-FINAL DRAFT- 

 

COST OF COMPLIANCE WITH WATER QUALITY CRITERIA FOR TOXIC 

POLLUTANTS FOR OREGON WATERS

 

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 International Corporation 

11251 Roger Bacon Drive 

Reston, VA 20190 

GSA Contract Number: GS-10F-0076J 

SAIC Contract Number: 06-6336-04-0347

 
June 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 Pollutants 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 Potential 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 Results and Statewide Extrapolation ............................................F-1 

June 2008 ii
List of Exhibits 

Exhibit ES-1. Summary of Potential 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 Toxic Pollutant TMDLs in Oregon.................................................. 2-11 

Exhibit 3-1. Human Health Criteria for Select Consumption Rates: Consumption of Water and 

Fish.......................................................................................................................................3-1 

Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish 

Only......................................................................................................................................3-4 

Exhibit 4-1. Summary of Sample Facilities................................................................................ 4-1 

Exhibit 4-2. Baseline and Potential Revised AWQC for Mercury ............................................. 4-3 

Exhibit 4-3. Summary of Reasonable Potential Results for Sample Facilities...........................4-5 

Exhibit 4-4. Summary of Projected AMELs for Sample Facilities............................................ 4-6 

Exhibit 4-5. Summary of Projected Baseline and Incremental Load Reductions for Sample 

Facilities...............................................................................................................................4-8 

Exhibit 4-6. Average Annual Influent and Effluent Mercury Concentrations, Mt. View SD ..4-13 

Exhibit 4-7. Influent Mercury Concentrations versus Percent Removal, EBMUD..................4-13 

Exhibit 4-8. Inflow and Infiltration Rehabilitation Unit Costs................................................. 4-15 

Exhibit 4-9. Summary of Potential 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 Select Ambient Monitoring Data....................................................... 5-2 

Exhibit 5-2. Potential Number of Exceedances 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 

Cb Ambient background concentration 

Cce Calculated effluent concentration 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 

fd 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 Wastewater 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 Qb Ambient flow Qe Effluent flow 

RCO-1 Regenerative catalytic/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 vi
June 2008 Executive Summary ES-1

ES.Executive Summary 

The Oregon Department of Environmental Quality (ODEQ) is considering revising the fish 

consumption rate for calculating water quality criteria applicable to waters in the state. This 

report provides estimates of the potential incremental compliance actions and 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 Quality Commission (EQC) adopted revisions to 

Oregon Administrative Rules (OAR) covering water quality criteria for 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 stringent than the existing criteria cannot be implemented without 

EPA approval). However, the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) 

and other tribes objected to the revised criteria on the basis that the fish consumption rate does 

not account for higher fish consuming populations, which 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, using available water quality and discharge data and 

information, the potential incremental compliance actions and costs that publicly owned 

wastewater treatment works (POTWs) and industrial point source dischargers may incur as a 

result of potential revised criteria. These impacts 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, including the large number of pollutants of concern 

and limited monitoring data, the estimates 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 wastewater point sources, the revised 

standards may also result in a need for incremental controls by municipal storm water and 

nonpoint sources discharging to surface waters. However, 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 statewide cost estimates. 

For changes to water quality criteria within an existing water quality standards and NPDES 

permitting program, compliance costs likely represent 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 increased 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 (municipal and industrial expenditures financed through 

user fees and profits) will be accompanied by increased employment, incomes, revenues, and 

profits to sectors supplying compliance technologies and services (which may be within or 

external to Oregon). The scope of this analysis is limited to an evaluation of potential 

compliance costs; this report does not provide estimates of potential 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 quality criteria for the 

protection of human health based on consumption of water and organisms (e.g., fish) and 

organisms only. ODEQ established the criteria 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 criteria 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 reflecting the baseline human health criteria. Nonpoint sources are 

primarily controlled through various management plans and policies and TMDL load allocations, 

although these baseline requirements to attain existing criteria (including TMDLs for nontoxic 

pollutants that could result in reduced 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 consumption 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 include nickel, benzene, and chloroform, 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 because 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 pollutants with baseline and revised human health 

criteria more stringent than the existing aquatic life criteria. 

June 2008 Executive Summary ES-2
ES.5 Method for Evaluating Effect on Point Sources 

Compliance costs for municipal and industrial point sources may result from changes to NPDES 

permit requirements. To evaluate the potential effect of the potential revised criteria on NPDES 

permit conditions and compliance actions for wastewater point sources, we evaluated available 

effluent and ambient data for a sample of facilities. We first evaluated compliance with baseline 

criteria by conducting a reasonable potential analysis (RPA), estimating load reductions, and 

determining controls (or alternative compliance measures) and costs needed for compliance. 

Then, we evaluated the incremental reductions that would be needed under the revised criteria, 

and estimated incremental compliance actions and costs. 

 

ODEQ (2005) procedures provide permit writers 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 the revised criteria, although there is uncertainty 

regarding implementation procedures that may accompany a revised fish consumption rate. For 

mercury, we used EPA procedures and default values for translating the fish tissue criterion into 

a water column number for implementation into permits (U.S. EPA, 2001). 

To identify potential compliance actions, we evaluated 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-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 pretreatment 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, TMDL, 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 treatment are highly uncertain due to the fact that 

no other dischargers have been required to treat to such low levels and performance data are not 

available. Thus, due to the uncertainty of achievable effluent levels, we did not identify any endof-pipe treatment technologies capable of producing the necessary effluent concentrations on a 

consistent and reliable basis. In addition, even for technologies that could in theory result in 

compliance, other factors such as disposal of residual streams and very high costs per pound of 

pollutant removed may render such solutions infeasible, especially 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 technologies 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 mercury in wastewater effluents. However, there 

could be some maximum level of effort beyond which a P2 program would not provide 

additional reductions and a discharger may need to pursue alternative 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 wastewater may be from contaminated groundwater leaking into the 

sewer system, I&I controls 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. 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 actions 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 for human health pollutants. The regulatory 

baseline for evaluating the potential impact of the revised criteria includes some requirements for 

nonpoint sources and storm water dischargers to implement BMPs and load allocations as part of 

TMDLs. ODEQ has developed TMDLs for a number of toxic pollutants already and will be 

developing TMDLs for others. However, the pollutant loading reductions and discharge 

concentrations that will be achieved through baseline BMPs is uncertain. Thus, there is also 

uncertainty in the extent of incremental controls that could be required under the potential 

revised criteria. 

Instream monitoring data can be used to assess the impact that a change in the fish consumption 

rate may have on attainment of water quality criteria and thus, control of potential nonpoint 

sources. Although not representative of all surface waters, ODEQ’s Laboratory Analytical 

Storage and Retrieval (LASAR) database contains 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 pollutants with detected values have concentrations 

that exceed the baseline criteria (the exception is nickel, for which potential revised criteria are 

less stringent than baseline criteria). Thus, source controls are necessary in the absence of 

revisions to the fish consumption rate. For antimony, beta-BHC, and mercury, the percent of the 

data that exceeds the criteria increases with increasing consumption rates (e.g., by a factor of 3 

for antimony between baseline criteria and criteria based on the highest 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 data are unavailable. Nonpoint sources and storm 

water may be at least partially responsible for these potential impairments. 

ES.7 Results 

Costs for compliance with baseline criteria include costs associated with implementation of 

existing permit limits, plans, and policies that reflect existing criteria. Incremental costs 

associated with compliance with the potential revised criteria represent the costs of any actions 

or controls above and beyond those needed to meet baseline requirements. 

Point Source Costs 

Exhibit ES-1 provides a summary of the potential total and incremental (i.e., above and beyond 

those needed for compliance with baseline standards) annual statewide costs, both with and 

without the costs for I&I controls to reduce arsenic 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 variance-related expenditures could range from 

$0.59 million to $2.68 million under revised criteria. 

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

Total Incremental1

Scenario With I&I Costs2 No I&I Costs With I&I Costs2 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 baseline 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 are 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 dischargers subject to effluent limitation 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 present at levels of concern, 

and those that may be (e.g., arsenic) may not contribute significantly 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 effluent 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 facilities, 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 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 pollutants for municipal dischargers less than 1 mgd. 

Indirect dischargers to municipal wastewater treatment plants could also incur costs associated 

with the baseline and revised criteria if the municipality imposes more stringent pretreatment 

standards or requirements on these dischargers in an effort to reduce effluent loads. However, 

indirect dischargers of pollutants for which a municipal wastewater treatment 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 dischargers 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 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 site-specific 

information available for each discharger to identify where the pollutant is originating [e.g., 

arsenic, bis(2-ethylhexyl) phthalate]. Thus, it is not possible to estimate pretreatment or P2 costs 

to indirect dischargers for pollutants other than mercury without specific information on the 

types of industrial dischargers in each service area. 

Nonpoint Source and Storm Water Costs 

Under the baseline, control costs for nonpoint sources (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 compliance under the baseline cannot be estimated. 

There are, however, indications that baseline compliance costs for nonpoint sources 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 source dischargers 

are not likely to be significant sources of mercury to those waters, it is possible that nonpoint 

source controls are needed to improve water quality to meet baseline criteria. 

There could also be incremental costs to nonpoint 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 incremental level of control would be necessary 

for compliance with the revised criteria. For any situation in which controls beyond those 

required under the baseline are necessary, controls could include: 

June 2008 Executive Summary ES-6
• Agricultural and forest lands – sediment and erosion controls beyond those specified 

under existing state and federal regulations and plans 

• Mining – cleanup and remediation including 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 – increased or additional nonstructural BMPs (e.g., institutional, 

education, or pollution prevention practices designed 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 the 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 attribution 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 with permit limits for mercury, arsenic, bis(2-

ethylhexyl) phthalate, DDT, alpha-BHC, and dioxin, 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 indicate a potential increase of 9 TMDLs at a 

consumption rate of 63.2 gpd and 21 TMDLs at a consumption 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 variance application review and TMDL development 

costs would not be incurred in any single year; rather, 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 analysis 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 uncertainties 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 whether the facility is in compliance with 

baseline standards and whether incremental controls would 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 evaluation 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. 

• Lack of available instream monitoring data prevents the estimation of potential statewide 

costs associated with reductions in pollutant loads from nonpoint sources. 

• Lack of data regarding 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 oxygen. Attainment of standards for these 

types of pollutants could also result 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 pollutant loading reductions that would result from 

compliance with baseline and revised 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 unproven. If compliance is not feasible, pollutant 

load reductions may be minimal. 

For point sources, we assumed that facilities would pursue the lowest cost option for compliance 

with either baseline or revised criteria. However, without site-specific data and analysis, it is 

uncertain whether any particular control option would guarantee compliance. 

In addition, there is uncertainty associated with the levels achievable with baseline controls. For 

both point and nonpoint sources, we assumed that in some cases baseline 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 Executive Summary ES-8
June 2008 1. Introduction 1-1

1. Introduction 

The Oregon Department of Environmental Quality (ODEQ) is considering revising the fish 

consumption rate for calculating water quality criteria applicable to waters in the state. This 

report provides estimates of the potential incremental compliance actions and costs that may be 

associated with such a change to the state’s water quality standards (WQS). 

1.1 Background 

The Clean Water Act (CWA) directs states, with oversight by the U.S. Environmental 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. Under Section 303, state WQS 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 requires states to hold public hearings once every 

three years for the purpose of reviewing applicable 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 any new or revised standards. 

 

In May 2004, the Oregon Environmental Quality Commission (EQC) adopted revisions to 

Oregon Administrative Rules (OAR) covering water quality criteria for 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 stringent than the existing criteria cannot be implemented without 

EPA approval). However, the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) 

and other tribes objected to the revised criteria on the basis that the fish consumption rate does 

not account for higher fish consuming populations, which 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, using available water quality and discharge data and 

information, the potential incremental compliance actions and costs that publicly owned 

wastewater treatment works (POTWs) and industrial point source dischargers may incur as a 

result of potential revised criteria. These impacts 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, including the large number of pollutants of concern 

and limited monitoring data, the estimates 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 wastewater point sources, the revised 

standards may also result in a need for incremental controls by municipal storm water and 

nonpoint sources discharging to surface waters. However, 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 statewide cost estimates. 

For changes to water quality criteria within an existing water quality standards and NPDES 

permitting program, compliance costs likely represent 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 increased 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 (municipal and industrial expenditures financed through 

user fees and profits) will be accompanied by increased employment, incomes, revenues, and 

profits to sectors supplying compliance technologies and services (which may be within or 

external to Oregon). The scope of this analysis is limited to an evaluation of potential 

compliance costs; this report does not provide estimates of potential 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 applicable toxic criteria and ODEQ 

procedures for implementing the criteria in NPDES permits, sources 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 existing water quality 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 baseline 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 associated with baseline and revised criteria for nonpoint 

sources. 

Section 6: Potential Compliance Costs – provides estimates of potential costs to comply with 

the revised water quality standards, and discusses the uncertainties associated 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 individual sample facilities, and analyses of 

potential impacts under the different scenarios. 

Appendix B: describes pollution prevention programs and estimated costs. 

Appendix C: provides details for various end-of-pipe 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 1-3
June 2008 2. Baseline for the Analysis 2-1

2. Baseline for the Analysis 

This section describes the applicable baseline for evaluating the incremental costs associated 

with potential revised fish consumption rates for calculating water quality criteria, including 

current water quality criteria, potential sources of the pollutants of concern, and the current level 

of impairment in Oregon waters. 

2.1 Water Quality Criteria 

OAR 340-041-0033, Table 33A, provides existing water 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, which are based on EPA’s recommended national fish consumption 

rate of 17.5 gpd, on May 20, 2004. Those criteria that are more stringent than the previous 

criteria became effective February 15, 2005. The remaining criteria are not to be implemented in 

NPDES permits until EPA approves the criteria because 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 for toxic pollutants. ODEQ designates all 

waters (except Bull Run River which has no dischargers) for the protection of both aquatic life 

and human health. Thus, pollutants for which the aquatic 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 Concern1

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 - - - - 380 850 
June 2008 2. Baseline for the Analysis 2-2

Exhibit 2-1. Baseline Human Health Criteria for Pollutants of Concern1

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 210 a,b - - 170,000 3,433,000 
June 2008 2. Baseline for the Analysis 2-3

Exhibit 2-1. Baseline Human Health Criteria for Pollutants of Concern1

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 0.053 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/kg2

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 Concern1

Freshwater Aquatic Life Saltwater Aquatic Human Health (μg/L) Pollutant (μg/L) Life (μg/L) 

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 approval) 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 revised criteria based on a fish consumption rate of 17.5 

gpd cannot be used until ODEQ receives EPA 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 industrial category specified in PCS. 

Exhibit 2-2. NPDES Permitted Direct Dischargers in Oregon 

Category1 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, construction that disturbs one acre or more, 

industrial storm water, oily storm water runoff, oil/water separators, tanks cleanup and treatment 

of groundwater, washwater, and noncontact geothermal 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 generated 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 regulates storm water discharges from municipal 

separate storm sewer systems (MS4s) through general 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 the maximum extent practicable (MEP). ODEQ 

interprets the MEP requirement to require all controls 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 participation and involvement; illicit 

discharge detection and elimination; construction runoff control; 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 permits. 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 counties in Oregon required to obtain “Phase II” MS4 

permits. Federal regulations also provide states the discretion to require other MS4s outside of 

urbanized areas to apply for a permit. 

Industrial dischargers, including those engaged in manufacturing, 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 reach surface waters through irrigation return flow, 

storm water runoff, and erosion of soils. Oregon’s Department of Agriculture’s (ODA) 

Agricultural Water Quality Program (AWQP) is charged with assisting the agriculture industry 

in reducing pollution from agricultural sources. The legal foundation of the AWQP is the 

Agricultural Water Quality Management Act (SB1010) created in 1993 (ODA, 2007). SB1010 

provides the department with enforcement authority to deal with situations where corrective 

action is needed, but is not voluntarily being taken by an operator. In those cases where a farmer 

or rancher refuses to take action, the law authorizes the department to require corrective 

measures or use civil penalties to address the issue. 

The ODA has identified 39 watershed-based agricultural water quality management areas 

(AWQMA). Within each AWQMA is a local advisory committee (LAC) consisting of water 

quality specialists, local farmers, ranchers, and community leaders. All 39 LACs have approved 

Agricultural Water Quality Management Area Plans (AWQMAP) along with enforceable 

administrative rules to ensure all landowners do their part to avoid and resolve water quality 

June 2008 2. Baseline for the Analysis 2-6
problems. AWQMAPs must describe a program to achieve water quality standards. AWQMA 

rules must be sufficient to assure that landowners will prevent and control 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 example, 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 existing 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 mercury 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 approximately 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 further investigate the relative contributions of 

mercury from various sources (ODEQ, 2006c). The current implementation plan offers sector 

level, general recommendations to reduce the level of mercury in the Willamette River system. 

ODEQ recommends updating applicable 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, fungicides, 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 enter surface waters in 

quantities that would degrade water quality or be harmful to the overall maintenance of terrestrial 

wildlife or aquatic life (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 pesticide 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 staging of chemical applications in locations 

where the site does not provide a route for any chemical spill to run into water 

• Chemical label requirements must be followed 

• Operators must obey buffer requirements for chemical application in the vicinity of water 

bodies (e.g., 10 feet for ground applications; 60 feet for aerial applications of herbicides, 

rodenticides, and biological insecticides; and 100 feet for aerial applications of fungicides 

and nonbiological insecticides) (ODF, 2007b). 

June 2008 2. Baseline for the Analysis 2-7
As described above, the Willamette Basin Mercury TMDL states that relative contribution of 

mercury to the basin from erosion of mercury containing soils is approximately 48%. ODEQ 

recommends implementing BMPs required by the 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 Oregon, 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 have identified over 140 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 responsible 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 constraints, ODEQ prioritizes sites based on risks 

to human health and the environment. The ODEQ also 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 meet existing TMDLs for toxic pollutants including 

mercury. For example, the Willamette Basin Mercury TMDL (ODEQ, 2006b) states that relative 

contribution of mercury to the basin from legacy mining operations is only 0.6%. However, 

ODEQ indicates that mercury residuals 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 approach for this TMDL with plans to update the 

current recommendation in 2011. The current implementation 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 tissues 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 legacy gold, silver, and mercury mining 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 River, 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 develop 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 funding 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 nonpoint source to surface waters through either 

direct or indirect deposition. Direct deposition occurs when pollutants deposited directly on 

surface waters from the atmosphere. Indirect deposition 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 water runoff. Atmospheric deposition is not 

directly addressed through any existing regulation, but is indirectly 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 estimated the relative contribution of direct 

and indirect atmospheric deposition of mercury in the Willamette Basin to be approximately 6% 

and 42%, respectively (ODEQ, 2006b). The Willamette 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 Snake River – Hells Canyon drainage identified 

atmospheric deposition as a potentially substantial 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 the 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 Toxic 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 

Columbia R. above WA/Canada border meet allocations. 

= 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 – fish tissue DDT:

exceed 1.29 μg/kg 

Dieldrin – fish tissue 

exceed 3.5 μg/kg 

PCBs – fish tissue 

exceed 2.46 μg/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 

Dieldrin: Sediments = 0.0108 mg/day; sedimentation. 

Storm Water = 9.6 mg/day; Future 

Growth = 4.8 mg/day 

• Monitor effectiveness of BMPs. 

• Monitor contribution of contaminated 

PCBs: Sediments = 0.161 mg/day; sediment sites. 

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 

Dioxin: Sediments = 1.31×10 Buffalo Slough. -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 – high fish tissue DDT:

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) 

Mercury – exceeds Interim Mercury Allocations:

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 Toxic 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 consumption rate for calculating human health criteria. 

The criteria can be calculated based on the pollutant reference dose (for noncarcinogens) or 

cancer potency factor (for carcinogens), bioconcentration 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 quality criterion in mg/L 

BW = human body weight default value of 70 kg 

RfD = reference dose based on noncancer human 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, RSC, 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, calculated using the following equation (EPA, 2001a): 

TRC BW RfD RSC

FIi i

= ∗ −

∑ =

( )

2

4

where, 

TRC = tissue residual concentration in mg methylmercury/kg fish 

1 FIi = 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 health criteria more stringent than the existing 

aquatic life criteria and for which reference dose/cancer potency factor and bioconcentration 

factor are available) for select fish consumption 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., benzene, chloroform, and nickel, among others). 

June 2008 3. Potential Revised Criteria 3-2
June 2008 3. Potential Revised Criteria 

Exhibit 3-1. Human Health Criteria for Select Consumption Rates: Consumption of Water and F

Revised Criteria based on Select Consumption R

Pollutant QL (μg/L) Baseline Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

1,1,2,2-Tetrachloroethane 0.5 0.17 0.15 0.14 0.12 0.081,1,2-Trichloroethane 0.5 0.59 0.54 0.49 0.44 0.33 1,1-Dichloroethylene 0.5 330 300 270 230 170 1,2,4,5-Tetrachlorobenzene 1.0 0.97 0.29 0.16 0.11 0.041,2,4-Trichlorobenzene 0.5 35 15 9.4 6.4 3.0 1,2-Dichlorobenzene 0.5 420 230 150 110 53 1,2-Dichloroethane 0.5 0.38 0.37 0.36 0.35 0.31 1,2-Dichloropropane 0.5 0.5 0.46 0.42 0.38 0.29 1,2-Diphenylhydrazine 5.0 0.036 0.024 0.018 0.014 0.0071,2-Trans-Dichloroethylene 0.5 140 130 130 120 110 1,3-Dichlorobenzene 0.5 320 170 110 80 40 1,3-Dichloropropene 0.5 0.34 0.33 0.32 0.30 0.26 1,4-Dichlorobenzene 0.5 63 34 23 16 7.9 2,3,7,8-TCDD (Dioxin) 5.0E-06 5.0E-09 1.4E-09 7.9E-10 5.1E-10 2.3E-2,4,5-Trichlorophenol 2.0 1,800 780 490 330 160 2,4,6-Trichlorophenol 1.0 1.2 0.55 0.34 0.23 0.11 2,4-Dichlorophenol 1.0 77 46 32 23 12 2,4-Dimethylphenol 2.0 380 180 110 76 36 2,4-Dinitrophenol 5.0 69 67 65 62 54 2,4-Dinitrotoluene 1.0 0.11 0.10 0.093 0.084 0.062-Chloronaphthalene 1.0 1,000 380 230 150 69 2-Chlorophenol 1.0 81 33 20 14 6.5 2-Methyl-4,6-Dinitrophenol 2.0 13 12 10 9.2 6.6 3,3'-Dichlorobenzidine 1.0 0.021 0.0072 0.0042 0.0027 0.0014,4'-DDD 0.01 0.00031 0.000086 0.000048 0.000031 0.00004,4'-DDE 0.01 0.00022 0.000061 0.000034 0.000022 0.00004,4'-DDT 0.01 0.000024 0.000061 0.000034 0.000022 0.0000Acenaphthene 1.0 670 240 140 95 44 Acrolein 5.0 190 70 42 28 13 Acrylonitrile 5.0 0.051 0.033 0.024 0.018 0.009
June 2008 3. Potential Revised Criteria 

Exhibit 3-1. Human Health Criteria for Select Consumption Rates: Consumption of Water and F

Revised Criteria based on Select Consumption R

Pollutant QL (μg/L) Baseline Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

Aldrin 0.01 0.000049 0.000014 0.0000078 0.0000050 0.0000alpha-BHC 0.01 0.0026 0.0011 0.00067 0.00045 0.000Anthracene 1.0 8,300 5,400 3,900 2,900 1,50Antimony 0.1 5.6 5.4 5.3 5.1 4.7 Arsenic 0.05 0.0022 0.0083 0.0057 0.0041 0.002Benzene 0.5 0.66 2.0 1.8 1.6 1.2 Benzidine 10.0 0.000086 0.000040 0.000026 0.000018 0.0000Benzo(a) Anthracene 1.0 0.0038 0.0025 0.0018 0.0013 0.000Benzo(a) Pyrene 1.0 0.0038 0.0025 0.0018 0.0013 0.000Benzo(b) Fluoranthene 1.0 0.0038 0.0025 0.0018 0.0013 0.000Benzo(k) Fluoranthene 1.0 0.0038 0.0025 0.0018 0.0013 0.000Beryllium 0.1 0.0068 0.0051 0.0039 0.0031 0.001beta-BHC 0.01 0.0091 0.0038 0.0023 0.0016 0.000Bis(2-Chloroethyl) Ether 1.0 0.03 0.026 0.023 0.020 0.01Bis(2-Chloroisopropyl) Ether 2.0 34.7 1,300 1,200 1,200 950 Bis(Chloromethyl) Ether a 3.7E-09 5.3E-05 3.5E-05 2.4E-05 1.2E-Bis(2-Ethylhexyl) Phthalate 1.0 1.2 0.49 0.30 0.20 0.09Bromoform 0.5 4.3 4.0 3.7 3.3 2.6 Butylbenzyl Phthalate 1.0 1,500 500 290 190 86 Carbon Tetrachloride 0.5 0.23 0.17 0.13 0.10 0.05Chlordane 0.1 0.00046 0.00022 0.00013 0.000081 0.0000Chlorobenzene 0.5 130 110 88 74 47 Chlorodibromomethane 0.5 0.4 0.37 0.34 0.31 0.24 Chloroform 0.5 0.19 5.1 4.7 4.3 3.3 Chrysene 1.0 0.0038 0.0025 0.0018 0.0013 0.000Dibenzo(a,h)Anthracene 1.0 0.0038 0.0025 0.0018 0.0013 0.000Dichlorobromomethane 0.5 0.55 0.50 0.47 0.43 0.33 Dieldrin 0.01 0.000052 0.000015 0.0000083 0.0000053 0.0000Diethyl Phthalate 1.0 17,000 8,500 5,500 3,800 1,80Dimethyl Phthalate 1.0 270,000 160,000 120,000 84,000 44,00Di-n-Butyl Phthalate 1.0 2,000 920 580 400 190 Endosulfan Sulfate 0.01 62 22 13 8.5 3.9 
June 2008 3. Potential Revised Criteria 

