Phthalate 3 3 2.91 - - Carbon Tetrachloride 3 3 0.07 - - Chlordane 3 3 0.481 - - Chloroform 3 0 - 1.2 0.64 Chrysene 3 3 2.91 - - Dibenzo(a,h)Anthracene 3 3 2.91 - - Dichlorobromomethane 3 3 0.09 - - Diethyl Phthalate 3 3 2.91 - - Dimethyl Phthalate 3 3 2.91 - - Di-n-Butyl Phthalate 3 3 2.91 - - Endosulfan Sulfate 1 1 0.0962 - - Endrin 1 1 0.0962 - - Endrin Aldehyde 1 1 0.0962 - - Ethylbenzene 3 3 0.04 - - Fluoranthene 3 3 2.91 - - Fluorene 3 3 2.91 - - gamma-BHC 1 1 0.0962 - -

### Exhibit A-7. Effluent Da ta Summary, Coos Bay WWTP #2 1 Summary of Detected Values Number of Observations (μg/L) Pollutant
Total Nondetect MDL 2 (μg/L) Maximum Average Heptachlor 1 1 0.0962 - - Heptachlor Epoxide 1 1 0.0962 - - Hexachlorobenzene 3 3 2.91 - - Hexachlorobutadiene 3 3 4.85 - - Hexachlorocyclopentadiene 3 3 4.85 - - Hexachloroethane 3 3 4.85 - - Ideno(1,2,3-cd)Pyrene 3 3 2.91 - - Isophorone 3 3 2.91 - - Mercury 3 0 - 0.0069 0.0032 Methylene Chloride 3 0 - 0.24 0.16 Nickel 3 0 - 1.64 1.49 Nitrobenzene 3 3 2.91 - - N-Nitrosodimethylamine 3 3 4.85 - - N-Nitrosodi-n-Propylamine 3 3 2.91 - - N-Nitrosodiphenylamine 3 3 2.91 - - Pentachlorophenol 3 3 4.85 - - Phenol 6 6 19.1 - - PCBs 1 1 0.481 - - Pyrene 3 3 2.91 - - Selenium 3 0 - 0.34 0.31 Tetrachloroethylene 3 3 0.06 - - Thallium 3 0 - 0.07 0.044 Toluene 3 0 - 3.21 1.71 Toxaphene 1 1 4.81 - - Trichloroethylene 3 3 0.05 - - Vinyl Chloride 3 3 0.05 - - MDL = Method detection limit. 1. Represents maximum and average effluent data from July 2006. 2. Represents the method detection limit reported by the facility’s analytical laboratory.



### Receiving Water Data

There are no upstream ambient data available fo r the pollutants of concern for this facility.

Potential Impacts

Baseline Criteria



### Under ODEQ (2005) procedures, the RPA for carc inogens would be based on the calculated average concentration and not the geometric mean because the raw data from which to calculate a geometric mean are not available. Exhibit A-8 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect). Coos Bay is estuarine; thus, human h ealth criteria for consumption of organisms only are app licable. Flow data from which to calculate the harmonic mean or 30Q5

June 2008 Appendix A. Facility Analyses A-12

### flows needed to calculate dilution are not ava ilable, however, the facility’s existing permit indicates a dilution factor of 41 (diluti on at edge of regulatory mixing zone).

Exhibit A-8. RPA for Baselin e Criteria, Coos Bay WWTP #2

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L)
Arsenic 0.64 0 0.016 0.0175 No Bis(2-Ethylhexyl) Phthalate 74.9 0 1.82 2.2 No Chloroform 1.92 0 0.047 15.7 No Methylene Chloride 0.48 0 0.012 590 No Mercury 4 0.021 0 0.00051 0.017 No Nickel 4.92 0 0.12 100 No Selenium 1.02 0 0.025 4200 No Thallium 0.21 0 0.0051 0.47 No Toluene 9.63 0 0.23 15000 No 1. Represents the calculated average concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on facility’s existing permit (factor = 41). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger does not have has RP to exceed baseline criteria for any pollutants. Thus, it is unlikely that the discharger would incur costs.

Revised Criteria



### Exhibit A-9 summarizes the RPA for the revised huma n health criteria for consumption of organisms only for those pollutants detected in th e effluent (there will be no RP or monitoring requirements if all obser vations are nondetect).

Exhibit A-9. RPA for Revised Criteria, Coos Bay WWTP #2

Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd
Arsenic 0.016 0.014* 0.0080* 0.0052* 0.0023* 0.0015*
0.61* 0.34* 0.22* 0.099* 0.062* Bis(2-Ethylhexyl) Phthalate 1.82 Chloroform 0.047 48.0 27.0 17.0 7.90 4.90 Methylene Chloride 0.012 160 92.0 59.0 27.0 17.0 Mercury 2 0.00051 0.0047 0.0026 0.0017 0.00076 0.00048*
Nickel 0.12 470 260 170 77.0 48.0
Selenium 0.025 1200 650 420 190 120 Thallium 0.0051 0.13 0.073 0.047 0.021 0.013 Toluene 0.23 4100 2300 1500 670 420 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on facility’s existing permit (factor = 41). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).

June 2008 Appendix A. Facility Analyses A-13

### As shown in the exhibit, the discharger would ha ve RP for arsenic, bis( 2-ethylhexyl) phthalate, and mercury.

Arsenic

The facility would have RP for arsenic at all of the alternative consumption rates. Exhibit A-10 shows the projected effluent limits for these consumption rates.

Exhibit A-10. Projected Effluent Limits for Arsenic, Coos Bay WWTP #2 Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.57 0.33 0.21 0.094 0.062 MDEL ( μ g/L) 1.15 0.66 0.43 0.19 0.12



### The maximum effluent arsenic c oncentration is 0.25 μg/L, which is lower than the projected effluent limits for consumption rates of 63.2 gpd and 113 gpd. Thus, the discharger would not likely implement controls for compliance with these revised criteria.

The maximum arsenic concentration is greater than the AMEL for a consumption rate of 175 gpd and the AMEL and MDEL for consumption rates of 389 gpd and 620 gpd. Thus, the discharger may need to implement controls to reduce efflue nt arsenic concentrations for compliance with these limits. Arsenic and arsenic-containing chemi cals are not used in wastewater treatment, and the facility does not have any significant or categorical industrial users. However, drinking water and groundwater infiltration are two potential so urces of arsenic to the treatment plant.

The Coos Bay-North Bend Water Board supplies the City with drinking water from its water treatment plant that draws water from Pony Creek. The City detected arsenic twice in drinking water since May 2004 (1.3 μg/L in 2007 and 0.5 μg/L in 2004) (ODHS, 2007b). Thus, it is possible that drinking water is cont ributing to high arsenic levels in the wastewater effluent. In this case, it is likely that the facility woul d pursue a variance or reque st that ODEQ consider granting the facility intake credits.

The facility’s permit indicates th at the collection system has si gnificant I&I because peak flows are nearly ten times the average dry weather flows. The permit also indicates that the City is addressing the issues with a major revamping of the collection system, but does not state the extent these efforts. Thus, it is uncertain whet her these baseline modifications to the collection system would address arsenic leve ls (there are a number of modi fications that can correct I&I issues that would not necessarily reduce arsenic concentrations). If groundwater infiltration is causing the high arsenic effluent levels, the facility may have to implement an I&I reduction program for compliance with the existing criteria.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $100,000 with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be $1,850,000 for a comprehensive I&I reduction

June 2008 Appendix A. Facility Analyses A-14

### program that includes pipe rehabilitation (source identification is not included because the City has presumably already conducted such a study) fo r a system with 50 miles of sewer pipes based on the number of miles of sewer pipe for a sy stem of similar size and makeup (approximately $174,000 per year annualized at 7% ove r 20 years). (Some portion of this cost may be incurred even in the absence of a revised fish consumption rate.) Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I re duction program alone may not be sufficient for compliance and the discharger w ould not likely undertak e such a program for compliance with toxic criteria alone.

Bis(2-ethylhexyl) phthalate

The discharger would have RP for bis(2-ethylh exyl) phthalate at consumption rates of 63.2 gpd, 113 gpd, 175 gpd, 389 gpd, and 620 gpd. Exhibit A-11 shows the projected effluent limits for these consumption rates.

Exhibit A-11. Projected Effluent Limits fo r Bis(2-ethylhexyl) Phthalate, Coos Bay WWTP #2 Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 25 14 9.0 4.1 2.5 MDEL ( μ g/L) 50 28 18 8.1 5.1



### The maximum effluent bis(2-ethy lhexyl) phthalate concentration is 55.4 μg/L, which is greater than the projected effluent limits for all the cons umption rates. Bis(2-et hylhexyl) phthalate is found mainly in plastics and is used as a plasticizer for pol yvinylchloride (PVC) and other polymers, and can be released from plastics manufacturing wastes or through release from plastic goods (Environment Canada, 1994). The facility’s permit indicates that it does not have any significant or categorical industria l users and that the only hospital in the area dischargers to the area’s other treatment plant. T hus, it is likely that the bis(2-ethyl hexyl) phthalate is not the result of any one major source, rather a combination of many sources including th e residential sector. High levels of bis(2-ethylhexyl ) phthalate in municipal wastew ater effluent can also be associated with sampling and/or laboratory anal ysis conditions (Fairfie ld-Suisun SD, 2003). If this is the case, cleaner sampling and analys is techniques could reduce the amount of bis(2- ethylhexyl) phthalate measur ed in the effluent.

Because the bis(2-ethylhexyl) phth alate in the effluent could be the result of sampling error or widespread leaching from PVC piping (that may not be controllable), a P2 program may not be feasible or cost-effective. Thus, the facility may pursue an alternative compliance mechanism such as a variance.

Costs for the facility could be relatively mode st for efforts to implement cleaner sampling techniques, or one-time costs of $35,000 to $100,000 for a variance with minimal costs associated with renewal. For consumption rate s of 175 gpd and greater, th e facility may already pursue a variance for arsenic, and additional study for bis(2-ethylhexyl) phthalate would be included in that effort.

June 2008 Appendix A. Facility Analyses A-15

### Mercury

The discharger would have RP for mercury at a consumption rate of 620 gpd. The projected AMEL is 0.02 μg/L and the MDEL is 0.04 μg/L. The maximum effluent concentration of 0.0069 μg/L is less than both limits. Thus, th e facility would not likely incur costs.

Summary



### Exhibit A-12 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent the any costs above and beyond those that would be needed for compliance with baseline criteria. Under a vari ance scenario for arsenic and/or bis(2-ethylhexyl) phthalate, incremental costs for all altern ative consumption rates could in clude a one-time expenditure of approximately $35,000 to $100,000.

Exhibit A-12. Summary of Potential Costs, Coos Bay WWTP #2

Alternative Compliance Scenario Total Annual Incremental Costs Annual Costs 1 Baseline • None $0 NA 63.2 gpd • Cleaner sampling or variance [bis(2-ethylhexyl) phthalate] $0 $0 113 gpd • Cleaner sampling or variance [bis(2-ethylhexyl) phthalate] $0 $0

• Intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 - $174,000 175 gpd

• Cleaner sampling or variance [bis(2-ethylhexyl) phthalate]

• Intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 - $174,000 389 gpd

• Cleaner sampling or variance [bis(2-ethylhexyl) phthalate]

• Intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 - $174,000 620 gpd

• Cleaner sampling or variance [bis(2-ethylhexyl) phthalate] NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-16

### Eugene-Springfield WWTP

Facility Description

The Metropolitan Wastewater Management Co mmission (MWMC) operates a wastewater treatment facility located in Eugene, Oregon (NPDES permit number OR0 031224). The facility serves the Eugene and Springfield areas, and has an ADWDF of 49 m gd. All flows up to 103 mgd receive secondary treatment. ODEQ classifies the facility as a major discharger. The facility discharges all treated effluent through Outfall 001 into the Willamette River at river mile 178.0. The facility also has 13 other outfa lls categorized as emergency overflows.

Treatment Processes

The 2002 NPDES permit for the facility lists curren t treatment processes as activated sludge with anaerobic digesters, ei ght aeration basins with coarse or fine bubble diffusers, chlorine disinfection, and dechlorinated with sulfur dioxide. Sludge is processed at two locations: anaerobic digestion takes place at the wastewater treatment facility, consis ting of three primary and two secondary anaerobic digester s and sludge from the secondary digesters undergoes further stabilization and drying at the Regional Biosolids Ma nagement Fac ility prior to land application.

Effluent Data and Limits

Exhibit A-13 summarizes monitoring data from Se ptember 2003 to September 2006 for those pollutants of concern for which effl uent data are available. The f acility does not have effluent limits for any toxic pollutants.

Exhibit A-13. Effluent Data Summary, Eugene-Springfield WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 6 6 5 - - - 1,1,2-Trichloroethane 6 6 5 - - - 1,1-Dichloroethylene 12 12 5 - - - 1,2,4-Trichlorobenzene 6 6 10 - - - 1,2-Dichlorobenzene 12 12 10 - - - 1,2-Dichloroethane 6 6 5 - - - 1,2-Dichloropropane 6 6 5 - - - 1,2-Diphenylhydrazine 6 6 10 - - - 1,2-Trans-Dichloroethylene 6 6 5 - - - 1,3-Dichlorobenzene 12 12 10 - - - 1,4-Dichlorobenzene 12 12 10 - - - 2,4,6-Trichlorophenol 6 6 10 - - - 2,4-Dichlorophenol 6 6 10 - - - 2,4-Dimethylphenol 6 6 10 - - - 2,4-Dinitrophenol 6 6 25 - - - 2,4-Dinitrotoluene 6 6 10 - - - 2-Chloronaphthalene 6 6 10 - - -

June 2008 Appendix A. Facility Analyses A-17June 2008 Appendix A. Facility Analyses A-18 

### Exhibit A-13. Effluent Data Summary, Eugene-Springfield WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2-Chlorophenol 6 6 10 - - - 2-Methyl-4,6-dinitrophenol 6 6 25 - - - 3,3'-Dichlorobenzidine 6 6 25 - - - 4,4'-DDD 6 6 0.05 - - - 4,4'-DDE 6 6 0.05 - - - 4,4'-DDT 6 5 0.048 0.08 0.08 0.08 Acenaphthene 6 6 10 - - - Acrolein 6 6 50 - - - Acrylonitrile 6 6 10 - - - Aldrin 6 6 0.05 - - - Alpha-BHC 6 5 0.048 0.068 0.068 0.068 Anthracene 6 6 10 - - - Benzene 6 6 5 - - - Benzidine 6 6 50 - - - Benzo(a) Anthracene 6 6 10 - - - Benzo(a) Pyrene 6 6 10 - - - Benzo(b) Fluoranthene 6 6 10 - - - Benzo(k) Fluoranthene 6 6 10 - - - Beta-BHC 6 6 0.075 - - - Bis(2-chloroethyl) Ether 6 6 10 - - - Bis(2-chloroisopropyl) Ether 6 6 10 - - - Bis(2-Ethylhexyl) Phthalate 6 6 10 - - - Bromoform 6 6 5 - - - Butylbenzyl Phthalate 6 6 10 - - - Carbon Tetrachloride 6 6 5 - - - Chlordane 6 6 1.1 - - - Chlorobenzene 6 6 5 - - - Chlorodibromomethane 6 6 5 - - - Chloroform 6 6 5 - - - Chrysene 6 6 10 - - - Dibenzo(a,h)Anthracene 6 6 10 - - - Dichlorobromomethane 6 6 5 - - - Dieldrin 6 6 0.05 - - - Diethyl phthalate 6 6 10 - - - Dimethyl phthalate 6 6 10 - - - Di-n-Butyl Phthalate 6 6 10 - - - Endosulfan sulfate 6 6 0.05 - - - Endrin 6 6 0.05 - - - Endrin Aldehyde 6 6 0.05 - - - Ethylbenzene 6 6 5 - - - Fluoranthene 6 6 10 - - - Fluorene 6 6 10 - - - gamma-BHC 6 6 0.01 - - - Heptachlor 6 6 0.05 - - -

### Exhibit A-13. Effluent Data Summary, Eugene-Springfield WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean Heptachlor Epoxide 6 6 0.05 - - - Hexachlorobenzene 6 6 10 - - - Hexachlorobutadiene 6 6 10 - - - Hexachlorocyclopentadiene 6 6 10 - - - Hexachloroethane 6 6 10 - - - Ideno(1,2,3-cd)Pyrene 6 6 10 - - - Isophorone 6 6 10 - - - Methylene chloride 6 6 5 - - - Nitrobenzene 6 6 10 - - - N-Nitrosodimethylamine 6 6 25 - - - N-Nitrosodi-N-Propylamine 6 6 10 - - - N-Nitrosodiphenylamine 6 6 25 - - - PCBs 3 6 6 1.1 - - - Pentachlorophenol 6 6 25 - - - Phenol 6 6 10 - - - Pyrene 6 6 10 - - - Tetrachloroethylene 6 6 5 - - - Toluene 6 6 5 - - - Toxaphene 6 6 2.5 - - - Vinyl chloride 6 6 5 - - - QL = Quantification limit. 1. Represents effluent data from Sept 2003 to Sept 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

There are no ambient receiving water data available for this facility. The facility’s monitoring data, provided by ODEQ, indicates that the W illamette River 30Q5 flow is 1,675 cubic feet per second (cfs) and the harmonic mean flow is 2,905 cfs during the fish rearing period.

Potential Impacts

Baseline Criteria



### Exhibit A-14 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Willamette River is a freshwater river; thus, huma n health criteria for consumption of water and organisms are applicable. ODEQ (2006b) allows 25% of the harmonic mean flow for dilution for carcinogens and 25% of the 30Q5 fl ow for dilution for noncarcinogens.

June 2008 Appendix A. Facility Analyses A-19

### Exhibit A-14. RPA for Baseline Cr iteria, Eugene-Springfield WWTP

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) 4,4’-DDT 0.17 0 0.016 0.000024 Yes alpha-BHC 0.15 0 0.014 0.0026 Yes 1. Represents the calculated average concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on 25% of 30Q5 flow for noncarcinogens (fac tor = 6.5) and 25% of harmonic mean flow for carcinogens (factor = 10.6).



### DDT and BHC

As shown in the exhibit, the f acility currently has RP to excee d the baseline criteria for 4,4-DDT and alpha-BHC. DDT is a pesticide that was widely used on agricultural crops to control disease-carrying insects. The United States banned uses of DDT in 1972, except for public health emergencies involving insect diseases and control of body lice (A TSDR, 2002). BHC is a manufactured chemical that exis ts in eight chemical forms calle d isomers. Technical-grade BHC was used as an insecticide in the United St ates and typically cont ained 10-15% gamma ( γ )-BHC as well as the alpha ( α ), beta ( β ), delta ( δ ), and epsilon ( ε ) forms (ATSDR, 2005). However, technical-grade BHC has not been produced or used in the United States in over 20 years (ATSDR, 2005). Thus, because neither pollutant is actively used nor are there any known sources to a municipal wastewater treatment plan t, it is likely that the facility would pursue a variance. Total costs for al ternative compliance mechanisms could range from $35,000 to $300,000, with minimal costs asso ciated with renewal.

As part of the variance, ODEQ may require the facility to im plement a P2 or source control program to identify the sources of the pollu tants (e.g., any commercia l/industrial indirect discharges that may have in the past used th e chemicals or manufactured pesticides containing the chemicals) because certain sources may be c ontrollable. Annual costs for a P2 program for both DDT and alpha-BHC may be approximately $50,000 ($25,000 + $25,000).

Mercury

Under the baseline Willamette River Basin merc ury TMDL, the facility would be required to develop and implement a mercury reduction stra tegy. Annual P2 program costs for a 49 mgd municipal facility may be approximately $150,000 (s ee Appendix B for details). As described in Appendix B, P2 costs also potentially include costs for indirect disc hargers to implement controls (see Exhibit B-2). Based on informati on on the discharger’s service area, incremental indirect discharger costs may be $48,000 (e.g., there are four univers ities in the service area). However, because ODEQ does not assign individual wasteload allocations to point source dischargers in the TMDL (point sources as a w hole are required to reduce existing load by 26%), it is uncertain whether the facili ty would incur costs beyond those for a P2 program to meet the wasteload allocation under the baseline TMDL.

June 2008 Appendix A. Facility Analyses A-20

### Revised Criteria



### Exhibit A-15 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-15. RPA for Revised Cr iteria, Eugene-Springfield WWTP Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 4,4’-DDT 0.016 0.000061* 0.000034* 0.000022* 0.0000098* 0.0000062* alpha-BHC 0.014 0.0011* 0.00067* 0.00045* 0.00021* 0.00013* *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on 25% of 30Q5 flow for noncarcinogens (fac tor = 6.5) and 25% of harmonic mean flow for carcinogens (factor = 10.6).



### The discharger would have RP for both 4,4-DDT a nd alpha-BHC at all consumption rates. As described in the baseline analysis, the discha rger may pursue variances for these pollutants because neither pollutant is actively used nor ar e there known sources to a municipal wastewater treatment plant. Under the assumption that the facility would pur sue a variance under the baseline, incremental impacts of the revised criteria are unlikely.

Summary



### Exhibit A-16 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent the any costs above and beyond those that would be needed for compliance with baseline criteria. In addition, the discharger would also incur one-time expenditures for variances for 4,4’-DDT and alpha-BHC of approximately $35,000 to $300,000.

Exhibit A-16. Summary of Potentia l Costs, Eugene-Springfield WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Variance with P2 program for 4,4-DDT and alpha-BHC Baseline $248,000 NA

• P2 program (mercury)

• Variance with P2 program for 4,4-DDT and alpha-BHC 63.2 gpd $248,000 $0

• P2 program (mercury)

• Variance with P2 program for 4,4-DDT and alpha-BHC 113 gpd $248,000 $0

• P2 program (mercury)

• Variance with P2 program for 4,4-DDT and alpha-BHC 175 gpd $248,000 $0

• P2 program (mercury)

• Variance with P2 program for 4,4-DDT and alpha-BHC 389 gpd $248,000 $0

• P2 program (mercury)

• Variance with P2 program for 4,4-DDT and alpha-BHC $248,000 $0 620 gpd

• P2 program (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-21

### Kellogg Creek Wastewater Treatment Plant

Facility Description

The Clackamas County Service Di strict’s Kellogg Creek Wastewater Treatment Plant (NPDES permit number OR0026221) is located in Milwa ukie, Oregon and serves Milwaukie, Happy Valley, Johnson City, and portions of Clackamas , Gladstone, and Damascus. ODEQ classifies this 7.1 mgd (ADWDF) facility as a major discharger. The facility discharges treated effluent into the Willamette River at river mile 18.5.

Treatment Processes

The 2006 NPDES permit for the facility lists curren t treatment processes as screening and grit removal, primary clarification, aeration basins and secondary cl arifiers, and ultraviolet light disinfection. The facility stabi lizes sludge from the primary clar ifiers using anaer obic digesters and disposes of biosolids by spreading on approved sites.

Effluent Data and Limits

Exhibit A-17 summarizes monitoring data from May 2005 to December 2006 for those pollutants of concern for which effl uent data are available. The f acility does not have effluent limits for any toxic pollutants.

Exhibit A-17. Effluent Da ta Summary, Kellogg Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 1 1 5 - - - 1,2,4-Trichlorobenzene 2 2 9.8 - - - 1,2-Dichlorobenzene 1 1 5 - - - 1,2-Dichloroethane 1 1 5 - - - 1,2-Dichloropropane 1 1 5 - - - 1,2-Diphenylhydrazine 2 2 9.8 - - - 1,2-Trans-Dichloroethylene 1 1 5 - - - 1,4-Dichlorobenzene 1 1 5 - - - 2,4,6-Trichlorophenol 2 2 9.8 - - - 2,4-Dichlorophenol 2 2 9.8 - - - 2,4-Dimethylphenol 2 2 9.8 - - - 2,4-Dinitrophenol 2 2 25 - - - 2,4-Dinitrotoluene 2 2 9.8 - - - 2-Chloronaphthalene 2 2 9.8 - - - 2-Chlorophenol 2 2 9.8 - - - 2-Methyl-4,6-Dinitrophenol 2 2 25 - - - 4,4'-DDD 2 2 0.0098 - - - 4,4'-DDE 2 2 0.0098 - - - 4,4'-DDT 2 2 0.0098 - - - Acenaphthene 2 2 9.8 - - -

June 2008 Appendix A. Facility Analyses A-22June 2008 Appendix A. Facility Analyses A-23 

### Exhibit A-17. Effluent Da ta Summary, Kellogg Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

Acrolein 1 1 50 - - - Acrylonitrile 1 1 10 - - - Aldrin 2 2 0.0098 - - - alpha-BHC 2 2 0.0098 - - - Anthracene 2 2 9.8 - - - Arsenic 21 0 0 1.3 0.79 0.60 Benzidine 2 2 49 - - - Benzo(a) Anthracene 2 2 9.8 - - - Benzo(a) Pyrene 2 2 9.8 - - - Benzo(b) Fluoranthene 2 2 9.8 - - - Benzo(k) Fluoranthene 2 2 9.8 - - - Bis(2-Chloroethyl) Ether 2 2 9.8 - - - Bis(2-Chloroisopropyl) Ether 2 2 9.8 - - - Bis(2-Ethylhexyl) Phthalate 2 2 9.8 - - - Bromoform 1 1 5 - - - Carbon Tetrachloride 1 1 5 - - - Chlordane 2 2 0.2 - - - Chlorobenzene 1 1 5 - - - Chloroform 1 1 5 - - - Chrysene 2 2 9.8 - - - Dibenzo(a,h)Anthracene 2 2 9.8 - - - Dichlorobromomethane 1 1 5 - - - Dieldrin 2 2 0.0098 - - - Diethyl Phthalate 2 2 9.8 - - - Dimethyl Phthalate 2 2 9.8 - - - Di-n-Butyl Phthalate 2 2 9.8 - - - Endosulfan Sulfate 2 2 0.0098 - - - Endrin Aldehyde 2 2 0.0098 - - - Ethylbenzene 1 1 5 - - - Fluoranthene 2 2 9.8 - - - Fluorene 2 2 9.8 - - - gamma-BHC 2 2 0.0096 - - - Heptachlor 2 2 0.0098 - - - Heptachlor Epoxide 2 2 0.0098 - - - Hexachlorobenzene 2 2 9.8 - - - Hexachlorobutadiene 2 2 9.8 - - - Hexachlorocyclopentadiene 2 2 9.8 - - - Hexachloroethane 2 2 9.8 - - - Ideno(1,2,3-cd)Pyrene 2 2 9.8 - - - Isophorone 2 2 9.8 - - - Mercury 21 4 0.005 0.013 0.0074 0.0053 Nickel 21 0 0 3.1 1.86 1.4 Nitrobenzene 2 2 9.8 - - - N-Nitrosodimethylamine 2 2 25 - - -

### Exhibit A-17. Effluent Da ta Summary, Kellogg Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean N-Nitrosodi-n-Propylamine 2 2 9.8 - - - PCBs 3 2 2 0.98 - - - Pentachlorophenol 2 2 25 - - - Phenol 2 2 9.8 - - - Pyrene 2 2 9.8 - - - Selenium 21 21 2 - - - Tetrachloroethylene 1 1 5 - - - Toxaphene 2 2 0.49 - - - Trichloroethylene 1 1 5 - - - Vinyl Chloride 1 1 5 - - - QL = Quantification limit. 1. Represents effluent data from May 2005 to December 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

Exhibit A-18 summarizes data from the Willamette River upstream of the facility from May 2004 to April 2007 for those pollutants of concer n for which ambient data are available.

Exhibit A-18. Ambient Data Summary, Kellogg Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 2 2 5 - - - 1,2,4-Trichlorobenzene 2 2 9.8 - - - 1,2-Dichlorobenzene 2 2 5 - - - 1,2-Dichloroethane 2 2 5 - - - 1,2-Dichloropropane 2 2 5 - - - 1,2-Diphenylhydrazine 2 2 9.8 - - - 1,2-Trans-Dichloroethylene 2 2 5 - - - 1,4-Dichlorobenzene 2 2 5 - - - 2,4,6-Trichlorophenol 2 2 9.8 - - - 2,4-Dichlorophenol 2 2 9.8 - - - 2,4-Dimethylphenol 2 2 9.8 - - - 2,4-Dinitrophenol 2 2 25 - - - 2,4-Dinitrotoluene 2 2 9.8 - - - 2-Chloronaphthalene 2 2 9.8 - - - 2-Chlorophenol 2 2 9.8 - - - 2-Methyl-4,6-Dinitrophenol 2 2 25 - - - 4,4'-DDD 2 2 0.0098 - - - 4,4'-DDE 2 2 0.0098 - - - 4,4'-DDT 2 2 0.0098 - - - Acenaphthene 2 2 9.8 - - -

June 2008 Appendix A. Facility Analyses A-24June 2008 Appendix A. Facility Analyses A-25 

### Exhibit A-18. Ambient Data Summary, Kellogg Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Maximum Geometric Mean Minimum

Acrolein 2 2 50 - - - Acrylonitrile 2 2 10 - - - Aldrin 2 2 0.0098 - - - alpha-BHC 2 2 0.0098 - - - Anthracene 2 2 9.8 - - - Arsenic 4 3 0.5 0.6 0.6 0.6 Benzidine 2 2 49 - - - Benzo(a) Anthracene 2 2 9.8 - - - Benzo(a) Pyrene 2 2 9.8 - - - Benzo(b) Fluoranthene 2 2 9.8 - - - Benzo(k) Fluoranthene 2 2 9.8 - - - Bis(2-Chloroethyl) Ether 2 2 9.8 - - - Bis(2-Chloroisopropyl) Ether 2 2 9.8 - - - Bis(2-Ethylhexyl) Phthalate 2 2 9.8 - - - Bromoform 2 2 5 - - - Carbon Tetrachloride 2 2 5 - - - Chlordane 2 2 0.2 - - - Chlorobenzene 2 2 5 - - - Chloroform 2 2 5 - - - Chrysene 2 2 9.8 - - - Dibenzo(a,h)Anthracene 2 2 9.8 - - - Dichlorobromomethane 2 2 5 - - - Dieldrin 2 2 0.0098 - - - Diethyl Phthalate 2 2 9.8 - - - Dimethyl Phthalate 2 2 9.8 - - - Di-n-Butyl Phthalate 2 2 9.8 - - - Endosulfan Sulfate 2 2 0.0098 - - - Endrin Aldehyde 2 2 0.0098 - - - Ethylbenzene 2 2 5 - - - Fluoranthene 2 2 9.8 - - - Fluorene 2 2 9.8 - - - Heptachlor 2 2 0.0098 - - - Heptachlor Epoxide 2 2 0.0098 - - - Hexachlorobenzene 2 2 9.8 - - - Hexachlorobutadiene 2 2 9.8 - - - Hexachlorocyclopentadiene 2 2 9.8 - - - Hexachloroethane 2 2 9.8 - - - Ideno(1,2,3-cd)Pyrene 2 2 9.8 - - - Isophorone 2 2 9.8 - - - Mercury 4 1 0.005 0.0024 0.0017 0.0009 Nickel 2 0 0 0.70 0.47 0.32 Nitrobenzene 2 2 9.8 - - - N-Nitrosodimethylamine 2 2 25 - - - N-Nitrosodi-n-Propylamine 2 2 9.8 - - -

### Exhibit A-18. Ambient Data Summary, Kellogg Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean
PCBs 2 2 2 0.98 - - - Pentachlorophenol 2 2 25 - - - Phenol 2 2 9.8 - - - Pyrene 2 2 9.8 - - - Selenium 4 4 2 - - - Tetrachloroethylene 2 2 5 - - - Toxaphene 2 2 0.49 - - - Trichloroethylene 2 2 5 - - - Vinyl Chloride 2 2 5 - - - QL = Quantification limit. 1. Represents ambient data from May 2004 to April 2007. 2. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Potential Impacts

Baseline Criteria



### Exhibit A-19 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Willamette River is a freshwater river; thus, huma n health criteria for consumption of water and organisms are applicable. Flow data from which to calculate the harmonic mean or 30Q5 flows are not available; however, the fa cility’s existing permit indicates the dilution factor is 19.9. The Willamette River at river mile 18 is on the st ate’s 303(d) list as im paired for DDT, DDE, dieldrin, dioxin, mercury, PCBs, pentachlorophen ol, and PAHs; thus, the facility would not receive dilution for these pollutants.

Exhibit A-19. RPA for Baseline Criteria, Kellogg Creek WWTP

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L)
Arsenic 1.06 0.6 1.06 0.0022 Yes Yes Mercury 4 0.018 0.0017 0.018 0.017 Nickel 4.16 0.47 0.66 13.4 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on the facility’s existing permit (factor = 19.9). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the facility has RP to exceed the baseline criterion for arsenic and mercury because the concentrations at the edge of the regulatory mixing zone are greater than the applicable existing human health criterion.

June 2008 Appendix A. Facility Analyses A-26

### Arsenic

Note that although ambient concentrations are gr eater than the criterion, the Willamette River near the discharge is no t on the state’s 303(d) list as impaired for arsenic. If ODEQ determines that the ambient concentration re presents natural background levels , it would grant dilution in the RPA calculation (ODEQ, 2005). Under this scenari o, the concentration at the edge of the mixing zone would be 0.62 μg/L, or approximately 4% above the ambient b ackground concentration. ODEQ (2005) indicates th at dischargers that cause less th an a 10% increase in downstream receiving water concentrations would not be give n numeric effluent limits; rather they would be required to implement narrative BMPs and increa sed monitoring. The costs of such measures could be comparable to the cost of implemen ting a mercury P2 program because the facility would likely conduct similar actions and activities. Thus, co sts could be approximately $100,000 per year.

If ODEQ determines that the water body is im paired, it would not gr ant dilution and base effluent limits on achieving the criterion end-of-pipe. However, because the baseline criterion is below the QL, the discharger would only need to reduce effluent levels to the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with baseline standards.

Arsenic and arsenic-containing chemicals are not us ed in wastewater treatm ent. The facility’s permit does not indicate whether ther e are any significant or categorical industrial users. If the facility determines that one or more of its indi rect dischargers is causi ng or contributing to high arsenic levels in the effluent, it would mostly likely implement a source control program to target the dischargers or impose more stringent pretre atment limits on the dischargers. Without specific information on the types of industrial di schargers that may need controls, it is not possible to estimate pretreatment or P2 costs to indirect dischargers.

Other potential sources of arsenic to the tr eatment plant are drinking water and groundwater infiltration. The City of Milwaukie’s wate r system relies on seven operating wells and 500,000 gallons of water per day from the Clackamas Wa ter Department (water is from the Clackamas River). Since 1985, arsenic has been detected in the groundwater wells numerous times, ranging from 2 μg/L up to 5.2 μg/L (ODHS, 2007c). Th ese concentrations, while lower than EPA’s drinking water maximum contaminant level (MCL) of 10 μg/L, could contribute to arsenic levels above the human health criterion of 0.0022 μg/L. However, the facility would still need to determine if the major effluent source is th e influent drinking wate r or infiltration from groundwater into the sewer system.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $200,000, with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be $3,511,000 for a comprehensive I&I reduction program that includes source identif ication and pipe rehabilitation for a system with 70 miles of sewer pipes (approximately $331,000 per year annualiz ed at 7% over 20 year s). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for comp liance and the discharg er would not likely undertake such a program for compli ance with toxic criteria alone.

June 2008 Appendix A. Facility Analyses A-27

### Mercury

Under existing procedures, the applicable AMEL is 0.017 μg/L and the MDEL is 0.034 μg/L (i.e., criterion end-of-pipe because the water body is impaired). The maximum effluent concentration at the facility is 0.013 μg/L, which is lower than both projected limits.

Under the baseline Willamette River Basin merc ury TMDL, the facility would be required to develop and implement a mercury reduction stra tegy. Annual P2 program costs for a 7.1 mgd municipal facility may be approximately $100,000 (s ee Appendix B for details). As described in Appendix B, P2 costs also potentially include costs for indirect disc hargers to implement controls (see Exhibit B-2). Based on informati on on the discharger’s service area, incremental indirect discharger costs may be minimal (e.g., th ere are no universities in the service area). However, because ODEQ does not assign individual wasteload allocations to point source dischargers in the TMDL (point sources as a w hole are required to reduce existing load by 26%), it is uncertain whether the facili ty would incur costs beyond those for a P2 program to meet the wasteload allocation under the baseline TMDL.

Revised Criteria



### Exhibit A-20 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-20. RPA for Revised Criteria, Kellogg Creek WWTP Human Health Criteria for Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd
Arsenic 1.06 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.018
Nickel 0.66 280 190 140 69.0 45.0 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on the facility’s existing permit (factor = 19.9). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger woul d have RP for arsenic and mercury based on all alternative fish consumption rates.

Arsenic

The discharger would have RP for arsenic at a ll fish consumption rates. Thus, because the ambient concentration is greater than the criteria, the discharger would need to reduce discharge concentrations to background (if ODEQ determines that ambient concentrations represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with revised standards. Howeve r, under the baseline, the discharge would need to meet those same levels. Thus, incremental compliance costs would be unlikely.

June 2008 Appendix A. Facility Analyses A-28

### Mercury

The discharger would have RP for mercury at all of the revised consumption rates. Exhibit A21 shows the AMELs and MDELs for each consumption rate in the absence of a TMDL.

Exhibit A-21. Projected Effluent Limits for Mercury, Kellogg Creek WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.0047 0.0026 0.0017 0.00076 0.00048 MDEL ( μ g/L) 0.0094 0.0052 0.0034 0.0015 0.00096



### The maximum effluent concentration is greater th an all of the AMELs and MDELs. The facility is already required to implem ent a mercury P2 program under the baseline as part of the Willamette Basin mercury TMDL. It is not clea r how ODEQ would adapt the baseline TMDL to attain the revised crit eria (e.g., increase point source load reduction requirements; establish individual effluent limits). Thus, it is uncertain whether c ontinued implementation of the baseline P2 program would be sufficient for compliance with th e revised criteria/TMDL because there could be some maximum level of effort beyond which a P2 program would not provide additional reductions.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consis tent basis, dischargers may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied) under mo re stringent TMDL requirements (alternatively, ODEQ may account for this situation in allocating loads under the TMDL). However, it is uncertain at which fish consumption rate the discharger would need a variance. If the discharger pursues a variance for arsenic, these efforts would also cover a variance for mercury. Otherwise, one-time costs a ssociated with pursuing a variance could range from $35,000 to $200,000. As part of a variance ODEQ, could require specific P2 program efforts. For dischargers covered under the Willamette River TMDL for mercury, these activities may already be included in thei r baseline mercury P2 requirement.

Summary



### Exhibit A-22 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline criteria. Under a variance scenario for arsenic an d/or mercury, costs would likely fall within the range shown in the exhibit (e.g., a one-time expenditure of approximately $35,000 to $200,000).

Exhibit A-22. Summary of Potential Costs, Kellogg Creek WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits, BMPs, varian ce, or I&I reduction program (arsenic) Baseline $100,000 - $431,000 NA

• P2 program (mercury)

June 2008 Appendix A. Facility Analyses A-29

### Exhibit A-22. Summary of Potential Costs, Kellogg Creek WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits, BMPs, varian ce, or I&I reduction program (arsenic) 63.2 gpd $100,000 - $431,000 $0

• P2 program possible variance (mercury)

• Intake credits, BMPs, varian ce, or I&I reduction program (arsenic) 113 gpd $100,000 - $431,000 $0

• P2 program possible variance (mercury)

• Intake credits, BMPs, varian ce, or I&I reduction program (arsenic) 175 gpd $100,000 - $431,000 $0

• P2 program possible variance (mercury)

• Intake credits, BMPs, varian ce, or I&I reduction program (arsenic) 389 gpd $100,000 - $431,000 $0

• P2 program possible variance (mercury)

• Intake credits, BMPs, varian ce, or I&I reduction program (arsenic) 620 gpd $100,000 - $431,000 $0

• P2 program possible variance (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-30

### City of McMinnville Water Reclamation Facility

Facility Description

The City of McMinnville Water Reclamation F acility (NPDES permit number OR0034002) is a major facility serving McMinnville, Oregon. Th e facility has an ADWDF of 5.6 mgd, and discharges treated effluent through Outfall 001 into the South Yamhill River at river mile 0.3 where the 7Q10 flow is 16 cfs. The facility al so has 15 other outfalls ca tegorized as emergency overflows.

Treatment Processes

The 2003 NPDES permit for the facility lists curr ent treatment processes as an off-site raw influent pump station and screen, headworks, activated sludge oxidation ditches, secondary clarifiers, tertiary clar ifiers, single media filters, UV di sinfection, and effluent reaeration. Secondary sludge is thickened with two gravity belt thickeners before undergoing autothermal thermophilic aerobic digestion. The City transfers digested sludge to a 2.8 million gallons biosolids storage tank, and land applies the stor ed liquid biosolids on local farms during the

summer.

Effluent Data and Limits

Exhibit A-23 summarizes monitoring data from June 2004 to March 2007 for those pollutants of concern for which effluent data ar e available. The facility does not have effluent limits for any toxic pollutants.

Exhibit A-23. Effluent Da ta Summary, McMinnville WRF 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 Geometric Maximum Minimum (μg/L) Mean 1,1,2,2-Tetrachloroethane 5 5 1 - - - 1,1,2-Trichloroethane 5 5 1 - - - 1,1-Dichloroethylene 5 5 1 - - - 1,2,4-Trichlorobenzene 4 4 4.76 - - - 1,2-Dichlorobenzene 9 9 4.76 - - - 1,2-Dichloroethane 5 5 1 - - - 1,2-Dichloropropane 5 5 1 - - - 1,2-Diphenylhydrazine 4 4 4.76 - - - 1,3-Dichlorobenzene 9 9 4.76 - - - 1,4-Dichlorobenzene 9 9 4.76 - - - 2,4,6-Trichlorophenol 4 4 4.76 - - - 2,4-Dichlorophenol 4 4 4.76 - - - 2,4-Dimethylphenol 4 4 9.52 - - - 2,4-Dinitrophenol 4 4 23.8 - - - 2,4-Dinitrotoluene 4 4 4.76 - - - 2-Chloronaphthalene 4 4 4.76 - - - 2-Chlorophenol 4 4 4.76 - - -

June 2008 Appendix A. Facility Analyses A-31June 2008 Appendix A. Facility Analyses A-32 

### Exhibit A-23. Effluent Da ta Summary, McMinnville WRF 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

3,3'-Dichlorobenzidine 4 4 4.76 - - - 4,4'-DDD 4 4 0.0952 - - - 4,4'-DDE 4 4 0.0952 - - - 4,4'-DDT 4 4 0.0952 - - - Acenaphthene 4 4 4.76 - - - Acrolein 5 5 10 - - - Acrylonitrile 5 5 10 - - - Aldrin 4 4 0.0952 - - - alpha-BHC 4 4 0.0952 - - - Anthracene 4 4 4.76 - - - Antimony 8 0 0.02 0.24 0.17 0.12 Arsenic (Inorganic) 23 0 0.075 1.3 0.97 0.52
Benzene 5 5 1 - - - Benzidine 4 4 57.1 - - - Benzo(a) Anthracene 4 4 4.76 - - - Benzo(a) pyrene 4 4 4.76 - - - Benzo(b) Fluoranthene 4 4 4.76 - - - Benzo(k) Fluoranthene 4 4 4.76 - - - Beryllium 4 4 0.06 - - - beta-BHC 4 4 0.0952 - - - Bis(2-Chloroethyl) Ether 4 4 4.76 - - - Bis(2-Chloroisopropyl) Ether 4 4 9.52 - - - Bis(2-Ethylhexyl) Phthalate 4 4 9.52 - - - Bromoform 5 5 1 - - - Butylbenzyl Phthalate 4 4 4.76 - - - Carbon tetrachloride 5 5 1 - - - Chlordane 4 4 0.0952 - - - Chlorobenzene 5 5 1 - - - Chlorodibromomethane 5 5 1 - - - Chloroform 5 5 1 - - - Chrysene 4 4 4.76 - - - Dibenzo(a,h)Anthracene 4 4 4.76 - - - Dichlorobromomethane 5 5 1 - - - Dieldrin 4 4 0.0952 - - - Diethyl Phthalate 4 4 4.76 - - - Dimethyl Phthalate 4 4 4.76 - - - Di-n-Butyl Phthalate 4 4 4.76 - - - Endosulfan sulfate 4 4 0.0952 - - - Endrin 4 4 0.0952 - - - Endrin Aldehyde 4 4 0.0952 - - - Ethylbenzene 5 5 1 - - - Fluoranthene 4 4 4.76 - - - Fluorene 4 4 4.76 - - -

### Exhibit A-23. Effluent Da ta Summary, McMinnville WRF 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean gamma-BHC 4 4 0.0952 - - - Heptachlor 4 4 0.0952 - - - Heptachlor Epoxide 4 4 0.0952 - - - Hexachlorobenzene 4 4 4.76 - - - Hexachlorobutadiene 4 4 9.52 - - - Hexachlorocyclopentadiene 4 4 9.52 - - - Hexachloroethane 4 4 9.52 - - - Ideno(1,2,3-cd)Pyrene 4 4 4.76 - - - Isophorone 4 4 4.76 - - - Mercury 23 0 0.0005 0.011 0.0021 0.0008 Methylene chloride 5 5 5 - - - Nickel 30 0 0.10 1.34 0.73 0.39 Nitrobenzene 4 4 4.76 - - - N-Nitrosodimethylamine 4 4 4.76 - - - N-Nitrosodi-n-Propylamine 4 4 9.52 - - - N-Nitrosodiphenylamine 4 4 4.76 - - - Pentachlorophenol 4 4 9.52 - - - PCBs 3 3 3 0.472 - - - Phenol 4 4 4.76 - - - Pyrene 4 4 4.76 - - - Selenium 30 21 0.6 0.49 0.37 0.28 Tetrachloroethylene 5 5 1 - - - Thallium 8 8 0.005 - - - Toluene 5 5 1 - - - Toxaphene 4 4 4.76 - - - Trichloroethylene 5 5 1 - - - Vinyl chloride 5 5 1 - - - QL = Quantification limit. 1. Represents effluent data from June 2004 to March 2007. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

The harmonic mean receiving water flow for the South Yamhill River is 85.5 cfs, based on daily stream flow measurements from August 2005 through March 2007. There are insufficient data available to calculate the 30Q5 from these measurem ents for the discharge. However, flow data from a United States Geological Survey (USGS) gauge station 5 miles downstream of the discharge indicates that the ratio of the 7Q10 fl ow to the 30Q5 flow is 2.37. Assuming a similar flow pattern and ratio, the 30Q5 for the South Ya mhill River upstream of the discharge would be 37.9 cfs (16 cfs 7Q10 flow × 2.37).