Exhibit 3-1. Human Health Criteria for Select Consumption Rates: Consumption of Water and F

Revised Criteria based on Select Consumption R

Pollutant QL (μg/L) Baseline Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

Endrin 0.01 0.059 0.017 0.0093 0.0060 0.002Endrin Aldehyde 0.01 0.29 0.083 0.047 0.030 0.01Ethylbenzene 0.5 530 320 220 160 84 Fluoranthene 2.0 42 37 21 14 6.2 Fluorene 1.0 1,100 720 520 390 200 gamma-BHC (Lindane) 0.01 0.0186 0.0053 0.0032 0.0022 0.001Heptachlor 0.01 0.000079 0.000022 0.000012 0.0000079 0.0000Heptachlor Epoxide 0.01 0.000039 0.000011 0.0000061 0.0000039 0.0000Hexachlorobenzene 1.0 0.00028 0.000079 0.000044 0.000029 0.0000Hexachlorobutadiene 2.0 0.44 0.41 0.39 0.36 0.29 Hexachlorocyclopentadiene 2.0 40 37 34 30 23 Hexachloroethane 2.0 1.4 0.67 0.42 0.29 0.14 Ideno(1,2,3-cd)Pyrene 1.0 0.0038 0.0025 0.0018 0.0013 0.000Isophorone 10.0 35 32 30 27 20 Methyl Bromide 0.5 47 44 40 37 28 Methylene Chloride 0.5 4.6 4.5 4.4 4.3 4.0 Methylmercury 0.00005 - 0.081 mg/kg1 0.045 mg/kg1 0.029 mg/kg1 0.013 mNickel 10.0 13.4 280 190 140 69 Nitrobenzene 1.0 17 16 15 14 11 N-Nitrosodibutylamine 10.0 0.0063 0.0058 0.0054 0.0050 0.003N-Nitrosodiethylamine 10.0 0.00080 0.00080 0.00080 0.00079 0.000N-Nitrosodimethylamine 1.0 0.00069 0.00069 0.00069 0.00068 0.000N-Nitrosodi-n-Propylamine 2.0 0.005 0.0048 0.0047 0.0046 0.004N-Nitrosodiphenylamine 1.0 3.3 1.3 0.82 0.55 0.26 N-Nitrosopyrrolidine 10.0 0.016 0.016 0.016 0.016 0.01Pentachlorobenzene 10.0 1.4 0.15 0.087 0.056 0.02Pentachlorophenol 2.0 0.27 0.22 0.18 0.15 0.09 Phenol 1.0 3,500 20,000 19,000 19,000 17,00PCBs 0.5 0.000064 0.000018 0.0000099 0.0000064 0.0000Pyrene 1.0 830 540 390 290 150 Selenium 2.0 10 150 140 120 91 Tetrachloroethylene 0.5 0.69 0.45 0.32 0.24 0.13 
Exhibit 3-1. Human Health Criteria for Select Consumption Rates: Consumption of Water and F

Revised Criteria based on Select Consumption R

Pollutant Baseline QL (μg/L) Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

Thallium 0.1 0.24 0.10 0.063 0.043 0.02Toluene 0.5 1,300 1,000 870 720 450 Toxaphene 0.5 0.00028 0.000077 0.000043 0.000028 0.0000Trichloroethylene 0.5 2.5 2.1 1.7 1.4 0.91 Vinyl Chloride 0.5 0.025 0.024 0.023 0.023 0.02a = Contact DEQ laboratory 1. 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 Only 

Revised Criteria based on Select Consumption R

Pollutant Baseline QL (μg/L) Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

1,1,2,2-Tetrachloroethane 0.5 4 1.1 0.62 0.40 0.18 1,1,2-Trichloroethane 0.5 16 4.3 2.4 1.6 0.70 1,1-Dichloroethylene 0.5 7,100 2,000 1,100 710 320 1,2,4,5-Tetrachlorobenzene 1.0 1.1 0.30 0.17 0.11 0.041,2,4-Trichlorobenzene 0.5 70 19 11 7.0 3.2 1,2-Dichlorobenzene 0.5 1,300 360 200 130 58 1,2-Dichloroethane 0.5 37 10 5.7 3.7 1.6 1,2-Dichloropropane 0.5 15 4.0 2.3 1.5 0.66 1,2-Diphenylhydrazine 5.0 0.2 0.056 0.031 0.020 0.0091,2-Trans-Dichloroethylene 0.5 10,000 2,800 1,600 1,000 460 1,3-Dichlorobenzene 0.5 960 270 150 96 43 1,3-Dichloropropene 0.5 21 5.8 3.3 2.1 0.95 1,4-Dichlorobenzene 0.5 190 53 30 19 8.7 2,3,7,8-TCDD (Dioxin) 5.0E-06 5.1E-09 1.4E-09 7.9E-10 5.1E-10 2.3E-2,4,5-Trichlorophenol 2.0 3,600 1,000 560 360 160 2,4,6-Trichlorophenol 1.0 2.4 0.67 0.38 0.24 0.11 2,4-Dichlorophenol 1.0 290 82 46 29 13 2,4-Dimethylphenol 2.0 850 240 130 85 38 2,4-Dinitrophenol 5.0 5,300 1,500 830 530 240 2,4-Dinitrotoluene 1.0 3.4 0.94 0.52 0.34 0.15 2-Chloronaphthalene 1.0 1,600 440 250 160 71 

June 2008 3. Potential Revised Criteria 
June 2008 3. Potential Revised Criteria 

Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish Only 

Revised Criteria based on Select Consumption R

Pollutant QL (μg/L) Baseline Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

2-Chlorophenol 1.0 150 41 23 15 6.7 2-Methyl-4,6-Dinitrophenol 2.0 280 79 44 28 13 3,3'-Dichlorobenzidine 1.0 0.028 0.0079 0.0044 0.0028 0.0014,4'-DDD 0.01 0.00031 0.000086 0.000048 0.000031 0.00004,4'-DDE 0.01 0.00022 0.000061 0.000034 0.000022 0.00004,4'-DDT 0.01 0.000024 0.000061 0.000034 0.000022 0.0000Acenaphthene 1.0 990 270 150 99 45 Acrolein 5.0 290 80 45 29 13 Acrylonitrile 5.0 0.25 0.068 0.038 0.025 0.01Aldrin 0.01 0.00005 0.000014 0.0000078 0.0000050 0.0000alpha-BHC 0.01 0.0049 0.0014 0.00076 0.00049 0.000Anthracene 1.0 40,000 11,000 6,200 4,000 1,80Antimony 0.1 640 180 99 64 29 Arsenic 0.05 0.0175 0.014 0.0080 0.0052 0.002Benzene 0.5 40 14 7.9 5.1 2.3 Benzidine 10.0 0.0002 0.000055 0.000031 0.000020 0.0000Benzo(a) Anthracene 1.0 0.018 0.0051 0.0028 0.0018 0.000Benzo(a) Pyrene 1.0 0.018 0.0051 0.0028 0.0018 0.000Benzo(b) Fluoranthene 1.0 0.018 0.0051 0.0028 0.0018 0.000Benzo(k) Fluoranthene 1.0 0.018 0.0051 0.0028 0.0018 0.000Beryllium 0.1 0.117 0.0140 0.0076 0.0049 0.002beta-BHC 0.01 0.017 0.0047 0.0026 0.0017 0.000Bis(2-Chloroethyl) Ether 1.0 0.53 0.150 0.082 0.053 0.02Bis(2-Chloroisopropyl) Ether 2.0 4,360 18,000 10,000 6,500 2,90Bis(2-Ethylhexyl) Phthalate 1.0 2.2 0.61 0.34 0.22 0.09Bis(Chloromethyl) Ether a 0.00184 0.000080 0.000045 0.000029 0.0000Bromoform 0.5 140 37 21 14 6.1 Butylbenzyl Phthalate 1.0 1,900 540 300 190 87 Carbon Tetrachloride 0.5 1.6 0.45 0.25 0.16 0.07Chlordane 0.1 0.00048 0.00022 0.00013 0.000081 0.0000Chlorobenzene 0.5 1,600 430 240 160 70 Chlorodibromomethane 0.5 13 3.5 2.0 1.3 0.57 
June 2008 3. Potential Revised Criteria 

Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish Only 

Revised Criteria based on Select Consumption R

Pollutant QL (μg/L) Baseline Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

Chloroform 0.5 15.7 48 27 17 7.9 Chrysene 1.0 0.018 0.0051 0.0028 0.0018 0.000Dibenzo(a,h) Anthracene 1.0 0.018 0.0051 0.0028 0.0018 0.000Dichlorobromomethane 0.5 17 4.8 2.7 1.7 0.77 Dieldrin 0.01 0.000054 0.000015 0.0000083 0.0000054 0.0000Diethyl Phthalate 1.0 44,000 12,000 6,800 4,400 2,00Dimethyl Phthalate 1.0 1,100,000 310,000 170,000 110,000 50,00Di-n-Butyl Phthalate 1.0 4,500 1,200 700 450 200 Endosulfan Sulfate 0.01 89 25 14 8.9 4.0 Endrin 0.01 0.06 0.017 0.0094 0.0060 0.002Endrin Aldehyde 0.01 0.3 0.084 0.047 0.030 0.01Ethylbenzene 0.5 2,100 590 330 210 96 Fluoranthene 2.0 54 39 22 14 6.3 Fluorene 1.0 5,300 1,500 830 530 240 gamma-BHC (Lindane) 0.01 0.0625 0.0066 0.0037 0.0024 0.001Heptachlor 0.01 0.000079 0.000022 0.000012 0.0000079 0.0000Heptachlor Epoxide 0.01 0.000039 0.000011 0.0000061 0.0000039 0.0000Hexachlorobenzene 1.0 0.00029 0.000080 0.000045 0.000029 0.0000Hexachlorobutadiene 2.0 18 5.1 2.9 1.8 0.83 Hexachlorocyclopentadiene 2.0 1,100 310 170 110 50 Hexachloroethane 2.0 3.3 0.91 0.51 0.33 0.15 Ideno(1,2,3-cd)Pyrene 1.0 0.018 0.0051 0.0028 0.0018 0.000Isophorone 10.0 960 270 150 96 43 Methyl Bromide 0.5 1,500 410 230 150 67 Methylene Chloride 0.5 590 160 92.0 59.0 27.0 Methylmercury 0.00005 300 μg/kg1 0.081 mg/kg1 0.045 mg/kg1 0.029 mg/kg1 0.013 mNickel 10.0 100 470 260 170 77 Nitrobenzene 1.0 690 190 110 69 31 N-Nitrosodibutylamine 10.0 0.22 0.060 0.034 0.022 0.009N-Nitrosodiethylamine 10.0 1.24 0.13 0.071 0.046 0.02N-Nitrosodimethylamine 1.0 3 0.84 0.47 0.30 0.14 N-Nitrosodi-n-Propylamine 2.0 0.51 0.14 0.078 0.051 0.02
Exhibit 3-2. Human Health Criteria for Select Consumption Rates: Consumption of Fish Only 

Revised Criteria based on Select Consumption R

Pollutant Baseline QL (μg/L) Criteria (μg/L) 63.2 gpd 113 gpd 175 gpd 389 g

N-Nitrosodiphenylamine 1.0 6 1.7 0.93 0.60 0.27 N-Nitrosopyrrolidine 10.0 34 9.5 5.3 3.4 1.5 Pentachlorobenzene 10.0 1.5 0.16 0.087 0.056 0.02Pentachlorophenol 2.0 3 0.84 0.47 0.30 0.14 Phenol 1.0 1,700,000 470,000 270,000 170,000 77,00PCBs 0.5 0.000064 0.000018 0.0000099 0.0000064 0.0000Pyrene 1.0 4,000 1,100 620 400 180 Selenium 2.0 4,200 1,200 650 420 190 Tetrachloroethylene 0.5 3.3 0.91 0.51 0.33 0.15 Thallium 0.1 0.47 0.13 0.073 0.047 0.02Toluene 0.5 15,000 4,100 2,300 1,500 670 Toxaphene 0.5 0.00028 0.000077 0.000043 0.000028 0.0000Trichloroethylene 0.5 30 8.3 4.6 3.0 1.3 Vinyl Chloride 0.5 2.4 0.68 0.38 0.24 0.11 a = Contact DEQ laboratory. 1. Represents a fish tissue criterion. 

June 2008 3. Potential Revised Criteria 
June 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 the potential costs to point sources associated 

with compliance with both baseline criteria and revised 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 potential magnitude of compliance costs include flow and facility 

type. Larger flows are typically associated with the largest treatment costs, although per-unit 

costs may decrease due to economies of scale. A certainty sample of the largest 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. Treatment requirements differ for municipal and 

industrial discharges, and effluent quality may be similar across categories of facilities. Minor 

dischargers typically do not have monitoring requirements for toxic pollutants and, may not 

contribute significantly to instream loads even if such pollutants were present in the effluent 

from these facilities. Thus, the potential for minor facilities to incur costs as a result of an 

increased fish consumption rate is low. 

As shown in Exhibit 2-2, there are 77 major (49 municipal and 28 industrials) and 313 minor 

(157 municipal and 156 industrials) individually permitted wastewater discharges to waters for 

which the potential revised human health criteria would apply. EPA uses the designation of 

“major” for municipal discharges of 1 million gallons per day (mgd) or more, and industrial 

discharges with a major rating code (based on the 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 potential for cost, we evaluated the four largest 

facilities based on the facility information section 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 potential worse case based on industrial process (steel mill). To evaluate 

potential for costs at the remaining municipal 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 Municipal1 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 effluent flows reported in the Effluent Measurements/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 writers 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 perform effluent monitoring (see Table 4) 

• All industrial sources ODEQ does not require to monitor, but has identified a concern for 

toxic pollutants (e.g., a facility that stores hazardous chemicals on site and has a recorded 

history of spills into to the wastewater stream 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 with a significant industrial user that may 

be a potential source of pollutants, discharging 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 individual 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 consumption of water and organisms. Human health 

criteria for consumption of organisms only apply to marine and estuarine waters. For mercury, 

the criterion represents the concentration 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 ambient 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 quality criterion in mg/L 

BW = human body weight default value of 70 kg 

RfD = reference dose based on noncancer human health effects in mg/kg body weight-day 

RSC = relative source contribution in mg/kg body weight-day 

DI = drinking water intake default value of 2 L/day 

FI = human fish consumption in kg fish/day 

BAFi = bioaccumulation factor for trophic level i (L/kg fish) 

fd = translator to convert dissolved methylmercury into total mercury . 

For this analysis, we assumed that ODEQ would use EPA’s default values to convert the 

methylmercury fish tissue criterion into a total mercury water column criterion: 

• National BAFs: BAF2 = 120,000 L/kg; BAF3 = 680,000 L/kg; BAF4 = 2,700,000 L/kg 

• Trophic level specific consumption rate percentages: FI2 = 22%; FI3 = 46%; FI4 = 33% 

• Dissolved methylmercury to total mercury translator: 0.014 for river; 0.032 for lakes. 

Exhibit 4-2 shows the AWQC for mercury for rivers and lakes at alternative fish consumption 

rates calculated using EPA’s default values. 

Exhibit 4-2. Baseline and Potential Revised AWQC for Mercury 

Water Body Baseline Criteria Alternative Fish Consumption Rate Criteria (μg/L) 

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 mercury 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 requirements for dischargers (because dischargers 

would only need to reduce total mercury to the QL of 0.01 μg/L under existing implementation 

procedures). To be conservative (i.e., erring on the side of higher costs), we assumed that 

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

dischargers would only use clean 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% confidence level and 95% probability basis (EPA, 

1991; Tables 3-1 and 3-2). For carcinogens, this value is the geometric mean effluent 

concentration times the multiplying factor. The fewer 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 coefficient of variance (CV) of 0.6], and the RPA 

would be based on an effluent concentration that is over six times greater than the actual 

measured value. 

If all effluent observations are nondetect and the criterion is greater than QL (ODEQ, 2005; 

Appendix B), the calculated effluent concentration 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 the 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 observations are nondetect) is less 

than the applicable criterion, there 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 scenario 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, 

CMZ = Concentration of the pollutant at the edge of the mixing zone 

Cce = Calculated effluent concentration of the pollutant 

Cb = Ambient background concentration (set to zero where all observations are nondetect or 

data are not available) 

D = Dilution factor. 

The dilution factor is calculated as: 

where, 

Qe = Effluent flow 

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

CMZ 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 the applicable criterion, there is no 

RP; if the mixing zone concentration is greater than the criterion, the permit writer must 

determine whether the point source is a significant contributor to the receiving water 

concentration of the pollutant. ODEQ (2005) indicates that a point source is a significant 

contributor to a receiving water load if: 

• For persistent bioaccumulative and toxic pollutants (PBTs) (e.g., mercury, aldrin, 

dieldrin, benzo(a)pyrene, chlordane, DDT, dioxins and furans, hexachlorobenzene, alkyllead, mirex, octachlorostyrene, PCBs, and toxaphene), downstream receiving water 

concentrations are at least 1% greater than upstream concentrations 

• For non-PBTs (e.g., arsenic), downstream receiving water concentrations are at least 10% 

greater than upstream concentrations. 

However, without upstream and downstream measurements, it is difficult to determine whether 

any dischargers would be considered significant contributors. Thus, we assumed that if the 

concentration at the edge of the mixing zone exceeds the applicable criterion there is RP.3

Exhibit 4-3 summarizes the RPA for the sample facilities; Appendix A provides the details of 

the analyses. As shown in the exhibit, under current procedures (ODEQ, 2005), dischargers in 

the sample have RP and thus need WQBELs for the following pollutants: 4,4’-DDT, alpha-BHC, 

arsenic, bis(2-ethylhexyl) phthalate, dioxin, mercury, and tetrachloroethylene. 

Exhibit 4-3. Summary of Reasonable Potential Results 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 Dioxin, 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 concentration for calculating the size of the 

mixing zone or results in removal of a 303(d) listing, could 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 Results 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 calculate 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 

Cb = 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 concentration (MEC) to the AMEL to determine 

compliance. This method ensures that dischargers 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, compliance actions and associated costs are likely. 

Exhibit 4-4 provides a comparison of observed MECs with projected average monthly effluent 

limits and QLs for the dischargers in the sample that have RP for a particular 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 AMELs2 (μg/L) Name MEC QL1

(μg/L) (μg/L) Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 

4,4’-DDT 

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

Exhibit 4-4. Summary of Projected AMELs for Sample Facilities 

Projected AMELs2 (μg/L) Name MEC 

(μg/L) 

QL1

(μg/L) Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 

EugeneSpringfield 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 AMELs2 (μg/L) Name MEC QL1

(μg/L) (μg/L) Baseline 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 

St. Helens 

WWTP 0.037 0.0005 NA 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 0.017 0.0047 0.0026 0.0017 0.00076 0.00048 

Pope & Talbot 0.0073 0.0005 0.017 0.0047 0.0026 0.0017 0.00076 0.00048 

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 which 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 applicable QL, the load reductions represent the 

amount needed to reduce effluent levels to the QL. 

Exhibit 4-5. Summary of Projected Baseline and Incremental Load Reductions for Sample 

Facilities (lbs/yr) 

Baseline Incremental (over baseline) Reduction 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 Projected Baseline and Incremental Load Reductions for Sample 

Facilities (lbs/yr) 

Baseline Incremental (over baseline) Reduction 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 limits 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 effluent concentration and average dry weather design flow. For 

pollutants with limits less than the applicable QL, load reductions represent the amount needed to reduce effluent levels to the 

QL. For the revised criteria, load reductions represent 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 pretreatment 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, TMDL, 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 pollutant loads increase throughout the treatment process as a result 

of chemical additions or treatment techniques. 

Process optimization usually involves process analysis and process modifications. Process 

analysis is an investigation of the performance-limiting factors of the treatment process and is a 

key factor in achieving optimum treatment efficiency. Performance-limiting factors for common 

wastewater treatment processes (e.g., sedimentation, activated sludge, filtration) may include 

operator training, response to changes in wastewater quality, maintenance activities, automation, 

and process control testing. The cost of process analysis includes the cost of additional or 

continuous monitoring throughout the treatment process, and a treatment performance 

evaluation. These costs vary based on the number of treatment processes analyzed and the 

magnitude of the reductions needed. 

Process modifications include activities short of adding new treatment technology units 

(conventional or unconventional) to the treatment train. For increasing pollutant removal 

efficiencies, process modifications could include adjusting coagulant 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 software. Several months of adjustments may be 

needed to achieve a desired level of process optimization. In practice, the process modifications 

necessary would be determined by the process analysis study. 

Process optimization costs depend on the pollutant needing reductions and existing treatment 

processes and operations. For example, a facility could add a flocculant aid to secondary 

treatment to increase solids removal, and thus, the removal of any pollutants that adhere to 

particulates [e.g., mercury and bis(2-ethylhexyl) phthalate]. In addition, chemicals used in 

wastewater treatment could contain contaminants (e.g., chlorine contaminated 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 largely 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 facility 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 designed to maximize removal of suspended solids, 

process optimization aimed at increasing those removal efficiencies may not result in significant 

reductions for pollutants existing primarily in dissolved form. Given the available information 

for the sample facilities, it is generally not possible 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 would not be feasible or would not be sufficient to achieve the 

necessary reductions, source controls would likely be the next most cost-effective control option. 

Source control could be used alone, or in conjunction with process 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 feasible 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., mercury), a facility would likely have to 

concentrate efforts on public outreach and education or a sewer use ordinance. Other pollutants, 

such as arsenic, may be due to natural sources (e.g., groundwater), and reducing inflow and 

infiltration (I&I) or treating source water may be necessary. 

Costs for source control activities depend on the pollutant and the measures or controls 

implemented. For this analysis, we estimated that the sample facilities would pursue pollution 

prevention (P2) programs (for mercury, DDT, BHC, dioxin, and bis(2-ethylhexyl) 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 effluent, the purpose for doing so, and a time line for completion 

• Develop an approach – including selecting sectors for P2 efforts, the criteria for targeting 

efforts (e.g., size of the source loading, authority available to control the source, time 

required to produce desired results), whether efforts 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 description 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 resources necessary to achieve 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, will vary based on existing treatment 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 community. Large municipal facilities with numerous 

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-11
potential mercury sources may see significant reductions after implementation of a measure that 

targets a major influent mercury source, such as a sewer use ordinance 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 their effluent with P2 due to a lower percent of 

easily identifiable and controllable sources contributing to the influent 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 originate from a wide range of products and smaller 

municipalities are likely to receive most of their inflow from the residential sector. 

The Western Lake Superior Sanitation District (WLSSD) in Minnesota 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 awareness 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% reduction) (WLSSD, 2002). 

A number of communities in California have also demonstrated results. The Mt. View Sanitary 

District has three dental offices, two hospitals, and one laboratory that discharge to the 

wastewater treatment plant. During an audit of the hospitals and laboratory, 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 discovered 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; effluent concentrations continued to decrease each 

year (this trend could be due to improvements in treatment performance or an increase of 

influent particulate mercury which is more easily removed with conventional treatment processes 

and so would not significantly affect 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 reductions 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 04-05

Total Mercury (ng/L) 

Influent

Effluent

There are a number of known and 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. Therefore, 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 effluent removal rates associated with decreased 

influent loads could also be due to the mechanisms 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 process cannot go below). 

Exhibit 4-7 shows how removal efficiencies for mercury at EBMUD vary with influent 

concentrations (Mena, 2005). The data shows that, for the most part, as influent mercury 

concentrations decrease, the percent of mercury removed also decreases. 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 may be released to air 

through incineration) may not be predicted or measured through changes in effluent levels alone 

(or compliance with applicable effluent limits). 

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

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-13
82.0%

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-specific 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 amount of resources for program development and 

outreach efforts as a large major municipal facility because the service area is smaller and 

contains fewer households and commercial/industrial dischargers to target. Smaller facilities 

may also pool their resources together and develop a joint P2 program to save time and money 

on program development and outreach materials. For this analysis, we assumed that P2 program 

costs for mercury may be approximately $50,000 per year for a small municipal 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 mgd). P2 program costs for pollutants with fewer 

potential sources would likely 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 other pollutants, identifying groups of indirect 

dischargers likely to be contributing 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 pretreatment or P2 costs to indirect dischargers for pollutants other 

than mercury without specific information on the types of industrial dischargers in each service 

area. 

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

I&I Reduction Projects 

The main components of an I&I reduction program are identifying sources through field 

investigations, designing and constructing rehabilitation improvements, and monitoring postconstruction flows to determine the effectiveness of the rehabilitation (King County, 2005). 