June 2008 Appendix A. Facility Analyses A-33

### Exhibit A-24 summarizes data for the South Yamhill River, approximately 300 yards upstream of the discharge, from August 2005 to October 2006 for those pollutants of concern for which ambient data are available.

Exhibit A-24. Ambient Data Summary, McMinnville WRF 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 2 2 1 - - - 1,1,2-Trichloroethane 2 2 1 - - - 1,1-Dichloroethylene 2 2 1 - - - 1,2-Dichlorobenzene 2 2 1 - - - 1,2-Dichloroethane 2 2 1 - - - 1,2-Dichloropropane 2 2 1 - - - 1,3-Dichlorobenzene 2 2 1 - - - 1,4-Dichlorobenzene 2 2 1 - - - Acrolein 2 2 10 - - - Acrylonitrile 2 2 6 - - - Antimony 4 0 0.02 0.064 0.043 0.037 Arsenic (Inorganic) 9 1 0.75 0.85 0.44 0.24
Benzene 2 2 1 - - - Beryllium 8 8 0.06 - - - Bromoform 2 2 1 - - - Carbon tetrachloride 2 2 1 - - - Chlorobenzene 2 2 1 - - - Chlorodibromomethane 2 2 1 - - - Chloroform 2 2 1 - - - Dichlorobromomethane 2 2 1 - - - Ethylbenzene 2 2 1 - - - Mercury 8 0 0.0005 0.0014 0.00094 0.00065 Methylene chloride 2 2 5 - - - Nickel 20 2 0.04 0.66 0.29 0.045 Selenium 21 13 1.5 0.55 0.39 0.30 Tetrachloroethylene 2 2 1 - - - Thallium 4 4 0.005 - - - Toluene 2 2 1 - - - Trichloroethylene 2 2 1 - - - Vinyl chloride 2 2 1 - - - QL = Quantification limit. 1. Represents ambient data from August 2005 to October 2006.



### Potential Impacts

Baseline Criteria



### Exhibit A-25 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The

June 2008 Appendix A. Facility Analyses A-34

### South Yamhill River is a freshwater river; thus , human health criteria for consumption of organisms and water are applicab le. ODEQ (2006b) allows 25% of the harmonic mean flow for dilution for carcinogens and 25% of the 30Q5 flow for dilution for noncarcinogens.

Exhibit A-25. RPA for Baseline Criteria, McMinnville WRF

Parameter Calculated Effluent Conc. 1 ( μ g/L) Conc. at Edge Ambient Human Health Reasonable of Mixing Conc. 2 (

μ g/L) Zone 3 (

μ g/L) Criterion ( μ g/L) Potential

Antimony 0.46 0.043 0.24 5.6 No Arsenic 1.04 0.44 1.04 0.0022 Yes Mercury 4 0.014 0.00094 0.0073 0.017 No Nickel 1.53 0.29 0.88 13.4 No Selenium 0.59 0.39 0.49 10 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants except ar senic (CV = 0.148) and nickel (CV = 0.42) (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on 25% of 30Q5 flow for noncarcinogens (fac tor = 1.1) and 25% of harmonic mean flow for carcinogens (factor = 2.5). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### Arsenic

As shown in the exhibit, the facility has RP to exceed baseline criteria for arsenic because the concentration at the edge of th e regulatory mixing zone is greate r than the applicable existing human health criterion. Note also that although ambient concen trations are greater than the criterion, the South Yamhill River is not on the st ate’s 303(d) list as impaired for arsenic. Regardless, the facility would be discharging arsenic above allo wable levels and, under existing procedures, ODEQ would require the facility to reduce discharge concentrations to background (if ODEQ determines that ambient concentrations represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with baseline standards.

Inorganic arsenic can enter surface waters throu gh atmospheric deposition (e.g., arsenic released into the air by volcanoes), soil erosion and weat hering of arsenic-contai ning minerals and ores, and commercial or industrial processes, such as metal smelting, wood preserving, and manufacturing of microelectr onics and semiconductors (ODEQ, 2006a). Arsenic and arseniccontaining chemicals are not used in wastewat er treatment. However, drinking water and groundwater infiltration are two pot ential sources of arsenic to th e treatment plant. McMinnville Water and Light supplies the City with drinking water from two reservoirs: Haskins and McGuire. All arsenic samples (organic plus inorganic) from the reservoirs since 1986 are nondetect below the minimum reporting levels (ODHS, 2007d). The minimum reporting levels are not specified, and the drinking water maximum c ontaminant level is 10 μg/L, which is higher than current effluent concentrations and human h ealth criteria. Thus, fr om these data it is not possible to determine if drinking water is contri buting to high arsenic leve ls in the wastewater effluent. However, if the facility determines that drinking water is th e source of high arsenic values in the wastewater, it is likely that the facility would pursue a variance or request that ODEQ consider granting the facility intake credits.

June 2008 Appendix A. Facility Analyses A-35

### USGS (1998) indicates that arsenic concentrations exceeding EPA’s previous maximum contaminant level of 50 μg/L are widespread in groundwater in the Willamette Basin. In addition, the facility has already begun addressing I&I issues. EP A and ODEQ have directed the City to control the sewage overflows into the Yamhill River. The City, with the assistance of consultants, determined that structural defects in sewer pi pes and manholes allow unwanted storm water inflow and infiltration to overload the sewage system (City of McMinnville, 2007). The City’s experts have estimated that approximately 60% of the infiltration is from private sewer laterals (e.g., broken pipes, roof downspout s, basement drains, or area drains that are connected to the private sewer lateral) (City of McMinnville, 2007). The City is currently requiring that all defective private sewer latera ls be replaced to meet the overflow control objective, targeting the areas of town where pipes are repaired and/or replaced first. The City plans to continue the program, moving from one area to another, for the next 10 to 20 years (City of McMinnville, 2007). However, it is not clear if , or when, the overflow reduction goal will be met, and whether meeting this goal would also result in the needed reductions in arsenic.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $200,000, with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be relatively minimal if the ongoing I&I study is sufficient to $3,700,000 for an I&I reduction progra m that includes pipe rehabilitation (source identification is not included because the City has already conducted such a study) for a system with 100 miles of sewer pipes (approximate ly $349,000 per year annualized at 7% over 20 years).

Mercury

Under the baseline Willamette River Basin merc ury TMDL, the facility would be required to develop and implement a mercury reduction stra tegy. Annual P2 program costs for a 5.6 mgd municipal facility may be approximately $100,000 (s ee Appendix B for details). As described in Appendix B, P2 costs also potentially include costs for indirect disc hargers to implement controls (see Exhibit B-2). Based on informati on on the discharger’s service area, incremental indirect discharger costs may be $12,000 per year (e.g., there is one university in the service area). However, because ODEQ does not assign i ndividual wasteload alloca tions to point source dischargers in the TMDL (point sources as a w hole are required to reduce existing load by 26%), it is uncertain whether the facili ty would incur costs beyond those for a P2 program to meet the wasteload allocation under the baseline TMDL.

Revised Criteria



### Exhibit A-26 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

June 2008 Appendix A. Facility Analyses A-36

### Exhibit A-26. RPA for Revised Criteria, McMinnville WRF Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Antimony 0.24 5.40 5.30 5.10 4.70 4.30 Arsenic 1.04 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.0073 Nickel 0.88 280 190 140 69.0 45.0 Selenium 0.49 150 140 120 91.0 70.0 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on 25% of 30Q5 flow for noncarcinogens (fac tor = 1.1) and 25% of harmonic mean flow for carcinogens (factor = 2.5). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger coul d have RP for arsenic and mercury based on the alternative fish consumption rates.

Arsenic

The discharger would have RP for arsenic at a ll fish consumption rates. Thus, because the ambient concentration is greater than the criteria, the discharger would need to reduce discharge concentrations to background (if ODEQ determines that ambient concentrations represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with revised standards. Howeve r, under the baseline, the discharge would need to meet those same levels. Thus, incremental compliance costs would be unlikely.

Mercury

The discharger would have RP for merc ury at all the consumption rates. Exhibit A-27 shows the AMELs and MDELs for each consumption rate. Note that because the background concentration is above the appli cable criteria the discharger w ould receive effluent limits based on criteria end-of-pipe (ODEQ, 2005).

Exhibit A-27. Projected Effluent Limits for Mercury, McMinnville WRF Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.0047 0.0026 0.0017 0.00076 0.00048 MDEL ( μ g/L) 0.0094 0.0052 0.0034 0.0015 0.00096



### The maximum effluent concentration at the facility is 0.011 μg/L, which is greater than all of the projected AMELs and MDELs. The facility is already required to implement a mercury P2 program under the baseline as part of the Willa mette Basin mercury TMDL. It is not clear how ODEQ would adapt the baseline TMDL to attain the revised criter ia (e.g., increase point source load reduction requirements; establ ish individual effluent limits). Thus, it is uncertain whether continued implementation of the baseline P2 pr ogram would be sufficient for compliance with

June 2008 Appendix A. Facility Analyses A-37

### the revised criteria/TMDL because there could be some maximum level of effort beyond which a P2 program would not provide additional reductions.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consis tent basis, dischargers may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied) under mo re stringent TMDL requirements (alternatively, ODEQ may account for this situation in allocating loads under the TMDL). However, it is uncertain for which c onsumption rates the discharger would need a variance. If the discharger pursues a variance for arsenic, these efforts would also cover a variance for mercury. Otherwise, one-time costs a ssociated with pursuing a variance could range from $35,000 to $200,000. As part of a variance ODEQ, could require specific P2 program efforts. For dischargers covered under the Willamette River TMDL for mercury, these activities may already be included in their baseline mercury P2 requirement.

Summary



### Exhibit A-28 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline criteria. Under a variance scenario for arseni c and/or mercury, costs could include a one-time expenditure of $35,000 to $200,000.

Exhibit A-28. Summary of Potential Costs, McMinnville WRF

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits, variance, or I&I reduction program (arsenic) $112,000 - $461,000 NA Baseline

• P2 program (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $112,000 - $461,000 $0 63.2 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $112,000 - $461,000 $0 113 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $112,000 - $461,000 $0 175 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $112,000 - $461,000 $0 389 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $112,000 - $461,000 $0 620 gpd

• P2 program, possible variance (mercury) 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-38

### City of North Bend Wast ewater Treatment Plant

Facility Description

The City of North Bend Waste Water Treatm ent Plant (NPDES permit number OR0023361) treats wastewater for North Bend, Oregon. The facility treats dome stic wastewater from residential and commercial sources for a populat ion of approximately 9,700. ODEQ classifies this 2.2 mgd (ADWDF) as a major discharger. Tr eated effluent is discharged through outfall 001 into Coos Bay. The facility also has nine othe r outfalls categorized as emergency overflows.

Treatment Processes

The 2003 NPDES permit for the facility lists cu rrent treatment processes as headworks, a primary clarifier, two secondary clarifiers, three aeration basi ns, and chlorine disinfection. Sludge from the primary and sec ondary clarifiers is stabilized and land applied as Class B biosolids to beneficial use sites locate d on the North Bend Airport properties.

Effluent Data and Limits

Exhibit A-29 summarizes monitoring data from January 2006 to December 2006 for those pollutants of concern for which effl uent data are available. The f acility does not have effluent limits for any toxic pollutants.

Exhibit A-29. Effluent Data Summary, North Bend WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 3 3 0.5 - - - 1,1,2-Trichloroethane 3 3 0.5 - - - 1,1-Dichloroethylene 3 3 0.5 - - - 1,2,4-Trichlorobenzene 6 6 10 - - - 1,2-Dichlorobenzene 6 6 20 - - - 1,2-Dichloroethane 3 3 0.5 - - - 1,2-Dichloropropane 3 3 0.5 - - - 1,2-Trans-Dichloroethylene 3 3 0.5 - - - 1,3-Dichlorobenzene 6 6 20 - - - 1,4-Dichlorobenzene 6 6 20 - - - 2,4,6-Trichlorophenol 3 3 20 - - - 2,4-Dichlorophenol 3 3 20 - - - 2,4-Dimethylphenol 3 3 20 - - - 2,4-Dinitrophenol 3 2 20 35 35 35 2,4-Dinitrotoluene 3 3 10 - - - 2-Chloronaphthalene 3 3 10 - - - 2-Chlorophenol 3 3 20 - - - 2-Methyl-4,6-Dinitrophenol 3 3 20 - - - 3,3'-Dichlorobenzidine 3 3 25 - - - 4,4'-DDD 3 3 0.04 - - -

June 2008 Appendix A. Facility Analyses A-39June 2008 Appendix A. Facility Analyses A-40 

### Exhibit A-29. Effluent Data Summary, North Bend WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

4,4'-DDE 3 3 0.04 - - - 4,4'-DDT 3 3 0.04 - - - Acenaphthene 3 3 10 - - - Acrolein 3 3 50 - - - Acrylonitrile 3 3 50 - - - Aldrin 3 3 0.02 - - - alpha-BHC 3 3 0.02 - - - Anthracene 3 3 10 - - - Antimony 3 1 0.2 0.74 0.50 0.34 Arsenic 1 0 0 0.72 0.72 0.72 Benzene 3 3 0.5 - - - Benzidine 3 3 10 - - - Benzo(a) Anthracene 3 3 10 - - - Benzo(a) Pyrene 3 3 10 - - - Benzo(b) Fluoranthene 3 3 10 - - - Benzo(k) Fluoranthene 3 3 20 - - - Beryllium 3 3 0.1 - - - beta-BHC 3 3 0.02 - - - Bis(2-Chloroethyl) Ether 3 3 10 - - - Bis(2-Chloroisopropyl) Ether 3 3 10 - - - Bis(2-Ethylhexyl) Phthalate 3 3 10 - - - Bromoform 3 3 0.5 - - - Butylbenzyl Phthalate 3 3 10 - - - Carbon Tetrachloride 3 3 0.5 - - - Chlordane 3 3 0.1 - - - Chlorobenzene 3 3 0.5 - - - Chlorodibromomethane 3 3 0.5 - - - Chloroform 3 0 0 1.7 0.98 0.65 Chrysene 3 3 10 - - - Dibenzo(a,h)Anthracene 3 3 10 - - - Dieldrin 3 3 0.04 - - - Diethyl Phthalate 3 3 10 - - - Dimethyl Phthalate 3 3 10 - - - Di-n-Butyl Phthalate 3 3 10 - - - Endosulfan Sulfate 3 3 0.04 - - - Endrin 3 3 0.04 - - - Endrin Aldehyde 3 3 0.04 - - - Ethylbenzene 3 3 0.5 - - - Fluoranthene 3 3 10 - - - Fluorene 3 3 10 - - - gamma-BHC 3 3 0.02 - - - Heptachlor 3 3 0.02 - - - Heptachlor Epoxide 3 3 0.02 - - - Hexachlorobenzene 3 3 10 - - -

### Exhibit A-29. Effluent Data Summary, North Bend WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean
Hexachlorobutadiene 3 3 10 - - - Hexachlorocyclopentadiene 3 3 20 - - - Hexachloroethane 3 3 20 - - - Ideno(1,2,3-cd)Pyrene 3 3 10 - - - Isophorone 3 3 10 - - - Mercury 1 1 0.1 - - - Methylene Chloride 3 3 2 - - - Nickel 3 0 0 5.9 1.92 0.98 Nitrobenzene 3 3 10 - - - N-Nitrosodimethylamine 3 3 10 - - - N-Nitrosodi-n-Propylamine 3 3 10 - - - N-Nitrosodiphenylamine 3 3 10 - - - PCBs 3 3 3 0.1 - - - Pentachlorophenol 3 3 20 - - - Phenol 3 3 20 - - - Pyrene 3 3 10 - - - Selenium 3 0 0 4.16 1.31 0.63 Tetrachloroethylene 3 3 0.5 - - - Thallium 2 2 0.5 - - - Toluene 3 0 0 1.2 0.87 0.54 Toxaphene 3 3 0.25 - - - Trichloroethylene 3 3 0.5 - - - Vinyl Chloride 3 3 0.5 - - - QL = Quantification limit. 1. Represents effluent data from January 2006 to December 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

Baseline Criteria



### Exhibit A-30 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect). Coos Bay is estuarine; thus, human h ealth criteria for consumption of organisms only are applicable. The dilution factors are based on the chronic mi xing zone factors used in the existing permit because flow data are not available from which to calculate the harmonic mean and 30Q5 flows.

June 2008 Appendix A. Facility Analyses A-41

### Exhibit A-30. RPA for Baseline Criteria, North Bend WRF

Parameter Calculated Effluent Conc. 1 ( μ g/L) Conc. at Edge Ambient Human Health Reasonable of Mixing Conc. 2 (

μ g/L) Zone 3 (

μ g/L) Criterion ( μ g/L) Potential

2,4-Dinitrophenol 105 0 1.0 5300 No Antimony 2.22 0 0.021 640 No Arsenic 4.46 0 0.042 0.018 Yes Chloroform 2.94 0 0.028 15.7 No Nickel 17.7 0 0.17 100 No Selenium 12.5 0 0.12 4200 No Toluene 3.6 0 0.034 15000 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on chronic mixing zone diluti on factors in existing permit (factor = 105).



### As shown in the exhibit, the facility has RP to exceed the baseline criterion for arsenic because the concentration at the edge of the regulatory mi xing zone is greater than the applicable existing human health criterion. However, the analysis is based on only one data point, resulting in a calculated effluent concentration more than six times greater than the actual effluent concentration. Thus, whether the discharger woul d have RP with more effluent data is highly uncertain.

If additional effluent data indicate RP, the facility would receive effluent limits. The AMEL would be 1.84 μg/L and the MDEL would be 3.69 μg /L based on the procedures described in Section 4.1.2 (assuming a CV of 0.6). The only effluent value availa ble is less than both projected effluent limits. Thus, it is possible that additional mon itoring data could indicate that the facility is in compliance with the projected effluent limits and no costs would be incurred for compliance. However, additional data could also indicate that effluent arsenic concentrations exceed the projected limits, and the discharger ma y need to reduce discharge concentrations for compliance with baseline standards.

Arsenic and arsenic-containing chemicals are not us ed in wastewater treatment, and the facility does not serve any significant i ndustrial users. Based on the mo st conservative dilution factors from the City’s mixing zone study, and influent , effluent and biosolids monitoring data, ODEQ (2003) determined that toxic metals are not pa ssing through the treatment facility. However, drinking water and groundwater infi ltration are two potential sources of arsenic to the treatment plant.

The Coos Bay-North Bend Water Board supplies the City with drinking water from its water treatment plant that draws water from Pony Creek. The City detected arsenic twice in drinking water since May 2004 (1.3 μg/L in 2007 and 0.5 μg/L in 2004) (ODHS, 2007b). Thus, it is possible that drinking water is cont ributing to high arsenic levels in the wastewater effluent. In this case, it is likely that the facility woul d pursue a variance or reque st that ODEQ consider granting the facility intake credits.

The facility’s permit also indicates that it has severe I&I problems and that primary treatment bypass occurs on average about once per month due to heavy rainfall and a high groundwater

June 2008 Appendix A. Facility Analyses A-42

### table. If groundwater infiltrati on is causing the high arsenic effl uent levels, the discharger may have to implement an I&I reduction program for co mpliance with the existing criteria. However, an I&I program that targets overflows may not include the same activities as a program that targets infiltration to reduce arsenic concentratio ns. For example, overflow detention basins may be used to collect excess flows until capacity is available to treat the water (similar to an equalization basin). Detention basins do not pr event groundwater high in arsenic from entering the system though; only pipe rehabilit ation would prevent infiltration.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $100,000, with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be $1,850,000 for an I&I reduction program that includes pipe rehabilitation (sour ce identification costs are not in cluded because this would be completed to address the existing I&I issues) for a system with 50 miles of sewer pipes (approximately $174,000 per year annualized at 7% over 20 years). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for compliance and th e discharger would not likely undertake such a program for compliance with toxic criteria alone.

Revised Criteria



### Exhibit A-31 summarizes the RPA for the revised human health criteria for consumption of organisms only for those pollutants detected in th e effluent (there will be no RP or monitoring requirements if all obser vations are nondetect).

Exhibit A-31. RPA for Revised Criteria, North Bend WWTP Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 2,4-Dinitrophenol 1.00 1500 830 530 240 150 Antimony 0.021 180 99.0 64.0 29.0 18.0
Arsenic 0.042 0.014* 0.0080* 0.0052* 0.0023* 0.0015*
Chloroform 0.028 48.0 27.0 17.0 7.90 4.90 Nickel 0.17 470 260 170 77.0 48.0
Selenium 0.12 1200 650 420 190 120 Toluene 0.034 4100 2300 1500 670 420 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on chronic mixing zone diluti on factors in existing permit (factor = 105).



### As shown in the exhibit, the discharger would ha ve RP for arsenic at al l alternative consumption

rates. Exhibit A-32 shows the projected effluent limits for these consumption rates.

Exhibit A-32. Projected Effluent Limits for Arsenic, North Bend WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 1.5 0.84 0.55 0.24 0.16 MDEL ( μ g/L) 3.0 1.7 1.1 0.48 0.32

June 2008 Appendix A. Facility Analyses A-43

### As described in the baseline analysis, the discharger may need to reduce effluent concentrations for compliance with baseline crit eria, or pursue alternative comp liance measures. These are the same compliance scenarios that would apply under all of the potential revised criteria. The baseline I&I reduction program includes a comp rehensive study to identify all potential infiltration sources and rehabilita tion of those sources. Thus, base line controls, or alternative actions, should also enable compliance with the revised criteria, and there would be no incremental compliance costs.

Summary



### Exhibit A-33 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent the any costs above and beyond those that would be needed for compliance with baseline criteria. Under a vari ance scenario for arsenic, costs would likely fall within the range shown in the exhibit (e.g., a one-time e xpenditure of approximately $35,000 to $100,000).

Exhibit A-33. Summary of Po tential Costs, North Bend WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• None (in compliance), intake credits, variance, or I&I

reduction program (arsenic) $0 - $174,000 NA Baseline

• None (in compliance), intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 63.2 gpd

• None (in compliance), intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 113 gpd

• None (in compliance), intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 175 gpd

• None (in compliance), intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 389 gpd

• None (in compliance), intake credits, variance, or I&I reduction program (arsenic) $0 - $174,000 $0 620 gpd

NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-44

### Portland, Columbia Boulevard WWTP

Facility Description

The City of Portland operates the Columbia Boulevard Wastewater Treatment Plant (NPDES permit number OR0026905) which treats domestic, co mmercial, and industri al wastewater from the City of Portland, Oregon. The ADWDF for the plant is 100 mgd, while the design peak wet weather flow is 300 mgd. ODEQ classifies the f acility as a major discharger. The facility discharges treated municipal wastewater th rough Outfall 001 and wastewater from its wet weather treatment facility through Outfall 003 to the Columbia River at river mile 105.5. EPA’s PCS database indicates that average monthly flows from Outfa lls 001 and 003 are 70 mgd and 10 mgd, respectively. The facility also has se veral outfalls for bypass and overflows.

Treatment Processes

The NPDES permit for the facility indicates th at the plant underwent many improvements during the 1990’s. Most notable were the disinfect ion system improvements completed in 1991, modifications to the secondary treatment sy stem completed in 1994, addition of an outfall diffuser in 1995, and replacement of the headworks completed in 1996. The facility hauls most biosolids to Northeastern Oregon for land applic ation, and composts the rest to create a soil amendment for local landscapers.

Effluent Data and Limits

Exhibits A-34 and A-35 summarizes monitoring data for Outfalls 001 and 003 from January 2004 to December 2006 for those pollutants of concer n for which effluent data are available. The facility does not have effluent limits for any toxic pollutants.

Exhibit A-34. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 001 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 22 22 3 - - - 1,1,2-Trichloroethane 22 22 2 - - - 1,1-Dichloroethylene 22 22 5 - - - 1,2,4-Trichlorobenzene 23 23 5 - - - 1,2-Dichlorobenzene 45 45 5 - - - 1,2-Dichloroethane 22 22 2 - - - 1,2-Dichloropropane 22 22 2 - - - 1,3-Dichlorobenzene 45 45 5 - - - 1,4-Dichlorobenzene 45 43 5 3.2 2.5 2.0 2,3,7,8-TCDD (Dioxin) 12 0 1.0E -7 5.5E-6 5.0E-6 4.8E-6 2,4,6-Trichlorophenol 23 23 5 - - - 2,4-Dichlorophenol 23 23 5 - - - 2,4-Dimethylphenol 23 23 10 - - - 2,4-Dinitrophenol 23 23 20 - - - 2,4-Dinitrotoluene 23 23 5 - - -

June 2008 Appendix A. Facility Analyses A-45June 2008 Appendix A. Facility Analyses A-46 

### Exhibit A-34. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 001 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2-Chloronaphthalene 23 23 5 - - - 2-Chlorophenol 23 23 5 - - - 2-Methyl-4,6-dinitrophenol 23 23 10 - - - 3,3'-Dichlorobenzidine 23 23 5 - - - 4,4'-DDD 23 23 0.5 - - - 4,4'-DDE 23 23 0.5 - - - 4,4'-DDT 23 23 0.962 - - - Acenaphthene 23 23 5 - - - Acrolein 22 22 10 - - - Acrylonitrile 22 22 10 - - - Aldrin 23 23 0.5 - - - Alpha-BHC 23 23 0.5 - - - Anthracene 23 23 5 - - - Arsenic 66 0 0.1 1.71 0.78 0.45 Benzene 22 22 3 - - - Benzidine 23 23 50 - - - Benzo(a) Anthracene 23 23 5 - - - Benzo(a) Pyrene 23 23 5 - - - Benzo(b) Fluoranthene 23 23 5 - - - Benzo(k) Fluoranthene 23 23 5 - - - Beta-BHC 23 23 1 - - - Bis(2-chloroethyl) ether 23 23 5 - - - Bis(2-chloroisopropyl) ether 23 23 10 - - - Bis(2-ethylhexyl) phthalate 23 11 10 10.9 4.28 2.7 Bromoform 22 22 2 - - - Butylbenzyl Phthalate 14 14 10 - - - Carbon tetrachloride 22 22 3 - - - Chlordane 23 23 25 - - - Chlorobenzene 22 22 2 - - - Chloroform 22 12 2 4.6 2.63 2 Chrysene 23 23 5 - - - Dibenzo(a,h)Anthracene 23 23 5 - - - Dichlorobromomethane 44 44 2 - - - Dieldrin 23 23 0.5 - - - Diethyl phthalate 23 22 5 1.2 1.2 1.2 Dimethyl phthalate 23 23 5 - - - Di-n-butyl phthalate 23 22 10 30.6 30.6 30.6 Endosulfan Sulfate 23 23 0.5 - - - Endrin 23 23 0.5 - - - Endrin Aldehyde 23 23 0.5 - - - Ethylbenzene 22 22 2 - - - Fluoranthene 23 23 5 - - - Fluorene 23 23 5 - - - Gamma-BHC 23 23 0.0962 - - -June 2008 Appendix A. Facility Analyses A-47 

### Exhibit A-34. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 001 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

Heptachlor 23 23 0.5 - - - Heptachlor Epoxide 23 23 0.5 - - - Hexachlorobenzene 23 23 5 - - - Hexachlorobutadiene 23 23 10 - - - Hexachlorocyclopentadiene 23 23 10 - - - Hexachloroethane 23 23 10 - - - Ideno(1,2,3-cd)Pyrene 23 23 5 - - - Isophorone 23 23 5 - - - Mercury 66 12 0.01 0.075* 0.013 0.0051 Methylene chloride 22 22 3 - - - Nickel 66 0 0.2 100 4.98 2.12 Nitrobenzene 23 23 5 - - - N-Nitrosodimethylamine 23 23 5 - - - N-Nitrosodi-n-Propylamine 23 23 10 - - - N-Nitrosodiphenylamine 23 23 5 - - - PCBs 3 161 161 2 - - - Pentachlorophenol 23 23 10 - - - Phenol 23 23 5 - - - Pyrene 23 23 5 - - - Selenium 66 56 0.5 0.98 0.63 0.5 Tetrachloroethylene 22 22 2 - - - Toluene 22 19 2 3.4 3.13 2.9 Toxaphene 23 23 25 - - - Trichloroethylene 22 22 3 - - - Vinyl chloride 22 22 10 - - - QL = Quantification limit. *Outlier removed because raw data indicates that value is estimated and may not represent actual concentration. 1. Represents effluent data from January 2004 to December 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Exhibit A-35. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 003 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

1,1,2,2-Tetrachloroethane 10 10 3 - - - 1,1,2-Trichloroethane 10 10 2 - - - 1,1-Dichloroethylene 10 10 5 - - - 1,2,4-Trichlorobenzene 11 11 5 - - - 1,2-Dichlorobenzene 21 21 5 - - - 1,2-Dichloroethane 10 10 2 - - - 1,2-Dichloropropane 10 10 2 - - - 1,3-Dichlorobenzene 21 21 5 - - - 1,4-Dichlorobenzene 21 18 5 13.9 5.29 2.6June 2008 Appendix A. Facility Analyses A-48 

### Exhibit A-35. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 003 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2,4,6-Trichlorophenol 11 11 5 - - - 2,4-Dichlorophenol 11 11 5 - - - 2,4-Dimethylphenol 11 11 10 - - - 2,4-Dinitrophenol 11 11 20 - - - 2,4-Dinitrotoluene 11 11 5 - - - 2-Chloronaphthalene 11 11 5 - - - 2-Chlorophenol 11 11 5 - - - 2-Methyl-4,6-dinitrophenol 11 11 10 - - - 3,3'-Dichlorobenzidine 11 11 5 - - - 4,4'-DDD 11 11 0.5 - - - 4,4'-DDE 11 11 0.5 - - - 4,4'-DDT 11 11 0.962 - - - Acenaphthene 11 11 5 - - - Acrolein 10 10 10 - - - Acrylonitrile 10 10 10 - - - Aldrin 11 11 0.5 - - - Alpha-BHC 11 11 0.5 - - - Anthracene 11 11 5 - - - Arsenic 32 0 0.1 4.08 1.26 0.78 Benzene 10 10 3 - - - Benzidine 11 11 50 - - - Benzo(a) Anthracene 11 11 5 - - - Benzo(a) Pyrene 11 11 5 - - - Benzo(b) Fluoranthene 11 11 5 - - - Benzo(k) Fluoranthene 11 11 5 - - - Beta-BHC 11 11 0.5 - - - Bis(2-chloroethyl) ether 11 11 5 - - - Bis(2-chloroisopropyl) ether 11 11 10 - - - Bis(2-ethylhexyl) Phthalate 11 2 10 24.8 15.1 8.66 Bromoform 10 10 2 - - - Butylbenzyl Phthalate 7 6 10 5.8 5.8 5.8 Carbon tetrachloride 10 10 3 - - - Chlordane 11 11 25 - - - Chlorobenzene 10 10 2 - - - Chloroform 10 5 2 9.6 4.7 2.4 Chrysene 11 11 5 - - - Dibenzo(a,h)Anthracene 11 11 5 - - - Dichlorobromomethane 20 20 2 - - - Dieldrin 11 11 0.5 - - - Diethyl phthalate 11 5 5 5.7 2.91 1.33 Dimethyl phthalate 11 11 5 - - - Di-n-butyl phthalate 11 10 10 3.2 3.2 3.2 Endosulfan Sulfate 11 11 0.5 - - - Endrin 11 11 0.5 - - -

### Exhibit A-35. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 003 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean Endrin Aldehyde 11 11 0.5 - - - Ethylbenzene 10 9 2 4.0 4.0 4.0 Fluoranthene 11 11 5 - - - Fluorene 11 11 5 - - - Gamma-BHC 11 11 0.0962 - - - Heptachlor 11 11 0.5 - - - Heptachlor Epoxide 11 11 0.5 - - - Hexachlorobenzene 11 11 5 - - - Hexachlorobutadiene 11 11 10 - - - Hexachlorocyclopentadiene 11 11 10 - - - Hexachloroethane 11 11 10 - - - Ideno(1,2,3-cd)Pyrene 11 11 5 - - - Isophorone 11 11 5 - - - Mercury 32 0 0.002 0.38 0.040 0.0079 Methylene chloride 10 10 3 - - - Nickel 32 0 0.2 278 5.39 2.28 Nitrobenzene 11 11 5 - - - N-Nitrosodimethylamine 11 11 5 - - - N-Nitrosodi-n-Propylamine 11 11 10 - - - N-Nitrosodiphenylamine 11 11 5 - - - PCBs 3 77 77 5 - - - Pentachlorophenol 11 11 10 - - - Phenol 11 8 5 6.3 3.02 1.9 Pyrene 11 11 5 - - - Selenium 32 24 0.5 1.58 0.86 0.52 Tetrachloroethylene 10 9 2 4.9 4.9 4.9 Toluene 10 5 2 6.9 4.34 2.5 Toxaphene 11 11 25 - - - Trichloroethylene 10 10 3 - - - Vinyl chloride 10 10 10 - - - QL = Quantification limit. 1. Represents effluent data from January 2004 to December 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

Baseline Criteria

June 2008 Appendix A. Facility Analyses A-49

### Exhibits A-36 and A-37 summarize the RPA for baseline criteria for Outfalls 001 and 003 for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect). The Columbia River is a freshwater river; thus, human health criteria for consumption of organisms and water are applicable. The dilu tion factor is based on the edge of the regulatory mixing zone factor in the facility’s permit. The Columbia River at river mile 105.5 is on the state’ s 303(d) as impaired for arsenic, DDE, dioxin, PCBs, and PAHs; thus, the facility would not receive dilution in the RP analysis for these pollutants.

Exhibit A-36. RPA for Baseline Criteria, Portland, Columbia Blvd WWTP, Outfall 001

Parameter Calculated Effluent Conc. 1 ( μ g/L) Conc. at Edge Ambient Human Health Reasonable of Mixing Conc. 2 (

μ g/L) Zone 3 (

μ g/L) Criterion ( μ g/L) Potential

1,4-Dichlorobenzene 3.43 0 0.037 63 No Yes 2,3,7,8-TCDD (Dioxin) 5.2E-06 0 5.2E-06 1.3E-08 Arsenic 0.76 0 0.76 0.0022 Yes Bis(2-Ethylhexyl) Phthalate 5.30 0 0.058 1.20 No Chloroform 3.04 0 0.033 0.19 No Diethyl Phthalate 1.57 0 0.017 17000 No Di-n-Butyl Phthalate 39.9 0 0.43 2000 No Mercury 4 0.072 0 0.00078 0.017 No Nickel 93.4 0 1.01 13.4 No Selenium 0.97 0 0.011 10 No Toluene 4.50 0 0.049 1300 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants except for arsenic (CV = 0.35), bis(2-ethylhexyl) phthalate (CV = 0.47), chloroform (CV = 0.29), mercury (CV = 0.82), nickel (C V = 1.79), and selenium (CV = 0.25) (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on mixing zone dilution fa ctor in existing permit (factor = 92). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### Exhibit A-37. RPA for Baseline Criteria, Portland, Columbia Blvd WWTP, Outfall 003

Parameter Calculated Effluent Conc. 1 ( μ g/L) Conc. at Edge Ambient Human Health Reasonable of Mixing Conc. 2 (

μ g/L) Zone 3 (

μ g/L) Criterion ( μ g/L) Potential

1,4-Dichlorobenzene 18.7 0 0.20 63 No Arsenic 1.43 0 1.43 0.0022 Yes Bis(2-Ethylhexyl) Phthalate 25.3 0 0.28 1.20 No Butylbenzyl Phthalate 11.6 0 0.13 1500 No Chloroform 8.17 0 0.089 0.19 No Diethyl Phthalate 9.56 0 0.10 17000 No Di-n-Butyl Phthalate 5.37 0 0.058 2000 No Ethylbenzene 6.96 0 0.076 1.4 No Mercury 4 0.50 0 0.0054 0.017 No Nickel 449 0 4.88 13.4 No Phenol 10.6 0 0.11 3500 No Selenium 1.87 0 0.020 10 No Tetrachloroethylene 8.52 0 0.093 0.69 No Toluene 12.0 0 0.13 1300 No

June 2008 Appendix A. Facility Analyses A-50

### Exhibit A-37. RPA for Baseline Criteria, Portland, Columbia Blvd WWTP, Outfall 003

Parameter Calculated Effluent Conc. 1 ( μ g/L) Conc. at Edge Ambient Human Health Reasonable of Mixing Conc. 2 (

μ g/L) Zone 3 (

μ g/L) Criterion ( μ g/L) Potential

1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants except fo r arsenic (CV = 0.43), mercury (CV = 1.10), and nickel (CV = 3.45) (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on mixing zone dilution fa ctor in existing permit (factor = 92). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibits, the facility has RP to exceed the baseline criterion for arsenic at both outfalls, and dioxin at Outfall 001 because the con centration at the edge of the regulatory mixing zone is greater than the appli cable existing human health criteri on. The Columbia River is also on the state’s 303(d) list as im paired for arsenic, and EPA co mpleted a TMDL for dioxin in
1991.

Arsenic

Because of the 303(d) listing, the discharger would ha ve to comply with criteria end-of-pipe (i.e., no dilution) and a waste load allocation under a fu ture TMDL for the Columbia River. If ODEQ determines that ambient background levels repr esent natural conditions, it may not require the facility to reduce discharge concentrations. Ho wever, if the facility is discharging above background concentrations or ODEQ determines that the river must meet the applicable criterion, it may require the facility to reduce effluent arsenic leve ls for compliance with effluent limits or load allocations under the TMDL.

Arsenic and arsenic-containing chemicals are not used in wastewater treatment. The facility has a large industrial base and regulates 80 signi ficant industrial users and 89 other industrial dischargers to the treatment system. If the facili ty determines that one or more of its indirect dischargers is causing or contributing to high arsenic levels in the effluent, it would most likely implement a source control program to target the dischargers or impose more stringent pretreatment limits on the discha rgers. Without specific information on the types of industrial dischargers that may need controls, it is not pos sible to estimate pretreatment or P2 costs to indirect dischargers.

The City’s primary drinking water source is th e Bull Run Watershed; the City also uses groundwater as a supplemental water supply. The City’s 2007 water quality report indicates that arsenic was detected in drinking water at 3 μg /L due to the erosion of natural deposits in groundwater aquifers (PWB, 2007). Thus, it is po ssible that drinking wate r is contributing to high arsenic levels in the wastewat er effluent. In this case, it is likely th at the facility would pursue a variance or request that ODEQ consid er granting the facility intake credits.

I&I could also be a problem for the City’s sewer system. If the facility determines that groundwater infiltration is causing or contributing to the high arsenic effluent levels, the facility may have to implement an I&I reduction progra m for compliance with the existing criteria.

June 2008 Appendix A. Facility Analyses A-51

### There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $300,000, with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be $113,200,000 for an I&I reduction program that includes source identification a nd pipe rehabilitation for a sy stem with 2,256 miles of sewer pipes (approximately $10,682,000 per ye ar annualized at 7% over 20 years). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for comp liance and the discharg er would not likely undertake such a program for comp liance with toxic criteria alone.

Dioxin

EPA’s 1991 Dioxin TMDL for the Columbia, Snake, and Willamette Rivers does not include wasteload allocations for municipa l wastewater treatment facilitie s (EPA only allocated loads to pulp mills). In addition, the facility’s existi ng permit does not contain an effluent limit for dioxin, only a quarterly dioxin monitoring requiremen t. Thus, it is unlikely that the facility would install end-of-pipe treatment controls to reduce effluent dioxi n levels to the criterion. The facility would either pursue a variance or site-s pecific criterion. One-time costs of associated with a variance could range from $35,000 to $300,000. However, if the discharger pursues a variance for arsenic, costs to in clude dioxin in the variance applic ation/analysis for arsenic would be minimal. As part of the variance, ODEQ coul d require the facility to implement a P2 program to determine if the dioxin is th e result of existing indirect di schargers or residual from prior industrial uses. Costs of a P2 program fo r dioxin could be appr oximately $50,000 per year.

Revised Criteria



### Exhibits A-38 and A-39 summarize the RPA for the revised human health criteria for consumption of water and organisms for Outfalls 001 and 003 for those pollutants detected in the effluent (there will be no RP or monitori ng requirements if all obs ervations are nondetect).

Exhibit A-38. RPA for Revised Criteria, Portland, Columbia Blvd WWTP, Outfall 001 Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 1,4-Dichlorobenzene 0.037 34 23 16 7.9 5.1 1.4E-09* 7.9E-10* 5.1E-10* 2.3E-10* 1.4E-10* 2,3,7,8-TCDD (Dioxin) 5.2E-06
Arsenic 0.76 0.0083* 0.0057* 0.0041* 0.0021* 0.0014* Bis(2-Ethylhexyl) Phthalate 0.0 58 0.49 0.30 0.20 0.095 0.061 Chloroform 0.033 5.10 4.70 4.30 3.30 2.70 Diethyl Phthalate 0.017 8,5 00 5,500 3,800 1,800 1,200 Di-n-Butyl Phthalate 0.43 920 580 400 190 120 Mercury 2 0.00078 0.0047 0.0026 0.0017 0.00076* 0.00048*
Nickel 1.01 280 190 140 69.0 45.0 Selenium 0.011 150 140 120 91.0 70.0 Toluene 0.049 1,000 870 720 450 320 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on mixing zone dilution fa ctor in existing permit (factor = 92).

June 2008 Appendix A. Facility Analyses A-52

### Exhibit A-38. RPA for Revised Criteria, Portland, Columbia Blvd WWTP, Outfall 001 Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd

2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### Exhibit A-39. RPA for Revised Criteria, Portland, Columbia Blvd WWTP, Outfall 003 Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 1,4-Dichlorobenzene 0.20 34.0 23.0 16.0 7.90 5.10 Arsenic 1.43 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
0.20* 0.095* 0.061* Bis(2-Ethylhexyl) Phthalate 0.28 0.49 0.30 Butylbenzyl Phthalate 0.13 500 290 190 86.0 54.0 Chloroform 0.089 5.10 4.70 4.30 3.30 2.70 Diethyl Phthalate 0.10 8500 5500 3800 1800 1200 Di-n-Butyl Phthalate 0.058 920 580 400 190 120 Ethylbenzene 0.076 1600 1100 820 420 280 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.0054
Nickel 4.88 280 190 140 69.0 45.0 Phenol 0.11 20000 19000 19000 17000 15000 Selenium 0.020 150 140 120 91.0 72.0 Tetrachloroethylene 0.093 0.45 0.32 0.24 0.13 0.084*
Toluene 0.13 1000 870 720 450 320 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on mixing zone dilution fa ctor in existing permit (factor = 92). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibits, the discharger woul d have RP for arsenic, dioxin, and mercury in Outfall 001, and arsenic, bis(2-ethy lhexyl) phthalate, mercury, and tetrachloroethylene in Outfall
003.

Arsenic

The discharger would have RP for arsenic at a ll fish consumption rates for both outfalls. Thus, because the criteria apply end of pipe (i.e., no dilution because the water body is listed as impaired), the discharger would need to reduc e discharge concentratio ns to background (if ODEQ determines that ambient conc entrations represent natural le vels) or the approved QL of 0.05 μg/L (because the criterion is below the QL ) for compliance with revised standards. However, under the baseline, the discharge would n eed to meet those same levels. Thus, there would be no incremental compliance costs.

Dioxin

The discharger would have RP for dioxin at al l fish consumption rates for Outfall 001. As described under the baseline crite ria analysis, the discharger does not have a wasteload allocation under the existing TMDL nor does its existing permit contain an effluent limit for dioxin. Thus,

June 2008 Appendix A. Facility Analyses A-53

### under the baseline, the discharger would likely pu rsue a variance and possi bly be required to implement a P2 program. Although the criteria b ecome more stringent un der the revised fish consumption rates, it is likely that the discharger would pursue the same ac tions as it would for compliance with baseline sta ndards. Thus, incremental compliance costs are unlikely.

Bis(2-ethylhexyl) phthalate

The discharger would have RP for bis(2-ethylh exyl) phthalate at consumption rates of 175 gpd, 389 gpd, and 620 gpd for Outfall 003. Exhibit A-40 shows the projected effluent limits for these consumption rates.

Exhibit A-40. Projected Effluent Limits for Bis( 2-ethylhexyl) Phthalate, Portland, Columbia Blvd WWTP, Outfall 003 Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) NA NA 18 8.7 5.6 MDEL ( μ g/L) NA NA 37 17 11



### The maximum effluent bis(2-ethylhexyl) phthala te concentration in Outfall 003 is 24.8 μg/L, which is greater than the projected effluent limits for all the consumption ra tes. The facility has a large industrial base and regulates 80 signi ficant industrial users and 89 other industrial dischargers to the treatment system. The high bis( 2-ethylhexyl) phthalate le vels in the effluent could be due to one or more of its indirect di schargers. Regulating th ese sources through a P2 program could reduce pollutant load ings to the necessary levels. High levels of bis(2-ethylhexyl) phthalate in municipal wastewater effluent can also be associated with sampling and/or laboratory analysis conditions (Fai rfield-Suisun SD, 2003). If this is the case, cleaner sampling and analysis techniques could re duce the amount of bis(2-ethylhe xyl) phthalate measured in the effluent. Thus, as described in Appendix B, cost s for the discharger could be minimal if cleaner sampling techniques result in lo wer effluent concentrations to approximately $50,000 for a P2 program for bis(2-ethy lhexyl) phthalate.

Mercury

The discharger would have RP for mercur y at consumption rates of 113 gpd, 175 gpd, 389 gpd, and 620 gpd for Outfall 003 and 620 gpd for Outfall 001. Exhibit A-41 shows the AMELs and MDELs for each consumption rate.