Identifying I&I sources can involve a wide range of field inspections and testing procedures. For 

most collection systems, I&I is the result of defects in pipelines and manhole structures or entry 

from connected storm sewers (Wade, 2002). Source identification activities include smoke 

testing, manhole inspections, pipeline cleaning, closed circuit television (CCTV) inspections, 

dyed-water testing, building inspections, and private 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 comprehensive study to identify I&I problems would 

cost approximately $2.50/ft of sewer system pipe. 

The results of the source identification study dictate the selection of rehabilitation 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 practices available to reduce I&I as well as project 

costs. Exhibit 4-8 provides unit costs for various rehabilitation options. 

Exhibit 4-8. Inflow and Infiltration 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 sewer pipe (2004 dollars). Escalated to 2007 dollars, using the 

Engineering News Record Construction Cost Index, unit costs would be approximately $8 per 

linear foot.4

 The useful life of sewer pipes in Oregon 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 comprehensive 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 effectiveness of an I&I reduction program on effluent 

arsenic concentrations at a wastewater treatment plant. The effectiveness of the program to 

reduce groundwater infiltration depends on the completeness 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 overflows 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 source control would not be sufficient for compliance with the 

baseline or revised criteria, alternative discharge options or end-of-pipe treatment technologies 

may be necessary. However, at the higher alternative 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, the lowest levels achievable through end-of-pipe 

treatment are highly uncertain due to the fact that no other dischargers have been required to treat 

to such low levels and performance data are not available. 

For metals such as mercury and arsenic, technologies 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 treatment controls designed to remove solids (see 

discussion of Process Optimization). For organic pollutants such as 4,4;-DDT, alpha-BHC, and 

dioxin, similar treatment technologies can be used, although operating parameters may have to 

be adjusted to achieve optimal removal rates. Bis(2-ethylhexyl) phthalate 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 pollutant sorbed to particulates, the potential for 

biological degradation is low. Thus, treatment technologies that target removal of solids should 

also remove bis(2-ethylhexyl) 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 Potential 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 Potential 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 treatment technology as well as available 

unit costs. Due to the uncertainty of achievable effluent levels, we did not identify any end-ofpipe treatment technologies capable 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 compliance 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 characteristics in the vicinity of their discharge warrant alternative 

criteria values (e.g., resulting in less stringent effluent 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-specific criteria are justifiable 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 characteristics 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 forms 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 rationale and not affect the existing 

designated use (ODEQ, 2007b). EPA must also review and approve the criteria prior to 

implementation. 

Because additional data are likely required to assess 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 within 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 increase 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 request that effluent limits be adjusted to 

reflect credit for pollutants in the discharger’s intake water if either: 

• The applicable effluent limitations and standards contained in 40 CFR subchapter N 

specifically provide that they shall be applied on a net basis 

• The discharger demonstrates that the control system it proposes or uses to meet 

applicable technology-based limits and standards would, if properly installed and 

operated, meet the limits and standards in the absence of pollutants in the intake waters. 

Intake credits will only be granted to the extent necessary to meet 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 may 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, dischargers in Oregon may be eligible for intake 

credits. 

Variances 

OAR 340-041-0061(2) allows the state’s EQC to grant point source dischargers variances from 

meeting water quality standards if attaining the water 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 flow conditions or water levels prevent the 

attainment of the use, unless these conditions may be compensated 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 pollution prevent the attainment of the use and 

cannot be remedied or would cause more environmental damage to correct than to leave 

in place. 

4. Dams, diversions, or other types of hydrologic modifications preclude the attainment of 

the use, and it is not feasible to restore the water body to its original condition or to 

operate such modification in a way which would result in the attainment of the use. 

5. Physical conditions related to the natural features 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 required by sections 301(b) and 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 conditions above apply as part of an application for a 

variance, dischargers would likely prepare documentation of the conditions warranting the 

variance. For example, New Jersey Department of Environmental Protection (NJDEP) was 

considering adopting more stringent water quality criteria for mercury, PCBs, and DDT. 

However, because the proposed criteria reflected extremely low concentration levels, and 

available analytical methods for DDT and PCBs cannot detect at such low levels, NJDEP 

evaluated the technological feasibility of available 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 third factor would also need to evaluate the 

feasibility of each technology as it relates to its own effluent characteristics and treatment train 

(e.g., through a comparison of performance data and theoretical effluent levels cited in the 

literature to their own treatment operations). 

Unfortunately, given the fact that few, if any, wastewater treatment plants discharging to surface 

waters have installed advanced end-of-pipe treatment technologies for compliance with toxics 

standards, performance data will be extremely limited. 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 data or conducting studies designed to measure the limits of 

performance of each technology. For this reason, dischargers may evaluate whether installing 

any of the identified treatment technologies would result in adverse 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 condition above), dischargers are likely to follow EPA’s (1995) Interim 

Economic Guidance for Water Quality Standards Workbook which provides worksheets and 

instructions for public and private sector entities. Following EPA (1995), dischargers conduct a 

two-step analysis, 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 granting a variance. It is not clear whether ODEQ would require 

such actions when granting a variance. However, 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. Thus, 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 alternative compliance mechanisms will depend to 

some extent on the implementation procedures accompanying the final revised criteria (e.g., 

some states have sought to minimize individual discharger demonstrations of applicable variance 

factors by establishing multidischarger variance procedures). 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 attributed to discharger preferences and not the 

regulation, because legal services are not necessary to prepare the analyses or applications 

related to any of the alternative compliance mechanisms discussed above. 

For temporary variances from WQBELs, dischargers 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 technological feasibility analyses. Note that initial 

efforts regarding technological feasibility may serve to reduce costs of subsequent applications 

(e.g., dischargers may rely on previously 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 mercury). Indeed, reducing costs 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 the 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 wastewater treatment facilities absent 

any regulatory changes. 

Exhibit 4-10. Potential Level of Effort to Investigate Technological Feasibility 

Component Hours Cost1 

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 factor of 3.03 to account for overhead, benefits, and profit 

(PSMJ, 2007). 

The cost associated with individual applications demonstrating adverse economic and social 

impacts would likely include the cost of a preliminary engineering analysis (preconceptual 

design; detailed design work is not necessary) and 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 and issues to evaluate, and more capabilities 

compared to smaller facilities). To provide some 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 months) with contract labor. Assuming that the 

scope of a study for large facilities (>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-third less for medium-sized facilities (>5 mgd and <20 mgd) (i.e., 

June 2008 4. Method for Estimating Potential Costs: Point Sources 4-20
June 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 baseline or revised criteria versus basic discharge-related program 

components. Nonetheless, assuming the State’s review of the engineering cost and financial 

impact analysis could require up to 100 hours5 and the average hourly wage rate for an 

environmental engineer at ODEQ is $39.20 including 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 criteria would likely fall within the range for variance 

applications for the different factors, and intake credit justification 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 concentrated animal feeding operation 

(U.S. EPA, 2000b), we assumed that, on average, the notification and response to comments activities would require 

an average of 68 hours. Thus, the total time requirement for each request is 100 hours. 6

 The average hourly rate across salary levels for an environmental engineer is $26.83. The benefits multiplier from 

BLS (2007b) is 1.46. 
June 2008 5. Method 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 for human health pollutants. The regulatory 

baseline for evaluating the potential impact of the revised criteria 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 developed 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 uncertainty in the extent of incremental controls that 

could be required under the potential revised criteria. 

5.1 Available Data 

Instream monitoring data can be used to assess the impact that a change in the fish consumption 

rate may have on attainment of water quality criteria and thus, control of potential nonpoint 

sources. Although not representative of all surface waters, ODEQ’s Laboratory Analytical 

Storage and Retrieval (LASAR) database contains 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 requires at least two exceedances of water quality standards for a 

water to be classified as impaired and needing a TMDL (Category 5). If data are insufficient, but 

there is one exceedance, ODEQ (2006e) indicates that the water should be classified as one of 

potential concern (Category 3B). 
June 2008 5. Method for Estimating Potential Costs: Nonpoint Sources 

Exhibit 5-1. Summary of Select Ambient Monitoring Data1

Number of Observations Percent of Detected Values Exce

Pollutant Number of Stations Total Detect Baseline3 62.3 gpd 113 gpd 175 g

1,1,2,2-Tetrachloroethane 1 1 0 NA NA NA NA 1,1,2,2-Tetrachloroethylene 1 1 0 NA NA NA NA 1,1,2-Trichloroethane 1 1 0 NA NA NA NA 1,1-Dichloroethylene 1 1 0 NA NA NA NA 1,2,4-Trichlorobenzene 2 2 0 NA NA NA NA 1,2-Dichlorobenzene 2 2 0 NA NA NA NA 1,2-Dichloroethane 1 1 0 NA NA NA NA 1,2-Dichloropropane 1 1 0 NA NA NA NA 1,3-Dichlorobenzene 2 2 0 NA NA NA NA 1,4-Dichlorobenzene 2 2 0 NA NA NA NA 2,4,6-Trichlorophenol 1 1 0 NA NA NA NA 2,4-Dichlorophenol 1 1 0 NA NA NA NA 2,4-Dimethylphenol 1 1 0 NA NA NA NA 2,4-Dinitrophenol 1 1 0 NA NA NA NA 2,4-Dinitrotoluene 1 1 0 NA NA NA NA 2-Chloronaphthalene 1 1 0 NA NA NA NA 2-Chlorophenol 1 1 0 NA NA NA NA 4,4`-DDD 23 81 11 100 100 100 100 4,4`-DDE 25 83 12 100 100 100 100 4,4`-DDT 23 81 15 100 100 100 100 4,6-Dinitro-2-methylphenol 1 1 0 NA NA NA NA Acenaphthene 2 2 0 NA NA NA NA Acenaphthylene 2 2 0 NA NA NA NA Acrolein (2-Propenal) 1 1 0 NA NA NA NA Aldrin 23 69 1 100 100 100 100 alpha-BHC 29 126 0 NA NA NA NA Anthracene 2 2 0 NA NA NA NA Antimony 153 468 29 10 14 17 17 Arsenic 209 534 68 100 100 100 100 Benzene 1 1 0 NA NA NA NA Benzo(a)pyrene 1 1 0 NA NA NA NA Benzo[a]Anthracene 2 2 0 NA NA NA NA 
June 2008 5. Method for Estimating Potential Costs: Nonpoint Sources 

Exhibit 5-1. Summary of Select Ambient Monitoring Data1

Number of Observations Percent of Detected Values Exce

Pollutant Number of Stations Total Detect Baseline3 62.3 gpd 113 gpd 175 g

Benzo[a]pyrene 1 1 0 NA NA NA NA Benzo[b]Fluoranthene 2 2 0 NA NA NA NA Benzo[k]Fluoranthene 2 2 0 NA NA NA NA Beryllium 99 183 82 100 100 100 100 beta-BHC 23 81 1 0 0 0 100 Bis(2-chloroethyl)ether 1 1 0 NA NA NA NA Bis(2-chloroisopropyl)ether 1 1 0 NA NA NA NA Bis(2-ethylhexyl)phthalate 1 1 0 NA NA NA NA Bromodichloromethane 1 1 0 NA NA NA NA Bromoform 1 1 0 NA NA NA NA Butylbenzylphthalate 1 1 0 NA NA NA NA Carbon Tetrachloride 1 1 0 NA NA NA NA Chlordane 23 56 0 NA NA NA NA Chlorobenzene 1 1 0 NA NA NA NA Chloroform 1 1 0 NA NA NA NA Chrysene 2 2 0 NA NA NA NA Dibenzo[a,h]Anthracene 2 2 0 NA NA NA NA Dibromochloromethane 1 1 0 NA NA NA NA Dieldrin 29 138 7 100 100 100 100 Diethylphthalate 1 1 0 NA NA NA NA Dimethylphthalate 1 1 0 NA NA NA NA di-n-Butylphthalate 1 1 0 NA NA NA NA Endosulfan sulfate 1 1 0 NA NA NA NA Endrin 18 76 0 NA NA NA NA Endrin Aldehyde 23 74 0 NA NA NA NA Ethyl Benzene 1 1 0 NA NA NA NA Fluoranthene 2 2 0 NA NA NA NA Fluorene 2 2 0 NA NA NA NA Heptachlor 23 69 5 100 100 100 100 Heptachlor Epoxide 23 81 5 100 100 100 100 Hexachlorobenzene 23 69 2 100 100 100 100 Hexachlorocyclopentadiene 12 32 0 NA NA NA NA 
Exhibit 5-1. Summary of Select Ambient Monitoring Data1

Number of Observations Percent of Detected Values Exce

Number of 

Pollutant Stations Total Detect Baseline3 62.3 gpd 113 gpd 175 g

Hexachloroethane 1 1 0 NA NA NA NA Ideno[1,2,3-cd]pyrene 2 2 0 NA NA NA NA Isophorone 1 1 0 NA NA NA NA Mercury4 77 304 242 1 19 28 40 Mercury (fish tissue)5 108 676 648 46 87 97 100 Methylene Chloride 1 1 0 NA NA NA NA Nickel 206 526 340 1 0 0 0 Nitrobenzene 1 1 0 NA NA NA NA N-Nitrosodiphenylamine 1 1 0 NA NA NA NA Pentachlorophenol 1 1 0 NA NA NA NA Pyrene 2 2 0 NA NA NA NA Selenium 153 467 35 0 0 0 0 Thallium 153 467 38 100 100 100 100 Toluene 1 1 0 NA NA NA NA Toxaphene 23 56 0 NA NA NA NA trans-1,2-Dichloroethylene 1 1 0 NA NA NA NA Trichloroethylene 1 1 0 NA NA NA NA Vinyl Chloride 1 1 0 NA NA NA NA NA = not applicable 1. Source: ODEQ (2007c); data from 1997 and 2007. Does not include 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 health criteria include criteria from OAR 2340-041-0033 Table 33A that became effective Februeffective without EPA approval) and Table 20 (original criteria since ODEQ’s 2004 proposed criteria are not effective pending EPA approval)]. 4. Water column data compared to potential water column criteria based on the revised fish tissue criteria, calculated using EPA default BAFs, trophwater column translator. 5. Wet weight fish tissue concentrations compared to revised fish tissue criteria. 

June 2008 5. Method for Estimating Potential Costs: Nonpoint Sources 
June 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 pollutants with detected values have concentrations 

that exceed the baseline criteria7

 (the exception is nickel, for which potential revised criteria are 

less stringent than baseline criteria). Thus, source controls are 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 increases 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 control 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 percent reduction in pollutants in a manner similar 

to how point source controls are typically implemented (e.g., specific treatment units in a 

treatment train can be operated to achieve more or less pollutant reductions depending on permit 

requirements). Thus, without more detailed data 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 for antimony. Each of the baseline criteria exceedances are on 

different water bodies. Thus, based on the existing listing policy these waters would be of 

potential concern but not impaired. 

There are 9 exceedances of the most stringent revised criterion (based 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 for the revised criterion based on a consumption 

rate of 620 gpd; the remaining water bodies would be of potential concern due to a lack of data. 

In addition, there would be no new listings for the 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 atmospheric deposition (e.g., antimony released into 

the air by volcanoes and forest fires), soil erosion and weathering 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 include criteria from OAR 2340-041-0033 Table 33A that became effective 

February 2005 (revised criteria that became effective without 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 water, and industrial point sources. 

It is uncertain whether additional data would indicate impairments or the need for an increase in 

the level of control above and beyond those needed for compliance with 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-BHC, 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, chlordane, and dieldrin. 

Chlordane and dieldrin are similar to BHC in that both were found in pesticides/insecticides and 

are no longer used or produced (ATSDR, 2005). Thus, the potential sources would likely be the 

same and controls implemented to reduce chlordane 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 column 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 increase 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 Mercury1

Number of Exceedances Water Bodies of Potential Impaired Water Bodies 

Scenario Concern (Category 3A) (Category 5) 

Total Incremental2 Total Incremental2 Total Incremental2

Baseline 299 NA 3 NA 21 NA 

63.2 gpd 610 311 4 1 30 9 

113 gpd 693 394 2 -13 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 water 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 impaired 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 criteria could be needed under the revised criteria alternatives. 

June 2008 5. Method for Estimating Potential Costs: Nonpoint Sources 5-6
June 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 ocean. Human-related sources primarily include 

coal combustion, waste incineration, industrial uses, and mining (USGS, 2003). The Willamette 

Basin Mercury TMDL identifies runoff and erosion from agricultural and forest lands, storm 

water, legacy mining, and municipal and industrial dischargers as potential sources of mercury. 

Natural sources and atmospheric deposition are generally 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 standards 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 already required under baseline conditions for 

compliance with the revised criteria. 

5.3 Identifying Potential Compliance Actions and Costs 

Data are too limited to reliably estimate the extent of nonpoint source and storm water controls 

needed to achieve the baseline water quality standards 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 pollutants exceeding baseline and revised water quality 

standards for which detection levels are too high or data are unavailable. Nonpoint sources and 

storm water may be at least partially responsible for these potential impairments. 

The magnitude of impacts attributable to the potential 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 revisions in comparison to compliance with existing 

baseline standards. Appendix E provides examples of applicable 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 typically 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 will 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 potential compliance costs, and discusses the 

limitations and uncertainties associated with the analysis. 

6.1 Point Sources 

Costs for compliance with baseline criteria include costs to point source dischargers associated 

with implementation of NPDES permit limits that reflect existing criteria. Incremental costs 

associated with compliance with the potential revised criteria represent the costs of any actions 

or controls above and beyond those needed to meet baseline requirements. 

NPDES permits for facilities in Oregon do not currently include WQBELs reflecting the baseline 

criteria. Thus, even in the absence of revised fish consumption rates 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 small 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-ethylhexyl) phthalate, dioxin, and mercury. 

DDT and alpha-BHC are legacy pollutants 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 sampling and/or laboratory analysis 

conditions (Fairfield-Suisun SD, 2003). Dioxin is primarily a byproduct formed during 

chlorination by wastewater treatment plants or in the manufacture of certain organic chemicals 

(ATSDR, 1999). Sources of dioxin to and within wastewater treatment plants are difficult to 

control without completely eliminating 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). Thus, it is likely that for these pollutants, source control would be 

the only cost-effective treatment option, although it would not necessarily result in compliance 

with baseline criteria and alternative compliance 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 actively 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 likely compliance scenarios under the 

baseline to include: 

• 4,4’-DDT – alternative compliance mechanism (such as variance with P2 program) 

• Alpha-BHC – alternative compliance mechanism (such as variance with P2 program) 
• Arsenic – alternative compliance mechanism (such as intake credits or site specific 

criteria) 

• Bis(2-ethylhexyl) phthalate – cleaner sampling or P2 program 

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

• Mercury – P2 program. 

The analysis of the sample dischargers also indicated 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) phthalate, 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 – cleaner 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 controls 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 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). 

The cost associated with pursuing alternative compliance mechanisms is uncertain because the 

particular mechanism is unknown. Implementation procedures accompanying the revised 

criteria may affect compliance scenarios. ODEQ (2005) also identifies a need to address the 

high natural background arsenic concentrations through various strategies for performing RP 

analyses and setting WQBELs, such as allowing greater than 25% of the stream 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 potential alternative compliance mechanisms that may 

ultimately be pursued. 

Exhibit 6-1 provides a summary of the potential total and incremental (i.e., above and beyond 

those needed for compliance with baseline standards) annual statewide costs, both with and 

without the costs for I&I controls to reduce arsenic 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 variance-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 Annual Compliance Costs (millions of $2007) 

Total Incremental1

Scenario With I&I Costs2 No I&I Costs With I&I Costs2 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 Annual Compliance Costs (millions of $2007) 

Total Incremental1

Scenario With I&I Costs2 No I&I Costs With I&I Costs2 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 baseline 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 revised criteria scenarios, there are no pollutant load reductions 

associated with alternative compliance mechanisms such as intake credits and variances. Even if 

ODEQ requires dischargers to implement P2 programs as a condition of a variance, load 

reductions could still be minimal especially for 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 cost-effective control option, there is uncertainty 

regarding the load reductions achievable through such actions. At some point, additional 

individual facility P2 program activities and expenditures may not provide additional reductions. 

Because there are currently no proven end-of-pipe 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 remedied or economic factors). Thus, as the 

criteria become more stringent (due to higher fish consumption rates), potential load reductions 

may become constant because additional reductions 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 estimates of the annual level of expenditures (the 

annual level of capital outlay or annualized capital costs, and annual operations and 

maintenance) needed to maintain full compliance. 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 challenges (e.g., changes in the community discharging to the sewer 

system) in maintaining compliance. However, technological capabilities will also change in the 

future. 

The costs for minor dischargers are highly uncertain because there is a lack of data to evaluate 

effluent quality. However, 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 dischargers subject to 

effluent limitation 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 

June 2008 6. Results of the Analysis 6-3
toxics are not likely to be present at levels of concern, and those that may be (e.g., arsenic) may 

not contribute significantly 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. 

Nonetheless, one potential pollutant of concern for minor municipal dischargers however 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 effluent 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 facilities, 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 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 pollutants for municipal dischargers less 

than 1 mgd. 

Indirect dischargers to municipal wastewater treatment plants could also incur costs associated 

with the baseline and revised criteria if the municipality imposes more stringent pretreatment 

standards or requirements on these dischargers in an effort to reduce effluent loads. However, 

indirect dischargers of pollutants for which a municipal wastewater treatment 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 dischargers 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 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 site-specific 

information available for each discharger to identify where the pollutant is originating [e.g., 

arsenic, bis(2-ethylhexyl) phthalate]. Thus, it is not possible to estimate pretreatment or P2 costs 

to indirect dischargers for pollutants other than mercury without specific information on the 

types of industrial dischargers in each service area. 

6.2 Nonpoint Sources and Storm Water 

Costs for compliance with baseline criteria include costs to nonpoint sources (e.g., agricultural 

and forest operations; contamination from historic mining sites), and municipal storm water 

sources associated with implementation of existing programs and TMDLs. Incremental costs 

associated with compliance with the potential revised criteria represent the costs of any actions 

or controls above and beyond those needed to meet baseline requirements. 

Under the baseline, control costs for these 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 

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 sources 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 source dischargers are not likely to be significant 

sources of mercury to those waters, it is possible that nonpoint source controls are needed to 

improve water quality to meet baseline criteria. 

There could also be incremental costs to nonpoint 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 incremental level of control would be necessary 

for compliance with the revised criteria. For any situation in which controls beyond those 

required under the baseline are necessary, controls could include: 

• Agricultural and forest lands – sediment and erosion controls beyond those specified 

under existing state and federal regulations and plans 

• Mining – cleanup and remediation including 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 – increased or additional nonstructural BMPs (e.g., institutional, 

education, or pollution prevention practices designed 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 the 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 attribution 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 with permit limits for mercury, arsenic, bis(2-

ethylhexyl) phthalate, DDT, alpha-BHC, and dioxin, 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 indicate a potential increase of 9 TMDLs at a 

consumption rate of 63.2 gpd and 21 TMDLs at a consumption 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 the variance application review and TMDL development costs would 

not be incurred in any single year; rather, the cost 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 analysis 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 uncertainties to the analysis 

of potential costs associated with compliance with the revised criteria. 

Point Sources 

Data are not available for all pollutants 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 Steel Mills. Additional data could result in 

compliance cost estimates higher or lower than shown. 

 

We are also lacking effluent flow data from which to calculate appropriate human health dilution 

factors. In those instances we used chronic aquatic life dilution factors based on the 7Q10 flow, 

rather than the 30Q5 or harmonic mean stream flow. The 7Q10 flow is often less than the 30Q5 

and harmonic mean flows; thus, more dilution may be available, which means estimated costs 

may be overstated. 

In estimating baseline control costs, facility permits and evaluation 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 some facilities, we had information on existing 

activities, and could reduce baseline control costs accordingly. Facility permits and evaluation 

reports also lack sufficient information on the sources of pollutants in a facility’s influent. For 

example, permits often state the number of significant industrial users to a plant, but do not 

describe the types of industries. Without such information, 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 loads from nonpoint sources. Additional data could 

show that some incremental level 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. However, without more information, the magnitude of 

those costs cannot be estimated. 

There is also a lack of data regarding 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 oxygen. Attainment of standards for these types of 

pollutants could also result in attainment of the baseline and revised criteria for toxic pollutants, 

negating the need for additional controls on nonpoint sources. 

6.3.2 Load Reductions 

There is uncertainty regarding the pollutant loading reductions that would result from 

compliance with baseline and revised 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 unproven. 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 measured. Thus, there may not 

be measurable or quantifiable incremental pollutant load reductions from wastewater point 

sources associated with more stringent human health criteria. 

6.3.3 Response to Revised Requirements 

For point sources, we assumed that facilities would 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 facility’s service area and existing plant processes 

and operations. In some cases, facilities may discover 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 and may be higher or lower than 

shown. For example, we assumed a single unit cost for pipe rehabilitation 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 how much system rehabilitation will cost until the 

source identification study is complete. 

Dischargers may also explore more holistic approaches that address problems in addition to 

compliance with the revised criteria which means costs may be overstated. For example, to 

address an increasing demand in water supply (due to increases in population and changes in 

climate), the Orange County water and sanitation districts partnered together to implement an 

advanced water purification project known as the Groundwater Replenishment (GWR) System. 

June 2008 6. Results of the Analysis 6-7
The GWR system purifies highly treated sewer effluent to replenish groundwater supplies. The 

system provides a new reliable, high-quality water supply for north and central Orange County, 

eliminates any immediate need for another ocean 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 that in some cases baseline 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 6-8
June 2008 7. References 7-1

7. References 

Agency for Toxic Substances and Disease Registry (ATSDR). 2005. Toxicological Profile for 

Alpha-, Beta-, Gamma-, and Delta-Hexachlorocyclohexane. August. 

Agency for Toxic Substances and Disease Registry (ATSDR). 1999. Toxicological Profile for 

Mercury. April. 

Agency for Toxic Substances and Disease Registry (ATSDR). 1992. Toxicological Profile for 

Antimony and Compounds. September. 

Bureau of Labor Statistics (BLS). 2006. State Occupational Employment and Wage Estimates 

Oregon. Online at http://www.bls.gov/oes/current/oes_or.htm. 

Bureau of Labor Statistics (BLS). 2007a. Employment Cost Index Historical Listing Current. 

Employment Cost Index for Wages and Salaries, All Civilians, Profession and Related (not 

seasonally adjusted). 

Bureau of Labor Statistics (BLS). 2007b. Employer 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 workers, by major occupational and industry group, 

September 2007, Management, professional and related. Online at 

http://www.bls.gov/news.release/pdf/ecec.pdf. 

Engler Environmental Associates. 2005. Annual Pollution Prevention Report for July 2004 – 

June 2005. Prepared for the Mountain View Sanitation District. 

Groundwater Replenishment System (GWRS). 2008. Examining the Cost of Building and 

Operating a Water Purification System to Provide a New Source of Water for an Arid Region. 

King County. 2005. Benefit/Cost Analysis Report: Regional Infiltration and Inflow Control 

Program King County, Washington. Prepared 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 Leachates. The Science of the Total Environment: 

Volume 301, Issues 1-3, pages 1-12. 

Mena, Deirdre. 2005. East Bay Municipal Utilities District Wastewater Department. Personal 

communication. June. 

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

Oregon Department of Environmental Quality (ODEQ). 2008. Salary Schedule. Online at 

http://www.deq.state.or.us/msd/hr/salaryschedule.pdf. 
Oregon Department of Environmental Quality (ODEQ). 2007a. 2007-2011 DEQ Mercury 

Reduction Strategy. March. 

Oregon Department of Environmental Quality (ODEQ). 2007b. Use Attainability Analysis and 

Site-Specific Criteria Internal Management Directive. April. 

Oregon Department of Environmental Quality (ODEQ). 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 (ODEQ). 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 Report 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 (ODEQ). 2005. Reasonable Potential Analysis 

for Toxic Pollutants Internal Management Directive. September. 

Oregon Department of Environmental Quality (ODEQ). 2004. Guidance Document for 

Preparation of the NPDES Strom Water Pollution Control Plan. May. 

Oregon Department of Environmental Quality (ODEQ). 1998. Columbia Slough Total 

Maximum Daily Loads (TMDLs) for Chlorophyll a, Dissolved Oxygen, pH, Phosphorus, 

Bacteria, DDE/DDT, PCBs, Pb, Dieldrin 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 (ODEQ) and Idaho Department of Environmental 

Quality (IDEQ). 2003. Snake River - Hells Canyon Total Maximum Daily Load (TMDL). July. 

Oregon Department of Forestry (ODF). 2007a. Oregon Department of Forestry Forest Practice 

Administrative Rules and Forest 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. Appendix J: Water, Sewer, Stormwater projects 

needed to address State/Federal Requirements 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. Technological Feasibility of 

Proposed Water Quality Criteria for New Jersey. Prepared for U.S. EPA Region 2. Prepared by 

Science Applications International Corporation. March. 

United States Environmental Protection Agency (U.S. EPA). 2002. National Recommended 

Water Quality Criteria: 2002. Human Health Criteria Calculation Matrix. EPA 822-R-02-012. 

November. 

United States Environmental Protection Agency (U.S. EPA). 2001a. Water Quality Criterion 

for the Protection of Human Health: Methylmercury. 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 (Draft 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 Protection 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 Workbook. EPA 823-B-95-002. March. 

June 2008 7. References 7-3
United States Environmental Protection Agency (U.S. EPA). 1991. Technical Support 

Document for Water Quality-based Toxics Control. EPA/505/2-90-001. March. 

United States Environmental Protection Agency (U.S. EPA). 1980. Guidelines and 

Methodology Used in the Preparation of Health Effect Assessment Chapters of the Consent 

Decree Water Criteria Documents. Federal Register 45: 79347, Appendix 3. 

U.S. Geological Survey (USGS). 2003. Mercury in Stream Ecosystems—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 Infiltration in Wastewater Collection Systems. 

Presented at Convergence 2000, July 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 Infrastructure 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 7-4
June 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 facility was originally designed to treat 

wastes from canneries as well as domestic wastewater, although the canneries are no longer in 

service. ODEQ classifies this 4.2 mgd (ADWDF) facility 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 categorical or significant industrial users, and therefore is not required to have 

a federal pretreatment program. However, ODEQ has requested that the facility conduct an 

industrial waste survey from which it may reevaluate the need for a pretreatment program. 

Treatment Processes 

The 2001 NPDES permit for the facility lists current treatment processes as headworks, two 

aerated lagoons, a polishing lagoon, and chlorine contact 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 are 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 effluent data are available. The facility does not have effluent 

limits for any toxic pollutants. 

Exhibit A-1. Effluent Data Summary, City of Astoria1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

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

Exhibit A-1. Effluent Data Summary, City of Astoria1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 Astoria1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2 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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 all 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 permit, 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 Baseline Criteria, Astoria WWTP 

Parameter Calculated 

Effluent 

Conc.1 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 

Mercury4 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 arsenic (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 the regulatory mixing zone is greater 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 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 sources to the treatment plant. 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; there 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 contaminant level is 10 μg/L, which is higher than 

current wastewater effluent concentrations and human health criteria. Therefore, 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 values in the wastewater, it is likely that the facility would pursue a 

variance or request that ODEQ 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 costs 

associated 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 identification and pipe rehabilitation for a system with 77 miles of 

sewer pipes (approximately $403,000 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 the discharger would not likely 

undertake such a program for compliance with toxic criteria alone. 

Revised Criteria 

Exhibit A-3 summarizes the RPA for the revised human health criteria for consumption of 

organisms only for those pollutants detected in the effluent (there will be no RP or monitoring 

requirements if all observations are nondetect). 

Exhibit A-3. RPA for Revised Criteria, Astoria WWTP

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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 

Mercury2 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 could have RP for arsenic and mercury based on the 

alternative fish consumption rates. 

Arsenic 

The discharger would have RP for arsenic 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 (μg/L) 0.49 0.28 0.18 0.081 0.053 

MDEL (μg/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 criteria, or pursue alternative compliance 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 comprehensive study to identify all potential 

infiltration sources and rehabilitation of those sources. Thus, baseline 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 mercury 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 (μg/L) NA NA 0.059 0.027 0.017 

MDEL (μg/L) NA NA 0.12 0.052 0.033 

The maximum effluent concentration at the facility 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 greater 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 mercury 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 Appendix B for details). As described in Appendix 

B, P2 costs also include expenditures by indirect dischargers to implement controls (see Exhibit 

B-2). Based on information on the discharger’s service area, incremental indirect discharger 

costs may be minimal (e.g., there are no universities 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 consumption rates, the incremental costs 

represent the any costs above and beyond those that would be needed for compliance with 

baseline criteria. Under a variance scenario for arsenic, costs would likely fall within the range 

shown in the exhibit (e.g., a one-time expenditure of approximately $35,000 to $100,000). 

Exhibit A-6. Summary of Potential Costs, Astoria WWTP 

Alternative Compliance Scenario Total Annual Costs Incremental 

($/yr) Costs1

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 Potential Costs, Astoria WWTP 

Alternative Compliance Scenario Total Annual Costs Incremental 

($/yr) Costs1

• Intake credits, variance, or I&I reduction program (arsenic) 389 gpd $100,000 - $503,000 $100,000 • P2 program (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 620 gpd $100,000 - $503,000 $100,000 • 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 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-8
City of Brookings Wastewater Treatment Plant 

Facility Description 

The City of Brookings Wastewater Treatment Plant (NPDES permit number OR0020354) is a 

secondary treatment facility that serves Brookings and the Harbor Sanitary District. Based on 

1995 estimates, the facility serves a population of 9,700, and primarily treats wastewater from 

domestic sources including residential and commercial sites. ODEQ classifies the facility as a 

major discharger. The ADWDF for the plant is 1.75 mgd. The facility discharges all treated 

effluent into the Pacific Ocean through outfall 001. There are 10 other outfalls used only in 

emergency overflow situations. 

Treatment Processes 

The 2000 NPDES permit for the facility lists current treatment processes as screening, grit 

removal, primary sedimentation, tricking filter/ solids contact secondary treatment, secondary 

clarification, and disinfection with chlorine gas. Sludge is sent to an anaerobic digester equipped 

with a sludge thickening system, and land applied to approved beneficial use sites. 

 

Effluent Data and Limits 

There are no effluent data available for the pollutants 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 dilution factor (which is generally lower than the human health 

dilution factors) is 70. Given such a large dilution factor, it is unlikely that the facility would 

have RP to cause or contribute to exceedances of the baseline criteria or the revised criteria based 

on alternative fish consumption rates.

June 2008 Appendix A. Facility Analyses A-9
City of Coos Bay Wastewater 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 City of Coos Bay and the Charleston Sanitary 

District. The treatment facility receives primarily domestic wastewater from residential and 

commercial sources from a population of approximately 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 Bay 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 current 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 lagoon 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 available data represent maximum and average values of 

three samples. Because the raw data are not available, the exhibit shows only the maximum and 

average concentrations for the detected values. The facility does not have effluent limits for any 

toxic pollutants. 

Exhibit A-7. Effluent Data Summary, Coos Bay WWTP #21

Summary of Detected Values Number of Observations Pollutant (μg/L) 

Total Nondetect MDL2 (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-10
June 2008 Appendix A. Facility Analyses A-11

Exhibit A-7. Effluent Data Summary, Coos Bay WWTP #21

Number of Observations Summary of Detected Values 

Pollutant (μg/L) 

Total Nondetect MDL2 (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 Data Summary, Coos Bay WWTP #21

Summary of Detected Values Number of Observations Pollutant (μg/L) 

Total Nondetect MDL2 (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 for the pollutants of concern for this facility. 

Potential Impacts 

Baseline Criteria 

Under ODEQ (2005) procedures, the RPA for carcinogens 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 health criteria for consumption 

of organisms only are applicable. 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 available, however, the facility’s existing permit 

indicates a dilution factor of 41 (dilution at edge of regulatory mixing zone). 

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

Parameter Calculated 

Effluent 

Conc.1 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 

Mercury4 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 human health criteria for consumption of 

organisms only for those pollutants detected in the effluent (there will be no RP or monitoring 

requirements if all observations are nondetect). 

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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Bis(2-Ethylhexyl) Phthalate 1.82 0.61* 0.34* 0.22* 0.099* 0.062* 

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 

Mercury2 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 have 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 (μg/L) 0.57 0.33 0.21 0.094 0.062 

MDEL (μg/L) 1.15 0.66 0.43 0.19 0.12 

The maximum effluent arsenic concentration 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 effluent arsenic concentrations for compliance with 

these limits. Arsenic and arsenic-containing chemicals 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 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 contributing to high arsenic levels in the wastewater effluent. In 

this case, it is likely that the facility would pursue a variance or request that ODEQ consider 

granting the facility intake credits. 

The facility’s permit indicates that the collection system has significant 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 whether these baseline modifications to the collection 

system would address arsenic levels (there are a number of modifications 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 costs 

associated 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) for a system with 50 miles of sewer pipes based 

on the number of miles of sewer pipe for a system of similar size and makeup (approximately 

$174,000 per year annualized at 7% over 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 reduction program alone may not be 

sufficient for compliance and the discharger would not likely undertake such a program for 

compliance with toxic criteria alone. 

Bis(2-ethylhexyl) phthalate 

The discharger would have RP for bis(2-ethylhexyl) 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 for 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 (μg/L) 25 14 9.0 4.1 2.5 

MDEL (μg/L) 50 28 18 8.1 5.1 

The maximum effluent bis(2-ethylhexyl) phthalate concentration is 55.4 μg/L, which is greater 

than the projected effluent limits for all the consumption rates. Bis(2-ethylhexyl) phthalate is 

found mainly in plastics and is used as a plasticizer for polyvinylchloride (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 industrial users and that the only hospital in the area dischargers to the 

area’s other treatment plant. Thus, it is likely that the bis(2-ethylhexyl) phthalate is not the result 

of any one major source, rather a combination of many sources including the residential sector. 

High levels of bis(2-ethylhexyl) phthalate in municipal wastewater effluent can also be 

associated 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. 

Because the bis(2-ethylhexyl) phthalate 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 modest 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 rates of 175 gpd and greater, the 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, the 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 consumption rates, the incremental costs 

represent the any costs above and beyond those that would be needed for compliance with 

baseline criteria. Under a variance scenario for arsenic and/or bis(2-ethylhexyl) phthalate, 

incremental costs for all alternative consumption rates could include 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 Costs1

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) 175 gpd $0 - $174,000 $0 - $174,000 • Cleaner sampling or variance [bis(2-ethylhexyl) phthalate] 

• Intake credits, variance, or I&I reduction program (arsenic) 389 gpd $0 - $174,000 $0 - $174,000 • Cleaner sampling or variance [bis(2-ethylhexyl) phthalate] 

• Intake credits, variance, or I&I reduction program (arsenic) 620 gpd $0 - $174,000 $0 - $174,000 • 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 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-16
Eugene-Springfield WWTP 

Facility Description 

The Metropolitan Wastewater Management Commission (MWMC) operates a wastewater 

treatment facility located in Eugene, Oregon (NPDES permit number OR0031224). The facility 

serves the Eugene and Springfield areas, and has an ADWDF of 49 mgd. 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 outfalls categorized as emergency overflows. 

Treatment Processes 

The 2002 NPDES permit for the facility lists current treatment processes as activated sludge with 

anaerobic digesters, eight 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, consisting of three primary and 

two secondary anaerobic digesters and sludge from the secondary digesters undergoes further 

stabilization and drying at the Regional Biosolids Management Facility prior to land application. 

Effluent Data and Limits 

Exhibit A-13 summarizes monitoring data from September 2003 to September 2006 for those 

pollutants of concern for which effluent data are available. The facility does not have effluent 

limits for any toxic pollutants. 

Exhibit A-13. Effluent Data Summary, Eugene-Springfield WWTP1

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

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

Exhibit A-13. Effluent Data Summary, Eugene-Springfield WWTP1

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 WWTP1

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 Willamette 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 all observations are nondetect). The 

Willamette River is a freshwater river; thus, human 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 flow for dilution for noncarcinogens. 

 

June 2008 Appendix A. Facility Analyses A-19
Exhibit A-14. RPA for Baseline Criteria, Eugene-Springfield WWTP 

Parameter Calculated 

Effluent 

Conc.1 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 (factor = 6.5) and 25% of harmonic mean flow for carcinogens 

(factor = 10.6). 

DDT and BHC 

As shown in the exhibit, the facility currently has RP to exceed 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 (ATSDR, 2002). BHC is a 

manufactured chemical that exists in eight chemical forms called isomers. Technical-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, 

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 plant, it is likely that the facility would pursue a 

variance. Total costs for alternative compliance mechanisms could range from $35,000 to 

$300,000, with minimal costs associated with renewal. 

As part of the variance, ODEQ may require the facility to implement a P2 or source control 

program to identify the sources of the pollutants (e.g., any commercial/industrial indirect 

discharges that may have in the past used the chemicals or manufactured pesticides containing 

the chemicals) because certain sources may be controllable. 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 mercury TMDL, the facility would be required to 

develop and implement a mercury reduction strategy. Annual P2 program costs for a 49 mgd 

municipal facility may be approximately $150,000 (see Appendix B for details). As described 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 service area, incremental 

indirect discharger costs may be $48,000 (e.g., there are four 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 whole are required to reduce existing 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. 

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 Criteria, Eugene-Springfield WWTP

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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 (factor = 6.5) and 25% of harmonic mean flow for carcinogens 

(factor = 10.6). 

The discharger would have RP for both 4,4-DDT and alpha-BHC at all consumption rates. As 

described in the baseline analysis, the discharger may pursue variances for these pollutants 

because neither pollutant is actively used nor are there known sources to a municipal wastewater 

treatment plant. Under the assumption that the facility would pursue 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 consumption 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 Potential Costs, Eugene-Springfield WWTP 

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs1

• 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 620 gpd $248,000 $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 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-21
Kellogg Creek Wastewater Treatment Plant 

Facility Description 

The Clackamas County Service District’s Kellogg Creek Wastewater Treatment Plant (NPDES 

permit number OR0026221) is located in Milwaukie, 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 current treatment processes as screening and grit 

removal, primary clarification, aeration basins and secondary clarifiers, and ultraviolet light 

disinfection. The facility stabilizes sludge from the primary clarifiers using anaerobic 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 effluent data are available. The facility does not have effluent 

limits for any toxic pollutants. 

Exhibit A-17. Effluent Data Summary, Kellogg Creek WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

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

Exhibit A-17. Effluent Data Summary, Kellogg Creek WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 Data Summary, Kellogg Creek WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(μg/L) 

Geometric Maximum Minimum Mean 

N-Nitrosodi-n-Propylamine 2 2 9.8 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 concern for which ambient data are available. 

Exhibit A-18. Ambient Data Summary, Kellogg Creek WWTP1 

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

Exhibit A-18. Ambient Data Summary, Kellogg Creek WWTP1 

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 WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL (μg/L) Geometric Maximum Minimum Mean 

PCBs2 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 (Aroclor 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 all observations are nondetect). The 

Willamette River is a freshwater river; thus, human 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 facility’s existing permit indicates the dilution factor is 19.9. The 

Willamette River at river mile 18 is on the state’s 303(d) list as impaired for DDT, DDE, 

dieldrin, dioxin, mercury, PCBs, pentachlorophenol, 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 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/L) 

Arsenic 1.06 0.6 1.06 0.0022 Yes 

Mercury Yes 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 greater than the criterion, the Willamette River 

near the discharge is not on the state’s 303(d) list as impaired for arsenic. 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 concentration at the edge of the mixing 

zone would be 0.62 μg/L, or approximately 4% above the ambient background concentration. 

ODEQ (2005) indicates that dischargers that cause less than a 10% increase in downstream 

receiving water concentrations would not be given numeric effluent limits; rather they would be 

required to implement narrative BMPs and increased monitoring. The costs of such measures 

could be comparable to the cost of implementing a mercury P2 program because the facility 

would likely conduct similar actions and activities. Thus, costs could be approximately 

$100,000 per year. 

If ODEQ determines that the water body is impaired, it would not grant 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 used in wastewater treatment. The facility’s 

permit does not indicate whether there are any significant or categorical industrial users. If the 

facility determines that one or more of its indirect dischargers is causing 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 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 costs to indirect dischargers. 

Other potential sources of arsenic to the treatment plant are drinking water and groundwater 

infiltration. The City of Milwaukie’s water system relies on seven operating wells and 500,000 

gallons of water per day from the Clackamas Water 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). These 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 the influent drinking water 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 costs 

associated 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 identification and pipe rehabilitation for a system with 70 miles of 

sewer pipes (approximately $331,000 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 the discharger would not likely 

undertake such a program for compliance 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 mercury TMDL, the facility would be required to 

develop and implement a mercury reduction strategy. Annual P2 program costs for a 7.1 mgd 

municipal facility may be approximately $100,000 (see Appendix B for details). As described 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 service area, incremental 

indirect discharger costs may be minimal (e.g., there 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 whole are required to reduce existing 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-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

Parameter Conc. at Edge of Human Health Criteria for Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 would have RP for arsenic and mercury based on all 

alternative fish consumption rates. 

Arsenic 

The discharger would have RP for arsenic at all 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. However, 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 (μg/L) 0.0047 0.0026 0.0017 0.00076 0.00048 

MDEL (μg/L) 0.0094 0.0052 0.0034 0.0015 0.00096 

The maximum effluent concentration is greater than all of the AMELs and MDELs. The facility 

is already required to implement 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 criteria (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 consistent basis, dischargers may need to pursue a variance (e.g., 

based on manmade conditions that cannot be remedied) under more 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 associated 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-22 provides a summary of the potential range in annual costs associated with the 

baseline and revised criteria. For the alternative fish consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

criteria. Under a variance scenario for arsenic and/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 Costs1

• Intake credits, BMPs, variance, or I&I reduction program 

Baseline (arsenic) $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 Costs1

• Intake credits, BMPs, variance, or I&I reduction program 

63.2 gpd (arsenic) $100,000 - $431,000 $0 

• P2 program possible variance (mercury) 

• Intake credits, BMPs, variance, or I&I reduction program 

113 gpd (arsenic) $100,000 - $431,000 $0 

• P2 program possible variance (mercury) 

• Intake credits, BMPs, variance, or I&I reduction program 

175 gpd (arsenic) $100,000 - $431,000 $0 

• P2 program possible variance (mercury) 

• Intake credits, BMPs, variance, or I&I reduction program 

389 gpd (arsenic) $100,000 - $431,000 $0 

• P2 program possible variance (mercury) 

• Intake credits, BMPs, variance, or I&I reduction program 

620 gpd (arsenic) $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 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-30
City of McMinnville Water Reclamation Facility 

Facility Description 

The City of McMinnville Water Reclamation Facility (NPDES permit number OR0034002) is a 

major facility serving McMinnville, Oregon. The 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 also has 15 other outfalls categorized as emergency 

overflows. 

Treatment Processes 

The 2003 NPDES permit for the facility lists current treatment processes as an off-site raw 

influent pump station and screen, headworks, activated sludge oxidation ditches, secondary 

clarifiers, tertiary clarifiers, single media filters, UV disinfection, 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 stored 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 are available. The facility does not have effluent limits for any 

toxic pollutants. 

Exhibit A-23. Effluent Data Summary, McMinnville WRF1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2 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-31
June 2008 Appendix A. Facility Analyses A-32

Exhibit A-23. Effluent Data Summary, McMinnville WRF1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2 

(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 Data Summary, McMinnville WRF1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2 

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 measurements 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 flow to the 30Q5 flow is 2.37. Assuming a similar 

flow pattern and ratio, the 30Q5 for the South Yamhill 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 WRF1 

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 all 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 applicable. 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

(μg/L) 

Conc. at Edge Ambient Human Health Reasonable of Mixing Conc.2 (μg/L) Zone3 (μg/L) Criterion (μg/L) Potential 

Antimony 0.46 0.043 0.24 5.6 No 

Arsenic 1.04 0.44 1.04 0.0022 Yes 

Mercury4 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 arsenic (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 (factor = 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 the regulatory mixing zone is greater than the applicable existing 

human health criterion. Note also that although ambient concentrations are greater than the 

criterion, the South Yamhill River is not on the state’s 303(d) list as impaired for arsenic. 

Regardless, the facility would be discharging arsenic above allowable 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 through atmospheric deposition (e.g., arsenic released 

into the air by volcanoes), soil erosion and weathering of arsenic-containing minerals and ores, 

and commercial or industrial processes, such as metal smelting, wood preserving, and 

manufacturing of microelectronics and semiconductors (ODEQ, 2006a). Arsenic and arseniccontaining chemicals are not used in wastewater treatment. However, drinking water and 

groundwater infiltration are two potential sources of arsenic to the 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 contaminant level is 10 μg/L, which is higher 

than current effluent concentrations and human health criteria. Thus, from these data it is not 

possible to determine if 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 

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. EPA 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 pipes 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 downspouts, 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 laterals 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 costs 

associated 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 program 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 (approximately $349,000 per year annualized at 7% over 20 

years). 

Mercury 

Under the baseline Willamette River Basin mercury TMDL, the facility would be required to 

develop and implement a mercury reduction strategy. Annual P2 program costs for a 5.6 mgd 

municipal facility may be approximately $100,000 (see Appendix B for details). As described 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 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 individual wasteload allocations to point source 

dischargers in the TMDL (point sources as a whole are required to reduce existing 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-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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 (factor = 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 could have RP for arsenic and mercury based on the 

alternative fish consumption rates. 

Arsenic 

The discharger would have RP for arsenic at all 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. However, 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 mercury 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 applicable criteria the discharger would 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 (μg/L) 0.0047 0.0026 0.0017 0.00076 0.00048 

MDEL (μg/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 Willamette Basin mercury TMDL. It is not clear how 

ODEQ would adapt the baseline TMDL to attain the revised criteria (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 

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 consistent basis, dischargers may need to pursue a variance (e.g., 

based on manmade conditions that cannot be remedied) under more stringent TMDL 

requirements (alternatively, ODEQ may account for this situation in allocating loads under the 

TMDL). However, it is uncertain for which consumption 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 associated 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 consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

criteria. Under a variance scenario for arsenic 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 Costs1

• Intake credits, variance, or I&I reduction program (arsenic) Baseline $112,000 - $461,000 NA • P2 program (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 63.2 gpd $112,000 - $461,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 113 gpd $112,000 - $461,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 175 gpd $112,000 - $461,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 389 gpd $112,000 - $461,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 620 gpd $112,000 - $461,000 $0 • 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 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-38
City of North Bend Wastewater Treatment Plant 

Facility Description 

The City of North Bend Waste Water Treatment Plant (NPDES permit number OR0023361) 

treats wastewater for North Bend, Oregon. The facility treats domestic wastewater from 

residential and commercial sources for a population of approximately 9,700. ODEQ classifies 

this 2.2 mgd (ADWDF) as a major discharger. Treated effluent is discharged through outfall 001 

into Coos Bay. The facility also has nine other outfalls categorized as emergency overflows. 