Exhibit A-41. Projected Effluent Limits for Mercury, Portland, Columbia Blvd WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd
Outfall 001 AMEL ( μ g/L) NA NA NA 0.07 0.04 MDEL ( μ g/L) NA NA NA 0.16 0.10 Outfall 003 AMEL ( μ g/L) 0.43 0.24 0.16 0.07 0.04 MDEL ( μ g/L) 1.13 0.62 0.41 0.18 0.12

June 2008 Appendix A. Facility Analyses A-54

### The maximum effluent concentration in Outfa ll 001 is 0.075 μg/L which is greater than the projected limits. The maximum effluent concen tration in Outfall 003 is 0.38 μg/L which is greater than the all of the proj ected limits except those based on a consumption rate of 63.2 gpd. Thus, the facility may need to implement controls to reduce effluent merc ury concentrations for compliance with these limits. Since the projected effluent levels are in the range achievable by municipal wastewater treatment plants that ha ve implemented P2, the facility would likely implement a P2 program for compliance with the projected effluent limits. Annual P2 program costs for a 100 mgd municipa l facility may be approximately $150,000 (see Appendix B for details). As described in Appe ndix B, P2 costs also potential ly include costs for indirect dischargers to implement controls (see Exhibit B-2). Based on information on the discharger’s service area, incremental indirect discharger costs may be $120,000 per year (e.g., there may be as many as 10 universities in the service area).

Tetrachloroethylene

The discharger has RP for tetrachloroethylene at a fish consumption rate of 620 gpd. The projected AMEL would be 7.7 μg/L and the MDEL would be 15.5 μg/L. The maximum effluent concentration is 4.9 μg/L (only one detected value with remaini ng nondetects less than 2 μg/L), which is lower than both projected limits. Thus , the discharger would likely be in compliance with the revised criteria a nd would not incur any costs.

Summary



### Exhibit A-42 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent the any costs above and beyond those that would be needed for compliance with baseline criteria. Under a vari ance scenario for dioxin and/or ar senic under the baseline scenario, one-time expenditure costs would ra nge from approximately $35,000 to $300,000.

Exhibit A-42. Summary of Potential Costs, Portland, Columbia Blvd WWTP

Alternative Compliance Scenario Incremental Annual Total Annual Costs Costs 1

• Intake credits, variance, or I&I reduction

program (arsenic) Baseline $50,000 - $10,732,000 NA

• Variance with P2 program (dioxin)

• Intake credits, variance, or I&I reduction

program (arsenic) 63.2 gpd $50,000 - $10,732,000 $0

• Variance with P2 program (dioxin)

• Intake credits, variance, or I&I reduction

program (arsenic) 113 gpd $320,000 - $11,002,000 $270,000

• Variance with P2 program (dioxin)

• P2 program (mercury)

June 2008 Appendix A. Facility Analyses A-55

### Exhibit A-42. Summary of Potential Costs, Portland, Columbia Blvd WWTP

Alternative Compliance Scenario Incremental Annual Total Annual Costs Costs 1

• Intake credits, variance, or I&I reduction

program (arsenic)

• Variance with P2 program (dioxin) $320,000 - $11,052,000 $270,000 - $320,000 175 gpd

• Cleaner sampling or P2 program [bis(2- ethylhexyl) phthalate]

• P2 program (mercury)

• Intake credits, variance, or I&I reduction

program (arsenic)

• Variance with P2 program (dioxin) 389 gpd $320,000 - $11,052,000 $270,000 - $320,000

• Cleaner sampling or P2 program [bis(2-

ethylhexyl) phthalate]

• P2 program (mercury)

• Intake credits, variance, or I&I reduction

program (arsenic)

• Variance with P2 program (dioxin) $320,000 - $11,052,000 $270,000 - $320,000 620 gpd

• Cleaner sampling or P2 program [bis(2- ethylhexyl) phthalate]

• P2 program (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-56

### Rock Creek Advanced Wastewater Treatment Facility

Facility Description

The Rock Creek Advanced Wastewater Treat ment Facility (NPDES permit number OR0029777) is located in Hillsboro, Oregon. The plant treats residential, commercial, and light industrial wastewater; wet industry flow, c onsisting of dilute, high volume wa stewater received from local industries year-round from the service area; and sludge, carrier water, and seasonal influent wastewater transfers from the Forest Grove and Hillsboro-Westside WWTPs. The facility is covered under a single watershed-based, integr ated municipal permit c overing all three other facilities, an MS4, and two i ndustrial storm water permits. The ADWDF for the Rock Creek Wastewater Treatment Plant is 39 mgd. ODEQ classifies the facility as a major discharger. The facility discharges all treated effluent into th e Tualatin River at river mile 38. The facility has two other outfalls classified as wet weather outfalls.

Treatment Processes

The 2005 NPDES permit for the facility lists th e major treatment processes as headworks, primary clarifiers, activated sludge, effluent filters, and digester complex. The facility thickens primary solids and returns activat ed sludge prior to anaerobic dige stion. The facility dewaters digested biosolids and sends them to land applica tion sites in either the Willamette Valley or the Madison Ranch in eastern Oregon.

Effluent Data and Limits

Exhibit A-43 summarizes monitoring data from February 2004 to March 2007 for those pollutants of concern for which effl uent data are available. The f acility does not have effluent limits for any toxic pollutants.

Exhibit A-43. Effluent Data Summary, Rock Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 4 4 5 - - - 1,1,2-Trichloroethane 4 4 5 - - - 1,2,4-Trichlorobenzene 4 4 11 - - - 1,2-Dichlorobenzene 4 4 11 - - - 1,2-Dichloroethane 4 4 5 - - - 1,2-Dichloropropane 4 4 5 - - - 1,2-Diphenylhydrazine 4 4 11 - - - 1,3-Dichlorobenzene 4 4 11 - - - 1,4-Dichlorobenzene 4 4 11 - - - 2,4,6-Trichlorophenol 4 4 11 - - - 2,4-Dichlorophenol 4 4 11 - - - 2,4-Dimethylphenol 4 4 11 - - - 2,4-Dinitrophenol 4 4 27 - - - 2,4-Dinitrotoluene 4 4 11 - - -

June 2008 Appendix A. Facility Analyses A-57June 2008 Appendix A. Facility Analyses A-58 

### Exhibit A-43. Effluent Data Summary, Rock Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2-Chloronaphthalene 4 4 11 - - - 2-Chlorophenol 4 4 11 - - - 2-Methyl-4,6-Dinitrophenol 4 4 27 - - - 3,3'-Dichlorobenzidine 4 4 27 - - - 4,4'-DDD 4 4 0.11 - - - 4,4'-DDE 4 4 0.11 - - - 4,4'-DDT 4 4 0.11 - - - Acenaphthene 4 4 11 - - - Acrolein 4 4 50 - - - Acrylonitrile 4 4 10 - - - Aldrin 4 4 0.11 - - - alpha-BHC 4 4 0.11 - - - Anthracene 4 4 11 - - - Antimony 42 7 0.2 0.46 0.30 0.11 Arsenic 42 42 4 - - - Benzene 4 4 5 - - - Benzidine 4 4 53 - - - Benzo(a) Anthracene 4 4 11 - - - Benzo(a) Pyrene 4 4 11 - - - Benzo(b) Fluoranthene 4 4 11 - - - Benzo(k) Fluoranthene 4 4 11 - - - Beryllium 42 42 0.16 - - - beta-BHC 4 4 0.16 - - - Bis(2-Chloroethyl) Ether 4 4 11 - - - Bis(2-Chloroisopropyl) Ether 4 4 11 - - - Bis(2-Ethylhexyl) Phthalate 4 4 11 - - - Bromoform 4 4 5 - - - Butylbenzyl Phthalate 4 4 11 - - - Carbon Tetrachloride 4 4 5 - - - Chlordane 4 4 2.1 - - - Chlorobenzene 4 4 5 - - - Chloroform 4 4 5 - - - Chrysene 4 4 11 - - - Dibenzo(a,h)Anthracene 4 4 11 - - - Dieldrin 4 4 0.11 - - - Diethyl Phthalate 4 4 11 - - - Dimethyl Phthalate 4 4 11 - - - Di-n-butyl Phthalate 4 4 11 - - - Endosulfan Sulfate 4 4 0.11 - - - Endrin 4 4 0.11 - - - Endrin Aldehyde 4 4 0.11 - - - Ethylbenzene 4 4 5 - - - Fluoranthene 4 4 11 - - - Fluorene 4 4 11 - - -

### Exhibit A-43. Effluent Data Summary, Rock Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean
Gamma-BHC 4 4 0.01 - - - Heptachlor 4 4 0.11 - - - Heptachlor Epoxide 4 4 0.11 - - - Hexachlorobenzene 4 4 11 - - - Hexachlorobutadiene 4 4 11 - - - Hexachlorocyclopentadiene 4 4 11 - - - Hexachloroethane 4 4 11 - - - Ideno(1,2,3-cd)Pyrene 4 4 11 - - - Isophorone 4 4 11 - - - Mercury 28 1 0.0005 0.0051 0.002 0.0006 Methylene Chloride 4 4 5 - - - Nickel 42 0 0 5.42 2.96 1.63 Nitrobenzene 4 4 11 - - - N-Nitrosodimethylamine 4 4 27 - - - N-Nitrosodi-n-Propylamine 8 8 11 - - - PCBs 3 4 4 1.2 - - - Pentachlorophenol 4 4 27 - - - Phenol 4 4 11 - - - Pyrene 4 4 11 - - - Selenium 0 0 0 - - - Thallium 42 42 0.04 - - - Toluene 4 4 5 - - - Vinyl Chloride 4 4 5 - - - QL = Quantification limit. 1. Represents effluent data from February 2004 to March 2007. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

Exhibit A-44 summarizes ambient data 0.44 miles upstr eam of the facility (at Rood Bridge) from May 2004 to April 2007 for those pollutants of concern for which ambient data are available.

Exhibit A-44. Ambient Data Summary, Rock Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 3 3 5 - - - 1,1,2-Trichloroethane 3 3 5 - - - 1,2,4-Trichlorobenzene 2 2 12 - - - 1,2-Dichlorobenzene 3 3 12 - - - 1,2-Dichloroethane 3 3 5 - - - 1,2-Dichloropropane 3 3 5 - - -

June 2008 Appendix A. Facility Analyses A-59June 2008 Appendix A. Facility Analyses A-60 

### Exhibit A-44. Ambient Data Summary, Rock Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Maximum Geometric Mean Minimum

1,2-Diphenylhydrazine 2 2 12 - - - 1,3-Dichlorobenzene 3 3 12 - - - 1,4-Dichlorobenzene 3 3 12 - - - 2,4,6-Trichlorophenol 2 2 12 - - - 2,4-Dichlorophenol 2 2 12 - - - 2,4-Dimethylphenol 2 2 12 - - - 2,4-Dinitrophenol 2 2 28 - - - 2,4-Dinitrotoluene 2 2 12 - - - 2-Chloronaphthalene 2 2 12 - - - 2-Chlorophenol 2 2 12 - - - 2-Methyl-4,6-Dinitrophenol 2 2 28 - - - 3,3'-Dichlorobenzidine 2 2 28 - - - 4,4'-DDD 3 3 0.012 - - - 4,4'-DDE 3 3 0.012 - - - 4,4'-DDT 3 3 0.012 - - - Acenaphthene 2 2 12 - - - Acrolein 3 3 50 - - - Acrylonitrile 3 3 10 - - - Aldrin 3 3 0.012 - - - alpha-BHC 3 3 0.012 - - - Anthracene 2 2 12 - - - Antimony 33 33 0.102 - - - Arsenic 34 34 2.04 - - - Benzene 3 3 5 - - - Benzidine 2 2 56 - - - Benzo(a) Anthracene 2 2 12 - - - Benzo(a) Pyrene 2 2 12 - - - Benzo(b) Fluoranthene 2 2 12 - - - Benzo(k) Fluoranthene 2 2 12 - - - Beryllium 34 34 0.0808 - - - beta-BHC 3 3 0.017 - - - Bis(2-Chloroethyl) Ether 2 2 12 - - - Bis(2-Chloroisopropyl) Ether 2 2 12 - - - Bis(2-Ethylhexyl) Phthalate 2 2 12 - - - Bromoform 3 3 5 - - - Butylbenzyl Phthalate 2 2 12 - - - Carbon Tetrachloride 3 3 5 - - - Chlordane 3 3 0.23 - - - Chlorobenzene 3 3 5 - - - Chloroform 3 3 5 - - - Chrysene 2 2 12 - - - Dibenzo(a,h)Anthracene 2 2 12 - - - Dieldrin 3 3 0.012 - - - Diethyl Phthalate 2 2 12 - - -

### Exhibit A-44. Ambient Data Summary, Rock Creek WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean Dimethyl Phthalate 2 2 12 - - - Di-n-butyl Phthalate 2 2 12 - - - Endosulfan Sulfate 3 3 0.012 - - - Endrin 3 3 0.012 - - - Endrin Aldehyde 3 3 0.012 - - - Ethylbenzene 3 3 5 - - - Fluoranthene 2 2 12 - - - Fluorene 2 2 12 - - - Heptachlor 3 3 0.012 - - - Heptachlor Epoxide 3 3 0.012 - - - Hexachlorobenzene 2 2 12 - - - Hexachlorobutadiene 2 2 12 - - - Hexachlorocyclopentadiene 2 2 12 - - - Hexachloroethane 2 2 12 - - - Ideno(1,2,3-cd)Pyrene 2 2 12 - - - Isophorone 2 2 12 - - - Methylene Chloride 3 3 5 - - - Nickel 34 0 0 1.09 0.57 0.35 Nitrobenzene 2 2 12 - - - N-Nitrosodimethylamine 2 2 28 - - - N-Nitrosodi-n-Propylamine 2 2 12 - - - PCBs 3 3 1.2 - - - Pentachlorophenol 2 2 28 - - - Phenol 2 2 12 - - - Pyrene 2 2 12 - - - Selenium 33 31 0.509 0.56 0.53 0.51 Thallium 34 34 0.0204 - - - Toluene 3 3 5 - - - Vinyl Chloride 3 3 5 - - - QL = Quantification limit. 1. Represents ambient data from May 2004 to April 2007.



### Potential Impacts

Baseline Criteria



### Exhibit A-45 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Tualatin River is a freshwater ri ver; thus, human health criteria for consumption of organisms and water are applicable. The dilution factors are based ODEQ estimates of dilution at critical conditions. Fish tissue monitoring data for the Tualatin River at Boones Ferry Road from 1997, about 20 miles downstream from the facility, indi cate that mercury tissue concentrations range from 0.11 to 0.74 mg/kg (wet weight). Thus, to be conservative (i.e., err on the side of overestimating costs), we assumed that the fa cility would not receive dilution for mercury.

June 2008 Appendix A. Facility Analyses A-61

### Exhibit A-45. RPA for Baseline Criteria, Rock Creek AWTF

Parameter Calculated Effluent Conc. 1 ( μ g/L) Conc. at Edge Ambient Human Health Reasonable of Mixing Conc. 2 (

μ g/L) Zone 3 (

μ g/L) Criterion ( μ g/L) Potential

Antimony 0.48 0 0.24 5.6 No Mercury 4 0.0058 0 0.0058 0.017 No Nickel 5.68 0.57 3.13 13.4 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.23 for antimony, 0.46 fo r mercury, and 0.30 for nickel (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on mixing zone dilution factor in existing RPA spreadsheet (factor = 2). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### The discharger does not have RP for any of the pollutants for whic h there are detected concentrations.

Under the baseline Willamette River Basin merc ury TMDL, the facility would be required to develop and implement a mercury reduction stra tegy. Annual P2 program costs for a 39 mgd municipal facility may be approximately $150,000 (s ee Appendix B for details). As described in Appendix B, P2 costs also potentially include costs for indirect disc hargers to implement controls (see Exhibit B-2). Based on informati on on the discharger’s service area, incremental indirect discharger costs may be minimal (e.g., th ere are no universities in the service area). However, because ODEQ does not assign individual wasteload allocations to point source dischargers in the TMDL (point sources as a w hole are required to reduce existing load by 26%), it is uncertain whether the facili ty would incur costs beyond those for a P2 program to meet the wasteload allocation under the baseline TMDL.

Revised Criteria



### Exhibit A-46 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-46. RPA for Revised Criteria, Rock Creek AWTF Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Antimony 0.24 5.40 5.30 5.10 4.70 4.30 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.0058
Nickel 3.13 280 190 140 69.0 45.0 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on mixing zone dilution factor in existing RPA spreadsheet (factor = 2). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the di scharger would have RP for me rcury at all alternative fish consumption rates, and would have to comply with effluent limits that represent criteria end-ofJune 2008 Appendix A. Facility Analyses A-62

### pipe. The facility is already required to impl ement a mercury P2 program under the baseline as part of the Willamette Basin mercury TMDL. It is not clear how ODEQ would adapt the baseline TMDL to attain the revised criter ia (e.g., increase point source load reduction requirements; establish individual effluent limits ). Thus, it is uncertain whether continued implementation of the baseline P2 program would be sufficient for compliance with the revised criteria/TMDL because there could be some maximum level of effort beyond which a P2 program would not provide additional reductions.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consis tent basis, dischargers may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied) under mo re stringent TMDL requirements (alternatively, ODEQ may account for this situation in allocating loads under the TMDL). However, it is uncertain for which c onsumption rates the discharger would need a variance. One-time costs associated with pursuing a variance coul d range from $35,000 to $300,000. As part of a variance ODEQ, could require specific P2 program efforts. For dischargers covered under the Willamette River TMDL for mercury, these activities may already be included in their baseline mercury P2 requirement.

Summary



### Exhibit A-47 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline criteria. Under a variance scenario for mercur y under the alternative fish consumption rates, incremental costs could include a one-time expenditure of $35,000 to $300,000.

Exhibit A-47. Summary of Potential Costs, Rock Creek AWTF

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1 Baseline • P2 program (mercury) $150,000 NA 63.2 gpd • P2 program, possible variance (mercury) $150,000 $0 113 gpd • P2 program, possible variance (mercury) $150,000 $0 175 gpd • P2 program, possible variance (mercury) $150,000 $0 389 gpd • P2 program, possible variance (mercury) $150,000 $0 620 gpd • P2 program, possible variance (mercury) $150,000 $0 NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-63

### City of Salem Willow Lake W astewater Treatment Plant

Facility Description

The City of Salem, Willow Lake Wastewat er Treatment Plant (NPDES permit number OR0026409) treats domestic, commercial, and industria l wastewater from the Salem/Keizer area. The service population is approximately 210,000. The treatment plant is composed of two distinct sets of facilities, referred to as the north plant and the south plant; the two plants can be run in series or parallel. ODEQ classifies this 35 mgd (ADWDF) facility as a major discharger. The facility discharges effluent through a 72-in ch outfall to the Willamette River at river mile
78.4.

Treatment Processes

The 2004 NPDES permit for the facility lists curren t treatment processes at the north plant as headworks, two primary center-feed circular clarifiers, four rock media trickling filters, and a circular center-feed secondary cl arifier and chlorine contact tank. The south plant has two primary clarifiers, a pure-oxygen ac tivated sludge process, four se condary clarifiers, a chlorine contact chamber, an additional gravity thickener, and four anaerobic digesters. The facility loads dewatered biosolids, at approxi mately 19% total solids, into dump trucks for hauling to application sites.

The facility is currently being expanded to treat an additional capacity of 100 mgd. The expansion includes four new ci rcular primary clarifiers, tw o new gravity thickeners for thickening primary sludge, expanded WAS thic kening and biosolids dewatering facility, permanent chlorination and dechlorination faciliti es, an additional pass on the existing chlorine contact basin, and a new parallel outfall and diffu ser structure. These expansions are scheduled to be completed in 2009.

Effluent Data and Limits

Exhibit A-48 summarizes monitoring data from July 2001 to June 2007 for those pollutants of concern for which effluent data ar e available. The facility does not have effluent limits for any toxic pollutants.

Exhibit A-48. Effluent Data Summary, Salem Willow Lake WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 2 2 1 - - - 1,1,2-Trichloroethane 2 2 1 - - - 1,1-Dichloroethylene 2 2 1 - - - 1,2,4-Trichlorobenzene 3 3 4.76 - - - 1,2-Dichlorobenzene 2 2 1 - - - 1,2-Dichloroethane 2 2 1 - - - 1,2-Dichloropropane 2 2 1 - - -

June 2008 Appendix A. Facility Analyses A-64June 2008 Appendix A. Facility Analyses A-65 

### Exhibit A-48. Effluent Data Summary, Salem Willow Lake WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

1,2-Diphenylhydrazine 1 1 4.76 - - - 1,2-Trans-Dichloroethylene 2 2 1 - - - 1,3-Dichlorobenzene 2 2 1 - - - 1,4-Dichlorobenzene 2 1 1 0.56 0.56 0.56 2,4,6-Trichlorophenol 2 2 4.76 - - - 2,4-Dichlorophenol 1 1 1.1 - - - 2,4-Dimethylphenol 2 2 9.52 - - - 2,4-Dinitrophenol 2 2 23.8 - - - 2,4-Dinitrotoluene 2 2 4.76 - - - 2-Chloronaphthalene 2 2 4.76 - - - 2-Chlorophenol 2 2 4.76 - - - 2-Methyl-4,6-Dinitrophenol 2 2 9.52 - - - 3,3'-Dichlorobenzidine 2 2 4.76 - - - 4,4'-DDD 2 2 0.0952 - - - 4,4'-DDE 2 2 0.0952 - - - 4,4'-DDT 2 2 0.0952 - - - Acenaphthene 2 2 4.76 - - - Acrolein 2 2 10 - - - Acrylonitrile 2 2 6 - - - Aldrin 2 2 0.0952 - - - alpha-BHC 2 2 0.0952 - - - Anthracene 2 2 4.76 - - - Arsenic 38 3 2 11 4.47 1.34 Benzene 2 2 1 - - - Benzidine 2 2 57.1 - - - Benzo(a) Anthracene 2 2 4.76 - - - Benzo(a) Pyrene 2 2 4.76 - - - Benzo(b) Fluoranthene 2 2 4.76 - - - Benzo(k) Fluoranthene 2 2 4.76 - - - Beryllium 1 1 1 - - - beta-BHC 2 2 0.0952 - - - Bis(2-Chloroethyl) Ether 2 2 4.76 - - - Bis(2-Chloroisopropyl) Ether 2 2 9.52 - - - Bis(2-Ethylhexyl) Phthalate 2 1 9.52 13 13 13 Bromoform 2 2 1 - - - Butylbenzyl Phthalate 2 2 4.76 - - - Carbon Tetrachloride 2 2 1 - - - Chlordane 2 2 4.76 - - - Chlorobenzene 2 2 1 - - - Chlorodibromomethane 1 1 0.26 - - - Chloroform 2 2 1 - - - Chrysene 2 2 4.76 - - - Dibenzo(a,h)Anthracene 2 2 4.76 - - - Dichlorobromomethane 1 1 1 - - -June 2008 Appendix A. Facility Analyses A-66 

### Exhibit A-48. Effluent Data Summary, Salem Willow Lake WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

Dieldrin 2 2 0.0952 - - - Diethyl Phthalate 2 2 4.76 - - - Dimethyl Phthalate 2 2 4.76 - - - Di-n-Butyl Phthalate 2 2 4.76 - - - Endosulfan Sulfate 2 2 0.0952 - - - Endrin 2 2 0.0952 - - - Endrin Aldehyde 2 2 0.0952 - - - Ethylbenzene 2 2 1 - - - Fluoranthene 2 2 4.76 - - - Fluorene 2 2 4.76 - - - Gamma-BHC 2 2 0.021 - - - Heptachlor 2 2 0.0952 - - - Heptachlor Epoxide 2 2 0.0952 - - - Hexachlorobenzene 2 2 4.76 - - - Hexachlorobutadiene 2 2 9.52 - - - Hexachlorocyclopentadiene 2 2 9.52 - - - Hexachloroethane 2 2 9.52 - - - Ideno(1,2,3-cd)Pyrene 1 1 4.76 - - - Ideno(1,2,3-cd)pyrene 1 1 0.85 - - - Isophorone 2 2 4.76 - - - Mercury 37 21 0.01 0.07 0.015 0.01 Methylene Chloride 2 2 5 - - - Nickel 1 1 2 - - - Nitrobenzene 2 2 4.76 - - - N-Nitrosodimethylamine 2 2 4.76 - - - N-Nitrosodi-n-Propylamine 2 2 9.52 - - - N-Nitrosodiphenylamine 2 2 4.76 - - - PCBs 3 2 2 0.476 - - - Pentachlorophenol 2 2 9.52 - - - Phenol 2 2 4.76 - - - Pyrene 2 2 4.76 - - - Selenium 1 1 2 - - - Tetrachloroethylene 2 2 1 - - - Thallium 1 1 1 - - - Toluene 2 1 1 0.51 0.51 0.51 Toxaphene 2 2 4.76 - - - Trichloroethylene 1 1 1 - - - Vinyl Chloride 2 2 1 - - - QL = Quantification limit. 1. Represents effluent data from July 2001 to June 2007. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).June 2008 Appendix A. Facility Analyses A-67 

### Receiving Water Data

The harmonic mean receiving water flow for the Willamette River at river mile 84.16 (approximately 6 miles upstream from the facil ity) is 12,715 cfs, based on daily stream flow measurements from January 1990 through Novemb er 2007 from USGS. Using the same stream flow data and EPA’s DFlow program, the 30Q5 flow is 6,040 cfs.

Exhibit A-49 summarizes data for the Willamette Ri ver at RM 78.4 from May 2006 to June 2007 for those pollutants of concern for which ambient data are available.

Exhibit A-49. Ambient Data Summary, Salem Willow Lake WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Maximum Geometric Mean Minimum

1,1,2,2-Tetrachloroethane 2 2 1 - - - 1,1,2-Trichloroethane 2 2 1 - - - 1,1-Dichloroethylene 2 2 1 - - - 1,2,4-Trichlorobenzene 3 3 4.85 - - - 1,2-Dichlorobenzene 3 3 1.4 - - - 1,2-Dichloroethane 2 2 1 - - - 1,2-Dichloropropane 2 2 1 - - - 1,2-Diphenylhydrazine 1 1 4.85 - - - 1,2-Trans-Dichloroethylene 2 2 1 - - - 1,3-Dichlorobenzene 3 3 1.4 - - - 1,4-Dichlorobenzene 3 3 1.4 - - - 2,4,6-Trichlorophenol 2 2 4.85 - - - 2,4-Dichlorophenol 1 1 1 - - - 2,4-Dimethylphenol 2 2 9.71 - - - 2,4-Dinitrophenol 2 2 24.3 - - - 2,4-Dinitrotoluene 2 2 4.85 - - - 2-Chloronaphthalene 2 2 4.85 - - - 2-Chlorophenol 2 2 4.85 - - - 2-Methyl-4,6-Dinitrophenol 2 2 9.71 - - - 3,3'-Dichlorobenzidine 2 2 4.85 - - - 4,4'-DDD 2 2 0.0971 - - - 4,4'-DDE 2 2 0.0971 - - - 4,4'-DDT 2 2 0.0971 - - - Acenaphthene 2 2 4.85 - - - Acrolein 2 2 10 - - - Acrylonitrile 2 2 6 - - - Aldrin 2 2 0.0971 - - - alpha-BHC 2 2 0.0971 - - - Anthracene 2 2 4.85 - - - Arsenic 1 1 1 - - - Benzene 2 2 1 - - - Benzidine 2 2 58.3 - - - Benzo(a) Anthracene 2 2 4.85 - - - Benzo(a) Pyrene 2 2 4.85 - - -June 2008 Appendix A. Facility Analyses A-68 

### Exhibit A-49. Ambient Data Summary, Salem Willow Lake WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Maximum Geometric Mean Minimum

Benzo(b) Fluoranthene 2 2 4.85 - - - Benzo(k) Fluoranthene 2 2 4.85 - - - Beryllium 1 1 1 - - - beta-BHC 2 2 0.0971 - - - Bis(2-Chloroethyl) Ether 2 2 4.85 - - - Bis(2-Chloroisopropyl) Ether 2 2 9.71 - - - Bis(2-Ethylhexyl) Phthalate 2 2 9.71 - - - Bromoform 2 2 1 - - - Butylbenzyl Phthalate 2 2 4.85 - - - Carbon Tetrachloride 2 2 1 - - - Chlordane 2 2 4.85 - - - Chlorobenzene 2 2 1 - - - Chloroform 2 2 1 - - - Chrysene 2 2 4.85 - - - Dibenzo(a,h)Anthracene 2 2 4.85 - - - Dichlorobromomethane 2 2 1 - - - Dieldrin 2 2 0.0971 - - - Diethyl Phthalate 2 2 4.85 - - - Dimethyl Phthalate 2 2 4.85 - - - Di-n-Butyl Phthalate 2 2 4.85 - - - Endosulfan Sulfate 2 2 0.0971 - - - Endrin 2 2 0.0971 - - - Endrin Aldehyde 2 2 0.0971 - - - Ethylbenzene 2 2 1 - - - Fluoranthene 2 2 4.85 - - - Fluorene 2 2 4.85 - - - Heptachlor 2 2 0.0971 - - - Heptachlor Epoxide 2 2 0.0971 - - - Hexachlorobenzene 2 2 4.85 - - - Hexachlorobutadiene 2 2 9.71 - - - Hexachlorocyclopentadiene 2 2 9.71 - - - Hexachloroethane 2 2 9.71 - - - Ideno(1,2,3-cd)Pyrene 2 2 4.85 - - - Isophorone 2 2 4.85 - - - Methylene Chloride 2 2 5 - - - Nickel 1 1 2 - - - Nitrobenzene 2 2 4.85 - - - N-Nitrosodimethylamine 2 2 4.85 - - - N-Nitrosodi-n-Propylamine 2 2 9.71 - - - N-Nitrosodiphenylamine 2 2 4.85 - - - PCBs 2 2 0.485 - - - Pentachlorophenol 2 2 9.71 - - - Phenol 2 2 4.85 - - - Pyrene 2 2 4.85 - - -

### Exhibit A-49. Ambient Data Summary, Salem Willow Lake WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean
Selenium 1 1 2 - - - Tetrachloroethylene 2 2 1 - - - Thallium 1 1 1 - - - Toluene 2 2 1 - - - Toxaphene 2 2 4.85 - - - Trichloroethylene 2 2 1 - - - Vinyl Chloride 2 2 1 - - - QL = Quantification limit. 1. Represents ambient data from May 2006 to June 2007.



### Potential Impacts

Baseline Criteria



### Exhibit A-50 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Willamette River is a freshwater river; thus, huma n health criteria for consumption of organisms and water are applicable. ODEQ (2006b) allows 25% of the harmonic mean flow for dilution for carcinogens and 25% of the 30Q5 flow for dilutio n for noncarcinogens. The Willamette River at river mile 78.4 is on the state’s 303(d) list for di oxin and mercury; thus, the facility would not receive dilution for these pollutants.

Exhibit A-50. RPA for Baseline Criteria, Salem Willow Lake WWTP

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) 1,4-Dichlorobenzene 2.12 0 0.074 63 No Arsenic 4.91 0 0.082 0.0022 Yes Bis(2-Ethylhexyl) Phthalate 49.3 0 0.82 1.2 No Mercury 4 0.082 0 0.082 0.017 Yes Toluene 1.94 0 0.067 1300 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants except ar senic (CV = 0.47) and mercury (CV = 0.81) (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on 25% of 30Q5 flow for noncarcinogens (fac tor = 28.9) and 25% of harmonic mean flow for carcinogens (factor = 60). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the facility has RP to exceed the baseline criterion for arsenic and mercury because the concentrations at the edge of the regulatory mixing zone are greater than the applicable existing human health criteria.

June 2008 Appendix A. Facility Analyses A-69

### Arsenic

Under existing conditions, the discharger woul d have to meet an AMEL of 0.026 μg/L and a MDEL of 0.047 μg/L for arsenic. However, beca use both limits are below the QL of 0.05 μg/L, the discharger would only be re quired to reduce discha rge concentrations to the QL value for compliance with baseline standards.

Inorganic arsenic can enter surface waters throu gh atmospheric deposition (e.g., arsenic released into the air by volcanoes), soil erosion and weathering of arsenic-contai ning minerals and ores, and commercial or industrial processes, such as metal smelting, wood preserving, and manufacturing of microelectr onics and semiconductors (ODEQ, 2006a). Arsenic and arseniccontaining chemicals are not used in wastewater treatment. The f acility’s permit indicates that it has a total of 27 significant indus trial users (SIUs) of which 8 are categorical industrial users (i.e., users subject to EPA’s na tional pretreatment standards). The permit indicates that a significant portion of the facility’s industrial load during a portion of the year is from fruit and vegetable packaging operations. If the fruits an d vegetables are treated with arsenic-containing pesticides, then any wash water from the pack aging operations could co ntribute to the high effluent arsenic levels. Thus, a source control program that targets th e most likely indirect industrial dischargers of arsenic to the plant could reduce arsenic concentrations to the necessary levels. Costs for such a program would de pend on the number of arsenic sources and the measures that could be implemented at those sources to reduce arsenic. Without specific information on the types of industr ial dischargers that may need controls, it is not possible to estimate pretreatment or P2 co sts to indirect dischargers.

The City’s drinking water comes from the North Sa ntiam River. Most arsenic samples (organic plus inorganic) from the water body since 1986 are nondetect below the minimum reporting levels, except for 2 detected observations in 1992 (4 μg/L) and 1987 (8 μg/L) (ODHS, 2007e). The minimum reporting levels are not specifie d, and the drinking water maximum contaminant level is 10 μg/L, which is higher than current effl uent concentrations and human health criteria. Thus, from these data it is not possible to dete rmine with any certainty if drinking water is contributing to high arsenic levels in the wastewater effl uent. However, if the facility determines that drinking water is the sour ce of high arsenic values in the wastewater, it is likely that the facility would pursue a variance or request that ODEQ consider granting the facility intake credits.

USGS (1998) indicates that arsenic concentrations exceeding EPA’s previous maximum contaminant level of 50 μg/L are widespread in groundwater in the Willamette Basin. Infiltration of groundwater with su ch high levels of arse nic into to the wast ewater system could result in increased effluent concen trations. If the facility determin es that the source of arsenic in its effluent is groundwater infi ltration, an I&I reducti on program would likely be necessary for compliance with the existing arsenic criteria.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $300,000, with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be $39,100,000 for an I&I reduction program that

June 2008 Appendix A. Facility Analyses A-70

### includes source identification and pipe rehabilitation for a sewer system with 780 miles of pipe (approximately $3,693,000 per year a nnualized at 7% over 20 years). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for compliance and th e discharger would not likely undertake such a program for compliance with toxic criteria alone.

Mercury

Under existing conditions, the discharger woul d have to meet an AMEL of 0.017 μg/L and a MDEL of 0.039 μg/L for mercury. The maximum ef fluent concentration is 0.07 μg/L, which is greater than the projected limits. Thus, the faci lity may need to implement controls to reduce effluent mercury concentrations for compliance w ith these limits. Under the baseline Willamette River Basin mercury TMDL, the facility would be required to develop and implement a mercury reduction strategy. Annual P2 program cost s for a 35 mgd municipal facility may be approximately $150,000 (see Appendix B for details). As described in Appendix B, P2 costs also potentially include costs fo r indirect dischargers to implem ent controls (see Exhibit B-2). Based on information on the discharger’s service ar ea, incremental indirect discharger costs may be $24,000 (e.g., there are 2 universities in the se rvice area). However, because ODEQ does not assign individual wasteload allocations to point source dischargers in th e TMDL (point sources as a whole are required to reduce existing load by 26%), it is uncertain wh ether the facility would incur costs beyond those for a P2 program to me et the wasteload allocation under the baseline
TMDL.

Revised Criteria



### Exhibit A-51 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-51. RPA for Revised Criteria, Salem Willow Lake WWTP Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 1,4-Dichlorobenzene 0.074 34.0 23.0 16.0 7.90 5.10 Arsenic 0.082 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
0.49* 0.30* 0.20* 0.095* 0.061* Bis(2-Ethylhexyl) Phthalate 0.82 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.082
Toluene 0.067 1000 870 720 450 320 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on 25% of 30Q5 flow for noncarcinogens (fac tor = 28.9) and 25% of harmonic mean flow for carcinogens (factor = 60). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger would ha ve RP for arsenic, bis( 2-ethylhexyl) phthalate, and mercury.

June 2008 Appendix A. Facility Analyses A-71

### Arsenic

The facility would have RP for arsenic at all of the alternative consumption rates. Exhibit A-52 shows the projected effluent limits for these consumption rates.

Exhibit A-52. Projected Effluent Limits for Arsenic, Salem Willow Lake WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.10 0.068 0.049 0.025 0.017 MDEL ( μ g/L) 0.18 0.12 0.088 0.045 0.030



### As described in the baseline analysis, the discharger may need to reduce effluent concentrations for compliance with baseline crit eria, or pursue alternative comp liance measures. These are the same compliance scenarios that would apply under all of the potential revised criteria. The baseline I&I reduction program includes a comp rehensive study to identify all potential infiltration sources and rehabilita tion of those sources. Thus, base line controls, or alternative actions, should also enable compliance with the revised criteria, and there would be no incremental compliance costs.

Bis(2-ethylhexyl) phthalate

The discharger would have RP for bis(2-ethylh exyl) phthalate at all alternative consumption

rates. Exhibit A-53 shows the projected effluent limits for these consumption rates.

Exhibit A-53. Projected Effluent Limits for Bis(2-ethylhexyl) Phthalate, Salem Willow Lake WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Average Monthly Limit ( μ g/L) 5.9 3.6 2.4 1.1 0.73 Maximum Daily Limit ( μ g/L) 12 7.2 4.8 2.3 1.5



### The maximum effluent bis(2-ethylhexyl) phthalate concentration is 13 μg/L, which is greater than the projected effluent limits for all the cons umption rates. Bis(2-et hylhexyl) phthalate is found mainly in plastics and is used as a plasticizer for pol yvinylchloride (PVC) and other polymers. The plasticizer can be released from plastics manufacturing wastes or through release from plastic goods (Environment Canada, 1994). The f acility’s permit indicates that it has a total of 27 SIUs. The high bis(2-ethylh exyl) phthalate levels in the e ffluent could be due to one or more of its indirect dischargers. Regulati ng these sources through a P2 program could reduce pollutant loadings to the necessary levels. High levels of bis(2-et hylhexyl) phthalate in municipal wastewater effluent can also be asso ciated with sampling and/ or laboratory analysis conditions (Fairfield-Suisun SD, 2003). If this is the case, cleaner sampling and analysis techniques could reduce the amount of bis(2-ethylhexyl) phthalate measured in the effluent. Thus, as described in Appendix B, costs for the discharger could be minimal if cleaner sampling techniques result in lower efflue nt concentrations to approxim ately $50,000 for a P2 program for bis(2-ethylhexyl ) phthalate.

June 2008 Appendix A. Facility Analyses A-72

### Mercury

The discharger would have RP for mercury at all consumption rates. Exhibit A-54 shows the projected effluent limits for these consumption rates.

Exhibit A-54. Projected Effluent Limi ts for Mercury, Salem Willow Lake WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.0047 0.0026 0.0017 0.00076 0.00048 MDEL ( μ g/L) 0.011 0.0060 0.0039 0.0018 0.0011



### The maximum effluent concentration is greater th an all of the AMELs and MDELs. The facility is already required to implem ent a mercury P2 program under the baseline as part of the Willamette Basin mercury TMDL. It is not clea r how ODEQ would adapt the baseline TMDL to attain the revised crit eria (e.g., increase point source load reduction requirements; establish individual effluent limits). Thus, it is uncertain whether c ontinued implementation of the baseline P2 program would be sufficient for compliance with th e revised criteria/TMDL because there could be some maximum level of effort beyond which a P2 program would not provide additional reductions.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consis tent basis, dischargers may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied) under mo re stringent TMDL requirements (alternatively, ODEQ may account for this situation in allocating loads under the TMDL). However, it is uncertain at which fish consumption rate the discharger would need a variance. If the discharger pursues a variance for arsenic, these efforts would also cover a variance for mercury. Otherwise, one-time costs a ssociated with pursuing a variance could range from $35,000 to $300,000. As part of a variance ODEQ, could require specific P2 program efforts. For dischargers covered under the Willamette River TMDL for mercury, these activities may already be included in thei r baseline mercury P2 requirement.

Summary



### Exhibit A-55 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline criteria. Under a variance scenario for arseni c and/or mercury, costs could include a one-time expenditure of $35,000 to $300,000.

Exhibit A-55. Summary of Potent ial Costs, Salem Willow Lake WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits, variance, or I&I reduction program (arsenic) $174,000 - $3,867,000 NA Baseline

• P2 program (mercury)

June 2008 Appendix A. Facility Analyses A-73

### Exhibit A-55. Summary of Potent ial Costs, Salem Willow Lake WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits, variance, or I&I reduction program (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 63.2 gpd $174,000 - $3,917,000 $0 -$50,000

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 113 gpd $174,000 - $3,917,000 $0 -$50,000

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 175 gpd $174,000 - $3,917,000 $0 -$50,000

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 389 gpd $174,000 - $3,917,000 $0 -$50,000

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 620 gpd $174,000 - $3,917,000 $0 -$50,000

• P2 program, possible variance (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised cr iteria represent the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-74

### St. Helens-Boise Cascade WWTP

Facility Description

The St. Helens-Boise Cascade Wastewater Treatment Plant (NPDES permit number OR0020834) treats wastewater fr om St. Helens, Colombia C ity, and the Boise Cascade Corporation pulp and paper mill. The City of St . Helens shares its NPDES permit with Boise Cascade, which is a fully integrated facility that uses the bleached Kraft pulping process to produce market pulp, tissue and fine papers. Wast ewater from the mill is sent to an aerated stabilization basin (ASB), where it is combined with treated municipal wastewater from the St. Helens’ WWTP. After secondary treatment in th e ASB, the combined pulp mill and municipal wastewater is discharged through Outfall 001 to th e Columbia River at river mile 86.9. Boise is responsible for the majority of the effluent. The mill contributes around 29 mgd to the ASB, while the municipal wastewater flow only contribu tes 1 mgd. There are two other outfalls to the Colombia River, 008 and 009, that are for overflo ws. Outfalls 007 and 010 are for emergency discharge from the ASB and return mill intake wa ter, and both are outfalls to the Multnomah Channel. Outfalls 002 through 006 are internal monitoring points.

Treatment Processes

The 2004 NPDES permit for the facility lists treatm ent processes as a primary aerated treatment basin, a chlorine contact chamber for disinfection, and a large aerated stabi lization basin (ASB) which provides secondary treatment to the City’s wastewater and wastewater from the Boise pulp and paper mill. Wastewater from the mill is treated in a primary clarifier, before being pumped to the ASB.

Effluent Data and Limits

Exhibit A-56 summarizes monitoring data from April 2004 to April 2007 for those pollutants of concern for which effluent data ar e available. The facility does not have effluent limits for any toxic pollutants.

Exhibit A-56. Effluent Data Su mmary, St. Helens-Boise Cascade WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 13 13 6 - - - 1,1,2-Trichloroethane 13 13 4 - - - 1,1-Dichloroethylene 13 13 10 - - - 1,2,4-Trichlorobenzene 13 13 5.56 - - - 1,2-Dichlorobenzene 13 13 5.56 - - - 1,2-Dichloroethane 13 13 4 - - - 1,2-Dichloropropane 13 13 4 - - - 1,2-Trans-Dichloroethylene 13 13 6 - - - 1,3-Dichlorobenzene 13 13 5.56 - - - 1,4-Dichlorobenzene 13 13 5.56 - - - 2,3,7,8-TCDD (Dioxin) 13 13 0.00001 - - -

June 2008 Appendix A. Facility Analyses A-75June 2008 Appendix A. Facility Analyses A-76 

### Exhibit A-56. Effluent Data Su mmary, St. Helens-Boise Cascade WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2,4,6-Trichlorophenol 13 13 5.56 - - - 2,4-Dichlorophenol 13 13 5.56 - - - 2,4-Dimethylphenol 13 13 11.1 - - - 2,4-Dinitrophenol 13 13 20 - - - 2,4-Dinitrotoluene 13 13 5.56 - - - 2-Chloronaphthalene 13 13 5.56 - - - 2-Chlorophenol 13 13 5.56 - - - 2-Methyl-4,6-Dinitrophenol 13 13 11.1 - - - 3,3'-Dichlorobenzidine 13 13 5.56 - - - 4,4'-DDD 13 13 1 - - - 4,4'-DDE 13 13 1 - - - 4,4'-DDT 13 13 1 - - - Acenaphthene 13 13 5.56 - - - Acrolein 13 13 20 - - - Acrylonitrile 13 13 20 - - - Aldrin 13 13 1 - - - alpha-BHC 13 13 1 - - - Antimony 13 0 - 0.82 0.42 0.26 Arsenic 13 0 - 2.28 1.21 0.76 Benzene 13 13 6 - - - Benzidine 13 13 66.7 - - - Benzo(a) Anthracene 13 13 5.56 - - - Benzo(a) Pyrene 13 13 5.56 - - - Benzo(b) Fluoranthene 13 13 5.56 - - - Benzo(k) Fluoranthene 13 13 5.56 - - - Beryllium 13 13 0.1 - - - Bis(2-Chloroethyl) Ether 13 13 5.56 - - - Bis(2-Chloroisopropyl) Ether 13 13 11.1 - - - Bis(2-Ethylhexyl) Phthalate 13 13 11.1 - - - Bromoform 13 13 4 - - - Carbon Tetrachloride 13 13 6 - - - Chlorobenzene 13 13 4 - - - Chloroform 13 13 4 - - - Chrysene 13 13 5.56 - - - Dibenzo(a,h)Anthracene 13 13 5.56 - - - Dichlorobromomethane 13 13 4 - - - Dieldrin 13 13 1 - - - Diethyl Phthalate 13 13 5.56 - - - Dimethyl Phthalate 13 13 5.56 - - - Di-n-Butyl Phthalate 13 12 10 14.7 14.7 14.7 Endosulfan Sulfate 13 13 1 - - - Endrin 13 13 1 - - - Endrin Aldehyde 13 13 1 - - - Ethylbenzene 13 13 4 - - -

### Exhibit A-56. Effluent Data Su mmary, St. Helens-Boise Cascade WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean
Fluoranthene 13 13 5.56 - - - Fluorene 13 13 5.56 - - - Gamma-BHC 13 13 0.1 - - - Heptachlor 13 13 1 - - - Heptachlor Epoxide 13 13 1 - - - Hexachlorobenzene 13 13 5.56 - - - Hexachlorobutadiene 13 13 11.1 - - - Hexachlorocyclopentadiene 13 13 11.1 - - - Hexachloroethane 13 13 11.1 - - - Ideno(1,2,3-cd)Pyrene 13 13 5.56 - - - Isophorone 13 13 10 - - - Mercury 13 5 0.005 0.037 0.015 0.0073 Methylene Chloride 13 13 6 - - - Nickel 13 0 - 16.7 6.99 2.83 Nitrobenzene 13 13 5.56 - - - N-Nitrosodimethylamine 13 13 5.56 - - - N-Nitrosodi-n-Propylamine 13 13 11.1 - - - N-Nitrosodiphenylamine 13 13 5.56 - - - PCBs 3 13 13 0.556 - - - Pentachlorophenol 13 13 11.1 - - - Phenol 26 26 100 - - - Pyrene 13 13 5.56 - - - Selenium 13 7 0.5 2.35 1.34 0.80 Tetrachloroethylene 13 13 4 - - - Thallium 13 13 0.1 - - - Toluene 13 11 4 7.3 4.10 2.3 Toxaphene 13 13 50 - - - Trichloroethylene 13 13 6 - - - Vinyl Chloride 13 13 20 - - - QL = Quantification limit. 1. Represents effluent data from April 2004 to April 2007. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

Through computer modeling of stre am flow data in the vicinity of the discharge, CH2MHill (2007) determined that the harmonic mean receivi ng water flow for the Columbia River at river mile 87 (0.1 miles upstream from the facility) is approximately 186,218 cfs, and the 30Q5 flow is 98,768 cfs.