Treatment Processes 

The 2003 NPDES permit for the facility lists current treatment processes as headworks, a 

primary clarifier, two secondary clarifiers, three aeration basins, and chlorine disinfection. 

Sludge from the primary and secondary clarifiers is stabilized and land applied as Class B 

biosolids to beneficial use sites located 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 effluent data are available. The facility does not have effluent 

limits for any toxic pollutants. 

Exhibit A-29. Effluent Data Summary, North Bend WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

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

Exhibit A-29. Effluent Data Summary, North Bend WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 health criteria for consumption of organisms only are applicable. 

The dilution factors are based on the chronic mixing 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

(μg/L) 

Conc. at Edge Ambient Human Health Reasonable of Mixing Conc.2 (μg/L) Zone3 (μg/L) Criterion (μg/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 dilution 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 mixing 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 would 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 available is less than both 

projected effluent limits. Thus, it is possible that additional monitoring 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 may need to reduce discharge concentrations for 

compliance with baseline standards. 

Arsenic and arsenic-containing chemicals are not used in wastewater treatment, and the facility 

does not serve any significant industrial users. Based on the most 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 passing through the treatment facility. However, 

drinking water and groundwater infiltration 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 contributing to high arsenic levels in the wastewater effluent. In 

this case, it is likely that the facility would pursue a variance or request 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 infiltration is causing the high arsenic effluent levels, the discharger may 

have to implement an I&I reduction program for compliance 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 concentrations. 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 prevent groundwater high in arsenic from entering 

the system though; only pipe rehabilitation 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 costs 

associated 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 (source identification costs are not included 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 the 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 the effluent (there will be no RP or monitoring 

requirements if all observations are nondetect). 

Exhibit A-31. RPA for Revised Criteria, North Bend WWTP

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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 dilution factors in existing permit (factor = 105). 

As shown in the exhibit, the discharger would have RP for arsenic at all 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 (μg/L) 1.5 0.84 0.55 0.24 0.16 

MDEL (μg/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 criteria, or pursue alternative compliance 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 comprehensive study to identify all potential 

infiltration sources and rehabilitation of those sources. Thus, baseline 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 consumption rates, the incremental costs 

represent the any costs above and beyond those that would be needed for compliance with 

baseline criteria. Under a variance scenario for arsenic, costs would likely fall within the range 

shown in the exhibit (e.g., a one-time expenditure of approximately $35,000 to $100,000). 

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

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs1

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

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

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

reduction program (arsenic) 63.2 gpd $0 - $174,000 $0 

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

reduction program (arsenic) 113 gpd $0 - $174,000 $0 

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

reduction program (arsenic) 175 gpd $0 - $174,000 $0 

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

reduction program (arsenic) 389 gpd $0 - $174,000 $0 

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

reduction program (arsenic) 620 gpd $0 - $174,000 $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 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-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, commercial, and industrial 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 facility as a major discharger. The facility 

discharges treated municipal wastewater through 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 Outfalls 001 and 003 are 70 mgd and 10 

mgd, respectively. The facility also has several outfalls for bypass and overflows. 

Treatment Processes 

The NPDES permit for the facility indicates that the plant underwent many improvements during 

the 1990’s. Most notable were the disinfection system improvements completed in 1991, 

modifications to the secondary treatment system 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 application, 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 concern 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 0011 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

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

Exhibit A-34. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 0011 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 0011 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 0031 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 2.6 
June 2008 Appendix A. Facility Analyses A-48

Exhibit A-35. Effluent Data Summary, City of Portland, Columbia Blvd WWTP, Outfall 0031 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 0031 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 dilution 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

(μg/L) 

Conc. at Edge Ambient Human Health Reasonable of Mixing Conc.2 (μg/L) Zone3 (μg/L) Criterion (μg/L) Potential 

1,4-Dichlorobenzene 3.43 0 0.037 63 No 

2,3,7,8-TCDD (Dioxin) 5.2E-06 0 5.2E-06 1.3E-08 Yes 

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 

Mercury4 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 (CV = 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 factor 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

(μg/L) 

Conc. at Edge Ambient Human Health Reasonable of Mixing Conc.2 (μg/L) Zone3 (μg/L) Criterion (μg/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 

Mercury4 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

(μg/L) 

Conc. at Edge Ambient Human Health Reasonable of Mixing Conc.2 (μg/L) Zone3 (μg/L) Criterion (μg/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 for 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 factor 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 concentration at the edge of the regulatory mixing 

zone is greater than the applicable existing human health criterion. The Columbia River is also 

on the state’s 303(d) list as impaired for arsenic, and EPA completed a TMDL for dioxin in 

1991. 

Arsenic 

Because of the 303(d) listing, the discharger would have to comply with criteria end-of-pipe (i.e., 

no dilution) and a waste load allocation under a future TMDL for the Columbia River. If ODEQ 

determines that ambient background levels represent natural conditions, it may not require the 

facility to reduce discharge concentrations. However, 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 levels 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 significant industrial users and 89 other industrial 

dischargers to the treatment system. If the facility 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 dischargers. Without specific information on the types of industrial 

dischargers that may need controls, it is not possible to estimate pretreatment or P2 costs to 

indirect dischargers. 

 

The City’s primary drinking water source is the 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 possible that drinking water is contributing to 

high arsenic levels in the wastewater effluent. In this case, it is likely that the facility would 

pursue a variance or request that ODEQ consider 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 program 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 costs 

associated 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 and pipe rehabilitation for a system with 2,256 miles of sewer 

pipes (approximately $10,682,000 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 the discharger would not likely 

undertake such a program for compliance with toxic criteria alone. 

Dioxin 

EPA’s 1991 Dioxin TMDL for the Columbia, Snake, and Willamette Rivers does not include 

wasteload allocations for municipal wastewater treatment facilities (EPA only allocated loads to 

pulp mills). In addition, the facility’s existing permit does not contain an effluent limit for 

dioxin, only a quarterly dioxin monitoring requirement. Thus, it is unlikely that the facility 

would install end-of-pipe treatment controls to reduce effluent dioxin levels to the criterion. The 

facility would either pursue a variance or site-specific 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 include dioxin in the variance application/analysis for arsenic would 

be minimal. As part of the variance, ODEQ could require the facility to implement a P2 program 

to determine if the dioxin is the result of existing indirect dischargers or residual from prior 

industrial uses. Costs of a P2 program for dioxin could be approximately $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 monitoring requirements if all observations are nondetect). 

Exhibit A-38. RPA for Revised Criteria, Portland, Columbia Blvd WWTP, Outfall 001

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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 

2,3,7,8-TCDD (Dioxin) 5.2E-06 1.4E-09* 7.9E-10* 5.1E-10* 2.3E-10* 1.4E-10* 

Arsenic 0.76 0.0083* 0.0057* 0.0041* 0.0021* 0.0014* 

Bis(2-Ethylhexyl) Phthalate 0.058 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 8,500 5,500 3,800 1,800 1,200 

Di-n-Butyl Phthalate 0.43 920 580 400 190 120 

Mercury2 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 factor 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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Bis(2-Ethylhexyl) Phthalate 0.28 0.49 0.30 0.20* 0.095* 0.061* 

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 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 factor 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 would have RP for arsenic, dioxin, and mercury in 

Outfall 001, and arsenic, bis(2-ethylhexyl) phthalate, mercury, and tetrachloroethylene in Outfall 

003. 

Arsenic 

The discharger would have RP for arsenic at all 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 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. 

However, under the baseline, the discharge would need to meet those same levels. Thus, there 

would be no incremental compliance costs. 

Dioxin 

The discharger would have RP for dioxin at all fish consumption rates for Outfall 001. As 

described under the baseline criteria 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 pursue a variance and possibly be required to 

implement a P2 program. Although the criteria become more stringent under the revised fish 

consumption rates, it is likely that the discharger would pursue the same actions as it would for 

compliance with baseline standards. Thus, incremental compliance costs are unlikely. 

Bis(2-ethylhexyl) phthalate 

The discharger would have RP for bis(2-ethylhexyl) 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 (μg/L) NA NA 18 8.7 5.6 

MDEL (μg/L) NA NA 37 17 11 

The maximum effluent bis(2-ethylhexyl) phthalate concentration in Outfall 003 is 24.8 μg/L, 

which is greater than the projected effluent limits for all the consumption rates. The facility has 

a large industrial base and regulates 80 significant industrial users and 89 other industrial 

dischargers to the treatment system. The high bis(2-ethylhexyl) phthalate levels in the effluent 

could be due to one or more of its indirect dischargers. Regulating these sources through a P2 

program could reduce pollutant loadings 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 (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 effluent concentrations to approximately $50,000 for a P2 

program for bis(2-ethylhexyl) phthalate. 

 

Mercury 

The discharger would have RP for mercury 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 (μg/L) NA NA NA 0.07 0.04 

MDEL (μg/L) NA NA NA 0.16 0.10 

Outfall 003 

AMEL (μg/L) 0.43 0.24 0.16 0.07 0.04 

MDEL (μg/L) 1.13 0.62 0.41 0.18 0.12 

June 2008 Appendix A. Facility Analyses A-54
The maximum effluent concentration in Outfall 001 is 0.075 μg/L which is greater than the 

projected limits. The maximum effluent concentration in Outfall 003 is 0.38 μg/L which is 

greater than the all of the projected limits except those based on a consumption rate of 63.2 gpd. 

Thus, the facility may need to implement controls to reduce effluent mercury 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 100 mgd municipal facility may be approximately $150,000 (see Appendix B for 

details). As described 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 

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 remaining 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 and 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 consumption rates, the incremental costs 

represent the any costs above and beyond those that would be needed for compliance with 

baseline criteria. Under a variance scenario for dioxin and/or arsenic under the baseline scenario, 

one-time expenditure costs would range 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 Costs1

• Intake credits, variance, or I&I reduction 

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

• Variance with P2 program (dioxin) 

• Intake credits, variance, or I&I reduction 

63.2 gpd program (arsenic) $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 Costs1

• Intake credits, variance, or I&I reduction 

program (arsenic) 

• Variance with P2 program (dioxin) 175 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) 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) 620 gpd $320,000 - $11,052,000 $270,000 - $320,000 • 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 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-56
Rock Creek Advanced Wastewater Treatment Facility 

Facility Description 

The Rock Creek Advanced Wastewater Treatment Facility (NPDES permit number OR0029777) 

is located in Hillsboro, Oregon. The plant treats residential, commercial, and light industrial 

wastewater; wet industry flow, consisting of dilute, high volume wastewater 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, integrated municipal permit covering all three other 

facilities, an MS4, and two industrial 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 the 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 the major treatment processes as headworks, 

primary clarifiers, activated sludge, effluent filters, and digester complex. The facility thickens 

primary solids and returns activated sludge prior to anaerobic digestion. The facility dewaters 

digested biosolids and sends them to land application 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 effluent data are available. The facility does not have effluent 

limits for any toxic pollutants. 

Exhibit A-43. Effluent Data Summary, Rock Creek WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

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

Exhibit A-43. Effluent Data Summary, Rock Creek WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 upstream 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 WWTP1 

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

Exhibit A-44. Ambient Data Summary, Rock Creek WWTP1 

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 WWTP1 

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 all observations are nondetect). The 

Tualatin River is a freshwater river; 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, indicate 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 facility 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

(μg/L) 

Conc. at Edge Ambient Human Health Reasonable of Mixing Conc.2 (μg/L) Zone3 (μg/L) Criterion (μg/L) Potential 

Antimony 0.48 0 0.24 5.6 No 

Mercury4 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 for 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 which there are detected 

concentrations. 

Under the baseline Willamette River Basin mercury TMDL, the facility would be required to 

develop and implement a mercury reduction strategy. Annual P2 program costs for a 39 mgd 

municipal facility may be approximately $150,000 (see Appendix B for details). As described 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 service area, incremental 

indirect discharger costs may be minimal (e.g., there 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 whole are required to reduce existing 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-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

Parameter Conc. at Edge of Mixing Human Health Criteria at Alternative FCRs (μg/L) 

Zone1 (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 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 discharger would have RP for mercury 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 implement 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 criteria (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 consistent basis, dischargers may need to pursue a variance (e.g., 

based on manmade conditions that cannot be remedied) under more stringent TMDL 

requirements (alternatively, ODEQ may account for this situation in allocating loads under the 

TMDL). However, it is uncertain for which consumption rates the discharger would need a 

variance. 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. 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 consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

criteria. Under a variance scenario for mercury 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 Costs1

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 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-63
City of Salem Willow Lake Wastewater Treatment Plant 

Facility Description 

The City of Salem, Willow Lake Wastewater Treatment Plant (NPDES permit number 

OR0026409) treats domestic, commercial, and industrial 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-inch outfall to the Willamette River at river mile 

78.4. 

Treatment Processes 

The 2004 NPDES permit for the facility lists current 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 clarifier and chlorine contact tank. The south plant has two 

primary clarifiers, a pure-oxygen activated sludge process, four secondary clarifiers, a chlorine 

contact chamber, an additional gravity thickener, and four anaerobic digesters. The facility loads 

dewatered biosolids, at approximately 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 circular primary clarifiers, two new gravity thickeners for 

thickening primary sludge, expanded WAS thickening and biosolids dewatering facility, 

permanent chlorination and dechlorination facilities, an additional pass on the existing chlorine 

contact basin, and a new parallel outfall and diffuser 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 are available. The facility does not have effluent limits for any 

toxic pollutants. 

Exhibit A-48. Effluent Data Summary, Salem Willow Lake WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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-64
June 2008 Appendix A. Facility Analyses A-65

Exhibit A-48. Effluent Data Summary, Salem Willow Lake WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 facility) is 12,715 cfs, based on daily stream flow 

measurements from January 1990 through November 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 River 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 WWTP1 

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 WWTP1 

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 WWTP1 

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 all observations are nondetect). The 

Willamette River is a freshwater river; thus, human 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 dilution for noncarcinogens. The Willamette River at 

river mile 78.4 is on the state’s 303(d) list for dioxin 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 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 

Mercury4 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 arsenic (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 (factor = 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 would have to meet an AMEL of 0.026 μg/L and a 

MDEL of 0.047 μg/L for arsenic. However, because both limits are below the QL of 0.05 μg/L, 

the discharger would only be required to reduce discharge concentrations to the QL value for 

compliance with baseline standards. 

Inorganic arsenic can enter surface waters through atmospheric deposition (e.g., arsenic released 

into the air by volcanoes), soil erosion and weathering of arsenic-containing minerals and ores, 

and commercial or industrial processes, such as metal smelting, wood preserving, and 

manufacturing of microelectronics and semiconductors (ODEQ, 2006a). Arsenic and arseniccontaining chemicals are not used in wastewater treatment. The facility’s permit indicates that it 

has a total of 27 significant industrial users (SIUs) of which 8 are categorical industrial users 

(i.e., users subject to EPA’s national 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 and vegetables are treated with arsenic-containing 

pesticides, then any wash water from the packaging operations could contribute to the high 

effluent arsenic levels. Thus, a source control program that targets the most likely indirect 

industrial dischargers of arsenic to the plant could reduce arsenic concentrations to the necessary 

levels. Costs for such a program would depend 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 industrial dischargers that may need controls, it is not possible to 

estimate pretreatment or P2 costs to indirect dischargers. 

The City’s drinking water comes from the North Santiam 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 specified, and the drinking water maximum contaminant 

level is 10 μg/L, which is higher than current effluent concentrations and human health criteria. 

Thus, from these data it is not possible to determine with any certainty if 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 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 such high levels of arsenic into to the wastewater system could 

result in increased effluent concentrations. If the facility determines that the source of arsenic in 

its effluent is groundwater infiltration, an I&I reduction 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 costs 

associated 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 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 the discharger would not likely undertake such a 

program for compliance with toxic criteria alone. 

Mercury 

Under existing conditions, the discharger would have to meet an AMEL of 0.017 μg/L and a 

MDEL of 0.039 μg/L for mercury. The maximum effluent concentration is 0.07 μg/L, which is 

greater than the projected limits. Thus, the facility may need to implement controls to reduce 

effluent mercury concentrations for compliance with 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 costs 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 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 $24,000 (e.g., there are 2 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 whole are required to reduce existing 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-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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Bis(2-Ethylhexyl) Phthalate 0.82 0.49* 0.30* 0.20* 0.095* 0.061* 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 (factor = 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 have 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 (μg/L) 0.10 0.068 0.049 0.025 0.017 

MDEL (μg/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 criteria, or pursue alternative compliance 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 comprehensive study to identify all potential 

infiltration sources and rehabilitation of those sources. Thus, baseline 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-ethylhexyl) 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 (μg/L) 5.9 3.6 2.4 1.1 0.73 

Maximum Daily Limit (μg/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 consumption rates. Bis(2-ethylhexyl) phthalate is 

found mainly in plastics and is used as a plasticizer for polyvinylchloride (PVC) and other 

polymers. The plasticizer can be released from plastics manufacturing wastes or through release 

from plastic goods (Environment Canada, 1994). The facility’s permit indicates that it has a total 

of 27 SIUs. The high bis(2-ethylhexyl) phthalate levels in the effluent could be due to one or 

more of its indirect dischargers. Regulating these sources through a P2 program could reduce 

pollutant loadings 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 (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 effluent concentrations to approximately $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 Limits for Mercury, Salem Willow Lake WWTP

Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 

AMEL (μg/L) 0.0047 0.0026 0.0017 0.00076 0.00048 

MDEL (μg/L) 0.011 0.0060 0.0039 0.0018 0.0011 

The maximum effluent concentration is greater than all of the AMELs and MDELs. The facility 

is already required to implement 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 criteria (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 consistent basis, dischargers may need to pursue a variance (e.g., 

based on manmade conditions that cannot be remedied) under more 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 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. 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-55 provides a summary of the potential range in annual costs associated with the 

baseline and revised criteria. For the alternative fish consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

criteria. Under a variance scenario for arsenic and/or mercury, costs could include a one-time 

expenditure of $35,000 to $300,000. 

Exhibit A-55. Summary of Potential Costs, Salem Willow Lake WWTP 

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs1

• Intake credits, variance, or I&I reduction program (arsenic) Baseline $174,000 - $3,867,000 NA • P2 program (mercury) 

June 2008 Appendix A. Facility Analyses A-73
Exhibit A-55. Summary of Potential Costs, Salem Willow Lake WWTP 

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs1

• 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 criteria 

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 from St. Helens, Colombia City, 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. Wastewater 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 the ASB, the combined pulp mill and municipal 

wastewater is discharged through Outfall 001 to the 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 contributes 1 mgd. There are two other outfalls to the 

Colombia River, 008 and 009, that are for overflows. Outfalls 007 and 010 are for emergency 

discharge from the ASB and return mill intake water, 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 treatment processes as a primary aerated treatment 

basin, a chlorine contact chamber for disinfection, and a large aerated stabilization 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 are available. The facility does not have effluent limits for any 

toxic pollutants. 

Exhibit A-56. Effluent Data Summary, St. Helens-Boise Cascade WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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-75
June 2008 Appendix A. Facility Analyses A-76

Exhibit A-56. Effluent Data Summary, St. Helens-Boise Cascade WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 Summary, St. Helens-Boise Cascade WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 

1248, Aroclor 1254, and Aroclor 1260). 

Receiving Water Data 

Through computer modeling of stream flow data in the vicinity of the discharge, CH2MHill 

(2007) determined that the harmonic mean receiving 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 Columbia 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 all observations are nondetect). The 

Columbia River is a freshwater river; thus, human 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 dilution 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 the 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 Criteria, St. Helens-Boise Cascade WWTP

Parameter Calculated 

Effluent 

Conc.1 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 

Mercury4 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 (factor = 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 Criteria, St. Helens-Boise Cascade WWTP

Parameter Calculated 

Effluent 

Conc.1 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 mixing zone is greater than the applicable existing 

human health criterion. Note also that although ambient concentrations are greater than the 

criterion, the Willamette River near the discharge is not on the state’s 303(d) list as impaired for 

arsenic. 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 

concentration at the edge of the mixing zone would be approximately 0.2% above the ambient 

background concentration. ODEQ (2005) indicates that dischargers that cause less than a 10% 

increase in downstream receiving water concentrations would not be given numeric effluent 

limits; rather they would be required to implement narrative BMPs (e.g., improve internal 

process control) and increased monitoring. The costs 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 activities. Thus, costs could be approximately $25,000 per year. 

If ODEQ determines that the water body is impaired, it would not grant 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 used 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 treatment 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 concentrations 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 observation in 1993 (3 μg/L) (ODHS, 2007f). The 

minimum reporting levels are not specified, and the drinking water 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 effluent 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 Criteria, St. Helens-Boise Cascade WWTP

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 (factor = 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 could have RP for arsenic and mercury based on the 

alternative fish consumption rates. 

Arsenic 

The discharger would have RP for arsenic at all 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. However, 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 mercury at all fish consumption rates. Exhibit A-60 shows 

the AMELs and MDELs for each consumption rate. Note that at the alternative consumption 

rates the ambient background concentration (0.005 μg/L) is greater than the applicable criteria so 

the discharger would not receive dilution 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 (μg/L) 0.0047 0.0026 0.0017 0.00076 0.00048 

MDEL (μg/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 facility 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 compliance with these limits. As described above, 

only about 1 mgd of the 30 mgd effluent is municipal 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 mercury 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 with 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 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 

service area, incremental indirect discharger costs may be minimal (e.g., there are no universities 

in the service area). 

The pulp mill would need to implement a P2 program to identify the sources of mercury and 

determine the most cost-effective measures for reducing 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 control 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 industrial facility so P2 costs are greater 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 and 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 the discharger pursues a variance 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 consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

criteria. Under a variance scenario for arsenic and/or mercury, costs could include a one-time 

expenditure of approximately $35,000 to $300,000. 

Exhibit A-61. Summary of Potential Costs, St. Helen-Boise Cascade WWTP 

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs1

Baseline • Intake credits, BMPs, or variance (arsenic) $0 - $25,000 NA 

• Intake credits, BMPs, or variance (arsenic) 63.2 gpd $75,000 - $100,000 $75,000 • P2 program, possible variance (mercury) 

June 2008 Appendix A. Facility Analyses A-81
Exhibit A-61. Summary of Potential Costs, St. Helen-Boise Cascade WWTP 

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs1

• Intake credits, BMPs, or variance (arsenic) 113 gpd $75,000 - $100,000 $75,000 • P2 program, possible variance (mercury) 

• Intake credits, BMPs, or variance (arsenic) 175 gpd $75,000 - $100,000 $75,000 • P2 program, possible variance (mercury) 

• Intake credits, BMPs, or variance (arsenic) 389 gpd $75,000 - $100,000 $75,000 • P2 program, possible variance (mercury) 

• Intake credits, BMPs, or variance (arsenic) 620 gpd $75,000 - $100,000 $75,000 • 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 

criteria 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-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 serves the cities of Gladstone, Oregon City, 

and West Linn. ODEQ classifies the facility as a major discharger, with an ADWDF of 8.4 mgd. 

The facility discharges treated effluent through 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 effluent data are available. The facility does not have effluent 

limits for any toxic pollutants. 

Exhibit A-62. Effluent Data Summary, Tri-City Service District1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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-83
June 2008 Appendix A. Facility Analyses A-84

Exhibit A-62. Effluent Data Summary, Tri-City Service District1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 1 1 0.97 - - - 
Exhibit A-62. Effluent Data Summary, Tri-City Service District1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 pollutants of concern for which ambient data are 

available. 

Exhibit A-63. Ambient Data Summary, Tri-City Service District1 

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-85
June 2008 Appendix A. Facility Analyses A-86

Exhibit A-63. Ambient Data Summary, Tri-City Service District1 

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 Summary, Tri-City Service District1 

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 (Aroclor 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 all observations are nondetect). The 

Willamette River is a freshwater river; thus, human 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 upstream of the facility, and the facility’s 

existing permit does not specify any dilution factors. 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 would 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 impaired for these pollutants. 

Exhibit A-64. RPA for Baseline Criteria, Tri-City Service District

Parameter Calculated 

Effluent 

Conc.1 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/L) 

Arsenic 0.60 0.5 0.60 0.0022 Yes 

Mercury Yes 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 arsenic (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 greater 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 above 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 used in wastewater treatment. The facility’s 

permit does not indicate whether there 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 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 dischargers. Without specific information on the types of industrial dischargers that may 

need controls, it is not possible to estimate pretreatment or P2 costs to indirect dischargers. 

The facility’s drinking water comes from the Clackamas 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 specified, and the drinking water maximum contaminant 

level is 10 μg/L, which is higher than current effluent concentrations and human health criteria. 