Exhibit A-57 summarizes monitoring data for the Co lumbia River at river mile 88.0, 1.1 miles upstream from the outfall location. Samples were taken at a location outside of influence of the

June 2008 Appendix A. Facility Analyses A-77

### Outfall 001 mixing zone, from July 2003 to April 2007 for those pollutants of concern for which ambient data are available.

Exhibit A-57. Ambient Data Summary, St. Helens-Boise Cascade WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean Antimony 16 1 0.100 0.16 0.13 0.10 Arsenic 10 0 - 1.06 0.90 0.70 Beryllium 6 5 0.009 0.05 0.05 0.05 Mercury 16 4 0.005 0.013 0.005 0.002 Nickel 6 0 - 2.3 1.45 0.40 Selenium 1 0 - 0.40 0.40 0.40 Thallium 10 10 0.100 - - - QL = Quantification limit. 1. Represents ambient data from July 2003 to April 2007.



### Potential Impacts

Baseline Criteria



### Exhibit A-58 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Columbia River is a freshwater river; thus, human health criteri a for consumption of organisms and water are applicable. ODEQ (2006b) allows 25% of the harmonic mean flow for dilution for carcinogens and 25% of the 30Q5 flow for d ilution for noncarcinogens. However, to be conservative (i.e., err on the side of higher costs), the dilution factors are based on using only 10% of the river flows. The Columbia River at river mile 86.9 is on th e state’s 303(d) list as impaired for dioxin, DDT, arsenic, and PCBs; thus , the facility would not receive dilution for these pollutants.

Exhibit A-58. RPA for Baseline Crit eria, St. Helens-Boise Cascade WWTP

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) Antimony 1.11 0.13 0.13 5.6 No Arsenic 1.69 0.90 1.69 0.0022 Yes Di-n-Butyl Phthalate 23.2 0 0.11 2000 No Mercury 4 0.058 0.005 0.0052 0.017 No Nickel 25.4 1.45 1.56 13.4 No Selenium 3.71 0.4 0.42 10 No Toluene 11.5 0 0.054 1300 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants except antimony (CV = 0.385), arsenic (CV = 0.42) and nickel (CV = 0.546) (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on 10% of 30Q5 flow for noncarcinogens (f actor = 214) and 10% of harmonic mean flow for carcinogens (factor = 404). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level

June 2008 Appendix A. Facility Analyses A-78

### Exhibit A-58. RPA for Baseline Crit eria, St. Helens-Boise Cascade WWTP

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the facility has RP to exceed the baseline criterion for arsenic because the concentration at the edge of the regulatory mi xing zone is greater than the applicable existing human health criterion. Note also that although ambient concen trations are greater than the criterion, the Willamette River near the discharge is not on the stat e’s 303(d) list as impaired for arsenic. If ODEQ determines that the ambi ent concentration represents natural background levels, it would grant dilution in the RPA calcu lation (ODEQ, 2005). Unde r this scenario, the concentration at the edge of the mixing zone would be approximately 0.2% above the ambient background concentration. ODEQ (2005) indicates th at dischargers that cause less than a 10% increase in downstream receiving water concentr ations would not be gi ven numeric effluent limits; rather they would be required to impl ement narrative BMPs (e.g., improve internal process control) and increased monitoring. The co sts of such measures could be comparable to the cost of implementing an industrial mercury P2 program because the facility would likely conduct similar actions and activ ities. Thus, costs could be approximately $25,000 per year.

If ODEQ determines that the water body is im paired, it would not gr ant dilution and base effluent limits on achieving the criterion end-of-pipe. However, because the baseline criterion is below the QL, the discharger would only need to reduce effluent levels to the QL of 0.05 μg/L (because the criterion is below the QL) for compliance with baseline standards.

Arsenic and arsenic-containing chemicals are not us ed in wastewater treatment. However, the City’s drinking water comes from the groundwater wells. The majority of the water is extracted from two wells on the banks of the Columbia River and treated at the City’s new membrane filtration water treatmen t facility (St. Helens Water Department, 2006). In the summer groundwater from a well located near Scappoose Bay Marina is used to meet peak demands (St. Helens Water Department, 2006). This water is not treated at the water treatment plant. USGS (1998) indicates that arsenic c oncentrations exceeding EPA’s previous maximum contaminant level of 50 μg/L are widespread in groundwater in the Willamette Basin. However, most arsenic samples (organic plus inorganic) from the wells since 1986 are nondetect below the minimum reporting levels, except for 1 detected obser vation in 1993 (3 μg/L) (ODHS, 2007f). The minimum reporting levels are not specified, and the drinking wa ter maximum contaminant level is 10 μg/L, which is higher than current effluent concentrations and human health criteria. Use of groundwater with high levels of arsenic could result in increased efflue nt concentrations as a result of use of drinking water at the Boise Cascade pulp mill.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $300,000, with minimal costs associated with renewal.

June 2008 Appendix A. Facility Analyses A-79

### Revised Criteria



### Exhibit A-59 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-59. RPA for Revised Crit eria, St. Helens-Boise Cascade WWTP Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Antimony 0.13 5.40 5.30 5.10 4.70 4.30 Arsenic 1.69 0.0083* 0.0057* 0.0041* 0.0021* 0.0014* Di-n-Butyl Phthalate 0.11 920 580 400 190 120 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.0052 Nickel 1.56 280 190 140 69.0 45.0 Selenium 0.42 150 140 120 91.0 70.0 Toluene 0.054 1000 870 720 450 320 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on 10% of 30Q5 flow for noncarcinogens (f actor = 214) and 10% of harmonic mean flow for carcinogens (factor = 404). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger coul d have RP for arsenic and mercury based on the alternative fish consumption rates.

Arsenic

The discharger would have RP for arsenic at a ll fish consumption rates. Thus, because the ambient concentration is greater than the criteria, the discharger would need to reduce discharge concentrations to background (if ODEQ determines that ambient concentrations represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with revised standards. Howeve r, under the baseline, the discharge would need to meet those same levels. Thus, incremental compliance costs would be unlikely.

Mercury

The discharger would have RP for merc ury at all fish consumption rates. Exhibit A-60 shows the AMELs and MDELs for each consumption rate. Note that at the a lternative consumption rates the ambient background concentr ation (0.005 μg/L) is greater than the applicable criteria so the discharger would not receive di lution in calculating effluent limits.

Exhibit A-60. Projected Effluent Limits for Mercury, St. Helens-Boise Cascade WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.0047 0.0026 0.0017 0.00076 0.00048 MDEL ( μ g/L) 0.0094 0.0052 0.0034 0.0015 0.00096

June 2008 Appendix A. Facility Analyses A-80

### The maximum effluent concentration at the faci lity is 0.037 μg/L, which is greater than the AMEL and MDEL for all consumption rates. Thus, the facility may need to implement controls to reduce effluent mercury concentrations for co mpliance with these limits. As described above, only about 1 mgd of the 30 mgd effluent is muni cipal wastewater. The remaining is pulp mill effluent. Because mercury monitoring data are not available for each waste stream, we assumed that both facilities would need to implement me rcury control measures for compliance with the revised effluent limits.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consistent basis, the municipal wastewater treatment plant would likely implement a P2 program for compliance w ith the projected effluent limits. Annual P2 program costs for a 1 mgd municipal facility may be approximately $50,000 (see Appendix B for details). As described in Appe ndix B, P2 costs also potential ly include costs for indirect dischargers to implement controls (see Exhibit B-2). Based on information on the discharger’s service area, incremental indirect discharger co sts may be minimal (e.g., there are no universities in the service area).

The pulp mill would need to implement a P2 pr ogram to identify the sources of mercury and determine the most cost-effective measures for re ducing mercury from those sources. Annual P2 program costs for an industrial facility may be approximately $25,000 (see Appendix B for details). Thus, total annual mercury contro l costs for this discharger are $75,000 ($50,000 + $25,000). Note that a municipality is likely to have many more potential sources of mercury to target and control than an industr ial facility so P2 costs are great er for the municipal portion of the facility even though the flow is less.

Note there could be some maximum level of effort beyond which a P2 program would not provide additional reductions a nd the facility may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied). However, it is uncertain for which consumption rates the discharger would need a variance. If th e discharger pursues a vari ance for arsenic, these efforts would also cover a variance for mercury. Otherwise, one-time costs associated with pursuing a variance could range from $35,000 to $300,000. As part of a variance ODEQ, could require specific P2 program efforts.

Summary



### Exhibit A-61 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline criteria. Under a variance scenario for arseni c and/or mercury, costs could include a one-time expenditure of approximately $35,000 to $300,000.

Exhibit A-61. Summary of Potentia l Costs, St. Helen-Boise Cascade WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1 Baseline • Intake credits, BMPs, or vari ance (arsenic) $0 - $25,000 NA

• Intake credits, BMPs, or variance (arsenic) $75,000 - $100,000 $75,000 63.2 gpd

• P2 program, possible variance (mercury)

June 2008 Appendix A. Facility Analyses A-81

### Exhibit A-61. Summary of Potentia l Costs, St. Helen-Boise Cascade WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits, BMPs, or variance (arsenic) $75,000 - $100,000 $75,000 113 gpd

• P2 program, possible variance (mercury)

• Intake credits, BMPs, or variance (arsenic) $75,000 - $100,000 $75,000 175 gpd

• P2 program, possible variance (mercury)

• Intake credits, BMPs, or variance (arsenic) $75,000 - $100,000 $75,000 389 gpd

• P2 program, possible variance (mercury)

• Intake credits, BMPs, or variance (arsenic) $75,000 - $100,000 $75,000 620 gpd

• P2 program, possible variance (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-82

### Tri-City Service District

Facility Description

The Tri-City Service District operates an activated biosolids sewage plant in Oregon City, Oregon (NPDES permit number OR0031259) and serv es the cities of Gl adstone, Oregon City, and West Linn. ODEQ classifies th e facility as a major discharg er, with an ADWDF of 8.4 mgd. The facility discharges treated effluent thr ough Outfall 001 into the Willamette River at river mile 0.2. The facility also has four other outfalls categorized as emergency overflows.

Treatment Processes

The major treatment processes at the facility are activated sludge, secondary treatment, and chlorine disinfection; sludge is anaerobically digested.

Effluent Data and Limits

Exhibit A-62 summarizes monitoring data from May 2005 to December 2006 for those pollutants of concern for which effl uent data are available. The f acility does not have effluent limits for any toxic pollutants.

Exhibit A-62. Effluent Data Su mmary, Tri-City Service District 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 2 2 5 - - - 1,2,4-Trichlorobenzene 2 2 10 - - - 1,2-Dichlorobenzene 2 2 5 - - - 1,2-Dichloroethane 2 2 5 - - - 1,2-Dichloropropane 2 2 5 - - - 1,2-Diphenylhydrazine 2 2 10 - - - 1,2-Trans-Dichloroethylene 2 2 5 - - - 1,4-Dichlorobenzene 4 4 5 - - - 2,4,6-Trichlorophenol 2 2 10 - - - 2,4-Dichlorophenol 2 2 25 - - - 2,4-Dimethylphenol 2 2 10 - - - 2,4-Dinitrophenol 2 2 25 - - - 2,4-Dinitrotoluene 2 2 10 - - - 2-Chloronaphthalene 2 2 10 - - - 2-Chlorophenol 2 2 10 - - - 2-Methyl-4,6-Dinitrophenol 2 2 25 - - - 4,4'-DDD 2 2 0.01 - - - 4,4'-DDE 2 2 0.01 - - - 4,4'-DDT 2 2 0.01 - - - Acenaphthene 2 2 10 - - - Acrolein 2 2 50 - - - Acrylonitrile 2 2 10 - - -

June 2008 Appendix A. Facility Analyses A-83June 2008 Appendix A. Facility Analyses A-84 

### Exhibit A-62. Effluent Data Su mmary, Tri-City Service District 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

Aldrin 2 2 0.01 - - - alpha-BHC 2 2 0.013 - - - Anthracene 2 2 10 - - - Arsenic 21 11 0.5 1 0.44 0.12 Benzidine 2 2 50 - - - Benzo(a) Anthracene 2 2 10 - - - Benzo(a) Pyrene 2 2 10 - - - Benzo(b) Fluoranthene 2 2 10 - - - Benzo(k) Fluoranthene 2 2 10 - - - Bis(2-Chloroethyl) Ether 2 2 10 - - - Bis(2-Chloroisopropyl) Ether 2 2 10 - - - Bis(2-Ethylhexyl) Phthalate 2 2 10 - - - Bromoform 2 2 5 - - - Carbon Tetrachloride 2 2 5 - - - Chlordane 2 2 0.2 - - - Chlorobenzene 2 2 5 - - - Chloroform 2 2 5 - - - Chrysene 2 2 10 - - - Dibenzo(a,h)Anthracene 2 2 10 - - - Dichlorobromomethane 2 2 5 - - - Dieldrin 2 2 0.01 - - - Diethyl Phthalate 2 2 10 - - - Dimethyl Phthalate 2 2 10 - - - Di-n-Butyl Phthalate 2 2 10 - - - Endosulfan Sulfate 2 2 0.01 - - - Endrin Aldehyde 2 2 0.01 - - - Ethylbenzene 2 2 5 - - - Fluoranthene 2 2 10 - - - Fluorene 2 2 10 - - - Gamma-BHC 2 2 0.01 - - - Heptachlor 2 2 0.01 - - - Heptachlor Epoxide 2 2 0.01 - - - Hexachlorobenzene 2 2 10 - - - Hexachlorobutadiene 2 2 10 - - - Hexachlorocyclopentadiene 2 2 10 - - - Hexachloroethane 2 2 10 - - - Ideno(1,2,3-cd)Pyrene 2 2 10 - - - Isophorone 2 2 10 - - - Mercury 21 6 0.05 0.020 0.0073 0.0039 Nickel 21 0 0 2.1 1.61 1.1 Nitrobenzene 2 2 10 - - - N-Nitrosodimethylamine 2 2 25 - - - N-Nitrosodi-n-Propylamine 2 2 10 - - - PCBs 3 1 1 0.97 - - -

### Exhibit A-62. Effluent Data Su mmary, Tri-City Service District 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean Pentachlorophenol 2 2 25 - - - Phenol 2 2 10 - - - Pyrene 2 2 10 - - - Selenium 21 21 2 - - - Tetrachloroethylene 2 2 5 - - - Toxaphene 2 2 0.5 - - - Trichloroethylene 2 2 5 - - - Vinyl Chloride 2 2 5 - - - QL = Quantification limit. 1. Represents effluent data from May 2005 to December 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

Exhibit A-63 summarizes data from the Willamette River upstream of the facility from November 2002 to December 2006 for those pollutan ts of concern for which ambient data are available.

Exhibit A-63. Ambient Data Su mmary, Tri-City Service District 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 2 2 5 - - - 1,2,4-Trichlorobenzene 2 2 11 - - - 1,2-Dichlorobenzene 2 2 5 - - - 1,2-Dichloroethane 2 2 5 - - - 1,2-Dichloropropane 2 2 5 - - - 1,2-Diphenylhydrazine 2 2 11 - - - 1,2-Trans-Dichloroethylene 2 2 5 - - - 1,4-Dichlorobenzene 4 4 5 - - - 2,4,6-Trichlorophenol 2 2 11 - - - 2,4-Dichlorophenol 2 2 11 - - - 2,4-Dimethylphenol 2 2 11 - - - 2,4-Dinitrophenol 2 2 25 - - - 2,4-Dinitrotoluene 2 2 11 - - - 2-Chloronaphthalene 2 2 11 - - - 2-Chlorophenol 2 2 11 - - - 2-Methyl-4,6-Dinitrophenol 2 2 27 - - - 4,4'-DDD 2 2 0.011 - - - 4,4'-DDE 2 2 0.011 - - - 4,4'-DDT 2 2 0.011 - - - Acenaphthene 2 2 11 - - - Acrolein 2 2 50 - - -

June 2008 Appendix A. Facility Analyses A-85June 2008 Appendix A. Facility Analyses A-86 

### Exhibit A-63. Ambient Data Su mmary, Tri-City Service District 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Maximum Geometric Mean Minimum

Acrylonitrile 2 2 10 - - - Aldrin 2 2 0.011 - - - alpha-BHC 2 2 0.011 - - - Anthracene 2 2 11 - - - Arsenic 4 3 0.5 0.5 0.5 0.5 Benzidine 2 2 53 - - - Benzo(a) Anthracene 2 2 11 - - - Benzo(a) Pyrene 2 2 11 - - - Benzo(b) Fluoranthene 2 2 11 - - - Benzo(k) Fluoranthene 2 2 11 - - - Bis(2-Chloroethyl) Ether 2 2 11 - - - Bis(2-Chloroisopropyl) Ether 2 2 11 - - - Bis(2-Ethylhexyl) Phthalate 2 2 11 - - - Bromoform 2 2 5 - - - Carbon Tetrachloride 2 2 5 - - - Chlordane 2 2 0.22 - - - Chlorobenzene 2 2 5 - - - Chloroform 2 2 5 - - - Chrysene 2 2 11 - - - Dibenzo(a,h)Anthracene 2 2 11 - - - Dichlorobromomethane 2 2 5 - - - Dieldrin 2 2 0.011 - - - Diethyl Phthalate 2 2 11 - - - Dimethyl Phthalate 2 2 11 - - - Di-n-Butyl Phthalate 2 2 11 - - - Endosulfan Sulfate 2 2 0.011 - - - Endrin Aldehyde 2 2 0.011 - - - Ethylbenzene 2 2 5 - - - Fluoranthene 2 2 11 - - - Fluorene 2 2 11 - - - Heptachlor 2 2 0.011 - - - Heptachlor Epoxide 2 2 0.011 - - - Hexachlorobenzene 2 2 11 - - - Hexachlorobutadiene 2 2 11 - - - Hexachlorocyclopentadiene 2 2 11 - - - Hexachloroethane 2 2 11 - - - Ideno(1,2,3-cd)Pyrene 2 2 11 - - - Isophorone 2 2 11 - - - Mercury 4 1 0.005 0.0025 0.0019 0.0011 Nickel 4 0 0 0.70 0.54 0.35 Nitrobenzene 2 2 11 - - - N-Nitrosodimethylamine 2 2 27 - - - N-Nitrosodi-n-Propylamine 2 2 11 - - - PCBs 2 2 1.1 - - -

### Exhibit A-63. Ambient Data Su mmary, Tri-City Service District 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean Pentachlorophenol 2 2 27 - - - Phenol 2 2 11 - - - Pyrene 2 2 11 - - - Selenium 4 4 2 - - - Tetrachloroethylene 2 2 5 - - - Toxaphene 2 2 0.53 - - - Trichloroethylene 2 2 5 - - - Vinyl Chloride 2 2 5 - - - “-“ = not applicable. QL = Quantification limit. 1. Represents ambient data from Nov 2002 to December 2006. 2. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Potential Impacts

Baseline Criteria



### Exhibit A-64 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Willamette River is a freshwater river; thus, huma n health criteria for consumption of organisms and water are applicable. There are no data available from which to determine the 30Q5 and harmonic means flows for the Willamette River ups tream of the facility, and the facility’s existing permit does not specify any dilution factor s. Therefore, we assumed that there is no dilution for this facility (i.e., dilution factor equals 1). Note , even if dilution factors were available, the discharger woul d not receive dilution for DDT , DDE, dieldrin, dioxin, mercury, PCBs, pentachlorophenol, or PAHs because the Willamette River at river mile 0.2 is on the state’s 303(d) list as impair ed for these pollutants.

Exhibit A-64. RPA for Baseline Cr iteria, Tri-City Service District

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L)
Arsenic 0.60 0.5 0.60 0.0022 Yes Yes Mercury 4 0.026 0.0019 0.026 0.017 Nickel 2.33 0.54 2.33 13.4 No Selenium 0.0097 0 0.0097 10 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants except ar senic (CV = 0.63), mercury (CV = 0.50), and nickel (CV = 0.20) (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Assumes no dilution (factor = 1). 4. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).

June 2008 Appendix A. Facility Analyses A-87

### As shown in the exhibit, the facility has RP to exceed the baseline criterion for arsenic and mercury because the concentrations at the edge of the regulatory mixing zone are greater than the applicable existing human health criteria.

Arsenic

Note that although ambient concentrations are gr eater than the criterion, the Willamette River near the discharge is not on the state’s 303(d) list as impaired for arsenic. Regardless, the facility would be discharging arsenic a bove allowable levels and would be required to reduce discharge concentrations to background (if ambient concentrations are determined to represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with baseline standards.

Arsenic and arsenic-containing chemicals are not us ed in wastewater treatm ent. The facility’s permit does not indicate whether th ere are any significant or categorical dischargers to the treatment plant. However, if the facility determines that one or more of its indirect dischargers is causing or contributing to high arse nic levels in the effluent, it would most likely implement a source control program to target the dischargers or impose more stringent pretreatment limits on the dischargers. Without specific information on the types of industrial dischargers that may need controls, it is not possible to estimate pretreatment or P2 cost s to indirect dischargers.

The facility’s drinking water comes from the Clack amas River. Most arsenic samples (organic plus inorganic) from the water body since 1986 are nondetect below the minimum reporting levels, except for 2 detected observations in 1987 (5 μg/L) and 1989 (6 μg/L) (ODHS, 2007g). The minimum reporting levels are not specifie d, and the drinking water maximum contaminant level is 10 μg/L, which is higher than current effl uent concentrations and human health criteria. Thus, from these data it is not possible to dete rmine with any certainty if drinking water is contributing to high arsenic levels in the wastewater effl uent. However, if the facility determines that drinking water is the sour ce of high arsenic values in the wastewater, it is likely that the facility would pursue a variance or request that ODEQ consider granting the facility intake credits.

USGS (1998) indicates that arsenic concentrations exceeding EPA’s previous maximum contaminant level of 50 μg/L are widespread in groundwater in the Willamette Basin. Infiltration of groundwater with su ch high levels of arse nic into to the wast ewater system could result in increased effluent concen trations. If the facility determin es that the source of arsenic in its effluent is groundwater in filtration, an I&I reduction pr ogram may be necessary for compliance with the existing arsenic criteria.

There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $200,000, with minimal costsassociated with renewal. If the arsenic effluent levels are the result of infiltration of arseniccontaminated groundwater, total costs could be $10,900,000 for an I&I reduction program that includes source identification and pipe rehabilitation for a sewer system with approximately 218 miles of pipe (approximately $1,032,000 per year annua lized at 7% over 20 year s). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction

June 2008 Appendix A. Facility Analyses A-88

### program alone may not be sufficient for comp liance and the discharg er would not likely undertake such a program for comp liance with toxic criteria alone.

Mercury

Under existing condition, the AMEL would be 0.017 μg/L and the MDEL would be 0.031 μg/L (i.e., criterion end-of-pipe because the water body is impaired). The maximum effluent concentration at the facility is 0.02 μg/L, which is greater than the projected limits. Thus, the facility may need to implement controls to reduce effluent mercur y concentrations for compliance with these limits. Since the projected effluent levels are in the range achievable by municipal wastewater treatment plants that ha ve implemented P2, the facility would likely implement a P2 program for compliance with the projected effluent limits. In addition, under the baseline Willamette River Basin mercury TMDL, th e facility would be required to develop and implement a mercury reduction strategy. Howe ver, because ODEQ does not assign individual wasteload allocations to point s ource dischargers in the TMDL (point sources as a whole are required to reduce existing load by 26%), it is un certain whether the facility would incur costs beyond those for a P2 program to meet the wast eload allocation under the baseline TMDL.

Annual P2 program costs for an 8.4 mgd munici pal facility may be approximately $100,000 (see Appendix B for details). As desc ribed in Appendix B, P2 costs also potentially include costs for indirect dischargers to implement controls (see Exhibit B-2). Based on information on the discharger’s servic e area, incremental indirect discharger costs may be minimal (e.g., there are no universities in the service area).

Revised Criteria



### Exhibit A-65 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-65 RPA for Revised Crite ria, Tri-City Service District Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd
Arsenic 0.60 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.026 Nickel 2.33 280 190 140 69.0 45.0 Selenium 0.0097 150 140 120 91.0 70.0 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Assumes no dilution (factor = 1). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger coul d have RP for arsenic and mercury based on the alternative fish consumption rates.

June 2008 Appendix A. Facility Analyses A-89

### Arsenic

The discharger would have RP for arsenic at a ll fish consumption rates. Thus, because the ambient concentration is greater than the criteria, the discharger would need to reduce discharge concentrations to background (if ODEQ determines that ambient concentrations represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with revised standards. Howeve r, under the baseline, the discharge would need to meet those same levels. Thus, incremental compliance costs are unlikely.

Mercury

The discharger would have RP for mercury at all of the revised consumption rates. Exhibit A66 shows the AMELs and MDELs for each consumption rate.

Exhibit A-66. Projected Effluent Limits for Mercury, Tri-City Service District Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Average Monthly Limit ( μ g/L) 0.0047 0.0026 0.0017 0.00076 0.00048 Maximum Daily Limit ( μ g/L) 0.0087 0.0048 0.0031 0.0014 0.00089



### The maximum effluent concentration is greater th an all of the AMELs and MDELs. The facility is already required to implem ent a mercury P2 program under the baseline as part of the Willamette Basin mercury TMDL. It is not clea r how ODEQ would adapt the baseline TMDL to attain the revised crit eria (e.g., increase point source load reduction requirements; establish individual effluent limits). Thus, it is uncertain whether c ontinued implementation of the baseline P2 program would be sufficient for compliance with th e revised criteria/TMDL because there could be some maximum level of effort beyond which a P2 program would not provide additional reductions.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consis tent basis, dischargers may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied) under mo re stringent TMDL requirements (alternatively, ODEQ may account for this situation in allocating loads under the TMDL). However, it is uncertain at which fish consumption rate the discharger would need a variance. If the discharger pursues a variance for arsenic, these efforts would also cover a variance for mercury. Otherwise, one-time costs a ssociated with pursuing a variance could range from $35,000 to $200,000. As part of a variance ODEQ, could require specific P2 program efforts. For dischargers covered under the Willamette River TMDL for mercury, these activities may already be included in their baseline mercury P2 requirement.

Summary



### Exhibit A-67 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline

June 2008 Appendix A. Facility Analyses A-90

### criteria. Under a variance scenario for arseni c and/or mercury, costs could include a one-time expenditure of $35,000 to $200,000.

Exhibit A-67. Summary of Potential Costs, Tri-City Service District

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits, variance, or I&I reduction program (arsenic) Baseline $100,000 - $1,132,000 NA

• P2 program (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $100,000 - $1,132,000 $0 63.2 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $100,000 - $1,132,000 $0 113 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $100,000 - $1,132,000 $0 175 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $100,000 - $1,132,000 $0 389 gpd

• P2 program, possible variance (mercury)

• Intake credits, variance, or I&I reduction program (arsenic) $100,000 - $1,132,000 $0 620 gpd

• P2 program, possible variance (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised cr iteria represent the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-91

### Woodburn Wastewater Treatment Plant

Facility Description

The Woodburn Wastewater Treatment Plan t (NPDES permit number OR0020001) is an advanced secondary wastewater treatment facility located near Woodburn, Oregon. The treatment facility serves the entire City of Woodburn, with the exception of some isolated residences. ODEQ classifies the discharger as a major municipa l, with an ADWDF of 3.33 mgd. Treated wastewater flows through Outfalls 001A a nd 001B into the Pudding River at river mile 21.4. Reclaimed wastewater at Outfall 002 is distributed on la nd for dissipation by evapotranspiration and controlled seepage. Ther e are three other outflows used for emergency overflows.

Treatment Processes

The 2004 NPDES permit for the facility lists curr ent treatment processes as headworks with screening and degritting, primary clarification, anoxic select or activated sludge secondary treatment and clarification, efflue nt filtration, and ultraviolet disi nfection. Treated wastewater is discharged to either the Pudding River (outfall 001) or a poplar tree pl antation (outfall 002). Sludge is anaerobically digested, stored in facultative sludge lagoons, and land applied on the poplar plantation.

Effluent Data and Limits

Exhibit A-68 summarizes monitoring data from June 2003 to March 2006 for those pollutants of concern for which effluent data ar e available. The facility does not have effluent limits for any toxic pollutants.

Exhibit A-68. Effluent Data Summary, Woodburn WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 2 2 0.5 - - - 1,1,2-Trichloroethane 4 4 0.5 - - - 1,1-Dichloroethylene 2 2 0.5 - - - 1,2,4-Trichlorobenzene 2 2 6.3 - - - 1,2-Dichlorobenzene 4 4 6.3 - - - 1,2-Dichloroethane 2 2 0.5 - - - 1,2-Dichloropropane 2 2 0.5 - - - 1,2-Diphenylhydrazine 2 2 6.3 - - - 1,3-Dichlorobenzene 4 4 6.3 - - - 1,4-Dichlorobenzene 4 4 6.3 - - - 2,4,6-Trichlorophenol 2 2 4.4 - - - 2,4-Dichlorophenol 2 2 4.4 - - - 2,4-Dimethylphenol 2 2 4.4 - - - 2,4-Dinitrophenol 2 2 4.4 - - - 2,4-Dinitrotoluene 2 2 12.6 - - -

June 2008 Appendix A. Facility Analyses A-92June 2008 Appendix A. Facility Analyses A-93 

### Exhibit A-68. Effluent Data Summary, Woodburn WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2-Chloronaphthalene 2 2 6.3 - - - 2-Chlorophenol 2 2 4.4 - - - 3,3'-Dichlorobenzidine 2 2 12.6 - - - 4,4'-DDD 2 2 20 - - - 4,4'-DDE 2 2 10 - - - 4,4'-DDT 2 2 20 - - - Acenaphthene 2 2 6.3 - - - Acrolein 2 2 100 - - - Acrylonitrile 2 2 10 - - - Aldrin 2 2 10 - - - Alpha-BHC 2 2 5 - - - Anthracene 2 2 6.3 - - - Antimony 2 2 200 - - - Arsenic 8 1 10 6.78 4.12 2.82 Benzene 2 2 0.5 - - - Benzidine 2 2 7.4 - - - Benzo(a) Anthracene 2 2 6.3 - - - Benzo(a) Pyrene 2 2 6.3 - - - Benzo(b) Fluoranthene 2 2 6.3 - - - Benzo(k) Fluoranthene 2 2 6.3 - - - Beryllium 2 2 10 - - - Beta-BHC 2 2 10 - - - Bis(2-Chloroethyl) Ether 2 2 6.3 - - - Bis(2-Chloroisopropyl) Ether 2 2 6.3 - - - Bis(2-Ethylhexyl) Phthalate 2 0 0 17.9 17.9 17.9 Bromoform 2 2 0.5 - - - Butylbenzyl Phthalate 2 2 6.3 - - - Carbon Tetrachloride 2 2 0.5 - - - Chlordane 2 2 10 - - - Chlorobenzene 2 2 0.5 - - - Chlorodibromomethane 2 2 0.5 - - - Chloroform 2 2 0.5 - - - Chrysene 2 2 6.3 - - - Dibenzo(a,h)Anthracene 2 2 6.3 - - - Dieldrin 2 2 10 - - - Diethyl Phthalate 2 2 6.3 - - - Dimethyl Phthalate 2 2 6.3 - - - Di-N-Butyl Phthalate 2 2 6.3 - - - Endosulfan Sulfate 2 2 20 - - - Endrin 2 2 10 - - - Endrin Aldehyde 2 2 25 - - - Ethylbenzene 2 2 0.5 - - - Fluoranthene 2 2 6.3 - - - Fluorene 2 2 6.3 - - -

### Exhibit A-68. Effluent Data Summary, Woodburn WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean
Gamma-BHC 2 2 4.4 - - - Heptachlor 2 2 10 - - - Heptachlor Epoxide 2 2 10 - - - Hexachlorobenzene 2 2 6.3 - - - Hexachlorobutadiene 2 2 6.3 - - - Hexachlorocyclopentadiene 2 2 31.5 - - - Hexachloroethane 2 2 6.3 - - - Ideno(1,2,3-cd)Pyrene 2 2 6.3 - - - Isophorone 2 2 6.3 - - - Mercury 3 2 2 0.01 - - - Methyl Bromide 2 2 0.5 - - - Methylene Chloride 2 2 0.5 - - - Nickel 5 0 0 0.89 0.21 0.026 Nitrobenzene 2 2 6.3 - - - N-Nitrosodimethylamine 2 2 6.3 - - - N-Nitrosodi-n-Propylamine 2 2 6.3 - - - N-Nitrosodiphenylamine 2 2 6.3 - - - PCBs 4 2 2 0.25 - - - Pentachlorophenol 2 2 22 - - - Phenol 2 2 4.4 - - - Pyrene 2 2 6.3 - - - Selenium 5 3 100 0.43 0.39 0.36 Tetrachloroethylene 2 2 0.5 - - - Thallium 2 2 200 - - - Toluene 2 2 0.5 - - - Toxaphene 2 2 200 - - - Trichloroethylene 2 2 0.5 - - - Vinyl Chloride 2 2 0.5 - - - QL = Quantification limit. 1. Represents effluent data from February 1999 to March 2006. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents data analyzed using Method 1631 only because the fa cility’s current permit requires special monitoring of mercury using clean analytical methods. 4. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

Exhibit A-69 summarizes data for the Pudding River a bove the mixing zone from April 2005 to April 2006 for those pollutants of concern for which ambient data are available.

Exhibit A-69. Ambient Data Summary, City of Woodburn WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean

June 2008 Appendix A. Facility Analyses A-94

### Exhibit A-69. Ambient Data Summary, City of Woodburn WWTP 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean
Arsenic 2 0 - 0.46 0.14 0.042 Mercury 3 0 - 0.00196 0.0017 0.00139 Nickel 2 0 - 0.34 0.11 0.036 Selenium 2 2 0.6 - - - QL = Quantification limit. 1. Represents ambient data from April 2005 to April 2006.



### Potential Impacts

Baseline (Revised) Criteria



### Exhibit A-70 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Pudding River is a freshwater rive r; thus, human health criteria for consumption of organisms and water are applicable. Based on the chronic mixing zone factors in the facility’s existing permit, the dilution factor is 1.2. The Pudding Ri ver at river mile 21.4 is on the state’s 303(d) list for DDT; thus the facility would not receive dilution for this pollutant.

Exhibit A-70. RPA for Baseline Criteria, Woodburn WWTP

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L)
Arsenic 7.82 0.14 7.82 0.0022 Yes Yes Bis(2-Ethylhexyl) Phthalate 67.9 0.0 42.5 1.2 Nickel 2.07 0.11 1.33 13.4 No Selenium 1.0 0.0 0.63 10 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on chronic mixing zone factor in facility’s existing permit (factor = 1.2).



### As shown in the exhibit, the facility has RP to exceed the baseline criter ia for arsenic and bis(2- ethylhexyl) phthalate becau se the concentrations at the edge of the regulatory mixing zone are greater than the applicable existing human health criteria.

Arsenic

Although ambient concentrations ar e greater than the criterion, the Pudding River is not on the state’s 303(d) list as impaired fo r arsenic. Regardless, the faci lity would be discharging above allowable levels and would be re quired to reduce di scharge concentrations to background (if ambient concentrations are determined to repr esent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL).

June 2008 Appendix A. Facility Analyses A-95

### Arsenic and arsenic-containing chemicals are not used in wastewater treatment. The City’s drinking water comes from six groundwater we lls. The 2005 drinking water quality report indicates that arsenic concentrations in dri nking water range from 5 μg/L to 12 μg/L (Woodburn Public Works, 2005). Use of this groundwater enters the sanitary sewer system and becomes influent water to the wastewater treatment plant. Because the source of ar senic to the wastewater treatment facility is likely the City’s drinking water, the facility would likely pursue intake credits or a variance. There w ould be no compliance costs associated with an intake credit scenario. The one-time cost a ssociated with pursuing a vari ance could range from $35,000 to $100,000, with minimal costs associated with renewal.

Bis(2-Ethylhexyl) Phthalate

Under existing procedures, the applicable AMEL is 1.9 μg/L and the MDEL is 3.8 μg/L. Bis-(2- ethylhexyl) phthalate is found main ly in plastics and is used as a plasticizer for polyvinylchloride (PVC) and other polymers. The plasticizer can be released fro m plastics manufacturing wastes or through release from plastic goods (Envir onment Canada, 1994). The facility’s permit indicates that it has one categoric al industrial user and 3 signifi cant industrial users, the exact types of which are not specified. If additional testing indicates that bis(2-ethylhexyl) phthalate is the result of indirect i ndustrial dischargers the facility w ould need to impose more stringent pretreatment limits or implement source controls to prevent bis(2-ethyl hexyl) phthalate from entering the treatment plant.

High levels of bis(2-ethylhexyl ) phthalate in municipal wastew ater effluent can also be associated with sampling and/or laboratory anal ysis conditions (Fairfie ld-Suisun SD, 2003). If this is the case, cleaner sampling and analys is techniques could reduce the amount of bis(2- ethylhexyl) phthalate measur ed in the effluent.

Therefore, costs for the facility could be mini mal if cleaner sampling techniques result in lower effluent concentrations to approximately $50,000 for a source control program that targets indirect industrial dischargers of bis(2-ethylhexyl) phthalate.

Mercury

Under the baseline Willamette River Basin merc ury TMDL, the facility would be required to develop and implement a mercury reduction strate gy. Thus, even though all effluent values are nondetect and there is no RP, the facility would still incur P2 program costs under the baseline. Annual P2 program costs for a 3.3 mgd munici pal facility may be approximately $100,000 (see Appendix B for details). As desc ribed in Appendix B, P2 costs also potentially include costs for indirect dischargers to implement controls (see Exhibit B-2). Based on information on the discharger’s servic e area, incremental indirect discharger costs may be minimal (e.g., there are no universities in the service area). Howe ver, because ODEQ does not assign individual wasteload allocations to point s ource dischargers in the TMDL (point sources as a whole are required to reduce existing load by 26%), it is un certain whether the facility would incur costs beyond those for a P2 program to meet the wast eload allocation under the baseline TMDL.

June 2008 Appendix A. Facility Analyses A-96

### Revised Criteria



### Exhibit A-71 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-71. RPA for Revised Criteria, Woodburn WWTP Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd
Arsenic 7.82 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
0.49* 0.30* 0.20* 0.095* 0.061* Bis(2-Ethylhexyl) Phthalate 42.5 Nickel 1.33 280 190 140 69.0 45.0 Selenium 0.63 150 140 120 91.0 70.0 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on chronic mixing zone factor in facility’s existing permit (factor = 1.2).



### As shown in the exhibit, the discharger could ha ve RP for arsenic and bis(2-ethylhexyl) phthalate based on the alternative fish consumption rates.

Arsenic

The discharger would have RP for arsenic at a ll fish consumption rates. Thus, because the ambient concentration is greater than the criteria, the discharger would need to reduce discharge concentrations to background (if ODEQ determines that ambient concentrations represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with revised standards. Howeve r, under the baseline, the discharge would need to meet those same levels. Thus, incremental compliance costs are unlikely.

Bis(2-ethylhexyl) Phthalate

The discharger would have RP for bis(2-ethylhe xyl) phthalate at all fish consumption rates. Exhibit A-72 shows the projected effluent limits for these consumption rates.

Exhibit A-72. Projected Effluent Limits for Bis(2-ethylhexyl) Phthalate, Woodburn WWTP Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.78 0.48 0.32 0.15 0.098 MDEL ( μ g/L) 1.6 0.96 0.64 0.30 0.20



### Based on existing effluent data, th e discharger would need to re duce effluent bi s(2-ethylhexyl) phthalate concentrations for compliance with th e projected limits shown in the exhibit. The current approved QL for bis(2-ethy lhexyl) phthalate is 1 μg/L. Therefore, the discharger would only have to reduce concentrati ons to below the QL for complia nce with the projected limits; controls for these consumption rates would not differ.

June 2008 Appendix A. Facility Analyses A-97

### As described in the baseline anal ysis, the discharger would either switch to cleaner sampling techniques or implement a P2 program for compli ance with baseline limits. The baseline P2 program includes source identification and im plementation of control measures for those sources. It is uncertain the magnitude of re ductions achievable through a P2 program because the specific sources have not yet been identi fied. However, given that bis(2-ethylhexyl) phthalate is widespread throughout a municipal collection system, the City would likely target any controllable source as part of compliance with baseline sta ndards, and that those actions would also result in compliance with the revised cr iteria (i.e., effluent levels below the QL). Thus, incremental compliance costs are unlikely.

Summary



### Exhibit A-73 provides a summary of the incremental impacts associated with the revised criteria in comparison to the impacts associated with ba seline criteria. For each fish consumption rate the incremental impacts represent the controls and costs above and beyond those needed for compliance with baseline criteria. Under a vari ance scenario for arsenic, one-time expenditures could range from $35,000 to $100,000.

Exhibit A-73. Summary of Potential Costs, Woodburn WWTP

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits or a variance (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] Baseline $100,000 - $150,000 NA

• P2 program (mercury)

• Intake credits or a variance (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 63.2 gpd $100,000 - $150,000 $0

• P2 program (mercury)

• Intake credits or a variance (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 113 gpd $100,000 - $150,000 $0

• P2 program (mercury)

• Intake credits or a variance (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 175 gpd $100,000 - $150,000 $0

• P2 program (mercury)

• Intake credits or a variance (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 389 gpd $100,000 - $150,000 $0

• P2 program (mercury)

• Intake credits or a variance (arsenic)

• Cleaner sampling or P2 program [bis(2-ethylhexyl)

phthalate] 620 gpd $100,000 - $150,000 $0

• P2 program (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-98

### City of Shady Cove Wast ewater Treatment Plant

Facility Description

The City of Shady Grove Wastewater Trea tment Plant (NPDES permit number OR0030660) treats wastewater generated from homes and busin esses in the City of Shady Cove. Two homes outside the city limits ar e also connected to the collection system because of failed septic systems. The plant opened in 1980 and is located on the west bank of the Rogu e River about 1.5 miles southwest of town. Classified by ODEQ as a minor municipal, the ADWDF is 0.45 mgd. Treated wastewater flows through a 6-inch Parshall flume and is di scharged through Outfall 001 to the Rogue River year-round at rive r mile 143.1. Outfal l 002 is for emergency overflows to be discharged into the Rogue River.

Treatment Processes

The 2002 NPDES permit for the facility lists cu rrent treatment processes as preliminary screening, two aeration basins, tw o secondary clarifiers, two sand filters, and a chlorine contact chamber for disinfection. Wast e secondary sludge is pumped to the aerobic digesters with surface aeration. After digestion, sludge is de watered by a vertical screw thickener. The thickened sludge is discharged to a paved and covered drying bed.

Effluent Data and Limits

There are no effluent data available for the pollutants of concern because minor facilities are not currently required to monitor for t oxic pollutants. Also, the facility does not have effluent limits for any toxic pollutants in its current permit.

Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

The facility discharges less than 0.5 mgd of treated effluent to the Rogue River. The dilution factor at the edge of the mixing zone is 161.4 to 1 during critical low flow conditions for aquatic life; human health dilution factors are likely to be of similar magnitude. Thus, given such a large dilution factor and the fact that by definition minor facilities do not discha rge toxic pollutants in toxic amounts, it is unlikely that the facility woul d have RP to cause or contribute to exceedances of the baseline criteria or the revised criteria ba sed on alternative fish cons umption rates. It is also unlikely that ODEQ would require toxic po llutant monitoring as a result of the revised criteria.

June 2008 Appendix A. Facility Analyses A-99

### Blue Heron Paper Company, Oregon City

Facility Description

The Blue Heron Paper Company is a paper mill located along the east bank of the Willamette River in Oregon City, Oregon (NPDES permit number OR0000566). The facility manufactures newsprint and other similar types of papers from a mixture of recycled newspapers and magazines, wood chips, and purchased pulp. ODEQ classifies the facility as a major discharger. Wastewater from the facility is generated in fi ve primary areas: the paper machine process, the deinking process, filter plant backwash, the steam plant, and the bleach plant. Wastewater from the process, steam plant, and bleach plant, al ong with any storm water runoff is treated and discharged through outfall 001. Wastewater from the filter plant is discharged through outfall 002. Outfalls 003, 004, and 005 are rarely used and handle only small discharges of miscellaneous wastewater. The facility’s permit i ndicates that total flows from the facility total 9.7 mgd.

Treatment Processes

The 2006 NPDES permit for the facility indicates that the process wastewater is sent to a primary clarifier for primary sedimentation. The primar y clarifier solids are dewatered and used as bedding for dairy cattle or land appl ied. Effluent from the primary cl arifier is sent to an aerated stabilization basin before being di scharged to the Willamette River.

Effluent Data and Limits

Exhibit A-74 summarizes monitoring data from May of 2004 for those pollutants of concern for which effluent data are available. The facili ty does not have effluent limits for any toxic pollutants.