Thus, from these data it is not possible to determine with any certainty if 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 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 such high levels of arsenic into to the wastewater system could 

result in increased effluent concentrations. If the facility determines that the source of arsenic in 

its effluent is groundwater infiltration, an I&I reduction program 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 costs 

associated 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 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 

June 2008 Appendix A. Facility Analyses A-88
program alone may not be sufficient for compliance and the discharger would not likely 

undertake such a program for compliance 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 mercury 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. 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 allocations to point source dischargers in the TMDL (point sources as a whole are 

required to reduce existing 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 8.4 mgd municipal facility may be approximately $100,000 (see 

Appendix B for details). As described 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 service 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 Criteria, Tri-City Service District

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 could 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 all 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. However, 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 (μg/L) 0.0047 0.0026 0.0017 0.00076 0.00048 

Maximum Daily Limit (μg/L) 0.0087 0.0048 0.0031 0.0014 0.00089 

The maximum effluent concentration is greater than all of the AMELs and MDELs. The facility 

is already required to implement 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 criteria (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 consistent basis, dischargers may need to pursue a variance (e.g., 

based on manmade conditions that cannot be remedied) under more 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 associated 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 consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

June 2008 Appendix A. Facility Analyses A-90
criteria. Under a variance scenario for arsenic 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 Costs1

• 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) 63.2 gpd $100,000 - $1,132,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 113 gpd $100,000 - $1,132,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 175 gpd $100,000 - $1,132,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 389 gpd $100,000 - $1,132,000 $0 • P2 program, possible variance (mercury) 

• Intake credits, variance, or I&I reduction program (arsenic) 620 gpd $100,000 - $1,132,000 $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 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 Plant (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 municipal, with an ADWDF of 3.33 mgd. 

Treated wastewater flows through Outfalls 001A and 001B into the Pudding River at river mile 

21.4. Reclaimed wastewater at Outfall 002 is distributed on land for dissipation by 

evapotranspiration and controlled seepage. There are three other outflows used for emergency 

overflows. 

Treatment Processes 

The 2004 NPDES permit for the facility lists current treatment processes as headworks with 

screening and degritting, primary clarification, anoxic selector activated sludge secondary 

treatment and clarification, effluent filtration, and ultraviolet disinfection. Treated wastewater is 

discharged to either the Pudding River (outfall 001) or a poplar tree plantation (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 are available. The facility does not have effluent limits for any 

toxic pollutants. 

Exhibit A-68. Effluent Data Summary, Woodburn WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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-92
June 2008 Appendix A. Facility Analyses A-93

Exhibit A-68. Effluent Data Summary, Woodburn WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 WWTP1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

Mercury3 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 - - - 

PCBs4 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents data analyzed using Method 1631 only because the facility’s current permit requires special monitoring of 

mercury using clean analytical methods. 

4. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 above 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 WWTP1 

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 WWTP1 

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 all observations are nondetect). The 

Pudding River is a freshwater river; 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 River 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 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/L) 

Arsenic 7.82 0.14 7.82 0.0022 Yes 

Bis(2-Ethylhexyl) Phthalate 67.9 0.0 42.5 1.2 Yes 

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 criteria for arsenic and bis(2-

ethylhexyl) phthalate because the concentrations at the edge of the regulatory mixing zone are 

greater than the applicable existing human health criteria. 

Arsenic 

Although ambient concentrations are greater than the criterion, the Pudding River is not on the 

state’s 303(d) list as impaired for arsenic. Regardless, the facility would be discharging above 

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). 

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 wells. The 2005 drinking water quality report 

indicates that arsenic concentrations in drinking 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 arsenic to the wastewater 

treatment facility is likely the City’s drinking water, the facility would likely pursue intake 

credits or a variance. 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 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 mainly in plastics and is used as a plasticizer for polyvinylchloride 

(PVC) and other polymers. The plasticizer can be released from plastics manufacturing wastes 

or through release from plastic goods (Environment Canada, 1994). The facility’s permit 

indicates that it has one categorical industrial user and 3 significant industrial users, the exact 

types of which are not specified. If additional testing indicates that bis(2-ethylhexyl) phthalate is 

the result of indirect industrial dischargers the facility would need to impose more stringent 

pretreatment limits or implement source controls to prevent bis(2-ethylhexyl) phthalate from 

entering the treatment plant. 

High levels of bis(2-ethylhexyl) phthalate in municipal wastewater effluent can also be 

associated 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. 

Therefore, costs for the facility could be minimal 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 mercury TMDL, the facility would be required to 

develop and implement a mercury reduction strategy. 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 municipal facility may be approximately $100,000 (see 

Appendix B for details). As described 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 service area, incremental indirect discharger costs may be minimal (e.g., there 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 whole are 

required to reduce existing 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. 

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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Bis(2-Ethylhexyl) Phthalate 42.5 0.49* 0.30* 0.20* 0.095* 0.061* 

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 have RP for arsenic and bis(2-ethylhexyl) phthalate 

based on the alternative fish consumption rates. 

Arsenic 

The discharger would have RP for arsenic at all 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. However, 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-ethylhexyl) 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 (μg/L) 0.78 0.48 0.32 0.15 0.098 

MDEL (μg/L) 1.6 0.96 0.64 0.30 0.20 

Based on existing effluent data, the discharger would need to reduce effluent bis(2-ethylhexyl) 

phthalate concentrations for compliance with the projected limits shown in the exhibit. The 

current approved QL for bis(2-ethylhexyl) phthalate is 1 μg/L. Therefore, the discharger would 

only have to reduce concentrations to below the QL for compliance 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 analysis, the discharger would either switch to cleaner sampling 

techniques or implement a P2 program for compliance with baseline limits. The baseline P2 

program includes source identification and implementation of control measures for those 

sources. It is uncertain the magnitude of reductions achievable through a P2 program because 

the specific sources have not yet been identified. 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 standards, and that those actions 

would also result in compliance with the revised criteria (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 baseline 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 variance 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 Costs1

• 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 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-98
City of Shady Cove Wastewater Treatment Plant 

Facility Description 

The City of Shady Grove Wastewater Treatment Plant (NPDES permit number OR0030660) 

treats wastewater generated from homes and businesses in the City of Shady Cove. Two homes 

outside the city limits are 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 Rogue 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 discharged through Outfall 001 to 

the Rogue River year-round at river mile 143.1. Outfall 002 is for emergency overflows to be 

discharged into the Rogue River. 

Treatment Processes 

The 2002 NPDES permit for the facility lists current treatment processes as preliminary 

screening, two aeration basins, two secondary clarifiers, two sand filters, and a chlorine contact 

chamber for disinfection. Waste secondary sludge is pumped to the aerobic digesters with 

surface aeration. After digestion, sludge is dewatered 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 toxic 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 discharge toxic pollutants in 

toxic amounts, it is unlikely that the facility would have RP to cause or contribute to exceedances 

of the baseline criteria or the revised criteria based on alternative fish consumption rates. It is 

also unlikely that ODEQ would require toxic pollutant 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 five 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, along 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 indicates 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 primary clarifier solids are dewatered and used as 

bedding for dairy cattle or land applied. Effluent from the primary clarifier is sent to an aerated 

stabilization basin before being discharged 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 facility does not have effluent limits for any toxic 

pollutants. 

Exhibit A-74. Effluent Data Summary, Blue Heron Paper Company1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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-100
June 2008 Appendix A. Facility Analyses A-101

Exhibit A-74. Effluent Data Summary, Blue Heron Paper Company1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 Summary, Blue Heron Paper Company1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 all observations are nondetect). The 

Willamette River is a freshwater river; thus, human 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, dieldrin, dioxin, mercury, and PCBs; 

thus, the facility would not receive 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 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 criterion for mercury because 

the concentration at the edge of the regulatory mixing 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 impaired). 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 discharger 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 allocations to point source dischargers in the TMDL (point 

sources as a whole are required to reduce existing 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 facility may be approximately $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

Parameter Conc. at Edge of Human Health Criteria (μg/L) 

Mixing Zone1 (μg/L) 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 2 0.52 

*Bolded values represent RP equal to “Yes.” 

1. Dilution based on values used in the facility’s draft 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 have RP for mercury at all consumption rates. 

Exhibit A-77 shows the AMELs and MDELs for each consumption 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 (μg/L) 0.0047 0.0026 0.0017 0.00076 0.00048 

Maximum Daily Limit (μg/L) 0.0094 0.0052 0.0034 0.0015 0.00096 

The maximum effluent concentration is greater than all of the AMELs and MDELs. The facility 

is already required to implement 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 criteria (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 consistent basis, dischargers may need to pursue a variance (e.g., 

based on manmade conditions that cannot be remedied) under more 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 could 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 consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

criteria. Under a variance scenario for mercury 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 Costs1

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 Costs1

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 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-105
Heinz Food Company 

Facility Description 

The Heinz Food Company (NPDES number OR0002402) 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 further 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 warehouse. The facility generates about 3.4 mgd of 

wastewater primarily from wet processes that wash, sort, blanch, cut, and transfer potatoes and 

during clean-up and equipment sanitation. Wastewater is discharged to the Snake River at river 

mile 371. 

Treatment Processes 

The 2003 permit for the facility indicates that before discharge to the wastewater system, potato 

wash water is routed through settling basins to remove silt, and raw starch is separated and 

recovered from potato white water (pump and cutting water). The wastewater treatment system 

consists of headworks, primary clarification, activated sludge, and sludge dewatering. The 

facility employs extensive recycling/reuse of water for conservation and to minimize the quantity 

of wastewater that must be discharged; recycled 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 the 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 require 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 permit 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 consists of a pulp mill, chlorine dioxide generator, 

power and recovery, recausticizing process, water treatment, and wastewater treatment. ODEQ 

classifies the facility as a major discharger. Effluent 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 indicates that the wastewater generated during the 

pulp production process is treated by primary clarification followed by biological treatment in 

two large aerated stabilization basins (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 basins are operated in series and each has a 

capacity of 113 million gallons and a detention time of about 10 days. Following the aeration 

basins, the treated effluent is sent to a secondary settling pond with a size of 150 square feet. 

Effluent Data and Limits 

Exhibit A-79 summarizes monitoring data for those pollutants 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, Hasley1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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-107
June 2008 Appendix A. Facility Analyses A-108

Exhibit A-79. Effluent Data Summary, Pope and Talbot, Hasley1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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, Hasley1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 - - - 

PCBs3 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 prior to November 2007 when ODEQ revised applicable QLs. 

3. Represents the lowest QL for the 7 congeners sampled (Aroclor 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 all observations are nondetect). The 

Willamette River is a freshwater river; thus, human 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, the 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 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 draft 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 arsenic according to ODEQ (2005) criteria, and the draft permit only requires 

additional arsenic testing using ultra clean methods to obtain lower detection limits. Thus, it is 

possible that the facility would not incur costs associated with baseline criteria. 

However, if the draft permit does not represent actual baseline (final permit) requirements, the 

facility may be required to reduce discharge concentrations to projected effluent limits of 0.31 

μg/L (AMEL) and 0.63 μg/L (MDEL). As mentioned 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, the 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 inorganic) from the surface waters since 1980 are 

nondetect below the minimum reporting levels; there 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. Although it is not possible to determine from these 

data with any certainty whether drinking water is contributing to high arsenic levels in the 

wastewater effluent, drinking 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 minimal 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 impaired). 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 mercury TMDL, the facility would be required to 

develop and implement a mercury reduction strategy. Annual P2 program costs for an industrial 

facility may be approximately $25,000 (see Appendix B for details). However, because ODEQ 

does not assign individual wasteload allocations to point source dischargers in the TMDL (point 

sources as a whole are required to reduce existing 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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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* 

Mercury 0.0047* 0.0026* 0.0017* 0.00076* 0.00048* 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 draft 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 could have RP for arsenic and mercury based on the 

alternative fish consumption rates. 

Arsenic 

The discharger would have RP for arsenic at all fish consumption rates. Exhibit A-82 shows the 

projected effluent limits for these consumption rates. 

Exhibit A-82. Projected Effluent Limits for Arsenic, Pope and Talbot, Hasley

Fish Consumption Rate Limit Type 63.2 gpd 113 gpd 175 gpd 389 gpd 620 gpd 

AMEL (μg/L) 1.2 0.82 0.59 0.30 0.20 

MDEL (μg/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 pursue 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 actions 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. Note that because the Willamette River is on 

the 303(d) list for mercury, the discharger 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 (μg/L) 0.0047 0.0026 0.0017 0.00076 0.00048 

MDEL (μg/L) 0.0094 0.0052 0.0034 0.0015 0.00096 

The maximum effluent concentration is greater than all the projected limits. The facility is 

already required to implement 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 criteria (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 consistent basis, dischargers may need to pursue a variance (e.g., 

based on manmade conditions that cannot be remedied) under more 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 associated 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-84 provides a summary of the potential range in annual costs associated with the 

baseline and revised criteria. For the alternative fish consumption rates, the incremental costs 

represent any costs above and beyond those that would be needed for compliance with baseline 

June 2008 Appendix A. Facility Analyses A-112
criteria. Under a variance scenario for arsenic and/or mercury, costs could include a one-time 

expenditure of approximately $35,000 to $200,000. 

Exhibit A-84. Summary of Potential Costs, Pope and Talbot, Hasley 

Alternative Compliance Scenario Incremental Total Annual Costs Annual Costs1

• Intake credits or variance (arsenic) Baseline $25,000 NA • P2 program (mercury) 

• Intake credits or variance (arsenic) 63.2 gpd $25,000 $0 • P2 program, possible variance (mercury) 

• Intake credits or variance (arsenic) 113 gpd $25,000 $0 • P2 program, possible variance (mercury) 

• Intake credits or variance (arsenic) 175 gpd $25,000 $0 • P2 program, possible variance (mercury) 

• Intake credits or variance (arsenic) 389 gpd $25,000 $0 • P2 program, possible variance (mercury) 

• Intake credits or variance (arsenic) 620 gpd $25,000 $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 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-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 aluminum 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 government in 1949 and operated it until 2000 when 

production was suspended. In 2002, the company announced that the facility would be 

permanently closed and dismantled. As a result of past waste handling practices at the facility, 

several waste disposal areas, soils, and groundwater are contaminated. The site is currently on 

EPA’s Superfund National Priorities List (NPL). The primary contaminants identified in the 

soils at the site include fluoride, cyanide, polycyclic aromatic hydrocarbons (PAHs), and 

polychlorinated biphenyls (PCBs). The groundwater beneath the site contains a significant 

fluoride plume. Groundwater from deep production wells (average flow of 2.37 mgd) and 

shallow, focused extraction wells (average flow 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 indicates that wastewater comes from pumped 

groundwater from deep production wells, shallow focused extraction wells, and small quantities 

of treated miscellaneous waste streams (e.g., laboratory sample analysis wastewater, sample 

basin water, monitoring well purge water, shallow groundwater and surface water pumped from 

dewatering activities for construction of subsurface infrastructure during property 

redevelopment, and occasional draw-down of groundwater 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 indicates that only trace amounts of aluminum and 

nondetects for PAHs characterize groundwater pumped from the deep and shallow extraction 

wells at the facility. The draft permit does not 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 acute or chronic toxicity outside the assigned mixing zone. The 2007 

fact sheet also indicates that the facility does not have RP for any of the pollutants for which the 

Columbia River is impaired: aldrin, DDE, arsenic, and dioxin. Dioxin is typically a contact 

product of chlorine interacting with biological material, and the facility no longer uses chlorine 

for disinfection. Aldrin, DDE, and 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 Manufacturing, LLC (BBSM) operates a stud mill and plywood 

manufacturing plant in Elgin, Oregon (NPDES permit number OR0002411). The facility includes 

a log storage yard (wet deck), veneer block vats and peeler, veneer lamination and dryer, saw 

mill, planer, boiler, lumber drying kilns, and product storage. ODEQ classifies the discharger as 

a minor industrial. The facility discharges process and nonprocess wastewaters, tile drain 

wastewater, and industrial storm water. Process wastewater includes veneer block sprinkling 

return flow, veneer dryer cleanup and deluge water, plywood press pit water (groundwater), kiln 

waters, filter backflush water, dry electrostatic precipitator (DESP) cleanup water, ash storage 

area runoff water, heavy equipment wash pad water, vat waters, and regenerative 

catalytic/thermal oxidizer (RCO-1) cleanup water. The facility discharges industrial storm water, 

boiler condensate, and fire system flush water through Outfall 001 and tile drain wastewater 

(groundwater collected from beneath the log yard) through Outfall 003 to Phillips Creek. Outfalls 

001 and 003 are approximately located at river mile 1 on Phillips Creek. 

Treatment Processes 

The 2005 NPDES permit for the facility 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. From the Frog Pond, combined flows 

are pumped to a 3-acre settling pond/open water wetland (SP/OWW), which overflows to a 15-acre 

Process Water Storage Pond (PWSP). The SP/OWW consists of two cells. The first cell is lined 

with 60-mil high-density polyethylene liner and includes an oil skimmer system. The second cell 

provides additional primary treatment. PWSP capacity is approximately 51 million gallons. PWSP 

wastewater is irrigated on land application sites, sprinkled on decked logs or veneer blocks for log 

quality control, or it is applied to roads and other unpaved areas for dust suppression. 

Effluent Data and Limits 

The facility’s permit evaluation report indicates that tile drain wastewater has elevated 

concentrations of iron, manganese and zinc, lacks appreciable oxygen and has very low turbidity; 

industrial storm water has elevated 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 pollutants of concern, the draft revised permit 

indicates that the facility has RP for iron, manganese, and zinc. Instead of establishing WQBELs 

for which an exceedance would indicate noncompliance, the permit contains “benchmarks” that 

June 2008 Appendix A. Facility Analyses A-116
trigger action plans. If a similar approach is used for baseline and revised criteria, some level of 

costs associated with developing action plans could be incurred for those pollutants with RP that 

exceed established benchmarks. However, without effluent data or indication 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 steel slabs, coils, and plates from recycled scrap metal, raw 

metals, and additives. Primary facilities at the site include scrap processing, a steel melt shop 

that includes slab casting and scarfing, plate rolling, plate coiling, surface processing, and a cutto-length facility. Support facilities include those associated with maintenance, utilities, oxygen 

production, wastewater treatment, slab storage, and transport of materials and products. The 

facility operates two central wastewater treatment systems (melt shop contact water and plant 

service water treatment systems). Effluent from these onsite water treatment units is primarily 

recycled onsite for process manufacturing reuse, 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, diluted laboratory wash water, some process treated 

water, and oil/water separator effluent. 

Treatment Processes 

The 2003 permit modification for the facility indicates 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 water increases, so that periodically, the facility 

must discharges a portion of the wastewater from 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 pollutants of concern for which effluent data 

are available from August 2007. The facility does not have effluent limits for any of the 

pollutants of concern. 

Exhibit A-85. Effluent Data Summary, Oregon Steel Mills1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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-118
June 2008 Appendix A. Facility Analyses A-119

Exhibit A-85. Effluent Data Summary, Oregon Steel Mills1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 Data Summary, Oregon Steel Mills1 

Number of Observations Summary of Detected Values (μg/L) 

Pollutant Total Nondetect QL2

(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 prior 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 available from the facility’s draft RPA analysis 

spreadsheet provided by ODEQ. 
Exhibit A-86. Ambient Data Summary, Oregon Steel Mills1 

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 all observations are nondetect). The 

Willamette River is a freshwater river; thus, human health criteria for consumption of organisms 

and water are applicable. The dilution factors are based on stream and effluent flows provided in 

the facility’s permit, assuming only 25% of the stream flow is allowed for dilution. The 

Willamette River at river mile 2.4 is on the state’s 303(d) list as impaired for DDT, DDE, 

dieldrin, dioxin, mercury, PCBs, pentachlorophenol, and PAHs. Also, the ambient background 

concentration for arsenic is above the applicable criterion. Thus, the facility would not receive 

dilution for these pollutants. 

Exhibit A-87. RPA for Baseline Criteria, Oregon Steel Mills

Parameter Calculated 

Effluent 

Conc.1 (μg/L)

Ambient 

Conc.2

(μg/L) 

Conc. at Edge Human Health Reasonable of Mixing Criterion Potential Zone3 (μg/L) (μg/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 factor = 

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 mixing 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 compliance with the baseline criterion, the discharger 

would not incur compliance costs. However, if additional data indicate effluent arsenic 

concentrations above necessary levels, the discharger could 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 impaired. 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 concentration at the edge of the mixing 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% increase in downstream receiving water concentrations 

would not be given numeric effluent limits; rather they would be required to implement narrative 

BMPs and increased monitoring. 

If ODEQ determines that the water body is impaired, it would not grant 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 from 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) indicates that releases from baghouse units are 

common, particularly during loading of trucks. Any dust that escapes from the baghouse onto 

the surrounding area could be taken up during storm events and collected in surrounding catch 

basins. The permit evaluation report indicates some portion of the wastewater discharged to the 

Willamette contains storm water from catch basins surrounding these baghouses. BMPs to 

reduce dust leaks or other potential 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 program 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 sources. The costs to implement narrative BMPs and 

increased monitoring under a scenario of dilution 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

Parameter Conc. at Edge of Human Health Criteria at Alternative FCRs (μg/L) 

Mixing Zone1 (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 factor = 

3,478; noncarcinogens factor = 1,455). 

The discharger would have RP for arsenic at all 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. However, 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 consumption rates, the incremental costs 

represent any costs above and beyond 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 Costs1

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 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-123
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DDT/DDE/DDD (Update). Atlanta, GA: U.S. Department of Health and Human Services, Public 

Health Service. 

AMSA. 2002. Mercury Source Control & Pollution Prevention Program Evaluation. Prepared 

by Larry Walker Associates. 

CH2MHill. 2007. Mixing Zone/Dilution Technical Evaluation Report. Prepared for City of St. 

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http://www.ci.mcminnville.or.us/city/departments/public-works-and-park-maintenance-sewerfaq/. 

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lsp1/bis_2/bis_2_ethylhexyl_phthalate_e.pdf. 

Fairfield-Suisun Sewer District (SD). 2003. 2003 NPDES Permit Renewal Infeasibility 

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5ainfeasibilityrev.doc. 

Huber, Kimberly. 1997. Wisconsin Mercury Sourcebook: A Guide to Help Your Community 

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http://170.104.158.45/arsenic.php3?pwsno=00055. Accessed November 19, 2007. 

June 2008 Appendix A. Facility Analyses A-124
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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 Arsenic 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/arsenic.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 http://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). Arsenic in Ground Water of the Willamette Basin, 

Oregon Water-Resources Investigations Report 98–4205. 

Woodburn Public Works. 2005. 2005 Water Quality 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-125
June 2008 Appendix B. Pollution Prevention Programs and Costs B-1

Appendix B. Pollution Prevention Programs and Costs 

Pollution prevention (P2) is the most cost-effective approach to reducing pollutants in waste 

water. P2 strategies focus on reducing the pollutant at the source where it is more concentrated 

and may be more easily controlled, rather than treating larger volumes of wastewater once 

diluted. Because of the cost-effectiveness of source controls, and the lack of cost effectiveness 

and demonstrated performance from end-of-pipe controls for pollutants 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, industries, businesses, and 

households associated with a municipal P2 program 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 efforts already underway, and the knowledge and 

experience of the municipality in this area. Municipalities would most likely target dentists, 

hospitals, medical facilities, educational institutions (primarily universities and high schools), 

households, and industries to reduce mercury discharges to the treatment plant. Program 

components could include: 

• Sampling and analysis – to characterize mercury at the facility and track treatment 

effectiveness 

• Program development – for source identification, materials development, program 

implementation, and management 

• Conducting site visits and holding workshops 

• Supplying mercury-free product replacements 

• Advertising – to promote and inform the community of various activities and events 

taking place 

• Website development – to provide the community with additional resources and serve as 

another means of promoting P2 activities. 

Sampling and Analysis 

As part of the sampling and analysis task, municipalities should characterize 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 removal efficiency. This enables the discharger to 

determine how much of the resulting effluent mercury loading is due to treatment performance 

and removal efficiencies, and how much is the result of industrial, commercial, institutional, or 

residential discharges. Dischargers should address any in plant sources 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 developing an understanding of mercury behavior 

within the plant. Therefore, on average, municipalities would likely sample on a monthly basis 

using Method 1631, which requires clean sampling techniques 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 biosolids) per month, municipalities would collect 36 samples per year 

(12 months × 3 samples per month). 

Costs associated with sampling include the time required to take the sample and analytical costs. 

It typically takes about 1 hour, on average, to collect each sample and prepare the shipment (e.g., 

complete the chain of custody form, wrap the bottles, and draft the shipping label) (Morris, 

2006). The average labor rate for a wastewater treatment plant operator in Oregon, including 

employer benefits is $29 per hour [escalated from 2006 dollars to 2007 dollars using Bureau of 

Labor Statistics (BLS) employment 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 per 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 sources, determining 

appropriate or cost-effective measures for targeting those sources, developing materials, 

implementing the program, and managing and assessing progress/effectiveness of the program. 

There are a large number of potential sources of mercury to any POTW, but there are few data 

on these sources from which to accurately predict the mercury load 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. Some facilities in California have taken the 

characterization a step further and estimated the 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 amalgam fillings accounts for 32% of its influent 

mercury load, the water supply accounts for 22%, human 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 (EBMUD) 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 known commercial dischargers, and 10% from 

hospitals and medical facilities (EBMUD, 2004). Both of these dischargers estimated the source 

loadings from a combination of available monitoring studies and actual sampling efforts. 

Therefore, to reduce costs, facilities could use 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, that the only way to truly characterize influent 

loads would be through site-specific sampling. 

Determining which P2 efforts to pursue requires evaluation of the contribution to total mercury 

loadings, relative magnitude of loading, feasibility of control, and effectiveness of proposed 

efforts. Source control efforts could be implemented through existing pretreatment programs. 

June 2008 Appendix B. Pollution Prevention Programs and Costs B-2
P2 practices could include BMPs, production/process changes at industrial facilities, and public 

outreach and education programs targeting local businesses (e.g., dentists, hospitals, and 

laboratories), consumers, and schools. 

Currently, most municipal facilities initially target dental offices and the residential sector 

through public outreach efforts. Municipalities can develop and distribute materials for dental 

offices that outline BMPs they can implement to reduce the amount of mercury discharged to the 

POTW. They may also encourage dentists to install amalgam separators, which often remove 

over 95% of amalgam particles prior to discharge. For example, the Central Contra Costa 

Sanitary District (CCCSD) developed a brochure for dentists that describes the mercury problem 

in the area, the role that dentists play in this problem, and measures 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 dental 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 Group (BAPPG) to guide 

the visit and recommend actions each dentist could take to reduce mercury discharges (Engler, 

2005). 

The most common activities targeting the residential sector include distributing educational 

material in the form of brochures or billing inserts, or organizing events to collect mercurycontaining equipment or products and ensure that they are properly disposed of or recycled. 

Some municipalities offer a mercury-free alternative in exchange for the mercury-containing 

one. Collection events held at easily accessible 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 thermometers over a couple of years by relying on 

individuals to bring their thermometers to the treatment plant at their convenience. However, 

once the City decided to hold events at a scheduled date and time within the community, they 

were able to double the number of thermometers collected in a much shorter time period (Bobel, 

2005). 

Other potentially significant sources of mercury to a POTW are hospitals and medical facilities 

and educational institutions. Most of the mercury from these sources can be found in equipment 

such as thermometers, manometers, and blood pressure cuffs and chemical reagents. 

Municipalities may develop materials or conduct workshops aimed at encouraging these 

facilities to conduct an inventory of mercury-containing equipment, switch to mercury-free 

alternative equipment, and implement BMPs that prevent releases of mercury from the 

equipment. For example, WLSSD worked with the St Mary’s-Duluth Health 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 educational institutions. Under the program, EBMUD 

replaced mercury-containing laboratory equipment with mercury-free alternatives, collected 

elemental mercury, worked with specific departments 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 alternatives (e.g., thermometers and some laboratory devices). 

Public outreach and education activities, however, do no always result in noticeable reductions in 

mercury loads to the POTW. For example, collection 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 directly affect the plant’s influent mercury load (e.g., fluorescent 

bulbs and thermostats). Also participation rates for implementing suggested BMPs or control 

measures are often low for commercial and institutional dischargers because there are no 

regulatory requirements. To increase participation rates and make voluntary efforts more 

successful, municipalities could offer indirect dischargers assistance with residuals disposal, or 

make it clear that if voluntary programs fail, mandatory programs that include noncompliance 

liability risk (i.e., fines) will follow. 

An increasing number of municipalities are implementing nonvoluntary measures such as 

limits/requirements in pretreatment permits or sewer use ordinances that require implementation 

of specific treatment controls and/or BMPs to obtain more measurable reductions in mercury 

loadings. For example, the Palo Alto RWQCP implemented a sewer use ordinance that requires 

all dental offices to install approved amalgam separators by March 31, 2005, and provide 

certification to the facility that they had done so. The facility also requires dentists to implement 

BMPs that: 

• Prohibit rinsing chairside traps, vacuum screens, or amalgam separator equipment in a 

sink or other sanitary sewer connection 

• Require staff to be trained in the proper handling and disposal of amalgam materials and 

fixer-containing solutions 

• Prohibit the use of bleach or other chlorine containing disinfectants 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 accordance with recycler or hauler instructions. 

The Palo Alto RWQCP developed its program in cooperation with the Mid-Peninsula Dental 

Society, the California Dental Association, 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 dischargers 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 installation of the separator and implementation of recommended BMPs. 

Costs of program development vary based on the level of effort and size of the service area. The 

Palo Alto RWQCP (design flow of 38 mgd) has a P2 program sector of its environmental 

compliance division that includes 4 staff. The staff works on various tasks and outreach efforts 

for a number of different pollutants including mercury. The program director estimates that 

approximately one quarter of these 4 staff members’ time is spent working on mercury-related 

tasks, resulting in average annual labor costs, including benefits, of approximately $85,000 per 

year (Bobel, 2005). Similarly, at EBMUD (design flow of 79.6 mgd), 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 alternative P2 strategies, develop outreach 

and education materials, request and draft changes to sewer use ordinances, schedule and 

organize collection events, conduct educational workshops for specific source sectors, maintain 

contact information for facilities within each sector, and put together annual program status 

reports. Thus, these estimates of 1 full-time equivalent (FTE) staff position (or approximately 

$85,000/year) are likely to be representative of costs for program development for large facilities 

(e.g., flows greater than 20 mgd). 

Medium (e.g., between 5 mgd and 20 mgd) and small (e.g., between 1 mgd and 5 mgd) facilities 

have smaller service areas, and thus, fewer sources to identify and target. Smaller facilities are 

also more likely to partner with large facilities that have already 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 facilities will most likely be less than those of 

a larger facility. 

For example, an employee of the San Mateo WWTP in California (design 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 formal P2 program for mercury, and relies heavily 

on partnerships with the Department of Health and other larger P2 organizations (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 coming 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 Sanitation 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 additional activities such as fluorescent light bulb collection events 

or regulatory requirements for dentists, additional 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 facilities (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 example, 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 groups 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 different sources of mercury 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 and advise them on BMPs 

for reducing mercury or ensure that they are complying with sewer use ordinance requirements. 

Palo Alto spends about $20,000 a year on this off-site 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 schools, and universities are 

harder to identify because of the larger discharge 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 year on site visits. Medium and smaller 

facilities, due to the nature and size of their service 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 year on additional assistance, or roughly 60% 

as much as a large facility, and small facilities 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 mercury-free products to the public or commercial 

sectors. For example, many localities hold collection events in which 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 thermometer and supplies local governments with free 

digital thermometers (ODEQ, 2007). Also, in 2005 and 2006, ODEQ, with grant assistance from 

EPA, worked with dairy and agricultural organizations to replace and properly dispose of 

mercury manometers used in dairy farm milking operations with mercury-free digital vacuum 

gauges (ODEQ, 2007). ODEQ also initiated a program with Portland General Electric, the 

Thermostat Recycling Corporation, and the Product Stewardship Institute through which 

participants receive $4 rebate coupons for each mercury-containing thermostat returned to a 

participating wholesaler for recycling. 

However, municipalities may also need to provide secondary schools or hospitals with mercuryfree equipment to replace all or part of their mercury-containing equipment. The Minnesota 

Pollution Prevention Agency (MPPA) works with schools to eliminate mercury. The school 

often conducts the mercury inventory with guidance from the MPPA. Then, MPPA gives the 

school a limited amount of free mercury-free equipment (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 recycling costs. Total average costs are about $400 

per school (Butler, 2002). 

Costs vary based on the number of exchange/collection events and the volume of equipment 

collected. Because ODEQ already provides municipalities 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 mercury-free product exchanges. Therefore, based on 

service area sizes, small facilities may replace mercury-containing equipment at 1 school ($400); 

medium facilities may replace mercury-containing equipment at 2 schools (2 × $400 = $800); 

and large facilities may replace mercury-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 because 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 for 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 English 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 different sources in different 

languages annually. Since medium and small facilities have fewer sources to target, they may 

need fewer announcements. 

Website 

Small municipalities would likely target primarily 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 commercial and industrial dischargers. The cost of a 

website depends on its function, number of pages, and security requirements. Websites with less 

than 10 pages and no animation or custom graphics 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 include 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 and 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 Program 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 Program 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 startup period than costs in subsequent 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 other potential sources such as automobile service 

stations and secondary schools. The estimates for conducting site visits and workshops reflect 

this sequential targeting of an equal number of sources 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 source controls. Municipalities would likely target 

dentists, hospitals and medical centers, secondary schools, universities, and industrial facilities. 

However, the program may not address 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 Bill 704 requiring dentists who place or remove 

dental amalgam and other mercury-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, those certified in compliance with ODA’s BMPs have 

until 2011 to install separators (ODA, 2007). Thus, costs for these actions 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 available for most mercury-containing chemicals and 

equipment. Although mercury-free products may 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 potential noncompliance, and potential health risks 

to staff, patients, and visitors. In the case of electronic thermometers, the mercury-free 

alternative also has time-saving benefits since an electronic thermometer gives a quicker 

temperature reading than a mercury thermometer (Pollution Probe, 1996). For example, 

comparison of a mercury-containing sphygmomanometer to a mercury-free aneroid 

sphygmomanometer shows that once staff training, spill cleanup, and administrative costs are 

taken into account, the mercury-free 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 Nature, 2003). The average wage rate of spill 

team members is about $100 per hour, 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 mercury 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 sphygmomanometers, and proper disposal of fluorescent 

lamps, through a contract with a recycler. Kaiser-Permanente predicted that elimination of 

mercury thermometers and sphygmomanometers would result in cost reductions of about 

$550,000 over the next 10 years across the system. These cost savings would also offset the cost 

of the recycling program (Tellus 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 those implemented by hospitals and medical centers. 

In addition to replacing mercury containing equipment (e.g., manometers and thermometers) and 

chemicals containing mercury with mercury-free alternatives, laboratories can also work to 

minimize the amount of waste generated during experiments and testing procedures. The 

University of Minnesota-Duluth has instituted micro-scale projects in undergraduate labs that 

dramatically reduced the quantities of possible mercury-containing chemicals used, purchased, 

and discarded (Second Nature, 2003). Laboratories in hospitals that have replaced their 

mercury-containing chemicals with mercury-free alternatives found that costs of mercury-free 

chemicals are about the same as costs of chemicals containing mercury (Pollution Probe, 1996). 

There may be instances, however, in which mercury-free alternatives do not exist. A 250-

employee laboratory in Massachusetts uses thimerosal as a bacteriostat/fungistat in many clinical 

tests. The facility is permitted to discharge up to 1 μg/L under the Massachusetts Water 

Resources Authority (MWRA) pretreatment program. The laboratory determined that thimerosal 

could not be readily replaced, so the laboratory employed source reduction techniques (e.g., 

collecting waste streams for hazardous waste disposal, 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 alternatives are often about the same as costs of mercury-containing 

chemicals, implementing P2 programs is not likely 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 implement 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 Schools 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 personnel on items that may contain mercury 

such as thermometers and laboratory chemicals, and proper disposal techniques) 

• Eliminate the use of mercury wherever possible and promote the use of alternative 

products that do not contain mercury (e.g., schools may have mercury-containing 

thermostats, barometers, thermometers, and wall 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 likely 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 environmental fate, and proper handling and clean 

up procedures. 

The EBMUD initiated a mercury reduction program with the University of California at 

Berkeley (UCB) through grant funding from EPA. The program focused on identifying all 

mercury-containing equipment and chemicals through the campus and replacing them with 

mercury-free alternatives. Another main component of the program focused on outreach and 

education targeting professors, students, and school 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). However, if other universities use the template 

developed as part of the program development and implementation, costs would be much less. 

P2 program implementation costs for secondary schools are most likely minimal because the 

municipality conducting the program generally conducts the mercury equipment inventory and 

arranges for equipment replacement and disposal (already 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 medical equipment to replace the schools’ mercurycontaining equipment and arranges for proper mercury disposal at a recycling facility (Butler, 

2002). The Oregon Association of Clean Water Agencies (ACWA), in conjunction with ODEQ, 

also developed a pilot program for 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 $6,000 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 costs to facilities in the various sectors. 

Exhibit B-2. Summary of Potential Annual Indirect Costs Associated 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-specific 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 addition, P2 activities for industrial dischargers vary greatly based 

on facility type, volume of wastewater discharged, existing wastewater treatment processes (if 

any), and the manufacturing processes and chemicals potentially responsible for mercury loads. 

For example, a facility that uses chlorine for disinfection or to prevent scaling may find that the 

type of chlorine used is contaminated with mercury. 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 straightforward at another type of industrial facility, especially those 

with multiple internal waste streams and industrial processes. Despite these differences though, 

it can be assumed that most industrial facilities will implement the basic components of a P2 

program, including process analysis and process modifications. 

During process analysis the discharger would identify pollutant uses and quantities within the 

facility (i.e., inventory facility), identify pollutant use and potential contamination in process 

streams, and identify P2 options for reducing 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 facility would need to implement the identified P2 options and make 

any necessary process modifications. 

June 2008 Appendix B. Pollution Prevention Programs and Costs B-11
June 2008 Appendix B. Pollution Prevention Programs and Costs B-12

We estimated the costs to identify potential pollutant 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 including employer benefits [escalated from 2006 

dollars to 2007 dollars using BLS employment 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 facilities 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 incurred 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 process modifications such as 

replacing mercury-containing equipment at the end of its useful 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) phthalate such as gloves, 

tubing, flexible bags (e.g., intravenous, nutritional, blood, collection and specimen), rigid 

containers, respiratory equipment (e.g., masks and oxygen tents), and packaging (Malcolm 

Pirnie, 2005). High levels of bis(2-ethylhexyl) phthalate in municipal wastewater effluent can 

also be associated 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. Therefore, facilities would likely need to 

conduct additional monitoring to determine potential sources of the pollutant. 

If additional testing indicates that bis(2-ethylhexyl) phthalate is the result of industrial or 

commercial dischargers, the facility would need to develop more stringent pretreatment 

standards or implement source controls to prevent bis(2-ethylhexyl) phthalate from entering the 

treatment plant. However, example costs of such programs at other wastewater treatment plants 

are unavailable. In fact, it is not certain whether any municipal wastewater treatment plants have 

actually been required to reduce effluent levels of bis(2-ethylhexyl) phthalate. For example, 

 

9

 BLS (2006) describes an environmental engineer (standard occupations classification 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 disciplines” and “work may include waste 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 Phoenix, the City began the process for developing 

local limits, but after finding no controllable sources, abandoned the efforts. Since that time, and 

without implementing specific actions targeting bis(2-ethylhexyl) phthalate, effluent 

concentrations have decreased to below detected levels. 

As described above (see Section B.1) mercury 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). There are 

not as many controllable sources under a bis(2-ethylhexyl) phthalate source program as there are 

under a mercury P2 program. Thus, we assumed that source program costs for bis(2-ethylhexyl) 

phthalate would be approximately $50,000 per year, although costs could be higher or lower 

depending on factors including discharger experience with the pollutant and P2 efforts, existing 

monitoring and controls, and sources 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 agricultural 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). BHC is a manufactured chemical that exists 

in eight chemical forms called isomers. Technical-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, technical-grade BHC has not been 

produced or used in the United States in over 20 years (ATSDR, 2005). 

P2 or source control programs to identify potential sources of the pollutants (e.g., any 

commercial/industrial indirect discharges that may 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 assessment, and local limits development and 

implementation, if appropriate. Monitoring would enable the municipality to determine the 

magnitude of the influent load and calculate the appropriate pretreatment limits for each potential 

source. However, example costs of such programs at other wastewater treatment plants are 

unavailable. 

As described above (see Section B.1) mercury 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 States and there are much fewer 

controllable sources than there are under a mercury 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 depending 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 during 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 identified laundry and shower graywater, storm 

water inflow, human and food waste, and toilet paper 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 pesticide manufacturing, motor vehicles, residential 

wood burning, incineration, historic activities, and paper bleaching (Palo Alto, 1997). However, 

the City predicts that implementation of all the control 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 limits 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 would 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 switching chemical brands. If the dioxin is from discharges to the 

treatment plant, the facility would need to identify 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 factors including discharger 

experience with dioxin and P2 efforts, existing 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. Online at http://www.atsdr.cdc.gov/tfacts43.pdf. 

Agency for Toxic Substances and Disease Registry (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. State Occupational Employment and Wage Estimates 

June 2008 Appendix B. Pollution Prevention Programs and Costs B-14
Oregon. Online at http://www.bls.gov/oes/current/oes_or.htm. 

Bureau of Labor Statistics (BLS). 2007a. Employment Cost Index Historical Listing 

Current-dollar March 2001 – September 2007. Table 11. Employment Cost Index for wages and 

salaries, for State and local government workers, by occupational group and industry (Not 

seasonally adjusted), Management, professional, and related. Online at 

http://www.bls.gov/web/echistrynaics.pdf. 

Bureau of Labor Statistics (BLS). 2007b. Employer 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 workers, by major occupational and industry group, 

September 2007, Management, professional and related. Online at 

http://www.bls.gov/news.release/pdf/ecec.pdf. 

Bureau of Labor Statistics (BLS). 2007c. Employment Cost Index Historical Listing Currentdollar March 2001 – September 2007. Table 9. Employment Cost Index for wages and salaries, 

for private industry workers, by occupational group and industry (Not seasonally adjusted), 

Professional, and related. Online at http://www.bls.gov/web/echistrynaics.pdf. 

Bureau of Labor Statistics (BLS). 2007d. Employer 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 major occupational group and bargaining unit status, 

September 2007, Management, professional and related. Online at 

http://www.bls.gov/news.release/pdf/ecec.pdf. 

Butler, Chris. 2002. Mercury Free Zone Coordinator. 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 (CCCSD). 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 (EBMUD). 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 District 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. Technical Memorandum - Mercury Source Identification Update: Dental 

Offices and Human Waste. To: Palo Alto Regional Water Quality Control Plant. 

Engler, Leslie. 2005. Mt. View Sanitary District Pollution Prevention Coordinator. Personal 

communication. 

Environment Canada. 1994. Priority Substances 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 District (SD). 2003. 2003 NPDES Permit Renewal Infeasibility 

Analyses. June 17. Online at http://www.swrcb.ca.gov/rwqcb2/Agenda/08-20-03/08-20-03-

5ainfeasibilityrev.doc. 

Malcolm Pirnie. 2005. SROG Phase II Local Limits Assistance, Best Management Practices 

Study: Protecting Our Water Quality. Meeting with Hospitals - August 9, 2005 

Massachusetts Office of Technical Assistance (OTA). 1995. Toxics Use Reduction Case Study: 

Reducing Mercury Discharge at a Testing Laboratory. Case Study No. 35. 

Mena, Deirdre. 2005. East Bay Municipal Utilities 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. Personal 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 Department 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 Quality (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 Quality Control Plant Dioxins Pollution Prevention 

Plan. October. Online at 

http://www.cityofpaloalto.org/civica/filebank/blobdload.asp?BlobID=3760. 

Pollution Probe. 1996. Mercury in the Health Care Sector: The Cost of Alternative Products. 

San Mateo Public Works. 2005. Environmental Compliance Section, Engineering Division. 

Personal communication. June. 

Second Nature. 2003. Greening Medical Facilities: Facts and Resources. Online at 

http://www.secondnature.org/pdf/snwritings/factsheets/green_hosp.pdf

Tellus Institute. 2000. Healthy Hospitals: Environmental Improvements Through EA. 

Test America. 2007. Personal communication. December 11, 2007. 

June 2008 Appendix B. Pollution Prevention Programs and Costs B-17
June 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 technologies that could be used to reduce toxic 

pollutants in wastewater effluents. However, in general there is a lack of performance data 

available to show that advanced treatment technologies will result in the effluent levels necessary 

for compliance with the baseline and revised criteria. 

C.1 Reverse Osmosis 

Theoretically, reverse osmosis (RO) can remove nearly all inorganic contaminants 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 through its pores. The contaminated water is 

subjected to high pressures that force pure water through the membrane, leaving pollutants 

behind in a brine solution (NDWC, 1997). 

Properly operated RO units can achieve 96% removal of arsenic (III), arsenic (IV), barium, 

cadmium, chromium (III), chromium (VI), fluoride, 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 and 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 surface waters that indicate that such removals are 

possible at these facilities on a consistent 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 are less than optimal when treating influents with 

low contaminant concentrations, performance testing using influent concentrations 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 appropriate effluent range. 

Even if the necessary pollutant levels are achievable with RO, it is important to consider the 

potential disadvantages and limitations of this technology, including: 

• High capital and operating (including energy) costs (which increase with decreasing 

desired effluent concentrations) 

• Management and disposal of residuals (brine 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 maintain 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 environment, rather transfers them to another 

medium (pollutants are concentrated in the reject discharge or brine). 

The most limiting of these disadvantages, especially for larger systems, is the management and 

disposal of residuals. Most RO systems reject 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 disposal of about 2 mgd to 4.5 mgd of residual waste; this brine 

contains the contaminants removed from the wastewater, and must be treated prior to disposal. 

The more feasible residual disposal options for wastewater treatment plants include: 

• Land disposal (e.g., evaporation pond, underground injection) 

• Treatment (e.g., brine concentrator, thermal evaporation) (Metcalf and Eddy, 2003). 

The first option requires that the 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 require a large amount of land (U.S. EPA, 2002), 

and if evaporation ponds are the only land disposal option, precipitation rates cannot be greater 

than evaporation rates. The treatment through controlled evaporation is feasible, although 

operating and maintenance costs may be extremely high. This approach 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 the residuals will not be 

re-released into the environment. The pollutant is simply transferred from the effluent to a 

residual brine that must be disposed of in some manner. If the brine is evaporated (either 

through an evaporation pond or flash/thermal evaporator), the pollutant could evaporate to the 

atmosphere and be redeposited into rivers and lakes. 

Since no wastewater treatment plants in the country have installed RO to remove toxics to very 

low levels for discharges to surface waters, there is no information on installed costs. Nor is 

information available from similar industrial applications. U.S. EPA’s Office of Groundwater 

and Drinking Water is developing detailed models for estimating compliance costs associated 

with drinking water regulations. Adjusting the input parameters to reflect average wastewater 

conditions, the RO model may provide an indication 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; generated by a separate cost model), two RO units in series (likely 

needed to achieve the low levels under the revised criteria), equalization basins 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 Microfiltration Pretreatment and Reverse 

Osmosis Cost Models for Wastewaters 

Component Input Value 

Microfiltration 

Temperature 20°C 

Membrane flux 26 gal/ft2/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 

HCO3 145 mg/L 

Chloride 45 mg/L 

SO4 150 mg/L 

pH 8.0 

Temperature 20° C 

First-pass RO recovery 90% 

First-pass RO flux 12 gal/ft2/day 

Second-pass RO recovery 85% 

Second-pass RO flux 20 gal/ft2/day 

Clean-in-place interval 2 months (1st pass); 12 months (2nd 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/comparative_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 scaling 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 and operating costs. If 

the concentration of barium or sulfate is higher than shown in the exhibit, or if silica is present, 

water recovery could be limited. 

Certain RO membranes are intolerant of free chlorine, and most microfiltration membranes have 

limited chlorine tolerance. Thus, prior to microfiltration, 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 scaling 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% over 20 years plus O&M costs. 

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-3
Exhibit C-2. Summary of Estimated 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 Costs2 

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, chemicals, energy, and solids disposal, where applicable. 

Capital costs include brine concentration followed by evaporation ponds to handle the residual 

brine from the RO units. While this option may be feasible in Eastern Oregon where 

precipitation rates are less than evaporation rates, it is likely infeasible 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 per 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 based on the total annual RO costs for each flow 

category in Exhibit C-2. 

Exhibit C-3. Cost Effectiveness of Reverse Osmosis for Reducing Mercury to Revised Criteria 

5 mgd 10 mgd 25 mgd 50 mgd 

Scenario LR1

(lb/yr) 

C-E 

($ million/lb) 

LR1

(lb/yr) 

C-E 

($ million/lb)

LR1

(lb/yr) 

C-E 

($ million/lb) 

LR1 C-E 

(lb/yr) ($ million/lb) 

63.2 gpd 0.19 $40.0 0.37 $33.7 0.94 $31.3 1.87 $30.3 

113 gpd 0.22 $32.4 0.44 $28.7 1.10 $26.7 2.19 $25.9 

175 gpd 0.23 $30.5 0.47 $27.1 1.16 $25.2 2.33 $24.3 

389 gpd 0.25 $28.8 0.49 $25.5 1.24 $23.7 2.47 $22.9 

620 gpd 0.25 $28.3 0.50 $25.1 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 contacted with the influent water. The resin is 

considered spent once it can no longer remove the desired amount of pollutant. Next, the 

backwash step is initiated to expand the bed and to remove fines that may be clogging the packed 

bed. The spent resin is regenerated using a concentrated solution of the original exchange ion, 

reversing the exchange process. Lastly, the rinse step removes 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 regenerated, and once they are spent (i.e., there is no more capacity to 

adsorb mercury), they are disposed of and replaced with fresh media. Advantages of a selective 

sorbent packed column process include: 

• Theoretically achieves extremely low effluent levels, under certain conditions (e.g., a 

number of columns in series, extensive pretreatment) 

• Contaminants can be recovered from most resins upon regeneration. 

Use of selective sorbents also has disadvantages: 

• Management and disposal of spent media or regenerated brine can be costly 

• Effluent quality may be highly variable (depending on sorbent loading) 

• To achieve low pollutant levels in wastewater, extensive pretreatment may be necessary 

• May need multiple units in series for desired effluent quality, which increases costs. 

Mercury 

For mercury, historically, the use of sorbent resins has been limited to anion resins applied to 

industrial wastewater containing inorganic 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 form a ring (or chelate) (U.S. EPA, 1997). 

Limited performance data on selective adsorbent resins indicate that mercury can be removed to 

ng/L levels. Few studies have used analytical 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 focused 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 wastewater from the Oak Ridge National 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 entering the sorbent columns consisted of dual media filtration, air 

stripping, and granular activated carbon; the remaining water was treated with precipitation, 

flocculation, and settling. The waste streams were combined prior to entering the sorptive media 

columns. Influent mercury to the columns ranged from 40 to 625 ng/L. Overall, the thiol-based 

sorbents such as Keyle:X and SIR-200 performed the best. The Keyle:X resin 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 efficiencies 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 average influent concentration of about 1,100 ng/L. 