Exhibit A-74. Effluent Data Su mmary, Blue Heron Paper Company 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 1 1 2 - - - 1,1,2-Trichloroethane 1 1 2 - - - 1,1-Dichloroethylene 1 1 2 - - - 1,2-Dichlorobenzene 1 1 2 - - - 1,2-Dichloropropane 1 1 2 - - - 1,2-Diphenylhydrazine 1 1 9.62 - - - 1,2-Trans-Dichloroethylene 1 1 2 - - - 1,3-Dichlorobenzene 1 1 2 - - - 1,4-Dichlorobenzene 1 1 2 - - - 2,3,7,8-TCDD (Dioxin) 1 1 9.5E-06 - - - 2,4-Dichlorophenol 1 1 9.62 - - - 2,4-Dimethylphenol 1 1 19.2 - - - 2,4-Dinitrophenol 1 1 48.1 - - - 2,4-Dinitrotoluene 1 1 9.62 - - -

June 2008 Appendix A. Facility Analyses A-100June 2008 Appendix A. Facility Analyses A-101 

### Exhibit A-74. Effluent Data Su mmary, Blue Heron Paper Company 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2-Chloronaphthalene 1 1 9.62 - - - 2-Chlorophenol 1 1 9.62 - - - 2-Methyl-4,6-Dinitrophenol 1 1 19.2 - - - 3,3'-Dichlorobenzidine 1 1 9.62 - - - 4,4'-DDD 1 1 0.1 - - - 4,4'-DDE 1 1 0.1 - - - 4,4'-DDT 1 1 0.5 - - - Acenaphthene 1 1 9.62 - - - Aldrin 1 1 0.1 - - - alpha-BHC 1 1 0.1 - - - Anthracene 1 1 9.62 - - - Antimony 1 1 1 - - - Arsenic 1 1 1 - - - Benzene 1 1 2 - - - Benzidine 1 1 115 - - - Benzo(a) Anthracene 1 1 9.62 - - - Benzo(a) Pyrene 1 1 9.62 - - - Benzo(b) Fluoranthene 1 1 9.62 - - - Benzo(k) Fluoranthene 1 1 9.62 - - - Beryllium 1 1 1 - - - beta-BHC 1 1 0.1 - - - Bis(2-Chloroethyl) Ether 1 1 9.62 - - - Bis(2-Chloroisopropyl) Ether 1 1 19.2 - - - Bis(2-Ethylhexyl) Phthalate 1 1 19.2 - - - Bromoform 1 1 2 - - - Carbon Tetrachloride 1 1 2 - - - Chlorobenzene 1 1 2 - - - Chloroform 1 1 2 - - - Chrysene 1 1 9.62 - - - Dibenzo(a,h)Anthracene 1 1 9.62 - - - Dichlorobromomethane 1 1 2 - - - Dieldrin 1 1 0.1 - - - Diethyl Phthalate 1 1 9.62 - - - Dimethyl Phthalate 1 1 9.62 - - - Di-n-Butyl Phthalate 1 1 9.62 - - - Endosulfan Sulfate 1 1 0.1 - - - Endrin 1 1 0.1 - - - Endrin Aldehyde 1 1 0.1 - - - Ethylbenzene 1 1 2 - - - Fluoranthene 1 1 9.62 - - - Fluorene 1 1 9.62 - - - Gamma-BHC 1 1 0.1 - - - Heptachlor 1 1 0.1 - - - Heptachlor Epoxide 1 1 0.1 - - -

### Exhibit A-74. Effluent Data Su mmary, Blue Heron Paper Company 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean
Hexachlorobenzene 1 1 9.62 - - - Hexachlorobutadiene 1 1 19.2 - - - Hexachlorocyclopentadiene 1 1 19.2 - - - Hexachloroethane 1 1 19.2 - - - Ideno(1,2,3-cd)Pyrene 1 1 9.62 - - - Isophorone 1 1 9.62 - - - Mercury 4 0 - 0.20 0.017 0.0013 Methylene Chloride 1 1 5 - - - Nitrobenzene 1 1 9.62 - - - N-Nitrosodimethylamine 1 1 9.62 - - - N-Nitrosodi-n-Propylamine 1 1 19.2 - - - N-Nitrosodiphenylamine 1 1 9.62 - - - PCBs 3 1 1 0.5 - - - Pentachlorophenol 1 1 19.2 - - - Phenol 1 1 9.62 - - - Pyrene 1 1 9.62 - - - Tetrachloroethylene 1 1 2 - - - Toluene 1 1 2 - - - Toxaphene 1 1 5 - - - Trichloroethylene 1 1 2 - - - Vinyl Chloride 1 1 2 - - - QL = Quantification limit. 1. Represents effluent data from May 2004. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

Baseline Criteria



### Exhibit A-75 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Willamette River is a freshwater river; thus, huma n health criteria for consumption of organisms and water are applicable. The Willamette River at river mile 27 (near the discharge) is on the state’s 303(d) list as impaired for 4,4’-DDT, 4,4’-DDE, dieldr in, dioxin, mercury, and PCBs; thus, the facility would not rece ive dilution for these pollutants.

June 2008 Appendix A. Facility Analyses A-102

### Exhibit A-75. RPA for Baseline Criteria, Blue Heron Paper Company

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) Mercury 0.52 0 0.52 0.017 Yes 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. The facility’ does not receive dilution for mercury because the river is already impaired.



### As shown in the exhibit, the facility has RP to exceed the baseline crit erion for mercury because the concentration at the edge of the regulatory mi xing zone is greater than the applicable existing human health criterion.

Under existing conditions, the AMEL is 0.017 μg /L and the MDEL is 0.034 μg/L (i.e., based on criterion end-of-pipe because the water body is imp aired). The maximum effluent concentration at the facility is 0.20 μg/L, which is greater than the projected limits. Thus, the discharger may need to implement controls to reduce effluent mercury concentrations for compliance with these limits. A mercury P2 program would enable the di scharger to identify the sources of mercury and determine the most cost-effective measures for reducing mercury from those sources. In addition, under the baseline Willamette River Basin mercury TMDL, the facility would be required to develop and implement a mercury reduction strategy. However, because ODEQ does not assign individual wasteload a llocations to point source disc hargers in the TMDL (point sources as a whole are required to reduce exis ting load by 26%), it is uncertain whether the facility would incur costs beyond those for a P2 program to meet the wasteload allocation under the baseline TMDL.

Annual P2 program costs for an industrial faci lity may be approximate ly $25,000 (see Appendix B for details).

Revised Criteria



### Exhibit A-76 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-76. RPA for Revised Criteria, Blue Heron Paper Company Human Health Criteria (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd
0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.52 *Bolded values represent RP equal to “Yes.” 1. Dilution based on values used in the facility’s dra ft 2007 permit for human health pollutants (carcinogen factor = 143; noncarcinogens factor = 72). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger would ha ve RP for mercury at all consumption rates. Exhibit A-77 shows the AMELs and MDELs for each cons umption rate. Note that because the

June 2008 Appendix A. Facility Analyses A-103

### Willamette River is on the 303(d) list for mercury, the discharger would receive effluent limits based on criteria end-of-pipe.

Exhibit A-77. Projected Effluent Limits for Mercury, Blue Heron Paper Company Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Average Monthly Limit ( μ g/L) 0.0047 0.0026 0.0017 0.00076 0.00048 Maximum Daily Limit ( μ g/L) 0.0094 0.0052 0.0034 0.0015 0.00096



### The maximum effluent concentration is greater th an all of the AMELs and MDELs. The facility is already required to implem ent a mercury P2 program under the baseline as part of the Willamette Basin mercury TMDL. It is not clea r how ODEQ would adapt the baseline TMDL to attain the revised crit eria (e.g., increase point source load reduction requirements; establish individual effluent limits). Thus, it is uncertain whether c ontinued implementation of the baseline P2 program would be sufficient for compliance with th e revised criteria/TMDL because there could be some maximum level of effort beyond which a P2 program would not provide additional reductions.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consis tent basis, dischargers may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied) under mo re stringent TMDL requirements (alternatively, ODEQ may account for this situation in allocating loads under the TMDL). However, it is uncertain at which fish consumption rate the discharger would need a variance. One-time costs associated with pursuing a variance coul d range from $35,000 to $100,000. As part of a variance ODEQ, could require specific P2 program efforts. For dischargers covered under the Willamette River TMDL for mercury, these activities may already be included in their baseline mercury P2 requirement.

Summary



### Exhibit A-78 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline criteria. Under a variance scenario for mercur y under the alternative fish consumption rates, incremental costs could include a one-time expenditure of $35,000 to $100,000.

Exhibit A-78. Summary of Potential Costs, Blue Heron Paper Company

Alternative Compliance Scenario Total Annual Incremental Costs Annual Costs 1 Baseline • P2 program (mercury) $25,000 NA 63.2 gpd • P2 program, possible variance (mercury) $25,000 $0 113 gpd • P2 program, possible variance (mercury) $25,000 $0 175 gpd • P2 program, possible variance (mercury) $25,000 $0 389 gpd • P2 program, possible variance (mercury) $25,000 $0 620 gpd • P2 program, possible variance (mercury) $25,000 $0

June 2008 Appendix A. Facility Analyses A-104

### Exhibit A-78. Summary of Potential Costs, Blue Heron Paper Company

Alternative Compliance Scenario Total Annual Incremental Costs Annual Costs 1 NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-105

### Heinz Food Company

Facility Description

The Heinz Food Company (NPDES number OR 0002402) is located in Ontario, Oregon, and processes raw vegetables into frozen products. The facility primarily processes potatoes into consumer products including french fries, batter fries, Tater Tots, and hash browns. In a single day, the facility washes, sorts, peels, blanches, and cuts about 3.5 million pounds of raw potatoes, which are then furthe r processed into frozen products . Depending on the product, the potato may also be dried, battered, and fried. Finished products are bagged, cased, and transferred to an adjacent cold storage ware house. The facility generates about 3.4 mgd of wastewater primarily from wet processes that was h, sort, blanch, cut, and transfer potatoes and during clean-up and equipment sanitation. Wastewater is discharged to th e Snake River at river mile 371.

Treatment Processes

The 2003 permit for the facility indicates that befo re discharge to the wastewater system, potato wash water is routed through settling basins to remove silt, and raw st arch is separated and recovered from potato white water (pump and cutti ng water). The wastewater treatment system consists of headworks, primary clarificati on, activated sludge, and sludge dewatering. The facility employs extensive recyc ling/reuse of water for conserva tion and to minimize the quantity of wastewater that must be discharged; recycl ed water is treated by a sand filter and sodium hypochlorite disinfection.

Effluent Data and Limits

There are no data available for this facility; ODEQ has not required the facility to conduct a priority pollutant scan.

Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

The 2003 permit evaluation indicates that, with th e exception of chlorine and ammonia, toxic substances in amounts which may be harmful to aquatic life are either not present in the discharge or are present in small quantities that are within water quality standards. Thus, given this finding and the fact that ODEQ does not re quire the facility to monitor for priority pollutants, it is unlikely that the discharger would incur costs for compliance with baseline or revised criteria.

June 2008 Appendix A. Facility Analyses A-106

### Pope and Talbot Inc, Hasley

Facility Description

The Pope and Talbot, Hasley Mill (NPDES pe rmit number OR0001074) is an integrated Kraft process pulp mill located in Hasley, Oregon. The facility produces bleached and unbleached pulp from Douglas fir wood chips. The plant consis ts of a pulp mill, chlorine dioxide generator, power and recovery, recausticizi ng process, water treatment, and wastewater treatment. ODEQ classifies the facility as a major discharger. E ffluent from the facility is discharged into the Willamette River at river mile 147.7. Effluent flow data from EPA’s PCS database indicate that average monthly flow from the facility is 10.3 mgd.

Treatment Processes

The draft 2007 NPDES permit for the facility indi cates that the wastewat er generated during the pulp production process is treated by primary clar ification followed by biological treatment in two large aerated stabilization basi ns (ASB). The clarifier has a diameter of 200 feet and can hold approximately 2.8 million gallons. Solids from the primary clarifier are beneficially applied to nearby agricultural fields. The two aeration ba sins are operated in series and each has a capacity of 113 million gallons and a detention ti me of about 10 days. Following the aeration basins, the treated effluent is se nt to a secondary sett ling pond with a size of 150 square feet.

Effluent Data and Limits

Exhibit A-79 summarizes monitoring data for those pollu tants of concern for which effluent data are available (the sampling date for the data is unknown). The facility has load-based limits for dioxin of 0.3 mg/day as an annual average and 0.41 mg/day as a 3-day maximum in its draft 2007 permit.

Exhibit A-79. Effluent Data Summary, Pope and Talbot, Hasley 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 1 1 5 - - - 1,1,2-Trichloroethane 1 1 5 - - - 1,1-Dichloroethylene 1 1 5 - - - 1,2,4-Trichlorobenzene 1 1 9.5 - - - 1,2-Dichlorobenzene 1 1 9.5 - - - 1,2-Dichloropropane 1 1 5 - - - 1,2-Trans-Dichloroethylene 1 1 5 - - - 1,3-Dichlorobenzene 1 1 9.5 - - - 1,3-Dichloropropene 1 1 5 - - - 1,4-Dichlorobenzene 1 1 9.5 - - - 2,3,7,8-TCDD (Dioxin) 1 1 0.01 - - - 2,4,6-Trichlorophenol 1 1 9.5 - - - 2,4-Dichlorophenol 1 1 9.5 - - - 2,4-Dimethylphenol 1 1 9.5 - - -

June 2008 Appendix A. Facility Analyses A-107June 2008 Appendix A. Facility Analyses A-108 

### Exhibit A-79. Effluent Data Summary, Pope and Talbot, Hasley 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

2,4-Dinitrophenol 1 1 24 - - - 2-Chloronaphthalene 1 1 9.5 - - - 2-Chlorophenol 1 1 9.5 - - - 3,3'-Dichlorobenzidine 1 1 24 - - - 4,4'-DDD 1 1 0.048 - - - 4,4'-DDE 1 1 0.048 - - - 4,4'-DDT 1 1 0.059 - - - Acenaphthene 1 1 9.5 - - - Acrolein 1 1 50 - - - Aldrin 1 1 0.048 - - - alpha-BHC 1 1 0.048 - - - Anthracene 2 2 9.5 - - - Antimony 1 0 0 0.51 0.51 0.51 Arsenic 1 0 0 1.8 1.8 1.8 Benzene 1 1 5 - - - Benzidine 1 1 48 - - - Benzo(a) Anthracene 1 1 9.5 - - - Benzo(a) Pyrene 1 1 9.5 - - - Beryllium 1 1 0.02 - - - beta-BHC 1 1 0.048 - - - Bis(2-Chloroethyl) Ether 1 1 9.5 - - - Bis(2-Chloroisopropyl) Ether 1 1 9.5 - - - Bis(2-Ethylhexyl) Phthalate 1 1 9.5 - - - Bromoform 1 1 5 - - - Carbon Tetrachloride 1 1 5 - - - Chlordane 1 1 0.96 - - - Chlorobenzene 1 1 5 - - - Chlorodibromomethane 1 1 5 - - - Chloroform 1 1 5 - - - Chrysene 1 1 9.5 - - - Dichlorobromomethane 1 1 5 - - - Dieldrin 1 1 0.048 - - - Diethyl Phthalate 1 1 9.5 - - - Dimethyl Phthalate 1 1 9.5 - - - Di-n-Butyl Phthalate 1 1 9.5 - - - Endrin 1 1 0.048 - - - Endrin Aldehyde 1 1 0.048 - - - Ethylbenzene 1 1 5 - - - Fluoranthene 2 2 9.5 - - - Fluorene 1 1 9.5 - - - Gamma-BHC 1 1 0.048 - - - Heptachlor 1 1 0.084 - - - Hexachlorobenzene 1 1 9.5 - - - Hexachlorobutadiene 1 1 9.5 - - -

### Exhibit A-79. Effluent Data Summary, Pope and Talbot, Hasley 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean Hexachlorocyclopentadiene 1 1 9.5 - - - Hexachloroethane 1 1 9.5 - - - Ideno(1,2,3-cd)Pyrene 1 1 9.5 - - - Isophorone 1 1 9.5 - - - Mercury 1 0 0 0.0073 0.0073 0.0073 Methyl Bromide 1 1 5 - - - Methylene Chloride 1 1 5 - - - Nickel 1 0 0 7.8 7.8 7.8 Nitrobenzene 1 1 9.5 - - - N-Nitrosodi-n-Propylamine 1 1 9.5 - - - N-Nitrosodiphenylamine 1 1 9.5 - - - PCBs 3 1 1 0.096 - - - Pentachlorophenol 1 1 24 - - - Phenol 1 1 9.5 - - - Pyrene 1 1 9.5 - - - Selenium 1 1 1 - - - Tetrachloroethylene 1 1 5 - - - Thallium 1 1 0.02 - - - Toluene 1 1 5 - - - Toxaphene 1 1 2.4 - - - Trichloroethylene 1 1 5 - - - Vinyl Chloride 2 2 10 - - - QL = Quantification limit. 1. Represents effluent data for the facility (sampling date for data is unknown). 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs. 3. Represents the lowest QL for the 7 congeners sampled (Aro clor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248, Aroclor 1254, and Aroclor 1260).



### Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

Baseline Criteria



### Exhibit A-80 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Willamette River is a freshwater river; thus, huma n health criteria for consumption of organisms and water are applicable. The dilution factors are based on values provided in the facility’s draft 2007 permit for human health pollutants. The Willamette River at river mile 147.7 is on the state’s 303(d) list as impaired for dioxin and mercury; thus, th e facility would not receive dilution for these pollutants.

June 2008 Appendix A. Facility Analyses A-109

### Exhibit A-80. RPA for Baseline Criteria, Pope and Talbot, Hasley

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) Antimony 3.16 0 0.044 5.6 No Arsenic 11.2 0 0.078 0.0022 Yes Mercury 0.045 0 0.045 0.017 Yes Nickel 48.3 0 0.67 13.4 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on values used in the facility’s dra ft 2007 permit for human health pollutants (carcinogen factor = 143; noncarcinogens factor = 72).



### As shown in the exhibit, the facility has RP to exceed the baseline criterion for arsenic and mercury because the concentrations at the edge of the regulatory mixing zone are greater than the applicable existing human health criteria.

Arsenic

The facility’s draft 2007 permit indicates that ODEQ does not consider it to be a significant contributor of arseni c according to ODEQ (2005) criteria, and the draft permit only requires additional arsenic testing using ul tra clean methods to obtain lowe r detection limits. Thus, it is possible that the facility w ould not incur costs associated with baseline criteria.

However, if the draft permit does not represent act ual baseline (final pe rmit) requirements, the facility may be required to reduce discharge conc entrations to projecte d effluent limits of 0.31 μg/L (AMEL) and 0.63 μg/L (MDEL). As menti oned above, the facility produces bleached and unbleached pulp from Douglas fir wood chips and does not use arsenic and arsenic-containing chemicals in the manufacturing process. Thus, th e arsenic in the facility’s effluent may be coming from an external source such as drinking water.

The facility operates a drinking water treatment plant that draws water from the Willamette River. Most arsenic samples (organic plus in organic) from the surface waters since 1980 are nondetect below the minimum reporting levels; th ere was 1 detected value of 6 μg/L in 1983 (ODHS, 2007h). The minimum reporting levels are not specified, and the drinking water maximum contaminant level is 10 μg/L, which is higher than current wastewater effluent concentrations and human health criteria. Alt hough it is not possible to determine from these data with any certainty whethe r drinking water is contributing to high arsenic levels in the wastewater effluent, dr inking water is a potential source. There would be no compliance costs associated with an intake credit scenario. The one-time cost associated with pursuing a variance could range from $35,000 to $100,000, with minima l costs associated with renewal.

June 2008 Appendix A. Facility Analyses A-110

### Mercury

Under existing conditions, the AMEL is 0.017 μg /L and the MDEL is 0.034 μg/L (i.e., based on criterion end-of-pipe because the water body is imp aired). The maximum effluent concentration at the facility is 0.0073 μg/L, which is less than the projected limits.

Under the baseline Willamette River Basin merc ury TMDL, the facility would be required to develop and implement a mercury reduction strate gy. Annual P2 program costs for an industrial facility may be approximately $25,000 (see Appe ndix B for details). However, because ODEQ does not assign individual wasteloa d allocations to point source di schargers in the TMDL (point sources as a whole are required to reduce exis ting load by 26%), it is uncertain whether the facility would incur costs beyond those for a P2 program to meet the wasteload allocation under the baseline TMDL.

Revised Criteria



### Exhibit A-81 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-81. RPA for Revised Criteria, Pope and Talbot, Hasley Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Antimony 0.044 5.40 5.30 5.10 4.70 4.30 Arsenic 0.078 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
0.0047* 0.0026* 0.0017* 0.00076* 0.00048* Mercury 2 0.045 Nickel 0.67 280 190 140 69.0 45.0 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on values used in the facility’s dra ft 2007 permit for human health pollutants (carcinogen factor = 143; noncarcinogens factor = 72). 2. Potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophic level consumption percentages, and water column translator (see Section 4).



### As shown in the exhibit, the discharger coul d have RP for arsenic and mercury based on the alternative fish consumption rates.

Arsenic

The discharger would have RP for arse nic at all fish consumption rates. Exhibit A-82 shows the projected effluent limits for these consumption rates.

Exhibit A-82. Projected Effluent Lim its for Arsenic, Pope and Talbot, Hasley Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 1.2 0.82 0.59 0.30 0.20 MDEL ( μ g/L) 2.4 1.6 1.2 0.60 0.40

June 2008 Appendix A. Facility Analyses A-111

### The maximum effluent concentration is greater than all the projected effluent limits. As described in the baseline analysis , the discharger would likely pursu e a variance or intake credits for compliance because arsenic is likely coming from an external source such as drinking water. The discharger would likely pursue the same acti ons for compliance with the revised criteria. Thus, incremental compliance costs are unlikely.

Mercury

The discharger would have RP for mercury at all consumption rates. Exhibit A-83 shows the AMELs and MDELs for each consumption rate. No te that because the Willamette River is on the 303(d) list for mercury, the di scharger would receive effluent limits based on criteria end-ofpipe.

Exhibit A-83. Projected Effluent Limits for Mercury, Pope and Talbot, Hasley Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd AMEL ( μ g/L) 0.0047 0.0026 0.0017 0.00076 0.00048 MDEL ( μ g/L) 0.0094 0.0052 0.0034 0.0015 0.00096



### The maximum effluent concentration is greater th an all the projected limits. The facility is already required to implement a mercury P2 progr am under the baseline as part of the Willamette Basin mercury TMDL. It is not clear how ODEQ would adapt the baseline TMDL to attain the revised criteria (e.g., increase po int source load reduction requir ements; establish individual effluent limits). Thus, it is uncertain whet her continued implementation of the baseline P2 program would be sufficient for compliance with the revised criteria/TMDL because there could be some maximum level of effort beyond whic h a P2 program would not provide additional reductions.

Because there are no proven end-of-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consis tent basis, dischargers may need to pursue a variance (e.g., based on manmade conditions that cannot be remedied) under mo re stringent TMDL requirements (alternatively, ODEQ may account for this situation in allocating loads under the TMDL). However, it is uncertain at which fish consumption rate the discharger would need a variance. If the discharger pursues a variance for arsenic, these efforts would also cover a variance for mercury. Otherwise, one-time costs a ssociated with pursuing a variance could range from $35,000 to $200,000. As part of a variance ODEQ, could require specific P2 program efforts. For dischargers covered under the Willamette River TMDL for mercury, these activities may already be included in thei r baseline mercury P2 requirement.

Summary



### Exhibit A-84 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline

June 2008 Appendix A. Facility Analyses A-112

### criteria. Under a variance scenario for arseni c and/or mercury, costs could include a one-time expenditure of approximately $35,000 to $200,000.

Exhibit A-84. Summary of Potentia l Costs, Pope and Talbot, Hasley

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1

• Intake credits or variance (arsenic) Baseline $25,000 NA

• P2 program (mercury)

• Intake credits or variance (arsenic) $25,000 $0 63.2 gpd

• P2 program, possible variance (mercury)

• Intake credits or variance (arsenic) $25,000 $0 113 gpd

• P2 program, possible variance (mercury)

• Intake credits or variance (arsenic) $25,000 $0 175 gpd

• P2 program, possible variance (mercury)

• Intake credits or variance (arsenic) $25,000 $0 389 gpd

• P2 program, possible variance (mercury)

• Intake credits or variance (arsenic) $25,000 $0 620 gpd

• P2 program, possible variance (mercury) NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-113

### Reynolds Metals Company, Troutdale

Facility Description

The Reynolds Metals Company owns a facility in Troutdale, Oregon (NPDES permit number OR0000060) that was used for primary alumi num production. The plant was originally constructed in 1941 to produce aluminum for the U.S. government’s wartime operations. The company purchased the plant from the govern ment in 1949 and opera ted it until 2000 when production was suspended. In 2002, the comp any announced that the facility would be permanently closed and dismantled. As a result of past waste handling pract ices at the facility, several waste disposal areas, soil s, and groundwater are contaminat ed. The site is currently on EPA’s Superfund National Priorities List (NPL). The primary contaminants identified in the soils at the site include fl uoride, cyanide, polycyclic ar omatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs). The groundwat er beneath the site contains a significant fluoride plume. Groundwater fr om deep production wells (ave rage flow of 2.37 mgd) and shallow, focused extraction wells (average fl ow of 0.17 mgd) provide the majority of the discharge at Outfall 001. Deep production well water combines with contaminated, focused extraction well flows. Wastewater is discharged into the south ditch of the facility and from there is it discharged directly to the Columbia River at river mile 120.

Treatment Processes

The draft 2007 NPDES permit for the facility in dicates that wastewater comes from pumped groundwater from deep production wells, shallow fo cused extraction wells, and small quantities of treated miscellaneous waste streams (e.g., la boratory sample analysis wastewater, sample basin water, monitoring well purge water, sha llow groundwater and surfa ce water pumped from dewatering activities for construction of subsurface infrastructure during property redevelopment, and occasional draw-down of gr oundwater in Company Lake). The permit does not specify the treatment processes, if any, that are associated with each source of wastewater.

Effluent Data and Limits

Toxicity testing for the draft 2007 permit indicat es that only trace amounts of aluminum and nondetects for PAHs characterize groundwater pu mped from the deep and shallow extraction wells at the facility. The draft permit does no t specify monitoring results for any other toxic pollutants.

Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

The facility’s 2007 fact sheet indicates that all sampling data for PAHs are nondetect for groundwater pumped from the deep and shallow extraction wells. ODEQ’ s analysis indicates

June 2008 Appendix A. Facility Analyses A-114

### that there is no RP to cause acu te or chronic toxicity outside the assigned mixing zone. The 2007 fact sheet also indicates that th e facility does not have RP for a ny of the pollutants for which the Columbia River is impaired: aldrin, DDE, arseni c, and dioxin. Dioxin is typically a contact product of chlorine interacting with biological mate rial, and the facility no longer uses chlorine for disinfection. Aldrin, DDE, a nd arsenic are not associated with groundwater. Thus, ODEQ concludes that based on permitted facility operations , there is no RP for any of these pollutants to be present in the treated groundwater discharged to the Columbia River. Therefore, it is unlikely that the facility would incur costs associated with meeting baseline or revised criteria.

June 2008 Appendix A. Facility Analyses A-115

### Boise Cascade, Elgin

Facility Description

Boise Building Solutions Manu facturing, LLC (BBSM) operate s a stud mill and plywood manufacturing plant in Elgin, Oreg on (NPDES permit number OR00024 11). The facility includes a log storage yard (wet deck), veneer block va ts and peeler, veneer la mination and dryer, saw mill, planer, boiler, lumber drying kilns, and prod uct storage. ODEQ classifies the discharger as a minor industrial. The facility discharges process and nonprocess wast ewaters, tile drain wastewater, and industrial storm water. Process wastewater in cludes veneer block sprinkling return flow, veneer dryer clea nup and deluge water, plywood pre ss pit water (groundwater), kiln waters, filter backflush water, dry electrostati c precipitator (DESP) cleanup water, ash storage area runoff water, heavy equipment wash pa d water, vat waters, and regenerative catalytic/thermal oxidizer (RCO-1) cleanup water. The facility discharges i ndustrial storm water, boiler condensate, and fire system flush water through Outfall 001 and tile drain wastewater (groundwater collected fr om beneath the log yard) through Outfall 003 to Phillips Creek. Outfalls 001 and 003 are approximat ely located at river mile 1 on Phillips Creek.

Treatment Processes

The 2005 NPDES permit for the fa cility indicates that the commingled process and nonprocess wastewater and storm water flow by gravity to the Frog Pond. An emergency gravity overflow/bypass vault and basin is adjacent to the Frog Pond. Fr om the Frog Pond, combined flows are pumped to a 3-acre settling po nd/open water wetland (SP/OWW), which overflows to a 15-acre Process Water Storage Pond (PWSP) . The SP/OWW consists of two cells. Th e first cell is lined with 60-mil high-density polyethylene liner and in cludes an oil skimmer system. The second cell provides additional primary treatme nt. PWSP capacity is approxim ately 51 million gallons. PWSP wastewater is irrigated on land ap plication sites, sprinkled on decked logs or veneer blocks for log quality control, or it is applied to roads an d other unpaved areas for dust suppression.

Effluent Data and Limits

The facility’s permit evaluation report indicate s that tile drain wastewater has elevated concentrations of iron, manganese and zinc, lack s appreciable oxygen and ha s very low turbidity; industrial storm water has elevat ed TSS. However, there are no data available for the toxic pollutants of concern.

Receiving Water Data

There are no upstream ambient data available for this facility.

Potential Impacts

Although there are no data available for the pol lutants of concern, th e draft revised permit indicates that the facility has RP for iron, manganese, and zinc. Instead of establishing WQBELs for which an exceedance would indicate noncomplia nce, the permit contains “benchmarks” that

June 2008 Appendix A. Facility Analyses A-116

### trigger action plans. If a similar approach is us ed for baseline and revised criteria, some level of costs associated with developing action plans could be incurred fo r those pollutants with RP that exceed established benchmarks. However, without effluent data or i ndication of basis for benchmark values, we cannot estimate potential costs.

June 2008 Appendix A. Facility Analyses A-117

### Oregon Steel Mills

Facility Description

Oregon Steel Mills (NPDES number OR0000451) is located in Portland, Oregon and operates a steel plate manufacturing plant. ODEQ classifies the discharger as a minor industrial discharge. The facility manufactures carbon st eel slabs, coils, and plates from recycled scrap metal, raw metals, and additives. Primary facilities at th e site include scrap processing, a steel melt shop that includes slab casting and s carfing, plate rolling, plate coi ling, surface processing, and a cutto-length facility. Support faci lities include those associated w ith maintenance, utilities, oxygen production, wastewater treatment, sl ab storage, and transport of materials and products. The facility operates two central wa stewater treatment systems (me lt shop contact water and plant service water treatment systems). Effluent from these onsite water treatment units is primarily recycled onsite for process manufacturing reus e, however, a portion is discharged to the Willamette River at river mile 2.4. Various onsite waters are discharged to the City of Portland sanitary sewer system: sanitary waters, dilute d laboratory wash water, some process treated water, and oil/water separator effluent.

Treatment Processes

The 2003 permit modification for the facility i ndicates that wastewater from manufacturing activities is directed to a large pond, where it is treated by a bank of sand filters and reused. As water is reused, the dissolved solids level in the wa ter increases, so that periodically, the facility must discharges a portion of the wastewater fr om the pond and add make-up water from the City of Portland public water supply and/ or from the Willamette River.

Effluent Data and Limits

Exhibit A-85 summarizes monitoring data for those pollu tants of concern for which effluent data are available from August 2007. The facility doe s not have effluent limits for any of the pollutants of concern.

Exhibit A-85. Effluent Da ta Summary, Oregon Steel Mills 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Geometric Maximum Minimum Mean 1,1,2,2-Tetrachloroethane 1 1 5 - - - 1,1,2-Trichloroethane 1 1 5 - - - 1,1-Dichloroethylene 1 1 5 - - - 1,2,4-Trichlorobenzene 1 1 9.6 - - - 1,2-Dichlorobenzene 1 1 5 - - - 1,2-Dichloroethane 1 1 5 - - - 1,2-Dichloropropane 1 1 5 - - - 1,2-Diphenylhydrazine 1 1 9.6 - - - 1,2-Trans-Dichloroethylene 1 1 5 - - - 1,3-Dichlorobenzene 1 1 5 - - - 1,3-Dichloropropene 1 1 5 - - -

June 2008 Appendix A. Facility Analyses A-118June 2008 Appendix A. Facility Analyses A-119 

### Exhibit A-85. Effluent Da ta Summary, Oregon Steel Mills 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

1,4-Dichlorobenzene 1 1 5 - - - 2,4,6-Trichlorophenol 1 1 9.6 - - - 2,4-Dichlorophenol 1 1 9.6 - - - 2,4-Dimethylphenol 1 1 9.6 - - - 2,4-Dinitrophenol 1 1 9.6 - - - 2,4-Dinitrotoluene 1 1 24 - - - 2-Chloronaphthalene 1 1 - - - - 2-Chlorophenol 1 1 9.6 - - - 3,3'-Dichlorobenzidine 1 1 24 - - - 4,4'-DDD 1 1 - - - - 4,4'-DDE 1 1 - - - - 4,4'-DDT 1 1 - - - - Acenaphthene 1 1 9.6 - - - Acrolein 1 1 50 - - - Acrylonitrile 1 1 10 - - - Aldrin 1 1 - - - - alpha-BHC 1 1 - - - - Anthracene 1 1 9.6 - - - Antimony 1 0 0.05 2.04 2.04 2.04 Arsenic 1 0 0.5 3.8 3.8 3.8 Benzene 1 1 5 - - - Benzidine 1 1 9.6 - - - Benzo(a) Anthracene 1 1 9.6 - - - Benzo(a) Pyrene 1 1 9.6 - - - Benzo(b) Fluoranthene 1 1 9.6 - - - Benzo(k) Fluoranthene 1 1 9.6 - - - Beryllium 1 1 - - - - beta-BHC 1 1 - - - - Bis(2-Chloroethyl) Ether 1 1 9.6 - - - Bis(2-Chloroisopropyl) Ether 1 1 9.6 - - - Bis(2-Ethylhexyl) Phthalate 1 1 9.6 - - - Bromoform 1 1 5 - - - Butylbenzyl Phthalate 1 1 9.6 - - - Carbon Tetrachloride 1 1 5 - - - Chlordane 1 1 - - - - Chlorobenzene 1 1 - - - - Chlorodibromomethane 1 1 5 - - - Chloroform 1 1 5 - - - Chrysene 1 1 9.6 - - - Dibenzo(a,h)Anthracene 1 1 9.6 - - - Dichlorobromomethane 1 1 5 - - - Dieldrin 1 1 - - - - Diethyl Phthalate 1 1 9.6 - - - Dimethyl Phthalate 1 1 9.6 - - -June 2008 Appendix A. Facility Analyses A-120 

### Exhibit A-85. Effluent Da ta Summary, Oregon Steel Mills 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL 2 (μg/L) Maximum Geometric Mean Minimum

Di-n-Butyl Phthalate 1 1 9.6 - - - Endosulfan Sulfate 1 1 - - - - Endrin 1 1 - - - - Endrin Aldehyde 1 1 - - - - Ethylbenzene 1 1 5 - - - Fluoranthene 1 1 9.6 - - - Fluorene 1 1 9.6 - - - Heptachlor 1 1 - - - - Heptachlor Epoxide 1 1 - - - - Hexachlorobenzene 1 1 9.6 - - - Hexachlorobutadiene 1 1 9.6 - - - Hexachlorocyclopentadiene 1 1 9.6 - - - Hexachloroethane 1 1 9.6 - - - Ideno(1,2,3-cd)Pyrene 1 1 9.6 - - - Isophorone 1 1 9.6 - - - Mercury 1 1 0.0005 - - - Methyl Bromide 1 1 - - - - Methylene Chloride 1 1 5 - - - Nickel 1 0 0.2 46.5 46.5 46.5 Nitrobenzene 1 1 9.6 - - - N-Nitrosodimethylamine 1 1 24 - - - N-Nitrosodi-n-Propylamine 1 1 9.6 - - - N-Nitrosodiphenylamine 1 1 9.6 - - - PCBs 1 1 - - - - Pentachlorophenol 1 1 25 - - - Phenol 1 1 9.6 - - - Pyrene 1 1 9.6 - - - Selenium 1 1 - - - - Tetrachloroethylene 1 1 5 - - - Thallium 1 1 0.02 - - - Toluene 1 1 5 - - - Toxaphene 1 1 - - - - Trichloroethylene 1 1 5 - - - Vinyl Chloride 1 1 5 - - - QL = Quantification limit. 1. Represents effluent data for the facility from August 2007. 2. May not match approved QLs because data was collected prio r to November 2007 when ODEQ revised applicable QLs.



### Receiving Water Data

Exhibit A-86 summarizes data for the Willamette River above the mixing zone for those pollutants of concern for which ambient data are av ailable from the facility’s draft RPA analysis spreadsheet provided by ODEQ.

### Exhibit A-86. Ambient Data Summary, Oregon Steel Mills 1

Number of Observations Summary of Detected Values (μg/L) Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean
Arsenic 2 0 - 0.46 0.14 0.042 Nickel 2 0 - 0.34 0.11 0.036 Selenium 2 2 0.6 - - - QL = Quantification limit. 1. Represents ambient data from April 2005 to April 2006.



### Potential Impacts

Baseline Criteria



### Exhibit A-87 summarizes the RPA for baseline criteria for those pollutants detected in the effluent (there will be no RP or monitoring requirements if a ll observations are nondetect). The Willamette River is a freshwater river; thus, huma n health criteria for consumption of organisms and water are applicable. The dilution factors ar e based on stream and effl uent flows provided in the facility’s permit, assuming only 25% of the stream fl ow is allowed for dilution. The Willamette River at river mile 2.4 is on the st ate’s 303(d) list as im paired for DDT, DDE, dieldrin, dioxin, mercury, PCBs, pentachloroph enol, and PAHs. Also, the ambient background concentration for arsenic is above the applicable criterion. Thus, the faci lity would not receive dilution for these pollutants.

Exhibit A-87. RPA for Baseline Criteria, Oregon Steel Mills

Parameter Calculated Effluent Conc. 1 ( μ g/L) Ambient Conc. 2 ( μ g/L) Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone 3 (

μ g/L) ( μ g/L) Antimony 12.6 0 0.0087 5.6 No Arsenic 23.5 0.70 23.5 0.0022 Yes Nickel 288.2 0.93 1.13 13.4 No 1. Represents the calculated geometric mean concentration for carcinogens and the calculated maximum concentration for noncarcinogens based on a CV of 0.6 for all pollutants (see Section 3.2). 2. Represents the geometric mean of detected values and zero if data are not available or if all values are nondetect. 3. Dilution based on effluent and stream flows specified in the facility’s permit for human health pollutants (carcinogen facto r = 3,478; noncarcinogens factor = 1,455).



### As shown in the exhibit, the facility has RP to exceed the baseline criterion for arsenic because the concentration at the edge of the regulatory mi xing zone is greater than the applicable existing human health criterion.

There is only one data point from which to determine compliance with the baseline arsenic criterion. Additional data would be needed to characterize the effluent and determine the need for WQBELs. If additional data indicate complia nce with the baseline cr iterion, the discharger would not incur compliance costs. However, if additional data indicate effluent arsenic concentrations above necessary levels, the discharger c ould incur compliance costs.

June 2008 Appendix A. Facility Analyses A-121

### The ambient background concentration for arsenic is above the applicable criterion, indicating that the stream may be impaire d. If ODEQ determines that the ambient concentration represents natural background levels, it would grant dilution in the RPA calculation (ODEQ, 2005). Under this scenario, the concentrat ion at the edge of the mixi ng zone would be 0.71 μg/L, or approximately 1% above the ambient background concentration. ODEQ (2005) indicates that dischargers that cause less than a 10% increas e in downstream receiving water concentrations would not be given numeric efflue nt limits; rather they would be required to implement narrative BMPs and increased monitoring.

If ODEQ determines that the water body is im paired, it would not gr ant dilution and base effluent limits on achieving the criterion end-of-pipe. However, because the baseline criterion is below the QL, the discharger would only need to reduce effluent levels to the QL. The permit application indicates that dust fr om the electric arc furnace unit contains arsenic, among other heavy metals, and that the discharger sends this dust to a baghouse for dust removal and ships the dust offsite to a permitted landfill. IDEM (2002) i ndicates that releases from baghouse units are common, particularly during load ing of trucks. Any dust that escapes from the baghouse onto the surrounding area could be taken up during st orm events and collected in surrounding catch basins. The permit evaluation repor t indicates some portion of the wastewater discharged to the Willamette contains storm water from catch ba sins surrounding these baghouses. BMPs to reduce dust leaks or other potentia l onsite arsenic sources would likely enable compliance with the baseline criterion. Costs for implementation of such BMPs are likely to be similar to those for an industrial P2 progr am for mercury ($25,000).

Thus, costs could range from zero if additional data indicate compliance to $25,000 per year if BMPs are needed to control onsite arsenic source s. The costs to implement narrative BMPs and increased monitoring under a scenario of dilutio n and no numeric effluent limits would likely fall within this range.

Revised Criteria



### Exhibit A-88 summarizes the RPA for the revised human health criteria for consumption of water and organisms for those pollutants detected in the effluent (there will be no RP or monitoring requirements if all observations are nondetect).

Exhibit A-88. RPA for Revised Criteria, Oregon Steel Mills Human Health Criteria at Alternative FCRs (μg/L) Parameter Conc. at Edge of Mixing Zone 1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Antimony 0.0087 5.40 5.30 5.10 4.70 4.30 Arsenic 23.5 0.0083* 0.0057* 0.0041* 0.0021* 0.0014*
Nickel 1.13 280 190 140 69.0 45.0 *Bolded values represent RP equal to “Yes.” FCRs = Fish consumption rates. 1. Dilution based on effluent and stream flows specified in the facility’s permit for human health pollutants (carcinogen facto r = 3,478; noncarcinogens factor = 1,455).



### The discharger would have RP for arsenic at a ll fish consumption rates. Thus, because the ambient concentration is greater than the criteria, the discharger would need to reduce discharge

June 2008 Appendix A. Facility Analyses A-122

### concentrations to background (if ODEQ determines that ambient concentrations represent natural levels) or the approved QL of 0.05 μg/L (because the criterion is below the QL) for compliance with revised standards. Howeve r, under the baseline, the discharge would need to meet those same levels. Thus, incremental compliance costs are unlikely.

Summary



### Exhibit A-89 provides a summary of the potential range in annual costs associated with the baseline and revised criteria. For the alternative fish consump tion rates, the incremental costs represent any costs above and be yond those that would be needed for compliance with baseline criteria.

Exhibit A-89. Summary of Potential Costs, Oregon Steel Mills

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs 1 Baseline • None or BMPs (arsenic) $0 - $25,000 NA 63.2 gpd • None or BMPs (arsenic) $0 - $25,000 $0 113 gpd • None or BMPs (arsenic) $0 - $25,000 $0 175 gpd • None or BMPs (arsenic) $0 - $25,000 $0 389 gpd • None or BMPs (arsenic) $0 - $25,000 $0 620 gpd • None or BMPs (arsenic) $0 - $25,000 $0 NA = Not applicable. 1. Annual costs for baseline criteria represent the costs needed for compliance under existing conditions; costs for revised criteria represent the difference betw een total annual cost and baseline costs (i.e., incremental costs above and beyond those needed for compliance with baseline criteria).

June 2008 Appendix A. Facility Analyses A-123

### References

Agency for Toxic Substances and Disease Regist ry (ATSDR). 2005. Toxicological Profile for Alpha-, Beta-, Gamma-, and Delta-Hexachlorocy clohexane (Update). Atlanta, GA: U.S. Department of Public Health and Huma n Services, Public Health Service.

Agency for Toxic Substances and Disease Registry (ATSDR). 2002. Toxicological Profile for DDT/DDE/DDD (Update). Atlanta, GA: U.S. Depart ment of Health and Human Services, Public Health Service.

AMSA. 2002. Mercury Source Control & Pollu tion Prevention Program Evaluation. Prepared by Larry Walker Associates.

CH2MHill. 2007. Mixing Zone/Dilution Technical Ev aluation Report. Prepared for City of St. Helens, Oregon and Boise White Paper LLC. January.

City of McMinnville. 2007. Public Works & Park Maintenance: Sewer FAQ. Online at http://www.ci.mcminnville.or.us/city/departments/public-works -and-park-maintenance-sewerfaq/

.

Environment Canada. 1994. Priority Substanc es List Assessment Report: Bis(2-ethylhexyl) phthalate. Government of Canada. Online at http://www.hc-sc.gc.ca/ewhsemt/alt_formats/hecs-sesc/pdf/pubs/contaminants/psl1- lsp1/bis_2/bis_2_ethylhexyl_phthalate_e.pdf

.

Fairfield-Suisun Sewer Distri ct (SD). 2003. 2003 NPDES Pe rmit Renewal Infeasibility Analyses. June 17. Online at http://www.swrcb.ca.gov/rwqc b2/Agenda/08-20-03/08-20-03- 5ainfeasibilityrev.doc

.

Huber, Kimberly. 1997. Wisconsin Mercury Sourcebook: A Guide to Help Your Community Identify & Reduce Releases of Elementa l Mercury. Prepared for Wisconsin DNR.

Indiana Department of Environmental Management (IDEM). 2002. Nonrule Policy Documents. Indiana Register, Volume 25, Nu mber 9, June 1, 2002. Online at http://www.in.gov/legislative/iac/ xml/old-ir/Vol25/09Jun/14Nonrul.pdf

Oregon Department of Environmental Quality (O DEQ). 2006a. Fact Sheet: Air Toxics of Concern in Oregon.

Oregon Department of Environmental Qualit y (ODEQ). 2006b. Regulatory Mixing Zone Internal Management Directive. Part 1: A llocating Regulatory Mixing Zones. Draft April.

Oregon Department of Health Services (ODHS ). 2007a. City of Astoria. Online at http://170.104.158.45/arsenic.php3?pwsno=00055 . Accessed November 19, 2007.

June 2008 Appendix A. Facility Analyses A-124

### Oregon Department of Health Services (ODHS ). 2007b. Drinking Water Program: Coos BayNorth Bend Water Board Arsenic Data. Online at http://170.104.158.45/arsenic.php3?pwsno=00205. Accessed November 27, 2007.

Oregon Department of Health Services (ODHS ). 2007c. Drinking Water Program: City of Milwaukie Arsenic Data. Online at http://170.104.158.45/arsenic.php3?pwsno=00528. Accessed November 29, 2007.

Oregon Department of Health Services (ODHS). 2007d. Drinking Water Program: McMinnville Water and Light Ar senic Data. Online at http://170.104.158.45/arsenic.php3?pwsno=00497 . Accessed October 18, 2007.

Oregon Department of Health Services ( ODHS). 2007e. Drinking Water Program: Salem Public Works Arsenic Data. Online at http://170.104.158.45/arse nic.php3?pwsno=00731. Accessed November 21, 2007.

Oregon Department of Health Services (ODHS). 2007f. Drinking Water Program: City of St Helens Arsenic Data. Online at http://170.104.158.45/arsenic.php3?pwsno=00724. Accessed November 26, 2007.

Oregon Department of Health Services (ODHS ). 2007g. Drinking Water Program: Oregon City South Fork Water Board Arsenic Data. Online at http://170.104.158.45/arsenic.php3?pwsno=00591. Accessed November 30, 2007.

Oregon Department of Health Services (ODHS ). 2007h. Drinking Water Program: Pope and Talbot Inc Arsenic Data. Online at ht tp://170.104.158.45/arsenic.php3?pwsno=92152. Accessed November 28, 2007.

Portland Water Bureau (PWB). Drinking Water Report: 2007. Online at http://www.portlandonline.com/shared/cfm/image.cfm?id=158017.

St. Helens Water Department. 2006. 2006 Water Quality Report. Online at http://www.ci.sthelens.or.us/

.

United States Geological Survey (USGS). Ar senic in Ground Water of the Willamette Basin, Oregon Water-Resources Inve stigations Report 98–4205.

Woodburn Public Works. 2005. 2005 Water Qua lity Report. Water Division. Online at http://www.ci.woodburn.or.us/publicworks/water/CCR%20-%202005%20-Eng.pdf

.

June 2008 Appendix A. Facility Analyses A-125June 2008 Appendix B. Pollution Prevention Programs and Costs B-1 

## Appendix B. Pollution Prevention Programs and Costs

Pollution prevention (P2) is the most cost-effec tive approach to reducing pollutants in waste water. P2 strategies focus on reducing the polluta nt at the source where it is more concentrated and may be more easily controlle d, rather than treating larger volumes of wastewater once diluted. Because of the cost-effectiveness of sour ce controls, and the lack of cost effectiveness and demonstrated performance from end-of-pipe controls for polluta nts like mercury, P2 is a key strategy for compliance with very low effluent limitations.

B.1 Municipal Mercury P2

A number of municipalities have developed P2 programs that provide a basis for estimating program components and costs. The costs to municipalities, industr ies, businesses, and households associated with a municipal P2 pr ogram for mercury will vary greatly based on a number of factors including the concentration of mercury in the treatment plant effluent, the community size and makeup, the extent of P2 e fforts already underway, and the knowledge and experience of the municipality in this area. Mu nicipalities would most likely target dentists, hospitals, medical facilities, educational institutions (primari ly universities and high schools), households, and industries to reduce mercury disc harges to the treatment plant. Program components could include:

• 

### Sampling and analysis – to characterize merc ury at the facility and track treatment effectiveness

• 

### Program development – for source identific ation, materials development, program implementation, and management

• 

### Conducting site visits and holding workshops

• 

### Supplying mercury-free product replacements

• 

### Advertising – to promote and inform the co mmunity of various act ivities and events taking place

• 

### Website development – to provide the commun ity with additional resources and serve as another means of promoting P2 activities.

Sampling and Analysis



### As part of the sampling and analysis task, m unicipalities should charac terize mercury inputs to the treatment plant and track program effectiveness. Characterization involves measuring mercury influent, effluent, and sludge concentrations to produce a better understanding of the load entering the plant and treatment process rem oval efficiency. This enables the discharger to determine how much of th e resulting effluent mercury loadin g is due to treatment performance and removal efficiencies, and how much is the resu lt of industrial, commercial, institutional, or residential discharges. Discharg ers should address any in plant s ources or issues in addition to focusing efforts on potential influent sources.

Although municipalities may sample frequently at the start of the program, they may reduce this frequency over the life of the program after de veloping an understandi ng of mercury behavior within the plant. Therefore, on average, muni cipalities would likely sample on a monthly basis using Method 1631, which requires clean sampling t echniques and allows for the determination

### of mercury at a minimum level of 0.5 ng/L. Assuming one sample at each sampling point (influent, effluent, and biosolid s) per month, municipa lities would collect 36 samples per year (12 months × 3 samples per month).

Costs associated with sampling include the time requi red to take the sample and analytical costs. It typically takes about 1 hour, on average, to co llect each sample and pr epare the shipment (e.g., complete the chain of custody form, wrap the bottles, and draft the ship ping label) (Morris, 2006). The average labor rate for a wastewater treatment plant operator in Oregon, including employer benefits is $29 per hour [escalated fr om 2006 dollars to 2007 dollars using Bureau of Labor Statistics (BLS) employme nt cost index] (BLS, 2006; 2007a; 2007b). Thus, costs would be about $29 per sample (1 hour per sample at an hourly wage rate of about $29). Laboratory analytical costs would be an additional $150 pe r sample (CAS, 2007; NRC, 2007; Test America, 2007). Therefore, total sampling costs may be approximately $180 per sample ($29 for operator labor + $150 for laboratory analysis = $180), or approximately $6,500 per year for 36 samples.

Program Development



### P2 program development involves identifying potential mercury s ources, determining appropriate or cost-effective measures for ta rgeting those sources, developing materials, implementing the program, and managing and assessi ng progress/effectivene ss of the program.

There are a large number of poten tial sources of mercury to any POTW, but there are few data on these sources from which to a ccurately predict the mercury lo ad measured at the headworks of a facility. Nevertheless, several municipal dischargers have attempted to quantify their mercury sources. For example, the WLSSD estimates that 44% of influent mercury is from commercial business (e.g., hospitals , dentists, universities), 34% is unknown, 14% is residential, and 8% is from permitted industrial users. So me facilities in California have taken the characterization a step further and estimated th e loads from individual commercial sources.

The Palo Alto Regional Water Quality Control Plant (RWQCP) in California estimates that residential and human waste not related to amal gam fillings accounts for 32% of its influent mercury load, the water supply accounts for 22%, hum an waste attributable to amalgam fillings accounts for 20%, dental offices account for 9%, and permitted industries account for 6% (EIP Associates, 1999). The East Bay Municipal Utilities District (E BMUD) in California estimates that 34% of their influent mercury load is from dental offices, 20% from the residential sector, 12% from inflow and infiltration, 11% from kno wn commercial dischargers, and 10% from hospitals and medical faci lities (EBMUD, 2004). Both of thes e dischargers estimated the source loadings from a combination of available m onitoring studies and actua l sampling efforts. Therefore, to reduce costs, facilities could us e information collected and developed from other POTWs to identify potential sources of mercury, as well as to roughly estimate influent mercury contributions from those sources. Note, however, th at the only way to truly characterize influent loads would be through site-specific sampling.

Determining which P2 efforts to pursue requires evaluation of the contri bution to total mercury loadings, relative magnitude of lo ading, feasibility of control, and effectiveness of proposed efforts. Source control efforts could be implem ented through existing pretreatment programs.

June 2008 Appendix B. Pollution Prevention Programs and Costs B-2

### P2 practices could include BMPs , production/process changes at i ndustrial facilitie s, and public outreach and education programs targeting lo cal businesses (e.g., dentists, hospitals, and laboratories), consumers, and schools.

Currently, most municipal faciliti es initially target dental offi ces and the residential sector through public outreach efforts. Municipalities can develop and distribute materi als for dental offices that outline BMPs they can implement to reduce the amount of merc ury discharged to the POTW. They may also encourage dentists to install amalgam separators, which often remove over 95% of amalgam particles prior to discharg e. For example, the Central Contra Costa Sanitary District (CCCSD) devel oped a brochure for dentists that describes the mercury problem in the area, the role that dentis ts play in this problem, and meas ures that dentists can take to reduce their mercury contributions (CCCSD, 2005). Developing brochures may not be necessary for smaller facilities if there are relatively few de ntal offices in the service area. For example, the Mt. View SD was able to conduct site visits to each of the four dental offices in their area, and use a checklist developed by the Bay Area Pollution Prevention Grou p (BAPPG) to guide the visit and recommend actions each dentist coul d take to reduce mercury discharges (Engler, 2005).

The most common activities targeting the reside ntial sector include distributing educational material in the form of brochur es or billing inserts, or orga nizing events to collect mercurycontaining equipment or products and ensure that they are properly disposed of or recycled. Some municipalities offer a mercury-free altern ative in exchange for the mercury-containing one. Collection events held at easily accessibl e places such as schools, community centers, and grocery stores are more successful than events held at the facility. For example, the Palo Alto RWQCB collected about 2,000 mercury thermome ters over a couple of years by relying on individuals to bring their thermo meters to the treatment plant at their convenience. However, once the City decided to hold events at a schedul ed date and time within the community, they were able to double the number of thermometers collected in a much sh orter time period (Bobel, 2005).

Other potentially signific ant sources of mercury to a POTW are hospitals and medical facilities and educational institutions. Most of the merc ury from these sources can be found in equipment such as thermometers, manometers, and blood pressure cuffs and chemical reagents. Municipalities may develop materials or c onduct workshops aimed at encouraging these facilities to conduct an inventor y of mercury-containing equipment, switch to mercury-free alternative equipment, and implement BMPs th at prevent releases of mercury from the equipment. For example, WLSSD worked with th e St Mary’s-Duluth Hea lth System to identify the major sources of mercury within the system and replace the source with mercury-free alternatives.

EBMUD, under a grant from EPA, partnered with the University of California, Berkeley to develop a mercury reduction program for educa tional institutions. Under the program, EBMUD replaced mercury-containing laboratory equipm ent with mercury-free a lternatives, collected elemental mercury, worked with specific de partments on campus to replace any additional mercury-containing devices, and developed a template based on these experiences for use at other institutions (EBMUD, 2007). In 2007, EBMUD worked with two local school districts and

June 2008 Appendix B. Pollution Prevention Programs and Costs B-3

### one university to collect and properly dispose of 112 pounds of mercury waste and replace equipment with nonmercury altern atives (e.g., thermometers and some laboratory devices).

Public outreach and education act ivities, however, do no always re sult in noticeable reductions in mercury loads to the POTW. For example, collec tion programs are aimed at reducing the overall load to the environment, and not only the load to the wastewater treatment plant, since many of the products collected may not dir ectly affect the plant’s influe nt mercury load (e.g., fluorescent bulbs and thermostats). Also participation rates for implemen ting suggested BMPs or control measures are often low for commercial and institutional discharger s because there are no regulatory requirements. To increase partic ipation rates and make voluntary efforts more successful, municipalities could offe r indirect dischargers assistan ce with residuals disposal, or make it clear that if voluntary programs fail, mandatory prog rams that include noncompliance liability risk (i.e., fines) will follow.

An increasing number of municipalities ar e implementing nonvoluntary measures such as limits/requirements in pretreatment permits or se wer use ordinances that require implementation of specific treatment controls a nd/or BMPs to obtain more meas urable reductions in mercury loadings. For example, the Palo Alto RWQCP im plemented a sewer use or dinance that requires all dental offices to instal l approved amalgam separators by March 31, 2005, and provide certification to the facility that th ey had done so. The facility also requires dentists to implement BMPs that:

• 

### Prohibit rinsing chairside traps, vacuum scr eens, or amalgam separator equipment in a sink or other sanitary sewer connection

• 

### Require staff to be trained in the proper ha ndling and disposal of amalgam materials and fixer-containing solutions

• 

### Prohibit the use of bleach or ot her chlorine containing disinf ectants to clean the vacuum line system

• 

### Prohibit the use of bulk liquid mercury; only precapsulated dental amalgam is permitted

• 

### Require that amalgam waste be stored in accord ance with recycler or hauler instructions.

The Palo Alto RWQCP developed its program in cooperation with the Mid-Peninsula Dental Society, the California Dental Asso ciation, and other stakeholders. The City also coordinated the program’s work plan and implementation with the City of San Francisco and the EBMUD.

Similarly, the EBMUD regulates its indirect disc hargers through permits. The permits for dental facilities require all dentists to install an ISO 11143 standard amalgam separator by June 30, 2005, and recommend implementation of specific BMPs . Dental facilities must also submit a report self-certifying installati on of the separator and implementation of recommended BMPs.

Costs of program development vary based on the leve l of effort and size of the service area. The Palo Alto RWQCP (design flow of 38 mgd) ha s a P2 program sector of its environmental compliance division that includes 4 staff. The staff works on various ta sks and outreach efforts for a number of different pollu tants including mercury. The progr am director estimates that approximately one quarter of these 4 staff memb ers’ time is spent working on mercury-related tasks, resulting in average annual labor cost s, including benefits, of approximately $85,000 per year (Bobel, 2005). Similarly, at EBMUD (design flow of 79.6 m gd), one staff member spends

June 2008 Appendix B. Pollution Prevention Programs and Costs B-4

### about 80% of her time on new mercury P2 tasks (Mena, 2005). Employee labor is used to identify potential source sectors, develop and evaluate alternativ e P2 strategies, develop outreach and education materials, request and draft ch anges to sewer use ordinances, schedule and organize collection events, conduc t educational workshops for speci fic source sectors, maintain contact information for facilities within each se ctor, and put together annual program status reports. Thus, these estimates of 1 full-time e quivalent (FTE) staff position (or approximately $85,000/year) are likely to be representative of co sts for program development for large facilities (e.g., flows greater than 20 mgd).

Medium (e.g., between 5 mgd and 20 mgd) and sma ll (e.g., between 1 mgd and 5 mgd) facilities have smaller service areas, and thus, fewer source s to identify and target. Smaller facilities are also more likely to partner w ith large facilities that have al ready established P2 programs or organizations such as the Department of Health Services or ODEQ to reduce costs. Therefore, in-house labor requirements for medium and small f acilities will most likely be less than those of a larger facility.

For example, an employee of the San Mateo WWT P in California (desig n flow of 13.6 mgd) estimates that in-house labor for mercury P2-related tasks equals about 0.1 FTE. The level of effort is low because the City does not have a fo rmal P2 program for merc ury, and relies heavily on partnerships with the Department of Health and other larger P2 or ganizations (e.g., a countywide storm water P2 program) to develop the outreach and educational information needed to target local businesses and residents (San Mateo Public Works, 2005). The City anticipates that more in-house labor will be needed in the co ming years as the program is expanded to target dentists and other potential source sectors (San Mateo Public Works, 2005). Similarly, the P2 coordinator at Mt. View Sanitati on District (average flow of 2 mgd) only spends about one week per year on mercury-related P2 tasks. However, most of the sources in the service area have already been targeted and the facility has developed numerous partnerships with other organizations, making the district’s P2 program for mercury virtually self-sustaining (Engler, 2005). If the district began addi tional activities such as fluores cent light bulb collection events or regulatory requirements for dentists, additio nal in-house labor would be needed (Engler, 2005).

Thus, given the San Mateo and Mt. View estimates , medium-sized facilities could require as much as two-thirds of the effort of large f acilities (approximately $56,000 or 0.67 FTE per year), and small facilities could require as much as one-third of the effort (approximately 0.33 FTE or $28,000 per year).

Site Visits and Workshops



### Municipal facilities may also supplement their own employee labor with expertise from outside the municipality (e.g., consultants). For exam ple, the Palo Alto RWQCP spends about $30,000 per year on a private consultant to help them develop outreach materials and conduct mercury education workshops and seminars at schools throughout their service area (Bobel, 2005). Workshops can be used to provide target group s with sector-specific information on mercury sources, effective BMPs, and sources for alternative equipment. The need for additional assistance varies depending on the number of diff erent sources of mercur y to the plant and the size of the service area.

June 2008 Appendix B. Pollution Prevention Programs and Costs B-5

### The Palo Alto RWQCP also hires a consultant to visit various sources an d advise them on BMPs for reducing mercury or ensure that they are co mplying with sewer use ordinance requirements. Palo Alto spends about $20,000 a year on this off-s ite consultant work (Bobel, 2005). Site-visits are useful to determine what BMPs, if any, are in place or could be employed at a particular site to reduce mercury discharges. Sources of mercury are usually easy to identify at dental offices. However, mercury sources at hospitals, medical centers, secondary schoo ls, and universities are harder to identify because of the larger di scharge volume and greater number of potential sources, and may require a greater amount of time.

Based on information from Palo Alto, large facilities may spend about $30,000 per year on tasks related to program maintenance and material development performed by persons not directly employed by the municipality, and $20,000 per y ear on site visits. Medium and smaller facilities, due to the nature and size of their serv ice areas would not have to spend as much. For example, in 2006, San Mateo plans to spend about $20,000 on consultants to target dentists and conduct site visits (San Mateo Public Works, 2005) . The facility may also need assistance in developing materials for those sources it has not yet targeted (e.g., hospitals). Therefore, medium facilities could spend about $30,000 per y ear on additional assistance, or roughly 60% as much as a large facility, and small facili ties could spend about $15,000 per year, or about 30% as much as a large facility.

Mercury-Free Products



### Municipalities may need funds to provide merc ury-free products to the public or commercial sectors. For example, many loca lities hold collection events in wh ich residents turn in mercury thermometers for recycling and receive either a free electronic thermometer or a coupon towards purchasing one. For example, ODEQ provides free digital thermometers at collection events to citizens turning in a mercury containing thermo meter and supplies local governments with free digital thermometers (ODEQ, 2007). Also, in 2005 and 2006, ODEQ, with gr ant assistance from EPA, worked with dairy and agricultural orga nizations to replace and properly dispose of mercury manometers used in dairy farm milki ng operations with mercury-free digital vacuum gauges (ODEQ, 2007). ODEQ also initiated a pr ogram with Portland General Electric, the Thermostat Recycling Corporation, and the Product Stewardship In stitute through which participants receive $4 rebate coupons for each mercury-containing thermostat returned to a participating wholesal er for recycling.

However, municipalities may also need to provide s econdary schools or hosp itals with mercuryfree equipment to replace all or part of their mercury-contai ning equipment. The Minnesota Pollution Prevention Agency (MPPA) works with schools to eliminate mercury. The school often conducts the mercury inventory with guida nce from the MPPA. Then, MPPA gives the school a limited amount of free mercury-free equi pment (including 40 laboratory thermometers, 2 digital fever thermometers, a blood pressure unit, and a digital barometer), lines up a proper recycling facility, and covers the mercury recy cling costs. Total av erage costs are about $400 per school (Butler, 2002).

Costs vary based on the number of exchange/col lection events and the volume of equipment collected. Because ODEQ already provides muni cipalities assistance with exchange and

June 2008 Appendix B. Pollution Prevention Programs and Costs B-6

### collection events for thermometers, thermostats, and dairy equipment, it is likely that only schools would need to be targeted for mercur y-free product exchanges. Therefore, based on service area sizes, small facilities may replace mercury-contai ning equipment at 1 school ($400); medium facilities may replace mercury-containing equipment at 2 schools (2 × $400 = $800); and large facilities may replace mercur y-containing equipment at 3 schools (3 × $400 = $1,200), assuming costs associated with replacing mercury equipment at schools are about $400 per school. Note that over time, the facility will replace most mercury-containing equipment in schools. However, these costs would likely still be incurred annually be cause facilities would just refocus their efforts on other source sectors (e.g., hospitals, medical centers, and laboratories).

Advertising



### Developing public service announcements (PSAs) and a website promoting mercury P2 efforts are relatively low-cost methods fo r distributing information. The PSA cost is for the time spent to prepare audio PSAs for radio broadcast use. For example, the price charged by Hispanic Radio Network to produce a Spanish or Englis h PSA under a General Services Agreement for the federal government (GSA contract GS-23F -0307M) is $200. Due to a large service area, large facilities could need a number of messages targeting di fferent sources in different languages annually. Since medium and small facili ties have fewer sources to target, they may need fewer announcements.

Website



### Small municipalities would likely target primar ily residential customers with a mercury P2 website (e.g., post collection event dates and times , links to mercury fact sheets). However, larger municipalities may also target commercia l and industrial dischargers. The cost of a website depends on its function, number of pages, and security requirement s. Websites with less than 10 pages and no animation or custom gra phics typically cost less than $1,000 (Numatek, 2007). Due to the nature of P2 programs and the need to adapt efforts based on sampling and outreach results, frequent maintenance would be needed to keep the websites up to date. However, over the life of a program, website development and maintenance might average approximately $1,000 per year. These costs do not incl ude the cost of the website itself. Rather, facilities would likely add information on the P2 program to a preexisting website run by the municipality or sewer district.

Total Municipal P2 Costs



### Exhibit B-1 summarizes potential program components a nd costs for different size facilities, based on the experiences of communities that have already implemented such programs. Actual costs may be higher or lower than shown.

Exhibit B-1. Potential Annual P2 Progr am Costs for Municipal Facilities (2007$) Component Small (1-5 mgd) Medium (5-20 mgd) Large (> 20 mgd) Sampling and Analysis $6,500 $6,500 $6,500 Program Development $28,000 $56,700 $85,000 Site Visits and Workshops $15,000 $30,000 $50,000

June 2008 Appendix B. Pollution Prevention Programs and Costs B-7

### Exhibit B-1. Potential Annual P2 Progr am Costs for Municipal Facilities (2007$) Component Small (1-5 mgd) Medium (5-20 mgd) Large (> 20 mgd) Mercury-Free Products $400 $800 $1,200 Advertising $400 $800 $1,200 Website Development $1000 $1,000 $1,000 Total $51,000 $96,000 $145,000



### Costs may be greater in the star tup period than costs in subseque nt years as the program becomes more established; the estimates represent average annual program expenditures. Facilities will likely initially target the largest or most known sources of mercury to the treatment plant, such as dentists and hospitals, and then move on to othe r potential sources such as automobile service stations and secondary schools. The estimates fo r conducting site visits and workshops reflect this sequential targeting of an equal number of sour ces in a given year.

Indirect Dischargers



### In addition to the cost of developing a P2 program, municipalities may require indirect dischargers to the sewer system to implement sour ce controls. Municipalities would likely target dentists, hospitals and medical cen ters, secondary schools, universitie s, and industrial facilities. However, the program may not addr ess all of these sectors immediately (i.e., in certain sectors, implementation of controls may not occur for several years).

Dental Offices

The Oregon Senate recently passed Senate Bi ll 704 requiring dentists who place or remove dental amalgam and other merc ury-containing materials to be certified in compliance with ODA’s BMPs. Senate Bill 704 took effect January 8, 2008. The law also requires these dentists to install amalgam separators. However, thos e certified in complian ce with ODA’s BMPs have until 2011 to install separators (ODA, 2007). Thus, costs for these ac tions are attributable to the bill (and not compliance with baseline or revised human health criteria).

Hospitals and Medical Centers

P2 measures for hospitals and medical centers include BMPs such as eliminating the use and handling of mercury-containing products and equipment through the modification of purchasing practices. Mercury-free substitutes are availa ble for most mercury-c ontaining chemicals and equipment. Although mercury-free products ma y currently be more expensive than those containing mercury, there are savings associated with eliminating the costs of hazardous waste training, storage and disposal, clean up, and poten tial noncompliance, and pot ential health risks to staff, patients, and visito rs. In the case of electronic thermometers, the mercury-free alternative also has time-saving benefits si nce an electronic thermometer gives a quicker temperature reading than a mercury thermo meter (Pollution Probe, 1996). For example, comparison of a mercury-containing sphygmom anometer to a mercury-free aneroid sphygmomanometer shows that once staff traini ng, spill cleanup, and administrative costs are taken into account, the mercury-fr ee alternative is actually more cost effective (Pollution Probe, 1996).

June 2008 Appendix B. Pollution Prevention Programs and Costs B-8

### The potential cost savings from using mercury-free equipment can be substantial. For example, the University of Minnesota-Duluth reports that phasing out mercury has significantly reduced costs due to hazardous spill cleanups (Second Natu re, 2003). The average wage rate of spill team members is about $100 per ho ur, and it takes on average about 6 hours to clean up a spill (California DHS, 2000). Spill kits range in costs from $15 to $200. Using mercury also requires administrative costs to keep procedures up to date and staff trained. The Butterworth hospital in Grand Rapids, Michigan spent over $3,000 per merc ury spill for clean up for several spills between 1993 and 1995 (Pollution Probe, 1996). In 1998, Kaiser-Permanente, which owns and operates 30 hospitals and 360 clinics, began a mercury minimization policy aimed at switching to mercury-free thermometers and sphygmomano meters, and proper disposal of fluorescent lamps, through a contract with a recycler. Ka iser-Permanente predicte d that elimination of mercury thermometers and sphygmomanometers would result in cost reductions of about $550,000 over the next 10 years across the system. Th ese cost savings would also offset the cost of the recycling program (T ellus Institute, 2000).

Therefore, implementing P2 activities is not likely to impose incremental costs on hospitals and medical centers.

Laboratories

P2 measures for laboratories that may reduce the amount of mercury released to the environment as a result of daily operations are similar to t hose implemented by hospitals and medical centers. In addition to replacing mercur y containing equipment (e.g., manometers and thermometers) and chemicals containing mercury with mercury-free alternatives, la boratories can also work to minimize the amount of waste generated during experiments and testing procedures. The University of Minnesota-Duluth ha s instituted micro-scale project s in undergraduate labs that dramatically reduced the quantities of possibl e mercury-containing chemicals used, purchased, and discarded (Second Nature, 2003). Laboratorie s in hospitals that have replaced their mercury-containing chemicals with mercury-free al ternatives found that costs of mercury-free chemicals are about the same as costs of chemi cals containing mercury (Pollution Probe, 1996).

There may be instances, however, in which me rcury-free alternatives do not exist. A 250- employee laboratory in Massachusetts uses thimeros al as a bacteriostat/fungi stat in many clinical tests. The facility is permitted to discha rge up to 1 μg/L under the Massachusetts Water Resources Authority (MWRA) pret reatment program. The laboratory determined that thimerosal could not be readily replaced, so the laborat ory employed source reduction techniques (e.g., collecting waste streams for hazardous waste dispos al, reducing the amount of reagent used) to reduce their mercury concentrations by 90%. The 90% reduction was not great enough for compliance with the pretreatment standard, and the facility had to install treatment using silverimpregnated granular activated carbon with flow equalization to reduce mercury to the required levels (Massachusetts OTA, 1995). However, since this case study, manufacturers have been working to create more alternatives for mercury-containing chemicals.

Because there is a cost savings associated with a decrease in mercury spill clean ups costs, and costs for mercury free alternativ es are often about the same as costs of mercury-containing chemicals, implementing P2 programs is not likel y to impose incremental costs on laboratories.

June 2008 Appendix B. Pollution Prevention Programs and Costs B-9

### Universities and Secondary Schools

There are a number of BMPs schools can implem ent to reduce mercury in their wastewater:

• 

### Educate students, teachers and administrators about the health hazards and environmental fate of mercury (e.g., see the Mercury in Sc hools Pollution Prevention project, located at http://www.mercuryinschools.uwex.edu)

• 

### Promote proper management and recycling of mercury and mercury- containing products (e.g., educate teachers and maintenance pers onnel on items that may contain mercury such as thermometers and laboratory chem icals, and proper disposal techniques)

• 

### Eliminate the use of mercury wherever po ssible and promote the use of alternative products that do not contain mercury (e .g., schools may have mercury-containing thermostats, barometers, thermometers, and wa ll switches that can easily be replaced with mercury-free alternatives)

• 

### Clean out plumbing (e.g., mercury builds up in plumbing over the years resulting in a constant mercury discharge even after the use of mercury is eliminated).

Universities and secondary schools would most likel y take an inventory of mercury and mercury containing equipment in each building, and replace each item with a mercury- free alternative, as well as set up an educational program for professors, teachers, maintenance personnel, and students on the health effects of mercury, its e nvironmental fate, and proper handling and clean up procedures.

The EBMUD initiated a mercury reduction progr am with the University of California at Berkeley (UCB) through grant funding from EPA. The program focused on identifying all mercury-containing equipment and chemicals th rough the campus and replacing them with mercury-free alternatives. Another main comp onent of the program focused on outreach and education targeting professors, students, and sc hool administrators. EBMUD also developed a template to guide other institutions on implementation of a successful mercury reduction program. UC Berkeley spent about $36,000 from 2002 through 2005 on the program (an average of $12,000 per year) for mercury waste disposal and recycling ($6,000) and program development and implementation ($30,000). Howeve r, if other universities use the template developed as part of the program development a nd implementation, costs would be much less.

P2 program implementation costs for secondary schools are most likely minimal because the municipality conducting the progr am generally conducts the merc ury equipment inventory and arranges for equipment replacement and disposal (a lready accounted for in the direct costs). For example, schools are not charged to participate in the MPPA’s Mercury Free Zone program. In addition, this Agency offers free lab and medi cal equipment to replace the schools’ mercurycontaining equipment and arranges for proper mercur y disposal at a recyc ling facility (Butler, 2002). The Oregon Association of Clean Water Agencies (ACWA), in conjunction with ODEQ, also developed a pilot program fo r two local school districts to eliminate the use of mercury in schools. ODEQ spent approximately $27,800 of staff time inventorying 5 schools for mercury equipment and chemicals, and an additional $6,0 00 on mercury replacement and disposal. All of these costs were covered by donations, City of Corvallis, City of Eugene, ACWA, and CWA 319 Nonpoint Source Grants from ODEQ (Oregon ACWA, 2005).

June 2008 Appendix B. Pollution Prevention Programs and Costs B-10

### Based on the above examples, it is likely that municipalities will conduct mercury inventories and supply mercury-free equipment for secondary schools. Therefore, the costs to secondary schools would be minimal.

Exhibit B-2 summarizes the estimated annual average cost s to facilities in th e various sectors.

Exhibit B-2. Summary of Potent ial Annual Indirect Costs Associ ated with Mercury P2 Programs
Sector Annual Cost None attributable to rule; SB 704 requires dentists to implement BMPs and amalgam separators Dentists

Hospitals and Medical Centers Potential cost savings Laboratories Potential cost savings $12,000 per year per university in initial years (based on experience of one California university) Universities

Secondary Schools Minimal; inventory and mercury replacement accounted for in direct costs



### B.2 Industrial Mercury P2

There is little information available on the cost of P2 programs for industrial facilities because facilities typically do not account for pollutant-sp ecific P2 costs as a budget item that can be verified apart from other source control costs. For example, one industrial facility spends between $5 and $6 million a year on waste minimization and P2 activities for a variety of pollutants and media (e.g., air, water, solid wastes ), but only a small portion of that is related to mercury (Barrett, 2005). In addi tion, P2 activities for industrial dischargers vary greatly based on facility type, volume of wast ewater discharged, existing wast ewater treatment processes (if any), and the manufacturing processes and chemical s potentially responsible for mercury loads. For example, a facility that uses chlorine for di sinfection or to prevent s caling may find that the type of chlorine used is contaminated with me rcury. Reducing effluent mercury concentrations could be as simple as switching to mercury-free chlorine. However, the identification of sources and solutions may not be as straig htforward at another t ype of industrial facil ity, especially those with multiple internal waste streams and industr ial processes. Despite these differences though, it can be assumed that most industrial faciliti es will implement the basic components of a P2 program, including process analys is and process modifications.

During process analysis the discharger would id entify pollutant uses a nd quantities within the facility (i.e., inventory facil ity), identify pollutant use and potential contamination in process streams, and identify P2 options for reduc ing the pollutant at the plant (e.g., on-going management of pollutants, recycling, and product and raw material substitutions). After the process analysis step, the facili ty would need to implement the identified P2 options and make any necessary process modifications.

June 2008 Appendix B. Pollution Prevention Programs and Costs B-11June 2008 Appendix B. Pollution Prevention Programs and Costs B-12 

### We estimated the costs to identify potential po llutant sources and sample process waste streams assuming a two-month study, or approximately 320 hours. The hourly wage in Oregon for an environmental engineer is approximately $50 in cluding employer benefits [escalated from 2006 dollars to 2007 dollars using BLS empl oyment cost index] (BLS, 2006; 2007c; 2007d). 9 

### This results in study costs of approximately $16,000 (320 × $50).

As discussed above, analytical costs for measuring mercury using Method 1631 may be approximately $180 per sample. We assumed that industrial facili ties would sample at 4 points within the treatment process (e.g., influent, effluent, and 2 internal points) monthly, resulting in analytical costs of approximately $8,600 (4 × 12 × 180). Thus, total process analysis for industrial facilities would be approximately $25,000 ($16,000 + $8,600).

Process analysis costs will likely only be incu rred during the first year. However, because process modifications are highly site-specific, we assumed that facilities would continue to incur the process analysis cost of $25,000 per year to cover any pr ocess modifications such as replacing mercury-containing equi pment at the end of its usef ul life, product substitution, switching chemical manufacturers, or installing treatment on internal waste stream where mercury is most concentrated.

B.3 Bis(2-ethylhexyl) Phthalate

Bis(2-ethylhexyl) phthalate is found mainly in plastics and is used as a plasticizer for polyvinylchloride (PVC) and other polymers. The plasticizers can be released from plastics manufacturing wastes or through release from plastic goods (Environment Canada, 1994). Hospitals use a number of products that contain bis(2-ethylhexyl) phthal ate such as gloves, tubing, flexible bags (e.g., intravenous, nut ritional, blood, collection and specimen), rigid containers, respiratory equipment (e.g., mask s and oxygen tents), and packaging (Malcolm Pirnie, 2005). High levels of bi s(2-ethylhexyl) phthalate in municipal wastewater effluent can also be associated with sampling and/or labor atory analysis conditions (Fairfield-Suisun SD, 2003). If this is the case, cleaner sampling a nd analysis techniques c ould reduce the amount of bis(2-ethylhexyl) phth alate measured in the effluent. Theref ore, facilities w ould likely need to conduct additional monitoring to determine potential sources of the pollutant.

If additional testing indicates that bis(2-ethylhe xyl) phthalate is the result of industrial or commercial dischargers, the faci lity would need to develop more stringent pretreatment standards or implement source cont rols to prevent bis(2-ethylhe xyl) phthalate from entering the treatment plant. However, example costs of such programs at other wastewater treatment plants are unavailable. In fact, it is no t certain whether any municipal wa stewater treatment plants have actually been required to reduce effluent levels of bis(2-ethylhexyl) phth alate. For example,

9 BLS (2006) describes an environmental engineer (stand ard occupations classificati on 17-2081) as one that can “design, plan, or perform engineering duties in the prevention, control, and remediation of environmental health hazards utilizing various engineering di sciplines” and “work may include wast e treatment, site remediation, or pollution control technology.”

### several dischargers in California found that switching to cleaner analytical methods resulted in reductions in detected effluent concentrations, thus eliminating the need for permit limits (Fairfield Suisun, 2003; EBMUD, 2003). In Phoe nix, the City began the process for developing local limits, but after finding no c ontrollable sources, abandoned the efforts. Since that time, and without implementing specific actions targeti ng bis(2-ethylhexyl) ph thalate, effluent concentrations have decreased to below detected levels.

As described above (see Section B.1) mercur y P2 program costs may range from about $50,000 for a small facility (1 mgd to 5 mgd) to $150,000 fo r a large, major facility (>20 mgd). There are not as many controllable sources under a bis(2-ethylhexyl) phthalat e source program as there are under a mercury P2 program. Thus, we assumed that source program cost s for bis(2-ethylhexyl) phthalate would be approximately $50,000 per year , although costs could be higher or lower depending on factors including disc harger experience with the pollu tant and P2 efforts, existing monitoring and controls, and source s to the treatment plant.

B.4 Pesticides

The main pesticides of concern for the municipal sample facilities are 4,4-DDT and alpha-BHC. DDT is a pesticide that was widely used on agri cultural crops to control insects. The United States banned uses of DDT in 1972, except for public health emergencies involving insect diseases and control of body lice (ATSDR, 2002). BH C is a manufactured chemical that exists in eight chemical forms called isomers. Technica l-grade BHC was used as an insecticide in the United States and typically contained 10-15% gamma ( γ )-BHC as well as the alpha ( α ), beta ( β ), delta ( δ ), and epsilon ( ε ) forms (ATSDR, 2005). However, te chnical-grade BHC has not been produced or used in the United Stat es in over 20 years (ATSDR, 2005).

P2 or source control programs to identif y potential sources of the pollutants (e.g., any commercial/industrial indirect discharges that ma y have in the past used the chemicals or manufactured pesticides containing the chemicals or storm water discharges to the sanitary sewer system) would likely include monitoring and a ssessment, and local limits development and implementation, if appropriate. Monitoring woul d enable the municipal ity to determine the magnitude of the influent load and calculate the appropriate pretreatment limits for each potential source. However, example costs of such progr ams at other wastewater treatment plants are unavailable.

As described above (see Section B.1) mercur y P2 program costs may range from about $50,000 for a small facility (1 mgd to 5 mgd) to $150,000 for a large, major facility (>20 mgd). These pesticides are no longer in use or production in the United Stat es and there are much fewer controllable sources than there are under a mercur y P2 program. Thus, we assumed that source program costs for legacy pesticides would be approximately $25,000 per year, although costs could be higher or lower depe nding on factors including discharger experience with the pollutant and P2 efforts, existing monitoring and controls, and sources to the treatment plant.

B.5 Dioxin

June 2008 Appendix B. Pollution Prevention Programs and Costs B-13

### Dioxin (2,3,7,8-TCDD) may form du ring chlorination by wastewater treatment plants or in the manufacture of certain organic chemicals (ATSDR, 1999). Industry only intentionally manufactures the chemical for research. The City of Palo Alto RWQCP has implemented a dioxin P2 program since 1997. The municipality id entified laundry and shower graywater, storm water inflow, human and food waste, and toilet pape r as the largest conveyances of dioxin to the treatment plant. There is a difference between the sources of dioxins and the conveyances by which they reach a treatment plant. Palo Alto identified the sources of dioxin as chlorinated chemical manufacturing, organochlorine pesticid e manufacturing, motor vehicles, residential wood burning, incineration, historic activities, and pape r bleaching (Palo Alto, 1997). However, the City predicts that implementation of all the cont rol strategies identified in their plan to reduce dioxin from these conveyances only has the potential to reduce the load to the treatment plant by a relatively small percentage (Palo Alto, 1997). Therefore, a municipal P2 program for dioxin may not result in compliance with effluent lim its end-of-pipe, at least not immediately.

Costs for a dioxin P2 program would include monitoring and source assessment and program development and implementation. Monitoring w ould enable the municipality to determine whether the dioxin is coming from chemicals used within the treatment process (e.g., chlorine) or influent sources to the treatment plant. If the dioxin is the result of treatment chemicals, the solution could be as simple as swit ching chemical brands. If the di oxin is from discharges to the treatment plant, the facility would need to id entify the likely sources, determine feasible and cost-effective control measures, and work with dischargers to implement those measures. As described above (see Section B.1) mercury P2 program costs may range from about $50,000 for a minor facility (1 mgd to 5 mgd) to $150,000 for a large, major facility (>20 mgd). There are not as many controllable sources under a dioxin P2 program as there are under a mercury P2 program. Thus, we assumed that P2 program costs for dioxin would be approximately $50,000 per year, although costs could be higher or lower depending on factor s including discharger experience with dioxin and P2 efforts, existi ng monitoring and controls , and sources to the treatment plant.

B.6 References

Agency for Toxic Substances and Disease Registry (ATSDR). 2005. ToxFAQs: Hexachlorocyclohexane CAS # 608-73-1. Onlin e at http://www.atsd r.cdc.gov/tfacts43.pdf.

Agency for Toxic Substances and Disease Regist ry (ATSDR). 2002. Toxicological Profile for DDT, DDE, and DDD. Online at http://www.atsdr.cdc.gov/toxprofiles/tp35.pdf

.

Agency for Toxic Substances and Disease Registry (ATSDR). 1999. ToxFAQs: Chlorinated Dibenzo-P-Dioxins (CDDs). Online at http://www.atsdr.cdc.gov/tfacts104.pdf

.

Barrett. 2005. Inland Ispat Indiana Harbor Works. Personal communication. December.

Bobel, Phil. 2005. Palo Alto Regional Water Quality Control Plant Environmental Compliance Division. Personal communication. June.

Bureau of Labor Statistics (BLS). 2006. Stat e Occupational Employment and Wage Estimates

June 2008 Appendix B. Pollution Prevention Programs and Costs B-14

### Oregon. Online at http://www.bl s.gov/oes/current/oes_or.htm.

Bureau of Labor Statistics (BLS). 2007a. Employment Cost Inde x Historical Listing Current-dollar March 2001 – September 2007. Ta ble 11. Employment Cost Index for wages and salaries, for State and local government work ers, by occupational group and industry (Not seasonally adjusted), Management, pr ofessional, and related. Online at http://www.bls.gov/web/echistrynaics.pdf.

Bureau of Labor Statistics (BLS). 2007b. Em ployer Costs for Employee Compensation. Table 3. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: State and local government work ers, by major occupational and industry group, September 2007, Management, professi onal and related. Online at http://www.bls.gov/news.release/pdf/ecec.pdf.

Bureau of Labor Statistics (BLS). 2007c. Empl oyment Cost Index Hist orical Listing Currentdollar March 2001 – September 2007. Table 9. Employ ment Cost Index for wages and salaries, for private industry workers, by occupational gr oup and industry (Not seasonally adjusted), Professional, and related. Online at http://www.bls.gov/web/echistrynaics.pdf.

Bureau of Labor Statistics (BLS). 2007d. Em ployer Costs for Employee Compensation. Table 5. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers, by majo r occupational group and bargaining unit status, September 2007, Management, professi onal and related. Online at http://www.bls.gov/news.release/pdf/ecec.pdf.

Butler, Chris. 2002. Mercury Free Zone Coor dinator. Personal communication. May.

California Department of Health Services ( DHS). 2000. A Guide to Mercury Assessment and Elimination in Health Care Facilities.

Central Contra Costa Sanitary District (CCCS D). 2005. Dental Office and Mercury Pollution Prevention.

Columbia Analytical Services (CAS). 2007. Personal communication with Loan Vo. November 20, 2007.

East Bay Municipal Utilities District (E BMUD). 2007. Mercury Program. Online at http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/pollution_preven tion_program/mercury%20program/default.htm

.

East Bay Municipal Utilities District (EBMUD). 2004. 2004 Pretreatment and Pollution Prevention Report.

East Bay Municipal Utility District (EBMUD). 2003. Amending Waste Discharge Requirements For: East Bay Municipal Utility Di strict Special District No. 1 Water Pollution

June 2008 Appendix B. Pollution Prevention Programs and Costs B-15

### Control Plant. Order No. R2-2003-0088. Online at http://www.swrcb.ca.gov/rwqcb2/Agenda/09-17-03/09-17-03-11finalorder.doc.

EIP Associates. 1999. Technica l Memorandum - Mercury Source Id entification Update: Dental Offices and Human Waste. To: Palo Alto Regional Water Quality Control Plant.

Engler, Leslie. 2005. Mt. View Sanitary Distri ct Pollution Prevention Coordinator. Personal communication.

Environment Canada. 1994. Priority Substanc es List Assessment Report: Bis(2-ethylhexyl) phthalate. Government of Canada. Online at http://www.hc-sc.gc.ca/ewhsemt/alt_formats/hecs-sesc/pdf/pubs/contaminants/psl1- lsp1/bis_2/bis_2_ethylhexyl_phthalate_e.pdf

.

Fairfield-Suisun Sewer Distri ct (SD). 2003. 2003 NPDES Pe rmit Renewal Infeasibility Analyses. June 17. Online at http://www.swrcb.ca.gov/rwqc b2/Agenda/08-20-03/08-20-03- 5ainfeasibilityrev.doc

.

Malcolm Pirnie. 2005. SROG Phase II Local Lim its Assistance, Best Management Practices Study: Protecting Our Water Quality. Meeting with Hospitals - August 9, 2005

Massachusetts Office of Techni cal Assistance (OTA). 1995. Toxics Use Reduction Case Study: Reducing Mercury Discharge at a Tes ting Laboratory. Case Study No. 35.

Mena, Deirdre. 2005. East Bay Municipal Utilit ies District Wastewater Department. Personal communication. June.

Morris, Patrick. 2006. Central Valley Regional Water Quality Control Board: Mercury TMDL Unit. Personal communication. January.

Neilson Research Corporation (NRC). 2007. Pe rsonal communication with Fay L. Fowler. November 13, 2007.

Numatek Web Design. 2007. Web Design Price Estimates. Online at http://www.numatek.com/web-design/estimate.html . Accessed December 6, 2007.

Oregon Association of Clean Water Agencies (ACWA). 2005. Mercury in Schools: Pilot Project. Prepared for Oregon Depa rtment of Environmental Quality.

Oregon Dental Association (ODA) . 2007. New Amalgam Separator Law. Accessed online at: http://www.oregondental.org/i4a/ pages/index.cfm?pageid=3542

.

Oregon Department of Environmental Qu ality (ODEQ). 2007. 2007-2011 ODEQ Mercury Reduction Strategy. March.

June 2008 Appendix B. Pollution Prevention Programs and Costs B-16

### Palo Alto. 1997. Palo Alto Regional Water Qu ality Control Plant Dioxins Pollution Prevention Plan. October. Online at http://www.cityofpaloalto.org/civi ca/filebank/blobdload.asp?BlobID=3760

.

Pollution Probe. 1996. Mercury in the Health Ca re Sector: The Cost of Alternative Products.

San Mateo Public Works. 2005. Environmenta l Compliance Section, En gineering Division. Personal communication. June.

Second Nature. 2003. Greening Medical Facili ties: Facts and Resources. Online at http://www.secondnature.org/pdf/s nwritings/factsheets/green_hosp.pdf

Tellus Institute. 2000. H ealthy Hospitals: Environmental Improvements Through EA.

Test America. 2007. Personal communication. December 11, 2007.

June 2008 Appendix B. Pollution Prevention Programs and Costs B-17June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-1 

## Appendix C. End-of-Pipe Treatment Controls and Costs

There are numerous end-of-pipe treatment tec hnologies that could be used to reduce toxic pollutants in wastewater effluent s. However, in general there is a lack of performance data available to show that advanced treatment technol ogies will result in the e ffluent levels necessary for compliance with the baseli ne and revised criteria.

C.1 Reverse Osmosis

Theoretically, reverse osmosis (RO) can remove n early all inorganic cont aminants from water, (NDWC, 1997), as well as viruses and most organic contaminants, including some pesticides. The process removes contaminants from water using a semipermeable membrane that permits water, and not dissolved compounds, to pass thro ugh its pores. The contaminated water is subjected to high pressures th at force pure water through the membrane, leaving pollutants behind in a brine solution (NDWC, 1997).

Properly operated RO units can achieve 96% rem oval of arsenic (III), arsenic (IV), barium, cadmium, chromium (III), chromium (VI), fluorid e, lead, mercury, nitrite, selenium (IV), selenium (VI), and silver. Multiple RO units operated in series, however, are capable of nondetectable or almost 100% removal rates (NDWC, 1997). 10 

### RO has several advantages, including:

• 

### Removal of nearly all contaminant ions and most other dissolved contaminants

• 

### Relatively insensitive to flow a nd total dissolved solids levels

• 

### Also removes bacteria and particulates (NDWC, 1997).

However, despite these claims there are no full scale performance data available from wastewater treatment plants discharging to surfac e waters that indicate that such removals are possible at these facilities on a c onsistent basis. This may be due to the fact that few, if any, facilities have been required to reduce toxic pollutants to such low levels through the use of endof-pipe treatment. The use of RO for treating wastewater is limited, and therefore performance data are scarce. Because removal efficiencies ar e less than optimal when treating influents with low contaminant concentrations, performance test ing using influent con centrations in the ppb (μg/L) or ppt (ng/L) range should be conducted on various types of wastewater to ensure that RO is capable of producing the a ppropriate effluent range.

Even if the necessary pollutant levels are achievable with RO, it is important to consider the potential disadvantages and limitati ons of this technology, including:

• 

### High capital and operating (including energy) costs (which increase with decreasing desired effluent concentrations)

• 

### Management and disposal of residuals (bri ne and media) is potentially costly and problematic

10 It was not clear how many data points or studies on which the percent removals are based. Also, NDWC (1997) does not indicate whether the percent removals represent single or dual stage RO processes.• 

### Expensive pretreatment may be required to ma intain the high treatment efficiency levels needed to achieve extremely low levels of pollutants (e.g., carbon prefilter for the reduction of chlorine, which can damage some types of chlorine sensitive RO membranes, sediment prefilter to ensure that fine suspended materials do not clog the membrane)

• 

### Membranes are prone to fouling (NDWC, 1997)

• 

### May not be feasible for treatment of large flows

• 

### Does not remove pollutants from the envir onment, rather transfers them to another medium (pollutants are concentrated in the reject disc harge or brine).

The most limiting of these disadvan tages, especially for larger systems, is the management and disposal of residuals. Most RO systems rej ect about 10% to 25% of influent water as a concentrated brine solution (U.S. EPA, 1996). For a 10 mgd facility running 2 RO units in series, this translates into di sposal of about 2 mgd to 4.5 mgd of residual waste; this brine contains the contaminants removed from the wastew ater, and must be treated prior to disposal. The more feasible residual disposal options for wastewater treatment plants include:

• 

### Land disposal (e.g., evaporati on pond, underground injection)

• 

### Treatment (e.g., brine concentrator, therma l evaporation) (Metcalf and Eddy, 2003).

The first option requires that th e waste be classified as nonhazardous . Otherwise, the brine must be disposed of as a hazardous waste, which can be extremely costly, especially for larger volumes. The land disposal option also may re quire a large amount of land (U.S. EPA, 2002), and if evaporation ponds are the only land dispos al option, precipitation ra tes cannot be greater than evaporation rates. The treatment through controlled ev aporation is feasible, although operating and maintenance costs may be extrem ely high. This appro ach is usually only employed where no other alternatives are available (Metcalf and Eddy, 2003).

In addition, these disposal options do not guarantee that the pollutants in th e residuals will not be re-released into the environment. The pollutant is simply transferred from the effluent to a residual brine that must be dis posed of in some manner. If the brine is evaporated (either through an evaporation pond or flash/thermal eva porator), the pollutant could evaporate to the atmosphere and be redeposited into rivers and lakes.

Since no wastewater treatment plants in the countr y have installed RO to remove toxics to very low levels for discharges to surface waters, ther e is no information on installed costs. Nor is information available from similar industrial ap plications. U.S. EPA’ s Office of Groundwater and Drinking Water is developing detailed mode ls for estimating compliance costs associated with drinking water regulations. Adjusting the input parameters to reflect average wastewater conditions, the RO model may provide an indi cation of potential costs for wastewater applications. Exhibit C-1 shows these wastewater input parameters. The total costs for RO include microfiltration pretreatment (essential to prevent fouling of the RO membranes for wastewater applications; generate d by a separate cost model), two RO units in series (likely needed to achieve the low levels under the revised criter ia), equalization basi ns to handle recycle flows from backwashing and chemical cleaning, and residuals management (brine concentrator followed by evaporation ponds).

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-2

### Exhibit C-1. Input Parameters for Mi crofiltration Pretr eatment and Reverse Osmosis Cost Models for Wastewaters Component Input Value Microfiltration Temperature 20°C Membrane flux 26 gal/ft 2 /day Chemical-enhanced backwash interval 15 minutes Clean-in-place interval 30 days Reverse Osmosis Total dissolved solids 490 mg/L Hardness 100 mg/L Alkalinity 120 mg/L Calcium 34 mg/L Magnesium 3.6 mg/L

Sodium 110 mg/L Barium 50 μg/L HCO 3 145 mg/L Chloride 45 mg/L

SO 4 150 mg/L pH 8.0 Temperature 20° C First-pass RO recovery 90% First-pass RO flux 12 gal/ft 2 /day Second-pass RO recovery 85% Second-pass RO flux 20 gal/ft 2 /day Clean-in-place interval 2 months (1 st pass); 12 months (2 nd

pass) Residuals Management Precipitation rate (Eastern OR) 1 32 cm/year Pan evaporation rate (Eastern OR) 2 134 cm/yr

1. Based on values from http://ocs.orst.edu/page_links/com parative_climate/oregon/or.jpg

. 2. Represents median of the evaporation rates measured at stations in climate zones 6, 7, 8, and 9 from http://ocs.orst.edu/page_links/comparative_climate/oregon/oregon.html converted to lake evaporation rates assuming a safety factor of 0.7.



### Scaling is a concern in RO operation; the sc aling potential may limit the water recovery percentage of each RO unit. The less water that is recovered from each unit, the greater volume of residual brine that needs treatment and disposal , thus increasing capital a nd operating costs. If the concentration of barium or sulf ate is higher than shown in the e xhibit, or if silica is present, water recovery could be limited.

Certain RO membranes are intolerant of free ch lorine, and most microfiltration membranes have limited chlorine tolerance. Thus, prior to micr ofiltration, the wastewater should be dechlorinated if chlorine is used in previous treatment units. Note that dechlorination may result in an increase in sulfate ions, which, as mentioned above, could contribute to the scalin g potential of the RO membranes. Costs may be higher than shown to account for these factors.

Exhibit C-2 summarizes capital and O&M costs for four size categories. Annual costs represent capital costs annualized at 7% ove r 20 years plus O&M costs.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-3

### Exhibit C-2. Summary of Esti mated Costs for Reverse Osmosis Component 5 mgd 10 mgd 25 mgd 50 mgd Capital Costs Microfiltration $6,820,000 $11,560,000 $22,650,000 $39,740,000 Equalization Basin $3,580,000 $7,150,000 $18,250,000 $36,230,000
Reverse Osmosis $18,800,000 $32,440,000 $79,350,000 $159,860,000 Residuals Management $11,190,000 $18,390,000 $39,970,000 $75,900,000
Total $40,390,000 $69,550,000 $160,220,000 $311,720,000
O&M Costs 2 Microfiltration $338,000 $627,000 $1,520,000 $2,930,000
Reverse Osmosis $1,410,000 $2,560,000 $5,890,000 $11,020,000 Residuals Management $1,550,000 $2,850,000 $6,780,000 $13,300,000
Total $3,290,000 $6,040,000 $14,190,000 $27,250,000 Annual Costs Annual Capital plus O&M $7,110,000 $12,600,000 $29,310,000 $56,670,000 1. Includes costs for brine concentrator and evaporation pond. 2. Includes costs for labor, materials, chemical s, energy, and solids disposal, where applicable.



### Capital costs include brine con centration followed by evaporati on ponds to handle the residual brine from the RO units. While this opti on may be feasible in Eastern Oregon where precipitation rates are less than evaporation rates, it is likely in feasible in Western Oregon where precipitation exceeds evaporation. More costly options such as thermal evaporation may be necessary, which could greatly increase O&M costs.

The cost effectiveness (cost pe r pound of pollutant reduced) of achieving incremental load reductions under the revised criteria with RO is very low. For example, Exhibit C-3 shows the cost effectiveness of reducing mercury from baseline criteria (0.017 μg/L) to the potential revised criteria for each consumption rate base d on the total annual RO costs for each flow category in Exhibit C-2.

Exhibit C-3. Cost Ef fectiveness of Reverse Osmosis for Reducing Mercury to Revised Criteria 5 mgd 10 mgd 25 mgd 50 mgd Scenario LR 1 (lb/yr) C-E ($ million/lb) LR 1 (lb/yr) C-E ($ million/lb) LR 1 (lb/yr) C-E ($ million/lb) LR 1 C-E (lb/yr) ($ million/lb) 63.2 gpd 0.19 $40.0 0.37 $3 3.7 0.94 $31.3 1.87 $30.3 113 gpd 0.22 $32.4 0.44 $2 8.7 1.10 $26.7 2.19 $25.9 175 gpd 0.23 $30.5 0.47 $2 7.1 1.16 $25.2 2.33 $24.3 389 gpd 0.25 $28.8 0.49 $2 5.5 1.24 $23.7 2.47 $22.9 620 gpd 0.25 $28.3 0.50 $2 5.1 1.26 $23.3 2.51 $22.5

C-E = Cost effectiveness gpd = grams per day LR = Load reduction mgd = million gallons per day 1. Load reductions calculated by multiplying the difference in concentration between the baseline (0.017 μg/L) and revised criterion (0.0047 μg/L for 63.2 gpd; 0.0026 μg/L for 113 gpd; 0.0017 μg/L for 175 gpd; 0.00076 μg/L for 389 gpd; 0.00048 μg/L for 620 gpd) by the flow, days per year ( 365), and a conversion factor (0.00834).

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-4

### C.2 Selective Sorbents

There are a number of sorbents designed to remove dissolved and ionic forms of pollutants from wastewater. Most of these sorbents rely on adsorption and chemical bonding of ions through chelation and/or ion exchange. Adsorptive technologies work best when waste streams are pretreated to remove suspended and dissolved solids to enhance pollutant removal and eliminate competing ions.

Selective resins are typically used in packed columns, similar to ion exchange. The ion exchange process consists of four operations: service, backwash, regeneration, and rinse (U.S. EPA, 1997). In the service step, the resin is cont acted with the influent water. The resin is considered spent once it can no longer remove th e desired amount of pollutant. Next, the backwash step is initiated to e xpand the bed and to remove fines that may be clogging the packed bed. The spent resin is regenerated using a con centrated solution of the original exchange ion, reversing the exchange process. Lastly, the rinse step remo ves excess regeneration solution before the column is brought back online for the next service cycle (U.S. EPA, 1997). Note that some sorbents cannot be regenera ted, and once they are spent (i.e ., there is no more capacity to adsorb mercury), they are disposed of and replaced with fresh media. A dvantages of a selective sorbent packed column process include:

• 

### Theoretically achieves extremely low efflue nt levels, under certain conditions (e.g., a number of columns in series, extensive pretreatment)

• 

### Contaminants can be recovered fr om most resins upon regeneration.

Use of selective sorbents also has disadvantages:

• 

### Management and disposal of spent medi a or regenerated brine can be costly

• 

### Effluent quality may be highly variable (depending on sorbent loading)

• 

### To achieve low pollutant levels in wastewat er, extensive pretreatment may be necessary

• 

### May need multiple units in series for desire d effluent quality, which increases costs.

Mercury



### For mercury, historically, the use of sorbent resi ns has been limited to anion resins applied to industrial wastewater containing in organic mercury with high concentrations of chloride. The chloride produces negatively charged mercury chloride complexes that are attracted to the positively charged resin. Cationic resins containing thiol groups can also be used to remove mercury because they have a high selectivity for mercury (U.S. EPA, 1997) . Another resin that can be used to remove mercury is a chelating resin, which, when attached to a complexing group, can bond negatively charged metal ions to fo rm a ring (or chelat e) (U.S. EPA, 1997).

Limited performance data on selec tive adsorbent resins indicate th at mercury can be removed to ng/L levels. Few studies have used analyti cal methods sensitive enough to measure below 200 ng/L. However, studies conducted at two U.S. Department of Energy (DOE) sites used clean analytical methods (e.g., Method 1631), and fo cused on the removal of mercury from mg/L levels to low ng/L levels (Klasson, et al., 1999, 2000; TN & Associates 1998).

Klasson et al. (1999) treated wa stewater from the Oak Ridge Na tional Laboratory (ORNL) with various selective sorbents to reduce effluent mercury concentrations. For a portion of the

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-5

### wastewater, treatment prior to en tering the sorbent columns consiste d of dual media filtration, air stripping, and granular activated carbon; the remaining water was treated with precipitation, flocculation, and settling. The waste streams we re combined prior to entering the sorptive media columns. Influent mercury to the columns range d from 40 to 625 ng/L. Overall, the thiol-based sorbents such as Keyle:X and SIR-200 performed th e best. The Keyle:X re sin produced effluent levels below 19 ng/L about 50% of the time when the water was chlorinated prior to entering the column to oxidize the mercury to a more treatable form. The removal efficiency of the selective resins was not specified; however , the report indicates that effici encies vary considerably over time, most likely the result of changes in the speciation of the mercury in the wastewater (Klasson, et al., 2000).

None of the tested sorbents at the second DOE site, the Y-12 Plant, reduced mercury concentrations to less than 12 ng/L from an av erage influent concentration of about 1,100 ng/L. Three sorbents, SIR-200, Keyle:X, and GT-73 redu ced mercury concentrations to less than 51 ng/L at flow rates of 0.3 bed volumes per minute to 1 bed volume per minute (TN & Associates, 1998). Removal efficiencies were approximately 95%, on average.

Although the sorbents tested above were cap able of reducing merc ury concentrations significantly, they did not demons trate the ability to produce effl uents that would comply with the any of the potential effluent limits on a consistent basis. Howe ver, influent concentrations at both sites were greater than typical conventiona l treatment effluents described in Section 2. Thus, reducing influent concentrations c ould potentially reduce achievable effluent concentrations as long as the di luted influent concentration do es not in turn reduce removal efficiencies.

For selective sorbents though, removal effici encies may not be affected by influent concentrations because at both sites, lower influe nt concentrations resulted in lower effluent concentrations, and the removal efficiency wa s not dependent on the number of bed volumes treated or the sorbent loading ra te (Klasson, et al., 2000). Theref ore, effluent concentrations could decrease as influent concentrations decrease (e.g., through sour ce control efforts or operating columns in series), although this result would need to be subs tantiated with further testing of waters with lower concentrations.

Arsenic



### Most of the research on the removal of arse nic from aqueous solution has been related to drinking water treatment, and the available data on arsenic in wastewater is extremely limited. The drinking water MCL is 10 μg/L, which is four orders of magnitude greater than the baseline water quality criterion for consumption of water a nd organisms for arsenic. As such, the studies on drinking water only aim to redu ce arsenic levels below the MC L. For example, EPA (2000) indicates that ion exchange can re duce influent arsenic source wa ter concentrations ranging from 45 μg/L to 60 μg/L down to below 5 μg/L. However, as shown in Appendix A, most of the dischargers are already dischargi ng at concentrations less than 2 μg/L. Thus, it is uncertain whether ion exchange could reduc e arsenic concentrations by the same percentage given lower influent concentrations. That is, there are no da ta available to show th at lowering the influent concentration does not also lower the percent reduction achievable.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-6

### C.3 Chemical Precipitation

Chemical precipitation involves the addition of chemicals to alter the physical state of dissolved and suspended solids and facilitate their rem oval by sedimentation (Metcalf and Eddy, 2003). Common precipitants for removal of heavy meta ls such as mercury and arsenic include hydroxide and sulfide, although carbona te can also be used in certain circumstances (Metcalf and Eddy, 2003). In practice, the minimum achievable effluent concentra tion depends not only on the precipitant used and the operating pH, but also the nature and concentr ation of organic matter and temperatures (Metcalf and Eddy, 2003).

Mercury



### Mercury may be present in three forms in wastewater: elemental mercury (Hg 0 

### ), ionic mercury (Hg +2 

### , usually present as complexes and chel ates with ligands), and organic (e.g., methylmercury). These species of mercury may bi nd to particulate matter in the wastewater to form physical agglomerates cont aining mercury that more readily settle out (MASCO, 1997). Particulate mercury is often the predominant form in wastewater st reams (MASCO, 1997). However, in order to achieve mercury levels in the low ng/L range, the dissolved and elemental forms of mercury, as well as particulate mercury may need to be removed.

The removal of mercury from wastewater to ng/L levels may be achieved using chemical precipitation and adsorption. Ionic mercury read ily combines with phos phate or sulfide to precipitate as mercury phosphates or sulfides. Wh en mercury is precipitated as sulfide, high mercury residuals are often observed due to redu ction of mercury to elemental mercury, which has a solubility in water of about 25 mg/L (much gr eater than potential effl uent limits). Once in the elemental form, the mercury will not form the insoluble sulfide. Therefore, this residual mercury must by oxidized to the ionic form and retreated with sulfide to achieve low residual concentrations (West General, 2004). Such a conversion can be done through the addition of an oxidant such as chlorine. [Thi s process is similar to the ad dition of chlorine to enhance performance of the Keyle:X resin tested at the DOE site discu ssed above. The chlorine oxidizes mercury to a more readily adsorbed form (Klasson et al., 2000).]

Exhibit C-1 shows the solubility of mercury sulfide in water. The solubility curve for mercuric sulfide in the exhibit shows that very low levels of mercury (l ess than 2 pg/L, or 0.002 ng/L) remain in the water when mercury is precipitated as sulfide.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-7

### Exhibit C-1. Solubility of Mercury (I) Sulfide in Water



### mg/L Sulfide

Source: West General (2004)



### Dischargers may choose to add sulfide in the form of iron sulfide or hydrogen sulfide to precipitate the mercury. Adding iron sulfide is more favorable than adding hydrogen sulfide because the generation, handling, and application of hydrogen sulfide may be challenging due to its highly toxic nature. Iron sulfide should be added in mg /L doses (e.g., 1 to 2 mg/L), concentrations much greater than the μg/L mercury concentrations found in effluent waters.

Once these sulfide precipitates are formed, additi onal treatment is needed because a portion of the precipitate is composed of fi ne particles that have such a high surface area to mass ratio that they do not settle out (U.S. EPA, 1980). U.S. EPA (1997) indicates that only levels in the μg/L range can be achieved with precipitation alone.

The most efficient way to remove this trace leve l solid mercurous sulfide is to attach it to a nonleaching media such as activated alumin a. Activated alumina adsorption is a physical/chemical process by which ions in solution are removed by the available adsorption sites on an oxide surface. Activated alumina is us ed primarily in packed beds where feed water is passed continuously through one or more beds (U.S. EPA, 2000). The precipitate adsorbs onto the activated alumina as the wastewater passes through it, thus reducing the mercury concentration of the final effluent. Note that, although the chemistry of th e process indicates that mercury will be effectively reduced, bench- a nd pilot-scale testing would be necessary to confirm that the necessary levels can be met fo r a particular wastewater and to determine the operating conditions required for optimal performance.

Precipitation and subsequent treatment is also not without disadvantages and limitations. The addition of sulfides to wastewater may generate toxic sulfide residual levels. Extensive testing would need to be conducted to ensure minimal residual levels. Otherwise the excess sulfides would have to be removed prior to discharge. Another concern associated with the addition of sulfides is the formation of hydroge n sulfide gas. If the pH of the wastewater is low, hydrogen

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-8

### sulfide gas may be produced, cau sing air toxicity and odor probl ems (U.S. EPA, 1980). Control of sulfide dose or enclosing and vacuum evacuat ing vessels may be necessary to prevent this problem.

The oxidation of elemental mercury may also cause problems. The use of chlorine or ozone to oxidize mercury could result in the formation of harmful by-products such as trihalomethanes, haloacetic acids, aldehyde s, and carboxylic acids.

Lastly, the limited performance data available for mercury precipitation followed by activated alumina presents a significant limitation. Alt hough in theory this process should remove mercury to the proposed criterion, actual performa nce on different wastewat er types has not been demonstrated. The effects that factors such as flow rate, competing contaminants, residuals production, and by-product formation have on the process and design requirements would need to be investigated before facilities are likely to install such a process for compliance with revised permit limits.

Arsenic



### Chemical precipitation is generally more effectiv e for arsenic(V) than arsenic(III) (U.S. EPA, 2000). Thus, to achieve low effluent levels, oxidat ion of arsenic(III) to ar senic(V) is necessary. Few wastewater treatment plants specifically aim to reduce arseni c levels. However, in drinking water treatment, iron and aluminum salts are wi dely used, with iron salts being more common because they are generally more effective for removing arsenic(III). Removal of arsenic occurs through chemical adsorption and coprecipitation during the formation of ferric hydroxides. Hering et al. (1996, as cited in U.S. EPA, 2000) observed “complete” remova l of arsenic(V) at pH of 7.0 and coagulant dose a bove 5 mg/L ferric chloride. However, use of such high coagulant doses also increases th e amount of sludge that must be disposed of. Low effluent levels will only likely be achieved with filtrati on or adsorption after chemical precipitation to remove colloidal arsenic.

C.5 Granular Activated Carbon

GAC has been used successfully in advanced tr eatment of municipal a nd industrial wastewater for years. GAC is primarily used to adsorb re fractory organics, such as 4,4’-DDT, alpha-BHC, dioxin, and bis(2-ethylhe xyl) phthalate, as well as residua l amounts of inorganics such as nitrogen, sulfides, and heavy metals (Met calf and Eddy, 2003). However, water-soluble compounds and small molecules are not adsorbed well (NAVFAC, 2008).

GAC adsorption occurs when pollutant molecules a dhere to the internal wa lls of pores in carbon particles produced by thermal activation (U.S. EP A, 2000). At municipal wastewater treatment plants, GAC is usually installed prior to disinfec tion, but after filtration (o r some other type of pretreatment) that removes suspended solids in or der to prevent fouling and maximize the time before breakthrough occurs (i.e., the point at which the contaminant is no longer absorbed).

Advantages of GAC include the following:

• 

### Proven, reliable technology for removing dissolved organics

• 

### Low space requirements

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-9• 

### Easy to incorporate into ex isting systems (U.S. EPA, 2000).

However, GAC is not without its disadvantages, including:

• 

### Under certain conditions, hydrogen sulfide ma y be generated from bacterial growth, creating odor and corrosion problems

• 

### Wet GAC is highly corrosive and abrasive

• 

### Requires pretreated wastewater with low susp ended solids, and little variations in pH, temperature, and flow rate (U.S. EPA, 2000)

• 

### Spent carbon may be a hazardous waste

• 

### Spent carbon must be regenerate d or disposed of and the adsorbed contaminants must be destroyed, often by incineration (possibl y re-releasing contaminants into the environment; organic contaminants are usually thermally degraded)

• 

### The presence of multiple contaminants can affect the process performance due to competitive adsorption of different classes of compounds; bench tests may be conducted to estimate carbon usage for mixtures

• 

### Some common chlorinated contaminants ar e weakly sorbed, resulting in low GAC capacity

• 

### Type and pore size of the carbon, as well as th e operating temperature, must be carefully selected to optimize contaminant removal (NAVFAC, 2008).

There are no studies demonstrating GAC organi cs removal at wastewater treatment plants, although there are several plan ts throughout the country using GAC either to supplement secondary treatment or to enhance phosphorus rem oval. Unfortunately, ther e are no effluent data for toxic pollutants in EPA’s PCS database for th ese facilities. GAC has been used for a number of groundwater cleanup operations. However, the removal rates vary based on the specific contaminant, quality of the source water, and op erating parameters of the GAC unit (e.g., single versus dual stage).

Although GAC can remove low concentrations of cer tain metals, it has not been widely used for this purpose possibly due to the fact that spent carbon used for me tals removal can be difficult to regenerate and may require trea tment and/or disposal as a hazardous waste (U.S. EPA, 1991). Also, traditional types of GAC have low adsorption capacity for mercury. Sulfur-impregnated GAC can be used to increase the adsorption capac ity for mercury because the sulfur chemically reacts with the mercury to form mercuric su lfide (HgS), a tightly bonded and highly insoluble compound (Grieco, 2007). Use of this type of GAC for mercury removal at wastewater treatment plants discharging to surface waters has not been demonstrated on a full scale. Performance data from groundwater cleanup ope rations indicate that dual stage sulfurimpregnated GAC can reduce mercury from 1,500 ng/L to 80 ng/L after the first stage, and from 80 ng/L to 2.5 ng/L after the second stage (Grieco, 2007). The major disadvantage to this type of GAC it that it cannot be regenerate d, so once its capacity is exhaus ted it must be replaced with new media, which can be costly; Grieco (2007) estimates unit costs to be approximately $200 per cubic foot, compared to approximately $34 to $52 per cubic foot for typical GAC media that can be regenerated (Calgon Carbon Co rporation, 2002; Arce Systems, Inc., 2002; Environtrol, 2003; updated to 2006 dollars using ENR CCI).

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-10

### Estimates from one vendor indicate that annual costs for a GAC system designed to remove PCBs may range from about $17,000 to $26,000 per mgd, depending on flow (Sherbondy, 2004). To remove DDT, the pH of the system may need to be adjusted, increasi ng annual costs to about $19,000 to $31,000 per mgd (Sherbondy, 2004). These costs do not include components such as pretreatment, residual disposal, process piping, site work, pilot studies, administrative fees, and contingencies. In addition, more than one GAC unit in series ma y be necessary to reduce certain pollutants to the required levels . The costs may also vary considerably based on source water quality and influent contaminant concentration.

C.6 Advanced Oxidation Processes

Advanced oxidation processes can be used to re duce the concentration of organic contaminants such as 4,4’-DDT, alpha-BHC, and dioxin in wastew ater. Advanced oxidation processes such as UV light coupled with ozone and/ or hydrogen peroxide, UV light coupled with titanium dioxide, and sonochemical degradation destroy organic contaminants through the production of hydroxyl radicals which react with organics to break th em down into non-toxic compounds such as carbon dioxide and water.

UV Oxidation



### UV oxidation involves the use of UV light coupled with one, or a combination of, chemical and physical agents that break up existing bonds, take away electrons, or elevat e the energy level of electrons in organic compounds to create new bonds. Examples of agents commonly used in this process include ozone, hydrogen peroxide, titanium dioxide, iron, and other oxidizing compounds. The oxidizing agents produce free ra dicals which also react with organic compounds destroying them (Rahuman et al., 2000).

The most common UV oxidation pro cesses involve the use of UV li ght paired with a catalyst (e.g., titanium dioxide) or str ong oxidizer (e.g., ozone , hydrogen peroxide). In UV oxidation, organic chemicals are oxidized by various mechan isms, including direct r eaction with oxidizers, UV photolysis, and the synergistic action of UV light (FRTR, 2002). If complete mineralization is achieved, the final products of oxidation are carbon dioxide, wa ter, and salts. Oxidation of organic compounds using only a strong oxidizer does not always completely oxidize the contaminants, resulting in the presence of interm ediate oxidation products. These intermediate products may be as toxic as or even more toxi c than the original compound. Therefore, these oxidizing agents are paired with UV light to e nhance the completion of the oxidation reactions, eliminating harmful byproducts (Munter, 2001).

UV oxidation using a catalyst generates electrons into the conduction band of the catalyst and produces valence band holes at the surface of th e catalyst. Electron accepting species such as oxygen are reduced by the electrons in the c onduction band, and water molecules or hydroxyl ions are oxidized at the holes. This process produces two hydr oxyl radicals that rapidly break down and mineralize organic contam inants (Powell, 2000). A numb er of properties such as the surface state of the semiconductor, the flat-band potential, and the dissociation of the organic contaminant are strongly dependent on pH. The op timal pH value varies w ith the contaminant of concern and wastewater type (M unter, 2001). Therefore, pilot testing to determine optimal operating conditions would be nece ssary to confirm performance.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-11

### Advantages to UV oxidation include:

• 

### Destroys, not removes, contaminants (there is no need to disp ose of residuals)

• 

### Also provides disinfection

• 

### Can be used over a wide range of influent concentrations and fl ow rates (e.g., 1 to 1,000 gpm)

• 

### Can be configured as batch or continuous process, depending on flow (FRTR, 2002; Kidman and Tsuji, 1991).

UV oxidation forms hydroxyl radica ls that can potentially reac t with almost any organic chemical present in the wastew ater. Therefore, to ensure that pollutants are completely destroyed there must be a sufficient amount of ra dicals, especially if other competing organic chemicals are present. However, overdosing with oxidizers such as ozone may actually decrease the destruction efficiency due to ozone absorpti on of the UV light. Ther efore, careful planning and testing would be necessary to dete rmine the optimal operating parameters.

Disadvantages associated with UV oxidation may include:

• 

### Pretreatment to lower suspended solids con centrations and turbidity to provide for good transmission of UV light and mini mize reactor and lamp maintenance

• 

### Free radical scavengers can i nhibit destruction efficiency (e.g., excessive dosages of oxidizers could become scavengers)

• 

### Fouling of UV quartz sleeve as a result of material deposition from temperature and UV light exposure, or as a result of compounds in the source water reacting with the sleeve surface

• 

### Handling and storage of oxidizers may require special safety precautions (FRTR, 2002)

• 

### Use of ozone or hydrogen peroxide may resu lt in the formation of harmful byproducts that would need to be removed prior to discharge.

U.S. EPA (1998) indicates that UV oxidation with hydrogen peroxi de or ozone can remove 86% to 99.9% of VOCs from contaminated groundwat er, and over 99% of semivolatile organic contaminants from contaminated groundwater, depe nding on the specific po llutant and treatment unit. However, most of the effluent concentr ations were still above the baseline and revised criteria, and it is unclear whethe r performance levels would rema in the same for treatment of municipal and industrial wastewater. Thus, addi tional full-scale testing is likely needed to determine the feasibility of UV oxidation for municipal and industrial wastewater.

Potential costs for UV oxidation differ depending on whether the process is coupled with ozone, hydrogen peroxide, or titanium dioxide catalyst. The major difference between the two processes is that UV oxidation wi th ozone or hydrogen peroxide requires the generation and handling of ozone and hydrogen peroxide onsit e, whereas UV/titanium dioxide oxidation does not require the handling of any hazardous chemi cals. Also, with UV oxidation with titanium dioxide, if the more efficient powder form of titanium dioxide is used, a mechanism for recovering the catalyst is necessary. Both proces ses will have relatively high energy costs due to the use of UV light. Exhibit C-5 provides a qualitative comparis on of operating costs for the various UV oxidation systems.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-12

### Exhibit C-5. Comparison of Operating Costs for Va rious UV Oxidation Processes

Process Cost of Oxidant Cost of UV UV/Ozone High Medium UV/Hydrogen Peroxide Medium High UV/Titanium Dioxide Very Low Medium to High Source: Munter (2001).



### Note, however, that the efficiency of each pr ocess is strongly dependent on the specific compounds targeted (Munter, 2001). Prelimin ary bench testing should be conducted to determine the appropriate oxidation process for rem oval of the target pollutants from a particular type of wastewater.

FRTR (2002) indicates that costs for UV oxi dation systems using ozone and/or hydrogen peroxide for the treatment of contaminated groundwater are generally between $36,000 and $3,650,000 per mgd. Costs may be slightly greater fo r wastewater treatment due to increases in the variability of water quality as well as add itional pretreatment requirements (e.g., filtration). The major operating cost for the ozone/hydrogen peroxide system is the cost of electricity for generating the chemicals (Munter, 2001).

Hand et al. (1995) estimated that annual costs for a 1 mgd UV oxidation system using titanium dioxide range from approximately $139,000 to $433,000 per mgd. Note that these costs were developed when this technology was still fairly ne w, therefore, actual costs may be lower due to advances in the technology or an incr ease in the number of manufacturers.

Factors that may influence th e cost of UV oxidation include:

• 

### Types and concentration of contaminants - affect oxidizer selec tion, oxidizer dose, UV light intensity, and contact time

• 

### Influent concentration (i.e., de struction efficiency required)

• 

### Flow

• 

### Pretreatment and post treatment requirements (FRTR, 2002).

Neither of the cost estimates above includes pre- or post-treatment costs. For low effluent levels in wastewater, pretreatment is necessary to ensure that the UV rays effectively reach and destroy the compounds; suspended solids and other contam inants may reduce the destruction efficiency of UV oxidation. Sand or dual media filtration sh ould be sufficient for this purpose, however, the exact type of treatment necessary will be site-specific and depend on influent water quality.

Sonochemical Degradation



### The two main mechanisms for sonochemical de gradation of pollutants are thermal reaction inside cavitating bubbles and radical ch emistry (Destaillant s et al., 2001).

Sonochemical degradation involves the use of ul trasound to create micron size gas cavities in water. These cavities collapse, generating a localized zone of high temperature (about 5,000°C) and pressure (greater than 100 atm). This pr ocess is called acoustic cavitation. Any organic molecules diffused in these gas bubbles before they collapse are rapidly hydrolyzed or oxidized to less toxic molecules such as carbon dioxide , water, and hydrochloric acid (Bruce, 2004).

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-13

### Cavitation is influenced by vapor pressure, surface tension, and hydrophobicity (Price, et al., 2004). As sound intensity increases, higher temper atures and pressures exist within the bubble interior, which increases the decomposition ra te of pollutants (Hua and Zhang, 2000).

In addition to the direct high te mperature and pressure destructi on of organic molecules within these localized zones, the ther molysis of water to release ra dical species (e.g., •H, •OH, and HOO•) and hydrogen peroxide is an important mechanism for the or ganic chemical destruction. These free radicals attack organic compounds pr esent in water, comprising another mechanism of sonochemistry (Hua and Zhang, 2000). Free radical formation is also enhanced with increased sound intensities, thus, further increas ing decomposition rates (Hua and Zhang, 2000).

Most studies on sonochemical degr adation have been performed us ing frequencies of 20-25 kHz. However, reaction rates may vary si gnificantly with variations in fr equencies (Price et al., 2004). For example, frequencies dictate the type of cavit ation that takes place. Under low frequencies transient cavitation occurs in wh ich bubbles undergo only a few osc illations before collapse. A larger concentration of radica ls will be formed on each individual bubble collapse during this type of cavitation because bubbles collapse from a larg er radius and thus, contain more water vapor. At high frequencies, a bubble undergoes hundreds or thousa nds of oscillations, known as stable cavitation. Under stable cavitation more collapse events occur per unit time, which may increase the overall rate of radi cal production (Price et al., 2004). It is also important to note that at higher frequencies, cavitation is produced in the liquid phase far from the surface of the transducer, thus protecting it from erosion cau se by bubble implosion (Destaillants et al., 2001). However, these situations have only been test ed in laboratories and not on larger, full-scale

reactors.

Destaillants et al. (2001) invest igated how laboratory conditions translate into larger-scale operation. They found that reac t rates for the nonvolatile cont aminants tested increased by factors of 2 to 5. Destaillants et al. (2001) also found that wh ile the reaction rates for one nonvolatile contaminant only varied by about 15% for various flow rates, re action rates for another varied by more than 50% depending on flow rate. In addition, degradation rates may also vary with reactor size and configuration, temperatur e, and influent contaminant concentration (Destaillants et al., 2001). Therefore, extensiv e testing is important to determine the optimal operating frequency for destruction in a particular type of wastewat er, as well as to determine if any harmful byproducts are formed during sonochemical oxidation.

There are many engineering and scientific issues that still need to be resolved before the technology can be used on a commerci al scale. These issues include scaling up bench test to full scale processes, variation of the sound field in reactors, and effects of source water quality associated with sonochemical degradation. The ge neral lack of full scale operating data prohibits determinations of the technology’s effectivenes s for any particular pollutant or group of pollutants.

Also, cost information for this technology is not available. However, since the main mechanism involved in sonochemical degradation is the sa me mechanism that destroys pollutants in UV oxidation (i.e., radical chemistry), it is not likely that sonochemical degradation would be used in

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-14

### place of UV oxidation, especially given the li mited performance data for sonochemical degradation.

C.7 References

Arce Systems, Inc. 2002. Personal communica tion with Jerry Jones. For purchase of 1000 pounds of 12x40 coconut shell GAC and 12x40 virgin activated carbon derived from bituminous coal in 55 lb sacks. May.

Bruce, David A. 2004. Personal communication (email). July.

Calgon Carbon Corporation. 2002. Personal co mmunication. For product called OLC 12x40, a coconut based GAC, with mesh size 12x40. June.

Destaillants, H., T.M. Lesko, M. Knowlton, H. Wallace, M.R. Hoffma nn. 2001. Scale Up of Sonochemical Reactors for Water Treatment. Ind. Eng. Chem. Res.; 40(18), 3855 3860.

Environtrol. 2003. Personal communication with Bob Scherrer. For virgin GAC 12x40 coal, regular activity. May.

Federal Remediation Technologies Roundtable (FRTR). 2002. Remediation Technologies Screening Matrix and Reference Guide, Version 4.0. Online at http://www.frtr.gov/matrix2/top_page.html.

Grieco, Scott A. 2007. Advanced Mercury Trea tment Technologies: Strategies to Successfully Meet Lower Limits. Clearwaters: Winter 2007.

Hand, D.W., D.L. Perram, and J.C. Crittenden. 1995. Destruction of DBP Precursors with Catalytic Oxidation, American Water Works As sociation Journal, Vol. 87, No. 6, pp. 84 96.

Hua, I. and G. Zhang. 2000. Cavitation Chemistry of Polychlorinated Biphenyls: Decomposition mechanisms and Rates. Enviro nmental Science and Technology. Vol. 34, No. 8 (1529 - 1534).

Kidman, R.B. and K.S. Tsuji. Preliminary Cost Comparison of Advanced Oxidation Processes. Los Alamos National Laboratory. SJB 1-21-91.

Klasson, K.T., D.T. Bostick, P.A. Taylor, L.L. Farr. 1999. Removal of Trace-Level Mercury from Surface Water. For Presentation at the Air and Waste Manage ment Association’s 92nd Annual Meeting and Exhibition, June 20-24, 1999, St. Louis, MO.

Klasson, K.T., D.T. Bostick, L.L. Farr, D.R. Mc Taggart, P.A. Taylor. 2000. Demonstration of Mercury Sorbents to Meet DOE Customer Needs. ORNL/TM-2000/12.

MWRA/MASCO Mercury Workgroup. 1997. E nd-of-Pipe Subcommittee Mercury Workgroup Pretreatment Guidance Manual. Online at www.masco.org/mercury/pretreatment/index.html.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-15

### Metcalf and Eddy. 2003. Wastewat er Engineering: Treatment a nd Reuse. Fourth Edition. McGraw Hill: Boston.

Munter, Rein. 2001. Advanced Oxidation Proce sses - Current Status an d Prospects. Proc. Estonian Acad. Sci. Chem. 50(2), 59-80.

National Drinking Water Clearinghouse (NDWC) . 1997. Tech Brief: Ion Exchange and Demineralization. Online at http://www.ne sc.wvu.edu/ndwc/pdf/OT/ TB/TB4_IonExchange.pdf

Naval Facilities Engineering Command (NAVFAC ). 2008. Environmental Restoration and BRAC: Granular Activated Carbon (GAC) Adsorption (Liq uid Phase). Online at https://portal.navfac.navy.mil/portal/pa ge?_pageid=181,5782928&_dad=portal&_schema=POR
TAL.

Powell, Tony. 2000. Treatment of PCBs in Water. Purifics ES Inc.

Price, G.J., M. Ashokkumar, F. Grieser. 2004. Sonoluminescence Quenching of Organic Compounds in Aqueous Solution: Frequency Eff ects and Implications for Sonochemistry. Journal of American Chemical Society, 126, 2755-2762.

Rahuman, M., L. Pistone, F. Trifirò, S. Miertus. 2000. Destruction Technologies for Polychlorinated Biphenyls (PCBs). UNIDO Pu blications: Proceedings of Expert Group Meetings on POPs and Pe sticides Contamination.

Sherbondy, John. 2004. Tigg Corporation. Personal communication. July.

TN & Associates. 1998. Mercury Treatability Study Final Report, Oak Ridge Y-12 Plant, Oak Ridge, Tennessee. BJC/OR-46.

U.S. EPA. 2002. Arsenic Rule Training Sess ions: Waste Disposal Issues. Online at http://www.epa.gov/safewater/ars/pr esentations/trai n6-residuals.pdf.

U.S. EPA. 2000. Arsenic Removal from Dri nking Water by Ion Exch ange and Activated Alumina Plants. EPA 600-R-00-088.

U.S. EPA. 1997. Capsule Report: Aqueous Me rcury Treatment. EPA 625-R-97-004. Office of Research and Development, Washington D.C.

U.S. EPA. 1996. Capsule Report: Reverse Osmosis. EPA 625-R- 96-009. Office of Research and Development, Washington D.C.

U.S. Environmental Protection Agency (EPA). 1991. Engineering Bulletin: Granular Activated Carbon Treatment. EPA/540/2-91/024.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-16

### U.S. EPA. 1980. Summary Report: Control and Treatment Technology for the Metal Finishing Industry, Sulfide Precipit ation. EPA 625/8-80-003.

West General. 2004. Out of the Box Chem ical Specifications: Mercury. Online at http://www.westgeneral.com/out ofthebox/masterframeset.html.

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-17June 2008 Appendix D. Vari ance Procedures Based on Adverse Economic Impacts D-1 

## Appendix D. Variance Procedures Based on Adverse Economic Impacts

This appendix describes the analysis of the poten tial for compliance costs to result in substantial and widespread economic and social imp acts pursuant to EPA (1995) guidance.

D.1 Analysis for Public Sector Entities

Public sector entities will evaluate whether the compliance costs associated with WQBELs will impose a substantial financial impact (estimate ch ange in household sewer bills resulting from the compliance costs; evaluate financial health of the community), and whether such an impact would have widespread advers e economic and social impact.

Substantial Impacts



### The analysis of whether compliance costs would impose a substantial financial impact involves the following steps.

Verify Project Costs

The first step of an economic analysis of a publicly financed project is to evaluate the appropriateness and the cost-effectiveness of th e proposed project. P ublic entities should consider a broad range of discharge mana gement options including pollution prevention, end-of-pipe treatment, and upgrades or additions to existing treatment. Specific types of pollution prevention activities that s hould be considered are (EPA, 1995):

• 

### public education

• 

### change in raw materials

• 

### substitution of process chemicals

• 

### change in process

• 

### water recycling and reuse

• 

### pretreatment requirements.

EPA (1995) provides worksheets to summarize ge neral information regarding the proposed pollution control project.

Calculate Annualized Cost per Household

Since capital costs will be paid over several years, a nnualized costs are used to evaluate the economic burden to the community. The capital porti on of project costs is financed by issuing a municipal debt instrument such as a ge neral obligation bond or a revenue bond. Local governments may also finance capital costs using bank loans or state infrastructure loans (e.g., State Revolving Fund loans). State and federa l grant funding may also be available for technology upgrades or other treatment options. EPA (1995) also provides a worksheet for calculating the total annualized cost of the project.

### To assess the burden that polluti on control costs are e xpected to have on hous eholds, an average annualized pollution control cost per household is calculated for all househol ds in the community that would bear project costs. To evaluate substantial impact s, therefore, applicants should determine which households will actually pay for po llution control, as well as what proportion of the costs will be borne by households. These ap portioned project costs are then added to existing pollution control costs paid by households. EPA ( 1995) provides worksheets for calculating the cost per household.

Municipal Preliminary Screener

Whether or not the community is expected to incur “substantial” economic impacts due to the pollution control project is determined by jointly c onsidering the results of two tests. The first test is a “screener” to establish whether the co mmunity can clearly pay for the project without incurring any substantial impacts. The Municipa l Preliminary Screener, or MPS, is the total annual pollution control costs per household (existing costs plus those attributable to the proposed project) as a percentage of MHI. EPA (1995) provides a worksheet for calculating and evaluating the MPS.

If the MPS value is less than 1.0, there is little potential for substantial impacts and the analysis can conclude with a determination of no substantial impact. Communities are expected to incur mid-range impacts when the ratio of total annua l compliance costs to MHI is between 1.0% and 2.0%. If the average annual cost per househol d exceeds 2.0%, then the project may place an unreasonable financial burden on many of the households within the community. In either case, applicants move on to the Secondary Test to demonstrate substantial impacts.

Secondary Test

The Secondary Test, which provides indication of the community’s ability to obtain financing and the socioeconomic health of the community, consists of six indicators for the community:

• 

### Debt Indicators

o Bond Rating - a measure of a jurisdic tion’s ability to repay its debt

o Overall Net Debt as a Percent of Full Market Value of Taxable Property - a measure of debt burden on resi dents within the jurisdiction

• 

### Socioeconomic Indicators

o Unemployment Rate - a measure of th e economic health of the jurisdiction

o MHI - a measure of the income of the jurisdiction

• 

### Financial Management Indicators

o Property Tax Revenue as a Percent of Full Market Value of Taxable Property - a measure of the capacity to support debt based on the wealth of the jurisdiction

o Property Tax Collection Rate - a measure of the strength of the local government administration, and of the jurisdiction’s acceptance of property tax rates.

Exhibit D-1 summarizes the indicators, and the scor ing of the values following EPA (1995) guidance. EPA (1995) provides worksheets for calculating the secondary score.

June 2008 Appendix D. Vari ance Procedures Based on Adverse Economic Impacts D-2

### Exhibit D-1. Sec ondary Indicators

Evaluation Indicator Weak (score of 1 point) Mid-Range Strong (score of 2 points) (score of 3 points)

Bond Rating Below BBB (Standard and Poor’s) Below Baa (Moody’s) BBB (Standard and Above BBB (Standard and Poor’s) Poor’s) Baa (Moody’s) Above Baa (Moody’s)
Overall Net Debt as Percent of Above 5% 2% - 5% Below 2% Full Market Value of Taxable Property

Unemployment More than 1% above National average More than 1% below National average National average

MHI More than 10% below State median More than 10% above State median State median Property Tax Revenues as a Above 4% 2% - 4% Below 2% Percent of Full Market Value of Taxable Property Property Tax Collection Below 94% 94% - 98% Above 98% Source: See U.S. EPA (1995), Table 2-1.



### Applicants then jointly evaluate results of the MPS and Secondary Test. Exhibit D-2 summarizes the scoring. An “X” in the matrix indicates that the impact is likely to be substantial. Similarly, the “ 9 ” indicates that the impact is not likely to be substantial. Finally, the “?” symbol in the exhibit indicates that the impact is unclear. For results falling into either the “X” or “?” category, applicants proceed to determine whether the impacts would also be widespread. EPA (1995) provides further discussi on of evaluating the results.

Exhibit D-2. Substant ial Impacts Matrix Municipal Preliminary Screener Secondary Score Less than 1.0% Between 1.0% and 2.0% Greater than 2.0% Less than 1.5 ? X X Between 1.5 and 2.5 9 ? X Greater than 2.5 9 9 ? Source: See EPA (1995), Table 2-2.



### Widespread Impacts



### The financial impacts of undertak ing pollution controls could poten tially cause far-reaching and serious socioeconomic impacts. Conversely, adverse financial imp acts experienced by the affected entities may be offset by the expenditure s on pollution controls to attain water quality standards, since these expenditu res do not vanish from the community but become business revenues and household incomes. Therefore, applicants must ex amine the estimated change in socioeconomic conditions that would result from compliance (EPA, 1995).

At a minimum, the analysis must (EPA, 1995):

• 

### define the affected community (the geogra phic area where project costs pass through to the local economy)

• 

### consider the baseline economi c health of the community

June 2008 Appendix D. Vari ance Procedures Based on Adverse Economic Impacts D-3• 

### evaluate how the proposed project will affect the socioeconomic well-being of the community.

For municipal control projects, the affected community is most often the immediate municipality. There are, however, exceptio ns where the affected community includes individuals and areas outside the immediate commun ity. For example, if business activity in the region is concentrated in a nearby community and not in the immediate community, then the nearby community may also be affected by loss of income in the immediate community and should be included in the analysis. If business activity of the region is concentrated in the immediate community, then outlying communities dependent upon the immediate municipality for employment, goods, and services should also be included in the analysis.

To demonstrate that there will be widespr ead impacts, EPA (1995) recommends evaluating changes in the following indicators:

• 

### MHI

• 

### community unemployment rate

• 

### overall net debt as a percent of fu ll market value of taxable property

• 

### property values

• 

### percent of households below poverty line

• 

### community development potential.

The first step in estimating the change in these indicators is to identify their precompliance values. Evaluation of baseline socioeconomic c onditions is important because the extent to which estimated changes can be interpreted as significant depends on the health of the community before compliance. For example, if a community is in a weak condition before compliance but the evaluation of widespread impacts suggests that all of the indicators listed above will remain virtually unchanged, then wide spread impacts have not been demonstrated. Alternatively, if the community is very healthy, the estimated change in the indicators listed above would have to be very large in order fo r widespread impacts to occur. Note that expenditures for pollution controls also become increased household and business incomes (costs to one sector become revenues to another). EP A (1995) provides a worksheet for applicants to qualitatively describe estimated changes.

D.2 Analysis for Private Sector Entities

Private sector entities will ev aluate whether the compliance co sts associated with WQBELs (variances from technology-based standards are no t available) will impose a substantial financial impact on the company (estimate impact of costs on profitability, liquidity, solvency, and leverage; compare to industry benchmarks; establis h that the company would be forced to curtail operations or shut down), and whether such an impact would have widespread adverse economic and social impact (the loss of employment and incomes would ha ve a widespread impact on the community).

Substantial Impacts



### To evaluate whether compliance costs will be s ubstantial, private sector entities will verify project costs and calculate the a nnual cost of the pollution contro l project, and then conduct a

June 2008 Appendix D. Vari ance Procedures Based on Adverse Economic Impacts D-4June 2008 Appendix D. Vari ance Procedures Based on Adverse Economic Impacts D-5 

### financial impact analysis. Considerations for verifying project costs a nd calculating annual costs are similar to those described above for public se ctor entities. EPA ( 1995) provides a worksheet for calculating the annualized cost of pollution control. 11

The purpose of the financial impact analysis is to assess the extent to wh ich existing or planned activities and employment will be reduced as a result of meeting water quality standards. There are four tests divided into a primary measure and three secondary measures of financial impacts:

• 

### Primary Measure

o Profit—how much will profits decline due to pollution control expenditures?

• 

### Secondary Measures

o Liquidity—how easily can an entity pay its short-term bills?

o Solvency—how easily can an entity pay its fixed and long-term bills?

o Leverage—how much money can the entity borrow?

Each type of test measures a different aspect of a discharger’s financ ial health. The primary measure evaluates the extent to which an applican t’s profit rate will change, and compares the profit level to typical profits in that industry. The secondary measures provide additional information about specific impacts that the discha rger would bear if requ ired to comply with WQBELs. Profit and solvency ratios are calc ulated both with and without the additional compliance costs (taking into consideration the en tity’s ability, if any, to increase its prices to cover part or all of the costs). Comparing thes e ratios to each other and to industry benchmarks provides a measure of the impact on the entit y. EPA (1995) provides worksheets for evaluating the primary and secondary measures.

Widespread Impacts



### Applicants that demonstrate that pollution contro l costs would have a substantial financial impact proceed to evaluate whether such an impact w ould have a widespread impact on the surrounding community. The steps in the analysis are identi cal to those described above for public sector entities.

D.3 References

United States Environmental Protection Agency (U.S. EPA). 1995. Interim Economic Guidance for Water Quality Standards. EPA 823-B-95-002. March.

11 Note, however, that entities that pay corporate income taxes may be able to deduct interest payments from their

taxes.June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-1 

## Appendix E. BMPs and Unit Costs for Nonpoint Sources

As discussed above, some level of incremental controls may be needed for runoff and erosion control from agricultural and forest lands, urban areas, and ab andoned mine sites. This section provides a description of potential controls and associated unit costs, where available.

E.1 Agricultural and Forest Lands

To control or reduce erosion and runoff of mercur y-containing soils from agricultural and forest lands as part of the Willamette Basin Merc ury TMDL, ODEQ recommends the implementation of sediment/erosion BMPs (ODEQ, 2006a). Howeve r, implementation of these BMPs is already required under existing state and fe deral regulations and plans. Fo r example, the Forest Practice Act and Agricultural Water Quality Management Area Plans require implementation of BMPs to minimize soil erosion and prevent runoff or use of products that contain harmful pollutants (ODEQ, 2006b). Thus, an incremental level of control would only be re quired if implementation to meet existing water quality standards would not also achieve compliance with the revised criteria.

Exhibit E-1 shows various practices that can be a dopted to control soil/sediment erosion.

Exhibit E-1. Eros ion Control Practices
Practice Description Protective cover Plant cover (as well as othe r covers such as mulc h, bark dust, rock, and concrete) protects soils from erosion.
Barriers Barriers slow wind and water and trap eroded soils. Barriers include grass strips in a field crop, silt f ences around a construction site, or a windbreak. Reduce slope length and steepness In general, plants can protect slopes that are less than 50% (2:1 gradient or 2 foot run for every 1 foot drop), mulches protect slopes less than 33 percent (3:1 gradient), and erosion control structures like terraces may be needed for slopes more than 50 %. Buffers Trees, shrubs, and/or grass slow water speed, filter pollutants, and trap sediment. Grass filter strips are effective on slopes less than 10 percent. Contour buffer strips combine contour farming (see below) with strips of permanent grass. A ratio of cultivated to buffer strip width between 4:1 to 9:1 is best. Riparian buffers are tree, shrub, and/or grass strips that protect streams, ditches, lakes, and ponds and may be 35 to 300 feet wide, based on site conditions and your goals. Conservation tillage Reduce the amount of tillage and leave at least 30% cover from crop residue after harvest and during winter months. Soil loss is reduced by 50% compared to bare soil. Contour farming Run rows "on the level" around the hill rather than up and down the slope. Crop rows form hundreds of small dams that slow water and reduce soil loss up to 50% compared to farming up and down a slope. Cover crops temporarily protect the soil until the main crop is planted.

### Exhibit E-1. Eros ion Control Practices
Practice Description Crop rotation Changes crops each year in a certain order. A rotation that includes grasses, legumes, or small grains will break pest cycles and reduce erosion compared to continuous row crops that may build up pest populations and leave soil open to erosion. Erosion control structure Drop water safely to a lower elevation. Rock, metal, or concrete structures prevent the soil from forming gullies. Grassed waterway A natural or constructed drainage way is graded and shaped to form a smooth, concave channel. This area is seeded to suitable vegetation. Runoff water that flows down the dr ainage way flows across the grass rather than tearing away soil and forming a gully. An outlet is often installed at the base of the drainage way to stabilize the waterway. Pasture management Balance livestock numbers, forage, and water. Pastures with at least 70% plant cover have little erosion and produce more forage. Set aside area where animals are held to protect pastures when soils are wet or plants are recovering from grazing. Terraces Long, low dikes of earth that follow the contour of the hill. They break long slopes into shorter runs, slow runo ff, and trap sediment. If terraces aren’t practical, consider planting 1-foot stri ps of stiff, perennial plants that are perpendicular to the slope of the land with the same spacing as terraces. Source: Washington County SWCD (1999)



### Many of these BMPs that control the erosion of toxic-containing sediments also reduce stream temperatures and nutrient loads. For example, riparian buffers increase shade cover for streams, cooling instream temperatures. As described in the exhibit, buffers al so slow runoff (reducing erosion), filter pollutants, and trap sediments. In the Stillaguamish River Fecal Coliform, Dissolved Oxygen, pH, Mercury, and Temperat ure TMDL, the Washington Department of Ecology (Ecology) indicates that the key to cont rolling mercury is to control suspended solids levels. However, the implementation plan does not identify specific actions to reduce mercury levels, rather Ecology indicates that mercury reduc tions will occur as part of efforts to improve temperatures through control of sediment (Eco logy, 2007). Thus, it is po ssible that controls being implemented for compliance with baseline standards for nontoxic pollu tants could result in compliance with the revised criteria.

In addition, if incremental controls are nece ssary, the USDA’s National Resources Conservation Service (NRCS) provides tech nical assistance and funding opportunities to agricultural landowners with the mission to conserve, mainta in, or improve natural resources. NRCS’ Environmental Quality Incentives Program (EQIP) is a voluntary conservation program that provides assistance to agricultural producers in a manner that promotes agricultural production and environmental quality as compatible goa ls (NRCS, 2007a). Through EQIP, farmers and ranchers receive financial and technical assist ance to implement structural and management conservation practices that optimize environmenta l benefits on working agricultural land. As part of EQIP, NRCS develops cost estimates fo r various BMPs in Oregon that may be available for funding assistance. Thus, the cost of additi onal BMPs that may be needed under the revised criteria would likely be similar to the NRCS estimates.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-2

### E.2 Mining

In the Willamette Basin mercury TMDL, DEQ does not specify the measures necessary to cleanup mines, only that it will continue effort s to remediate abandoned mine sites to minimize the flow of mercury into adjacent water bodies ( ODEQ, 2006a). The Horse Heaven Mine is an abandoned mercury mine, located in the east-centr al portion of Jefferson County. Potential remedial actions to address the presence of mercury and arsenic in contaminated soils and groundwater may include:

• 

### Excavation and on-site entombment and capping of contaminated soils

• 

### Collection, entombment and capping of solid waste mining debris on-site

• 

### Re-grading of tailings to mitigate mass wasting and off-site migration

• 

### Abatement and mitigation of physical haza rds represented by extant mine portals.

However, the cost of assessment and clea nup at abandoned mines varies widely.

For example, elevated levels of mercury have be en detected in soil at Bonanza Mine in Douglas County. ODEQ has spent about $500,000 to inve stigate the site and remove the most contaminated soil around one area of contaminati on. Black Butte Mine has been identified as a major contributor of mercury to the Cottage Grove Watershed. Although the mine is now abandoned, remnants from past mining activity are stil l readily visible. Site features include: 1) remnants of mining equipment including two mercury-extraction furnaces, tramway, and ore crusher; 2) tailings piles; a nd 3) mine openings (adits and stopes). Through 2004, ODEQ spent about $50,000 from Oregon’s Orphan Site Account for environmental investiga tion of the site.

E.3 Municipal Storm Water

In the Willamette Basin TMDL, DEQ require s all MS4s to address mercury through modifications to existing storm water management plans (SWMP), and all other areas to develop SWMPs for mercury (ODEQ, 2006a). In general, dischargers are required to control pollutants to the maximum extent practicable (MEP) throu gh their SWMPs. As described in Section 2.2.2, ODEQ interprets the MEP requirement to require a ll controls that are reasonable and available. In some areas this level of control may be neces sary for compliance with baseline standards, in which case additional controls for compliance with revised criteria would not be required because all reasonable and availa ble controls are already being implemented. In other areas, however, MEP controls may not be fully implem ented and some incremental level of control may be necessary for compliance with the revise d criteria. Thus, for any situation in which storm water sources are specifically required to control toxic polluta nts to levels that are lower than what would be necessary under the baseline , potential compliance ac tions could include:

• 

### increased or additional nonstructural BMPs – institutional, education, or pollution prevention practices designed to limit genera tion of runoff or reduce the pollutants load of runoff

• 

### structural controls – engin eered and constructed system s designed to provide water quantity or quality control.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-3

### Nonstructural BMPs



### Nonstructural BMPs can be effective in control ling pollution at the sour ce, which in turn can reduce or eliminate the need for costly end-of-pipe treatment or structural controls. Examples include expanding an existing outreach and educ ation program to a larger or new target audience, refocusing source control efforts on pollutants and sources of concern, increasing program compliance efforts, and increasing frequ ency, duration, or efficiency of maintenance practices such as street sweeping.

Street sweeping programs reduce the amount of debris and particulates that enter surface waters. The effectiveness of street sweeping depends on the type and operation of the equipment, sweeping frequency and number of passes, a nd climate (FHWA, 2002). Thus, increasing the frequency of sweeping or changing the type of sw eeper used may result in decreases in pollutant loads. Incremental costs for more extensive sweeping would depend on a municipality’s current sweeping practices and the extent of the increas e needed to reduce toxi c loadings (e.g., the incremental curb miles and whether new sweepers need to be purchased).

For example, most municipalities use mechani cal/brush model sweepers (Minton, 2007). These models are generally only half as effective as vacuum sweepers which are much more effective at removing fine sediments, silts and clays wher e much of the pollution resides. There are two types of vacuum sweepers: wet and dry. The dr y vacuum sweepers remove a greater percentage of small particulates and sediments than the we t vacuum sweepers. Thus, depending on the load reductions needed, switching to either a wet or dr y vacuum sweeper could increase pollutant load reductions to surface waters.

Structural Controls



### There are a variety of structural means to cont rol the quantity and quality of storm water runoff including infiltration systems, detention systems, retention systems, constructed wetlands, filtration systems, and vegetated systems. The cost for any particular structure depends on the type of control, the quantity of water treated, and site-specific factors such as land cost.

Infiltration systems capture runoff and allow it to infiltrate into the ground. These systems provide both water quality and quant ity control. Typically, these sy stems infiltrate water into the ground relatively rapidly (from a few hours up to 72 hours). Howeve r, the primary drawback of infiltration systems is that they are not appropr iate in areas where groundwater is used as a drinking water source. Additional constraints incl ude identifying sites with appropriate soils and risk of failure due to clogging. Exhibit E-2 summarizes the different types of infiltration systems.

Exhibit E-2. Summary of St orm Water Infiltration Systems System Type Description Large capacity of infiltration systems. Basins should be designed to drain within 72 hours in order to prevent mosquito breeding

and possible odor. Infiltration basin

Removes pollutant and helps restore or maintain predevelopment hydrology.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-4

### Exhibit E-2. Summary of St orm Water Infiltration Systems System Type Description Include porous asphalt, porous concrete, modular perforated concrete block, cobble pavers

with porous joints or gaps or reinforced/stabilized turf. Porous pavement systems Only effective in areas not exposed to high volumes of traffic, heavy equipment, and high amounts of sediments in runoff. Appropriate for driveways/streets in residential areas and parking areas in commercial areas.
Infiltration trenches and wells Typically designed to capture only a small volume of water (appropriate to capture first flush of a runoff event). Source: U.S. EPA (1999).



### Detention systems capture runoff and temporarily retain it for later release. Detention systems do not retain a significant permanent pool of water between runoff events. These systems provide quantity and quality control; however, re suspension of particulate matter often occurs. Exhibit E-3 summarizes the different types of detention systems.

Exhibit E-3. Summary of St orm Water Detention Systems System Type Description Primary purpose is quantity control. Typically designed to empty within 24 hours of a runoff event. Detention basin Limited quality control through gravity setting of suspended solids. Earthen basins achieve high levels of quality control by allowing some infiltration (however,

ground water is then a risk of contamination). Same primary purpose as basins – storage to limit downstream effects due to high peak flow

rates. Underground vaults, pipes, and tanks Limit quality control. Source: U.S. EPA (1999).



### Retention systems capture runoff and retain it unt il it is displaced by the next runoff event, and maintain a significant permanent pool volume of water between runoff events. The most common retention system is a retention pond (wet pond). The primary pollutant removal mechanism is sedimentation. These systems can also benefit from added biological and biochemical pollutant removal mechanisms provi ded by aquatic plants and microorganisms. Compared to detention systems, resuspension is less likely due to the presence of a permanent pool of water. The primary constraint to these sy stems is the need for a perennial flow to sustain the permanent pool. Furthermore, these systems t ypically require more la nd than other controls (U.S. EPA, 1999).

Constructed wetland systems are similar to retenti on and detention systems, except that a major portion of the water surface area (for pond system s) or bottom (for meadow-type systems) contains wetland vegetation. These systems can be effective in both quantity and quality control, but, as with natural wetlands, are relatively deli cate and require a water balance to sustain the aquatic vegetation. Sedimentation can especia lly reduce the effectiveness of the system. Pollutant removal in wetlands can occur th rough a number of mechanisms including sedimentation, filtration, volatili zation, adsorption, absorption, microbial decomposition, and plant uptake. Pretreatment of runoff may be n ecessary for these systems (U.S. EPA, 1999).

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-5

### Filtration systems use some combination of a gra nular filtration media rem ove constituents found in runoff such as sand, soil, organic material, car bon, or membranes. Often these systems treat only the first half inch to inch of runoff, and ar e common at small sites such as parking lots and developments, in areas with high pollution potentia l such as industrial areas, or in highly urbanized areas where land availa bility or costs preclude the use of other controls (U.S. EPA, 1999). Exhibit E-4 summarizes the different types of filtration systems.

Exhibit E-4. Summary of St orm Water Filtration Systems System Type Description Most common system is the Austin sand filter. Runoff first enters a sedimentation basin where coarse particles are removed by gravity

settling. Surface sand filter The filter bed consists of sand with a grav el and perforated pipe under-drain system to capture the treated water. Underground vault sand filter Common systems are the D.C. sand filt er and the Delaware sand filter. Basic design premise is the same as the surface sand filter. Designed to mimic the functions of a natural forest ecosystem for treating storm water

runoff. Biofiltration/bioretention systems Variation of surface sand filter where sand filtration media is replaced with a planted soil bed. Pollutants are removed by a number of processes including adsorption, filtration,

volatilization, ion exchange, and decomposition. Source: U.S. EPA (1999).



### Vegetated systems (biofilters) such as swales and filter strips are desi gned to convey and treat either shallow flow (swales) or sheetflow (filter strips) runoff. Open channel vegetated systems are alternatives to the tradit ional curb-and-gutter and storm sewer conveyance systems. By conveying storm water runoff in vegetated systems treatment, storage, and infiltration can be provided prior to discharge to the st orm sewer system (U.S. EPA, 1999). Exhibit E-5 summarizes the different types of vegetated systems.

Exhibit E-5. Summary of St orm Water Vegetated Systems System Type Description Densely vegetated, uniformly graded areas that intercept sheet runoff from impervious surfaces

such as parking lots, highways, and rooftops. Grass filter strips Designed to trap sediments, to par tially infiltrate runoff, and to reduce the velocity of the runoff. Frequently used as a pretreatment system prior to storm water being treated by BMPs such as

filters or bioretention systems. Broad, shallow channels with a dense stand of vegetation covering the side slopes and channel

bottom. Vegetated swales Designed to slowly convey storm water runoff, and in the process trap pollutants, promote infiltration, and redu ce flow velocities. Swales can be either wet or dry. Source: U.S. EPA (1999).



### The performance of BMPs can vary considerably based on differences in the design criteria and performance standards. Factor s that influence performance a nd design include size of the drainage area, the level of watershed impervi ousness, duration and volume of runoff, and the

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-6

### land use of contributing drainage areas. Ranges for pollutant removal for various controls are summarized in Exhibit E-6

.

Exhibit E-6. Potential Pollut ant Removal Efficiencies for Stru ctural Storm Water Controls BMP Type Suspended Solids Metals Infiltration basin 1 50% - 80% 50% - 80% Infiltration trenches 1 50% - 80% 50% - 80% Porous pavement 1 65% - 100% 65% - 100% Detention basins 30% - 65% 15% - 45% Retention basins 50% - 80% 50% - 80% Constructed wetlands 50% - 80% 50% - 80% Surface sand filters 2 50% - 80% 50% - 80% Other media filters 2 65% - 100% 50% - 80% Vegetated filter strips 50% - 80% 30% - 65% Grassed swales 30% - 65% 15% - 45% Source: U.S. EPA (1999); Caltrans (2004). 1. Removal is considered to be 100% when the water is infiltrated and not discharged to surface waters. 2. Filters must be placed off-line to assure continued functioning; only provide treatment based on a design storm.



### The cost of constructing storm water controls depends on site conditions and drainage area. Furthermore, there are often economies of scale, making it difficult to develop a unit construction cost. As described below, U.S. EPA (1999) and the Caltrans (2001) provide cost estimates for various controls.

EPA’s Engineering and Analysis Division (E AD) reviewed and summarized the available information related to expected costs of storm water controls (U .S. EPA, 1999). EAD identified only three studies that systemati cally evaluated the construction co sts associated with structural controls since 1985. EAD used thes e studies to develop construction costs for specified drainage size and percent impervious cover ( Exhibit E-7 ).

Exhibit E-7. Estimated Costs of Storm Water Controls in the U.S.

BMP Type Typical Construction Cost ($/Control) Approximate Unit Cost Drainage Size (Acre) ($/acre) 35% Impervious Cover (Residential)
Retention Basin $136,500 50 $2,730 Wetland $170,500 50 $3,410 Grass Swale $5,000 5 $1,000 Filter Strip $0-$12,500 5 $0-$2,500 65% Impervious Co ver (Commercial)
Infiltration Trench $61,500 5 $12,300 Infiltration Basin $20,500 5 $4,100 Sand Filter 1 $47,500-$95,500 5 $9,500-$19,100 Bioretention $82,000 5 $16,400 Source: U.S. EPA (1999); escalated from 1997 dollars to 2007 dollars using the Environmental News Record (ENR) Construction Cost Index (CCI) and round to the near $500. 1. Range accounts for design variations.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-7

### In addition to capital costs, additional costs include design, contingency, and permitting costs; land costs; and operation and maintenance (O&M) costs. EPA (1999) estimated that the design, contingency, and permitting costs equal approximat ely 25%-32% of the base construction costs. Land costs are extremely variable. For example, little or no land acquisition may be needed for a particular storm water control resulting in low or zero additi onal costs. However, if land acquisition is needed for the c onstruction of a storm water cont rol, the cost could potentially outweigh the design and construction costs combined.

EPA (1999) indicates that most studies estimate O&M costs as a fraction of base construction costs. O&M costs vary across controls and ma y also vary based on site and region specific parameters. Potential O&M costs are presented in Exhibit E-8

.

Exhibit E-8. Potential Annual O& M Costs for Storm Water Controls Control Type Percent of Construction Cost Infiltration basin 1%-10% Infiltration trenches 5%-20%

Detention basins <1% Retention basins 3%-6% Constructed wetlands 2%-6%

Surface sand filters 11%-13% Bioretention 5%-7% Vegetated filter strips $320/acre (maintained)
Grassed swales 5%-7% Source: U.S. EPA (1999).



### The Portland Bureau of Environmental Serv ices (BES) has also conducted a number of demonstration projects aimed at reducing the vo lume of storm water and pollutant loadings entering its combined sewer system. The projec t BMPs provide runoff vo lume control and water quality benefits, while impr oving the existing landscape:

• 

### Storm water planters – vegetative landscapi ng added to parking ga rages and lots that capture and infiltrate runoff from paved surf aces; adds attractive green space to urban

areas

• 

### Curb extensions – landscaped add-ons to exis ting curbs designed to capture runoff from streets and side walks; can increase pedestrian safety

• 

### Pervious pavers – use of paving blocks (rather than impervious asphalt) that allow storm water infiltration

• 

### Landscape infiltration basin – landscaped basin and captures storm water

• 

### Ecoroof - cover roof top with vegetation to ab sorb/retain storm water; roofscaping covers and protects the waterproofing and structur al components of a roof, which extends the life of a conventional roof.

Exhibit E-10 provides a summary of various stor m water BMP demonstration projects implemented throughout Portland. Portland BES and EPA grants funded some part of most of the projects.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-8

### Exhibit E-10. Portland-Area Storm Water BMP Demonstration Projects

BMP Description Total Project

Cost Impervious Unit Benefit Area Treated Cost (sf) ($/sf) Reduces peak flows and retains storm water volumes to reduce CSOs NE Fremont Street - curb extension $16,400 4,500 $3.64

Reduces peak flows and retains storm water volumes to reduce CSOs SE Ankeny - 2 curb extensions $11,946 7,300 $1.64

Reduces peak flow from 25-yr storm by 88% NE Siskiyou - 2 curb extensions $17,000 9,300 $1.83

SW 12th Avenue - 4 consecutive planters $34,850 7,500 $4.65 Reduces peak flow from a 25-yr storm by 70% ReBuilding Center - 2 planters with pervious parking lot $108,232 35,000 $2.79 Treats >870,000 gallons/year of storm water onsite Mississippi Commons - planters for building complex $42,105 25,000 $1.68 Treats 500,000 gallons/year of storm water onsite Liberty Centre Parking Garage - 2 planters $75,530 36,155 $2.10 Treats most storm water from area

East Holladay Park - new pervious pavers parking lot $165,000 5,225 $31.58 Complete onsite storm water treatment

Substantial reduction in runoff from the roof; extends roof life. Multnomah Building - ecoroof $179,807 11,900 $15.11

Manages about 768,000 gallons of potential storm water; extends roof life. Hamilton West Apartments - ecoroof $127,500 8,400 $15.18

Oregon Natural Resources Council - pervious pavers; infiltration basin $76,731 5,750 $6.00 Complete onsite storm water treatment

Barrington Square Apartments - infiltration basins and mini soakage trenches $54,200 16,585 $3.25 Removes >350,000 gallons/year of runoff

Page 19 LLC – smaller parking lot, gravel courtyard, infiltration basin, and landscape areas $37,080 10,000 $3.80 Treats most storm water from area

Natural Resource Program Eastside Field Office - swales, infiltration basin, and vegetated filter $55,183 14,000 $3.94 Removes >314,000 gallons/year of runoff from the sewer

Reed College Apartments - soakage trench $33,042 12,000 $2.75 Removes >269,000 gallon/year of runoff from the sewer Wattles Boys and Girls Club - infiltration facilities/basins, subsurface sand filter; and 2 planters $56,581 21,000 $2.60 Removes >314,000 gallons/year of runoff from the sewer

Sources: Portland BES (2006; 2005a; 2005b; 2005c; 2004a; 2004b; 2003a; 2003b; 2002a; 2002b; 2002c; 2002d; 2002e; 2002f; 2001; 1999). Costs in project year dollars CSO = combined sewer overflow sf = square feet



### E.4 References

California Department of Transportation (Caltr ans). 2004. BMP Retrofit Pilot Program – Final Report. January.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-9

### Federal Highway Administration (FHWA). 2002. St ormwater Best Management Practices in an Ultra-Urban Setting: Selection and Monitoring. May.

Minton, Gary. 2007. The Street Sweep. Online at http://www.stormwaterauthority.org/ library/view_article.aspx?id=872.

Oregon Department of Environmental Quality (ODEQ). 2006a. Willamette Basin TMDL - Chapter 14: Water Quality Management Plan. September.

Oregon Department of Environmental Qualit y (ODEQ). 2006b. Assessment Methodology for Oregon’s 2004/2006 Integrated Report on Water Quality Status.

National Resources Conservation Service (N RCS). 2007a. FY08 Environmental Quality Incentives Program (EQIP) – Oregon. October.

Portland Bureau of Environmental Services (B ES). 2006. East Holladay Park. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES ). 2005a. NE Fremont Street Green Street Project. Online at http://www.portlandonline.co m/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES). 2005b. SW 12th Avenue Green Street Project. Online at http://www.portlandonline.co m/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (B ES). 2005c. ReBuilding Center. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES ). 2004a. SE Ankeny Green Street Project. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES). 2004b. Mississippi Commons. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES). 2003a. NE Siskiyou Green Street Project. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (B ES). 2003b. Multnomah Building Green Roof. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES ). 2002a. Liberty Centre Parking Garage. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (B ES). 2002b. Oregon Natural Resources Council. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-10

### Portland Bureau of Environmental Services (B ES). 2002c. Barrington Square Apartments. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES). 2002d. Page 19 LLC. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES ). 2002e. Natural Resource Program Eastside Field Office. Online at http://www.portlandonline. com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES). 2002f. Reed College Apartments. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (B ES). 2001. Wattles Boys and Girls Club. Online

at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES ). 1999. Hamilton West Apartments Ecoroof. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&

.

United States Environmental Protection Agency (U.S. EPA). 1999. Prel iminary Data Summary of Urban Storm Water Best Ma nagement Practices. August.

Washington County Soil and Water Conservation District (SWCD). 1999. Protection Your Land from Erosion. January.

Washington Department of Ecology (Ecology). 2007. Stillaguamish River Fecal Coliform, Dissolved Oxygen, pH, Mercury, and Temperatur e Total Maximum Daily Load: Water Quality Implementation Plan. June.

June 2008 Appendix E. BMPs and Unit Costs for Nonpoint Sources E-11

## Appendix F. Sample Facility Results and Statewide Extrapolation

This appendix provides a summary of the sample facility results and show s the extrapolation of statewide costs.

F.1 Baseline Criteria

Exhibit F-1 summarizes the potential compliance costs to the sample facilities associated with the baseline criteria scenario.

Exhibit F-1. Potential Total Annual Compliance Costs for Sample Facili ties: Baseline Criteria (millions 2007$)

June 2008 Appendix F. Sa mple Facility Results and Statewide Extrapolation F-1 

### Exhibits F-2 and F-3 show the extrapolation of the random sample results, and addition to the certainty sample results with and without I&I costs for reduci ng arsenic in municipal sewer systems, respectively, for the baseline scenario. There are no costs for either of the minor facilities in the random sample, as well as no data; expansion of this sample is unlikely to change this result due to the lack of monitoring requirements for toxic pollutants for these facilities. Facility Name Discharger Category Total Baseline Costs Total Baseline Costs with I&I without I&I Certainty Sample Eugene/Springfield WPCF Major Municipal $0.25 $0.25 Portland Columbia Blvd WWTP Major Municipal $0.050 - $10.7 $0.050 Salem Willow Lake WWTP Major Municipal $0.17 - $3.87 $0.17 St Helen-Boise WWTP Major Municipal 1 $0 - $0.025 $0 - $0.025 Oregon Steel Mills Minor Industrial $0 - $0.025 $0 - $0.025 Random Sample Astoria WWTP Major Municipal $0 - $0.40 $0 Brookings WWTP Major Municipal $0 $0 Coos Bay WWTP #2 Major Municipal $0 $0 Kellogg Creek WWTP Major Municipal $0.10 - $0.43 $0.10 McMinnville WRF Major Municipal $0.11 - $0.46 $0.11 North Bend WWTP Major Municipal $0 - $0.17 $0 Rock Creek WWTP Major Municipal $0.15 $0.15 Tri-City S. D. Major Municipal $0.10 - $1.13 $0.10 Woodburn WWTP Major Municipal $0.10 - $0.15 $0.10 - $0.15 Blue Heron Paper Major Industrial $0.025 $0.025 Heinz Food Major Industrial $0 $0 Pope and Talbot Major Industrial $0.025 $0.025 Reynolds Metals Major Industrial $0 $0 Shady Cove WWTP Minor Municipal $0 $0 Boise Cascade, Elgin Mill Minor Industrial $0 $0 1. Dominated by industrial flow.June 2008 Appendix F. Sa mple Facility Results and Statewide Extrapolation F-2 

### Exhibit F-2. Potential Annua l Statewide Baseline Compliance Costs: Includes I&I Costs (millions of 2007$) Sample Statewide Category Total Annual Cost Number of Facilities Average Cost per Facility Number of Facilities 1 Extrapolated Annual Cost

Certainty Sample Multiple 2 $0.47 - $14.9 5 NA 5 $0.47 - $14.9 Random Sample Major Municipals $0.56 - $2.90 9 $0.062 - $0.32 45 $2.81 - $14.5 Major Industrials $0.050 4 $0.013 27 $0.34 Total $1.08 - $17.8 18 NA 77 $3.62 - $29.7 Note: Detail may not add to totals due to rounding. NA = not applicable 1. Random sample results extrapolated to total number in category less number in certainty sample. 2. Large flow municipals (one of which is dominated by industrial flow) plus one minor industrial.



### Exhibit F-3. Potential Annua l Statewide Baseline Compliance Costs: Excludes I&I Costs (millions of 2007$) 1 Sample Statewide Category Total Annual Cost Number of Facilities Average Cost per Facility Number of Facilities 1 Extrapolated Annual Cost

Certainty Sample Multiple 2 $0.47 - $0.52 5 NA 5 $0.47 - $0.52 Random Sample Major Municipals $0.56 - $0.61 9 $0.062 - $0.068 45 $2.81 - $3.06 Major Industrials $0.050 4 $0.013 27 $0.34 Total $1.08 - $1.23 18 NA 77 $3.62 - $3.92 Note: Detail may not add to totals due to rounding. NA = not applicable 1. Random sample results extrapolated to total number in category less number in certainty sample. 2. Large flow municipals (one of which is dominated by industrial flow) plus one minor industrial.



### F.2 Revised Criteria

Exhibits F-4 and F-5 summarize the potential incrementa l (i.e., costs above and beyond those needed for compliance with current regulations) compliance costs to the sample facilities, with and without I&I costs to contro l arsenic in municipal sewer systems, respectively, associated with the revised criteria scenarios that inco rporate alternative fish consumption rates.

Exhibit F-4. Potential Annual In cremental Compliance Costs for Sample Facilities: Revised Criteria (millions 2007$) Incremental Costs of Alternative Fish Consumption Rate Scenarios Facility Name 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Certainty Sample Eugene/Springfield WPCF $0 $0 $0 $0 $0 Portland Columbia Blvd WWTP $0 $0.27 $0.27 - $0.32 $0.27 - $0.32 $0.27 - $0.32

Salem Willow Lake WWTP $0 - $0.050 $0 - $0.050 $0 - $0.050 $0 - $0.050 $0 - $0.050June 2008 Appendix F. Sa mple Facility Results and Statewide Extrapolation F-3 

### Exhibit F-4. Potential Annual In cremental Compliance Costs for Sample Facilities: Revised Criteria (millions 2007$) Incremental Costs of Alternative Fish Consumption Rate Scenarios Facility Name 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd St Helen-Boise WWTP $0.075 $0.075 $0.075 $0.075 $0.075 Oregon Steel Mills $0 $0 $0 $0 $0 Major Municipals Astoria WWTP $0 $0 $0 $0.10 $0.10 Brookings WWTP $0 $0 $0 $0 $0 Coos Bay WWTP #2 $0 $0 $0 - $0.17 $0 - $0.17 $0 - $0.17 Kellogg Creek WWTP $0 $0 $0 $0 $0 McMinnville WRF $0 $0 $0 $0 $0 North Bend WWTP $0 $0 $0 $0 $0 Rock Creek WWTP $0 $0 $0 $0 $0 Tri-City S. D. $0 $0 $0 $0 $0 Woodburn WWTP $0 $0 $0 $0 $0 Major Industrials Blue Heron Paper $0 $0 $0 $0 $0 Heinz Food $0 $0 $0 $0 $0 Pope and Talbot $0 $0 $0 $0 $0 Reynolds Metals $0 $0 $0 $0 $0 Minors Shady Cove WWTP $0 $0 $0 $0 $0 Boise Cascade, Elgin Mill $0 $0 $0 $0 $0



### Exhibit F-5. Potential Annual Incremental Comp liance Costs for Sample Facilities Excluding I&I Costs: Revised Crit eria (millions 2007$) Incremental Costs of Alternative Fish Consumption Rate Scenarios Facility Name 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Certainty Sample Eugene/Springfield WPCF $0 $0 $0 $0 $0 Portland Columbia Blvd WWTP $0 $0.27 $0.27 - $0.32 $0.27 - $0.32 $0.27 - $0.32

Salem Willow Lake WWTP $0 - $0.050 $0 - $0.050 $0 - $0.050 $0 - $0.050 $0 - $0.050 St Helen-Boise WWTP $0.075 $0.075 $0.075 $0.075 $0.075 Oregon Steel Mills $0 $0 $0 $0 $0 Major Municipals Astoria WWTP $0 $0 $0 $0.10 $0.10 Brookings WWTP $0 $0 $0 $0 $0 Coos Bay WWTP #2 $0 $0 $0 $0 $0 Kellogg Creek WWTP $0 $0 $0 $0 $0 McMinnville WRF $0 $0 $0 $0 $0 North Bend WWTP $0 $0 $0 $0 $0 Rock Creek WWTP $0 $0 $0 $0 $0 Tri-City S. D. $0 $0 $0 $0 $0 Woodburn WWTP $0 $0 $0 $0 $0 Major IndustrialsJune 2008 Appendix F. Sa mple Facility Results and Statewide Extrapolation F-4 

### Exhibit F-5. Potential Annual Incremental Comp liance Costs for Sample Facilities Excluding I&I Costs: Revised Crit eria (millions 2007$) Incremental Costs of Alternative Fish Consumption Rate Scenarios Facility Name 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd Blue Heron Paper $0 $0 $0 $0 $0 Heinz Food $0 $0 $0 $0 $0 Pope and Talbot $0 $0 $0 $0 $0 Reynolds Metals $0 $0 $0 $0 $0 Minors Shady Cove WWTP $0 $0 $0 $0 $0 Boise Cascade, Elgin Mill $0 $0 $0 $0 $0



### Exhibits F-6 and F-7 show the extrapolation of the incr emental compliance costs for the random sample, and addition to the certainty sample result s, for the revised criteria scenarios, with and without I&I costs to control arse nic in municipal sewer systems, respectively. Again, there are no costs for the minor facilities in the random sample (and no data); expansion of this sample is not likely to change this result due to a lack of monitoring requ irements for toxic pollutants for these facilities.

Exhibit F-6. Potential Annual Incremental St atewide Compliance Costs: Including I&I Costs (millions of 2007$) 1 Sample Statewide Category Total Annual Cost Number of Facilities Average Cost per Facility Number of Facilities 2 Extrapolated Annual Cost

63.2 gpd Certainty Sample 3 $0.075 - $0.13 5 NA 5 $0.075 - $0.13 Major Municipals $0 9 $0 45 $0 Major Industrials $0 4 $0 27 $0 Total $0.075 - $0.13 18 NA 77 $0.075 - $0.13 113 gpd Certainty Sample 3 $0.35 - $0.40 5 NA 5 $0.35 - $0.40 Major Municipals $0 9 $0 45 $0 Major Industrials $0 4 $0 27 $0 Total $0. 35 - $0.40 18 NA 77 $0.35 - $0.40 175 gpd Certainty Sample 3 $0.35 - $0.45 5 NA 5 $0.35 - $0.45 Major Municipals $0 - $0.17 9 $0 - $0.019 45 $0 - $0.87 Major Industrials $0 4 $0 27 $0 Total $0.35 - $0.62 18 NA 77 $0.35 - $1.32 389 and 620 gpd Certainty Sample 3 $0.35 - $0.45 5 NA 5 $0.35 - $0.45 Major Municipals $0.10 - $0.27 9 $0.011 - $0.030 45 $0.50 - $1.37 Major Industrials $0 4 $0 27 $0 Total $0.45 - $0.72 18 NA 77 $0.85 - $1.82June 2008 Appendix F. Sa mple Facility Results and Statewide Extrapolation F-5 NA = not applicable 1. Represents the annual costs of compliance above and beyond those needed for compliance with baseline criteria. 2. Random sample results extrapolated to total number in category less number in certainty sample. 3. Large flow municipals (one of which is dominated by industrial flow) plus one minor industrial.



### Exhibit F-7. Potential Annual Incremental St atewide Compliance Costs: Excluding I&I Costs (millions of 2007$) 1 Sample Statewide Category Total Annual Cost Number of Facilities Average Cost per Facility Number of Facilities 2 Extrapolated Annual Cost

63.2 gpd Certainty Sample 3 $0.075 - $0.13 5 NA 5 $0.075 - $0.13 Major Municipals $0 9 $0 45 $0 Major Industrials $0 4 $0 27 $0 Total $0.075 - $0.13 18 NA 77 $0.075 - $0.13 113 gpd Certainty Sample 3 $0.35 - $0.40 5 NA 5 $0.35 - $0.40 Major Municipals $0 9 $0 45 $0 Major Industrials $0 4 $0 27 $0 Total $0. 35 - $0.40 18 NA 77 $0.35 - $0.40 175 gpd Certainty Sample 3 $0.35 - $0.45 5 NA 5 $0.35 - $0.45 Major Municipals $0 9 $0 45 $0 Major Industrials $0 4 $0 27 $0 Total $0.35 - $0.45 18 NA 77 $0.35 - $0.45 389 and 620 gpd Certainty Sample 3 $0.35 - $0.45 5 NA 5 $0.35 - $0.45 Major Municipals $0.10 9 $0.011 45 $0.50 Major Industrials $0 4 $0 27 $0 Total $0.45 - $0.55 18 NA 77 $0.85 - $0.95 NA = not applicable 1. Represents the annual costs of compliance above and beyond those needed for compliance with baseline criteria. 2. Random sample results extrapolated to total number in category less number in certainty sample. 3. Large flow municipals (one of which is dominated by industrial flow) plus one minor industrial.



### F.5 Variance Costs

Exhibit F-8 summarizes the potential one-time baseline and incremental (i.e., costs above and beyond those needed for compliance with curren t regulations) variance costs to the sample facilities.

Exhibit F-8. Potential Baseline and Incrementa l One-Time Variance Costs for Sample Facilities (millions 2007$)

Facility Name Discharger Category Baseline Costs Incremental Costs of Revised Criteria Certainty Sample Eugene/Springfield WPCF Major Municipal $0.035 - $0.30 $0 Portland Columbia Blvd WWTP Major Municipal $0.035 - $0.30 $0June 2008 Appendix F. Sa mple Facility Results and Statewide Extrapolation F-6 

### Exhibit F-8. Potential Baseline and Incrementa l One-Time Variance Costs for Sample Facilities (millions 2007$)

Facility Name Discharger Category Baseline Costs Incremental Costs of Revised Criteria Salem Willow Lake WWTP Major Municipal $0.035 - $0.30 $0 St Helen-Boise WWTP Major Municipal 1 $0.035 - $0.30 $0 Oregon Steel Mills Minor Industrial $0 $0 Random Sample Astoria WWTP Major Municipal $0.035 - $0.10 $0 Brookings WWTP Major Municipal $0 $0 Coos Bay WWTP #2 Major Municipal $0 $0.035 - $0.10 Kellogg Creek WWTP Major Municipal $0.035 - $0.20 $0 McMinnville WRF Major Municipal $0.035 - $0.20 $0 North Bend WWTP Major Municipal $0.035 - $0.10 $0 Rock Creek WWTP Major Municipal $0 $0.035 - $0.30 Tri-City S. D. Major Municipal $0.035 - $0.20 $0 Woodburn WWTP Major Municipal $0.035 - $0.10 $0 Blue Heron Paper Major Industrial $0 $0.035 - $0.10 Heinz Food Major Industrial $0 $0 Pope and Talbot Major Industrial $0.035 - $0.20 $0 Reynolds Metals Major Industrial $0 $0 Shady Cove WWTP Minor Municipal $0 $0 Boise Cascade, Elgin Mill Minor Industrial $0 $0 1. Dominated by industrial flow.



### Exhibit F-9 shows the extrapolation of the baseline a nd incremental one-time variance costs for the random sample facilities, and addition to the cer tainty sample results. There are no costs associated with the minor faciliti es in the random sample (and no data); expansion of this sample is not likely to change this result due to a lack of monitoring requirements for toxic pollutants for these facilities.

Exhibit F-9. Potential Baseline and Increm ental Statewide One-Time Variance Costs (millions of 2007$) Sample Statewide Category Total One-Time Cost Number of Facilities Average Cost per Facility Number of Facilities 1 Extrapolated OneTime Cost

Baseline Criteria Certainty Sample 2 $0.14 - $1.20 5 NA 5 $0.14 - $1.20 Major Municipals $0.21 - $0.90 9 $0.023 - $0.10 45 $1.05 - $4.50 Major Industrials $0.035 - $0.20 4 $0.009 - $0.050 27 $0.24 - $1.35 Total $0.39 - $2.30 18 NA 77 $1.43 - $7.05 Revised Criteria (Incremental) 3 Certainty Sample 2 $0 5 NA 5 $0 Major Municipals $0.070 - $0.40 9 $0.008 - $0.044 45 $0.35 - $2.0 Major Industrials $0.035 - $0.10 4 $0.009 - $0.025 27 $0.24 - $0.68 Total $0.11 - $0.50 18 NA 77 $0.59 - $2.68June 2008 Appendix F. Sa mple Facility Results and Statewide Extrapolation F-7 NA = not applicable 1. Random sample results extrapolated to total number in category less number in certainty sample. 2. Large flow municipals (one of which is dominated by industrial flow) plus one minor industrial. 3. Represents the annual costs of compliance above and beyond those needed for compliance with baseline criteria.



### Extrapolating the potential number of variance applications for the sample facilities, ODEQ may need to review approximately 40 requests under the baseline, and an additional 16 under the revised criteria. Assuming a cost of $3,900 per re view, baseline costs could be approximately $159,000, with incremental cost s of approximately $65,000 under the revised criteria.