Three sorbents, SIR-200, Keyle:X, and GT-73 reduced 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 capable of reducing mercury concentrations 

significantly, they did not demonstrate the ability to produce effluents that would comply with 

the any of the potential effluent limits on a consistent basis. However, influent concentrations at 

both sites were greater than typical conventional treatment effluents described in Section 2. 

Thus, reducing influent concentrations could potentially reduce achievable effluent 

concentrations as long as the diluted influent concentration does not in turn reduce removal 

efficiencies. 

For selective sorbents though, removal efficiencies may not be affected by influent 

concentrations because at both sites, lower influent concentrations resulted in lower effluent 

concentrations, and the removal efficiency was not dependent on the number of bed volumes 

treated or the sorbent loading rate (Klasson, et al., 2000). Therefore, effluent concentrations 

could decrease as influent concentrations decrease (e.g., through source control efforts or 

operating columns in series), although this result would need to be substantiated with further 

testing of waters with lower concentrations. 

Arsenic 

Most of the research on the removal of arsenic 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 and organisms for arsenic. As such, the studies 

on drinking water only aim to reduce arsenic levels below the MCL. For example, EPA (2000) 

indicates that ion exchange can reduce influent arsenic source water 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 discharging at concentrations less than 2 μg/L. Thus, it is uncertain 

whether ion exchange could reduce arsenic concentrations by the same percentage given lower 

influent concentrations. That is, there are no data available to show that 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 removal by sedimentation (Metcalf and Eddy, 2003). 

Common precipitants for removal of heavy metals such as mercury and arsenic include 

hydroxide and sulfide, although carbonate can also be used in certain circumstances (Metcalf and 

Eddy, 2003). In practice, the minimum achievable effluent concentration depends not only on 

the precipitant used and the operating pH, but also the nature and concentration of organic matter 

and temperatures (Metcalf and Eddy, 2003). 

Mercury 

Mercury may be present in three forms in wastewater: elemental mercury (Hg0), ionic mercury 

(Hg+2, usually present as complexes and chelates with ligands), and organic (e.g., 

methylmercury). These species of mercury may bind to particulate matter in the wastewater to 

form physical agglomerates containing mercury that more readily settle out (MASCO, 1997). 

Particulate mercury is often the predominant form in wastewater streams (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 readily combines with phosphate or sulfide to 

precipitate as mercury phosphates or sulfides. When mercury is precipitated as sulfide, high 

mercury residuals are often observed due to reduction of mercury to elemental mercury, which 

has a solubility in water of about 25 mg/L (much greater than potential effluent 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. [This process is similar to the addition of chlorine to enhance 

performance of the Keyle:X resin tested at the DOE site discussed 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 (less 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, additional treatment is needed because a portion of 

the precipitate is composed of fine 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 level solid mercurous sulfide is to attach it to a 

nonleaching media such as activated alumina. 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 used 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 the process indicates that 

mercury will be effectively reduced, bench- and pilot-scale testing would be necessary to 

confirm that the necessary levels can be met for 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 hydrogen 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, causing air toxicity and odor problems (U.S. EPA, 1980). Control 

of sulfide dose or enclosing and vacuum evacuating 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, aldehydes, and carboxylic acids. 

Lastly, the limited performance data available for mercury precipitation followed by activated 

alumina presents a significant limitation. Although in theory this process should remove 

mercury to the proposed criterion, actual performance on different wastewater 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 effective for arsenic(V) than arsenic(III) (U.S. EPA, 

2000). Thus, to achieve low effluent levels, oxidation of arsenic(III) to arsenic(V) is necessary. 

Few wastewater treatment plants specifically aim to reduce arsenic levels. However, in drinking 

water treatment, iron and aluminum salts are widely 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” removal of arsenic(V) at 

pH of 7.0 and coagulant dose above 5 mg/L ferric chloride. However, use of such high 

coagulant doses also increases the amount of sludge that must be disposed of. Low effluent 

levels will only likely be achieved with filtration or adsorption after chemical precipitation to 

remove colloidal arsenic. 

C.5 Granular Activated Carbon 

GAC has been used successfully in advanced treatment of municipal and industrial wastewater 

for years. GAC is primarily used to adsorb refractory organics, such as 4,4’-DDT, alpha-BHC, 

dioxin, and bis(2-ethylhexyl) phthalate, as well as residual amounts of inorganics such as 

nitrogen, sulfides, and heavy metals (Metcalf and Eddy, 2003). However, water-soluble 

compounds and small molecules are not adsorbed well (NAVFAC, 2008). 

GAC adsorption occurs when pollutant molecules adhere to the internal walls of pores in carbon 

particles produced by thermal activation (U.S. EPA, 2000). At municipal wastewater treatment 

plants, GAC is usually installed prior to disinfection, but after filtration (or some other type of 

pretreatment) that removes suspended solids in order 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 existing systems (U.S. EPA, 2000). 

However, GAC is not without its disadvantages, including: 

• Under certain conditions, hydrogen sulfide may be generated from bacterial growth, 

creating odor and corrosion problems 

• Wet GAC is highly corrosive and abrasive 

• Requires pretreated wastewater with low suspended 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 regenerated or disposed of and the adsorbed contaminants must be 

destroyed, often by incineration (possibly 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 are weakly sorbed, resulting in low GAC 

capacity 

• Type and pore size of the carbon, as well as the operating temperature, must be carefully 

selected to optimize contaminant removal (NAVFAC, 2008). 

There are no studies demonstrating GAC organics removal at wastewater treatment plants, 

although there are several plants throughout the country using GAC either to supplement 

secondary treatment or to enhance phosphorus removal. Unfortunately, there are no effluent data 

for toxic pollutants in EPA’s PCS database for these 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 operating parameters of the GAC unit (e.g., single 

versus dual stage). 

Although GAC can remove low concentrations of certain metals, it has not been widely used for 

this purpose possibly due to the fact that spent carbon used for metals removal can be difficult to 

regenerate and may require treatment 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 capacity for mercury because the sulfur chemically 

reacts with the mercury to form mercuric sulfide (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 operations 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 regenerated, so once its capacity is exhausted 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 Corporation, 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, increasing 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 may 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 reduce the concentration of organic contaminants 

such as 4,4’-DDT, alpha-BHC, and dioxin in wastewater. 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 them 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 elevate 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 radicals which also react with organic 

compounds destroying them (Rahuman et al., 2000). 

The most common UV oxidation processes involve the use of UV light paired with a catalyst 

(e.g., titanium dioxide) or strong oxidizer (e.g., ozone, hydrogen peroxide). In UV oxidation, 

organic chemicals are oxidized by various mechanisms, including direct reaction 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, water, and salts. Oxidation of 

organic compounds using only a strong oxidizer does not always completely oxidize the 

contaminants, resulting in the presence of intermediate oxidation products. These intermediate 

products may be as toxic as or even more toxic than the original compound. Therefore, these 

oxidizing agents are paired with UV light to enhance 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 the catalyst. Electron accepting species such as 

oxygen are reduced by the electrons in the conduction band, and water molecules or hydroxyl 

ions are oxidized at the holes. This process produces two hydroxyl radicals that rapidly break 

down and mineralize organic contaminants (Powell, 2000). A number 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 optimal pH value varies with the contaminant of 

concern and wastewater type (Munter, 2001). Therefore, pilot testing to determine optimal 

operating conditions would be necessary 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 dispose of residuals) 

• Also provides disinfection 

• Can be used over a wide range of influent concentrations and flow 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 radicals that can potentially react with almost any organic 

chemical present in the wastewater. Therefore, to ensure that pollutants are completely 

destroyed there must be a sufficient amount of radicals, especially if other competing organic 

chemicals are present. However, overdosing with oxidizers such as ozone may actually decrease 

the destruction efficiency due to ozone absorption of the UV light. Therefore, careful planning 

and testing would be necessary to determine the optimal operating parameters. 

Disadvantages associated with UV oxidation may include: 

• Pretreatment to lower suspended solids concentrations and turbidity to provide for good 

transmission of UV light and minimize reactor and lamp maintenance 

• Free radical scavengers can inhibit 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 result 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 peroxide or ozone can remove 86% 

to 99.9% of VOCs from contaminated groundwater, and over 99% of semivolatile organic 

contaminants from contaminated groundwater, depending on the specific pollutant and treatment 

unit. However, most of the effluent concentrations were still above the baseline and revised 

criteria, and it is unclear whether performance levels would remain the same for treatment of 

municipal and industrial wastewater. Thus, additional 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 with ozone or hydrogen peroxide requires the generation and 

handling of ozone and hydrogen peroxide onsite, whereas UV/titanium dioxide oxidation does 

not require the handling of any hazardous chemicals. 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 processes will have relatively high energy costs due to 

the use of UV light. Exhibit C-5 provides a qualitative comparison 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 Various 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 process is strongly dependent on the specific 

compounds targeted (Munter, 2001). Preliminary bench testing should be conducted to 

determine the appropriate oxidation process for removal of the target pollutants from a particular 

type of wastewater. 

FRTR (2002) indicates that costs for UV oxidation 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 for wastewater treatment due to increases in 

the variability of water quality as well as additional 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 new, therefore, actual costs may be lower due to 

advances in the technology or an increase in the number of manufacturers. 

Factors that may influence the cost of UV oxidation include: 

• Types and concentration of contaminants - affect oxidizer selection, oxidizer dose, UV 

light intensity, and contact time 

• Influent concentration (i.e., destruction 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 contaminants may reduce the destruction efficiency 

of UV oxidation. Sand or dual media filtration should 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 degradation of pollutants are thermal reaction 

inside cavitating bubbles and radical chemistry (Destaillants et al., 2001). 

Sonochemical degradation involves the use of ultrasound 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 process 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 temperatures and pressures exist within the bubble 

interior, which increases the decomposition rate of pollutants (Hua and Zhang, 2000). 

In addition to the direct high temperature and pressure destruction of organic molecules within 

these localized zones, the thermolysis of water to release radical species (e.g., •H, •OH, and 

HOO•) and hydrogen peroxide is an important mechanism for the organic chemical destruction. 

These free radicals attack organic compounds present in water, comprising another mechanism 

of sonochemistry (Hua and Zhang, 2000). Free radical formation is also enhanced with 

increased sound intensities, thus, further increasing decomposition rates (Hua and Zhang, 2000). 

Most studies on sonochemical degradation have been performed using frequencies of 20-25 kHz. 

However, reaction rates may vary significantly with variations in frequencies (Price et al., 2004). 

For example, frequencies dictate the type of cavitation that takes place. Under low frequencies 

transient cavitation occurs in which bubbles undergo only a few oscillations before collapse. A 

larger concentration of radicals will be formed on each individual bubble collapse during this 

type of cavitation because bubbles collapse from a larger radius and thus, contain more water 

vapor. At high frequencies, a bubble undergoes hundreds or thousands of oscillations, known as 

stable cavitation. Under stable cavitation more collapse events occur per unit time, which may 

increase the overall rate of radical 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 cause by bubble implosion (Destaillants et al., 2001). 

However, these situations have only been tested in laboratories and not on larger, full-scale 

reactors. 

Destaillants et al. (2001) investigated how laboratory conditions translate into larger-scale 

operation. They found that react rates for the nonvolatile contaminants tested increased by 

factors of 2 to 5. Destaillants et al. (2001) also found that while the reaction rates for one nonvolatile contaminant only varied by about 15% for various flow rates, reaction rates for another 

varied by more than 50% depending on flow rate. In addition, degradation rates may also vary 

with reactor size and configuration, temperature, and influent contaminant concentration 

(Destaillants et al., 2001). Therefore, extensive testing is important to determine the optimal 

operating frequency for destruction in a particular type of wastewater, 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 commercial 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 general lack of full scale operating data prohibits 

determinations of the technology’s effectiveness 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 same 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 limited performance data for sonochemical 

degradation. 

C.7 References 

Arce Systems, Inc. 2002. Personal communication 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 communication. 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. Hoffmann. 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 Treatment 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 Association Journal, Vol. 87, No. 6, pp. 84 96. 

Hua, I. and G. Zhang. 2000. Cavitation Chemistry of Polychlorinated Biphenyls: 

Decomposition mechanisms and Rates. Environmental 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 Management 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. McTaggart, P.A. Taylor. 2000. Demonstration of 

Mercury Sorbents to Meet DOE Customer Needs. ORNL/TM-2000/12. 

MWRA/MASCO Mercury Workgroup. 1997. End-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. Wastewater Engineering: Treatment and Reuse. Fourth Edition. 

McGraw Hill: Boston. 

Munter, Rein. 2001. Advanced Oxidation Processes - Current Status and 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.nesc.wvu.edu/ndwc/pdf/OT/TB/TB4_IonExchange.pdf 

Naval Facilities Engineering Command (NAVFAC). 2008. Environmental Restoration and 

BRAC: Granular Activated Carbon (GAC) Adsorption (Liquid Phase). Online at 

https://portal.navfac.navy.mil/portal/page?_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 Effects 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 Publications: Proceedings of Expert Group 

Meetings on POPs and Pesticides 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 Sessions: Waste Disposal Issues. Online at 

http://www.epa.gov/safewater/ars/presentations/train6-residuals.pdf. 

U.S. EPA. 2000. Arsenic Removal from Drinking Water by Ion Exchange and Activated 

Alumina Plants. EPA 600-R-00-088. 

U.S. EPA. 1997. Capsule Report: Aqueous Mercury 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 Precipitation. EPA 625/8-80-003. 

West General. 2004. Out of the Box Chemical Specifications: Mercury. Online at 

http://www.westgeneral.com/outofthebox/masterframeset.html. 

June 2008 Appendix C. End-of-Pipe Treatment Controls and Costs C-17
June 2008 Appendix D. Variance Procedures Based on Adverse Economic Impacts D-1

Appendix D. Variance Procedures Based on Adverse Economic 

Impacts 

This appendix describes the analysis of the potential for compliance costs to result in substantial 

and widespread economic and social impacts 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 change in household sewer bills resulting from 

the compliance costs; evaluate financial health of the community), and whether such an impact 

would have widespread adverse 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 the proposed project. Public entities should 

consider a broad range of discharge management options including pollution prevention, 

end-of-pipe treatment, and upgrades or additions to existing treatment. Specific types of 

pollution prevention activities that should 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 general information regarding the proposed 

pollution control project. 

Calculate Annualized Cost per Household 

Since capital costs will be paid over several years, annualized costs are used to evaluate the 

economic burden to the community. The capital portion of project costs is financed by issuing a 

municipal debt instrument such as a general 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 federal 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 pollution control costs are expected to have on households, an average 

annualized pollution control cost per household is calculated for all households in the community 

that would bear project costs. To evaluate substantial impacts, therefore, applicants should 

determine which households will actually pay for pollution control, as well as what proportion of 

the costs will be borne by households. These apportioned 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 considering the results of two tests. The first 

test is a “screener” to establish whether the community can clearly pay for the project without 

incurring any substantial impacts. The Municipal 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 annual compliance costs to MHI is between 1.0% and 

2.0%. If the average annual cost per household 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 jurisdiction’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 residents within the jurisdiction 

• Socioeconomic Indicators 

o Unemployment Rate - a measure of the 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 scoring of the values following EPA (1995) 

guidance. EPA (1995) provides worksheets for calculating the secondary score. 

 

June 2008 Appendix D. Variance Procedures Based on Adverse Economic Impacts D-2
Exhibit D-1. Secondary 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 

Full Market Value of Taxable Above 5% 2% - 5% Below 2% 

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 

Percent of Full Market Value of Above 4% 2% - 4% Below 2% 

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 discussion of evaluating the results. 

Exhibit D-2. Substantial 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 undertaking pollution controls could potentially cause far-reaching and 

serious socioeconomic impacts. Conversely, adverse financial impacts experienced by the 

affected entities may be offset by the expenditures on pollution controls to attain water quality 

standards, since these expenditures do not vanish from the community but become business 

revenues and household incomes. Therefore, applicants must examine 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 geographic area where project costs pass through to 

the local economy) 

• consider the baseline economic health of the community 

June 2008 Appendix D. Variance 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, exceptions where the affected community includes 

individuals and areas outside the immediate community. 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 widespread impacts, EPA (1995) recommends evaluating 

changes in the following indicators: 

• MHI 

• community unemployment rate 

• overall net debt as a percent of full 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 conditions 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 widespread 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 for 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). EPA (1995) provides a worksheet for applicants to 

qualitatively describe estimated changes. 

D.2 Analysis for Private Sector Entities 

Private sector entities will evaluate whether the compliance costs associated with WQBELs 

(variances from technology-based standards are not available) will impose a substantial financial 

impact on the company (estimate impact of costs on profitability, liquidity, solvency, and 

leverage; compare to industry benchmarks; establish 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 have a widespread impact on the 

community). 

Substantial Impacts 

To evaluate whether compliance costs will be substantial, private sector entities will verify 

project costs and calculate the annual cost of the pollution control project, and then conduct a 

June 2008 Appendix D. Variance Procedures Based on Adverse Economic Impacts D-4
June 2008 Appendix D. Variance Procedures Based on Adverse Economic Impacts D-5

financial impact analysis. Considerations for verifying project costs and calculating annual costs 

are similar to those described above for public sector 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 which 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 financial health. The primary 

measure evaluates the extent to which an applicant’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 discharger would bear if required to comply with 

WQBELs. Profit and solvency ratios are calculated both with and without the additional 

compliance costs (taking into consideration the entity’s ability, if any, to increase its prices to 

cover part or all of the costs). Comparing these ratios to each other and to industry benchmarks 

provides a measure of the impact on the entity. EPA (1995) provides worksheets for evaluating 

the primary and secondary measures. 

Widespread Impacts 

Applicants that demonstrate that pollution control costs would have a substantial financial impact 

proceed to evaluate whether such an impact would have a widespread impact on the surrounding 

community. The steps in the analysis are identical 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 abandoned 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 mercury-containing soils from agricultural and forest 

lands as part of the Willamette Basin Mercury TMDL, ODEQ recommends the implementation 

of sediment/erosion BMPs (ODEQ, 2006a). However, implementation of these BMPs is already 

required under existing state and federal regulations and plans. For 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 required 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 adopted to control soil/sediment erosion. 

Exhibit E-1. Erosion Control Practices 

Practice Description 

Protective cover Plant cover (as well as other covers such as mulch, 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 fences 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. Erosion 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 drainage 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 runoff, and trap sediment. If terraces aren’t 

practical, consider planting 1-foot strips 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 also slow runoff (reducing 

erosion), filter pollutants, and trap sediments. In the Stillaguamish River Fecal Coliform, 

Dissolved Oxygen, pH, Mercury, and Temperature TMDL, the Washington Department of 

Ecology (Ecology) indicates that the key to controlling 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 reductions will occur as part of efforts to improve 

temperatures through control of sediment (Ecology, 2007). Thus, it is possible that controls 

being implemented for compliance with baseline standards for nontoxic pollutants could result in 

compliance with the revised criteria. 

In addition, if incremental controls are necessary, the USDA’s National Resources Conservation 

Service (NRCS) provides technical assistance and funding opportunities to agricultural 

landowners with the mission to conserve, maintain, 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 goals (NRCS, 2007a). Through EQIP, farmers and 

ranchers receive financial and technical assistance to implement structural and management 

conservation practices that optimize environmental benefits on working agricultural land. As 

part of EQIP, NRCS develops cost estimates for various BMPs in Oregon that may be available 

for funding assistance. Thus, the cost of additional 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 efforts 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-central 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 hazards represented by extant mine portals. 

However, the cost of assessment and cleanup at abandoned mines varies widely. 

For example, elevated levels of mercury have been detected in soil at Bonanza Mine in Douglas 

County. ODEQ has spent about $500,000 to investigate the site and remove the most 

contaminated soil around one area of contamination. 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 still readily visible. Site features include: 1) 

remnants of mining equipment including two mercury-extraction furnaces, tramway, and ore 

crusher; 2) tailings piles; and 3) mine openings (adits and stopes). Through 2004, ODEQ spent 

about $50,000 from Oregon’s Orphan Site Account for environmental investigation of the site. 

E.3 Municipal Storm Water 

In the Willamette Basin TMDL, DEQ requires 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) through their SWMPs. As described in Section 2.2.2, 

ODEQ interprets the MEP requirement to require all controls that are reasonable and available. 

In some areas this level of control may be necessary for compliance with baseline standards, in 

which case additional controls for compliance with revised criteria would not be required 

because all reasonable and available controls are already being implemented. In other areas, 

however, MEP controls may not be fully implemented and some incremental level of control 

may be necessary for compliance with the revised criteria. Thus, for any situation in which 

storm water sources are specifically required to control toxic pollutants to levels that are lower 

than what would be necessary under the baseline, potential compliance actions could include: 

• increased or additional nonstructural BMPs – institutional, education, or pollution 

prevention practices designed to limit generation of runoff or reduce the pollutants load 

of runoff 

• structural controls – engineered and constructed systems 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 controlling pollution at the source, 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 education program to a larger or new target 

audience, refocusing source control efforts on pollutants and sources of concern, increasing 

program compliance efforts, and increasing frequency, 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, and climate (FHWA, 2002). Thus, increasing the 

frequency of sweeping or changing the type of sweeper 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 increase needed to reduce toxic loadings (e.g., the 

incremental curb miles and whether new sweepers need to be purchased). 

For example, most municipalities use mechanical/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 where much of the pollution resides. There are two 

types of vacuum sweepers: wet and dry. The dry vacuum sweepers remove a greater percentage 

of small particulates and sediments than the wet vacuum sweepers. Thus, depending on the load 

reductions needed, switching to either a wet or dry vacuum sweeper could increase pollutant load 

reductions to surface waters. 

 

Structural Controls 

There are a variety of structural means to control 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 quantity control. Typically, these systems infiltrate water into the 

ground relatively rapidly (from a few hours up to 72 hours). However, the primary drawback of 

infiltration systems is that they are not appropriate in areas where groundwater is used as a 

drinking water source. Additional constraints include 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 Storm 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 Storm 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, resuspension of particulate matter often occurs. 

Exhibit E-3 summarizes the different types of detention systems. 

Exhibit E-3. Summary of Storm 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 until 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 provided 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 systems is the need for a perennial flow to sustain 

the permanent pool. Furthermore, these systems typically require more land than other controls 

(U.S. EPA, 1999). 

Constructed wetland systems are similar to retention and detention systems, except that a major 

portion of the water surface area (for pond systems) 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 delicate and require a water balance to sustain the 

aquatic vegetation. Sedimentation can especially reduce the effectiveness of the system. 

Pollutant removal in wetlands can occur through a number of mechanisms including 

sedimentation, filtration, volatilization, adsorption, absorption, microbial decomposition, and 

plant uptake. Pretreatment of runoff may be necessary 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 granular filtration media remove constituents found 

in runoff such as sand, soil, organic material, carbon, or membranes. Often these systems treat 

only the first half inch to inch of runoff, and are common at small sites such as parking lots and 

developments, in areas with high pollution potential such as industrial areas, or in highly 

urbanized areas where land availability 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 Storm 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 

Surface sand filter settling. 

The filter bed consists of sand with a gravel and perforated pipe under-drain system to 

capture the treated water. 

Underground vault sand 

filter 

Common systems are the D.C. sand filter 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 designed to convey and treat 

either shallow flow (swales) or sheetflow (filter strips) runoff. Open channel vegetated systems 

are alternatives to the traditional 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 storm sewer system (U.S. EPA, 1999). Exhibit E-5 

summarizes the different types of vegetated systems. 

Exhibit E-5. Summary of Storm 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 partially 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 reduce 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. Factors that influence performance and design include size of the 

drainage area, the level of watershed imperviousness, 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 Pollutant Removal Efficiencies for Structural Storm Water Controls 

BMP Type Suspended Solids Metals 

Infiltration basin1 50% - 80% 50% - 80% 

Infiltration trenches1 50% - 80% 50% - 80% 

Porous pavement1 65% - 100% 65% - 100% 

Detention basins 30% - 65% 15% - 45% 

Retention basins 50% - 80% 50% - 80% 

Constructed wetlands 50% - 80% 50% - 80% 

Surface sand filters2 50% - 80% 50% - 80% 

Other media filters2 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 (EAD) reviewed and summarized the available 

information related to expected costs of storm water controls (U.S. EPA, 1999). EAD identified 

only three studies that systematically evaluated the construction costs associated with structural 

controls since 1985. EAD used these 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 Cover (Commercial) 

Infiltration Trench $61,500 5 $12,300 

Infiltration Basin $20,500 5 $4,100 

Sand Filter1 $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 approximately 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 additional costs. However, if land 

acquisition is needed for the construction of a storm water control, 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 may 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 Services (BES) has also conducted a number of 

demonstration projects aimed at reducing the volume of storm water and pollutant loadings 

entering its combined sewer system. The project BMPs provide runoff volume control and water 

quality benefits, while improving the existing landscape: 

• Storm water planters – vegetative landscaping added to parking garages and lots that 

capture and infiltrate runoff from paved surfaces; adds attractive green space to urban 

areas 

• Curb extensions – landscaped add-ons to existing 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 absorb/retain storm water; roofscaping covers 

and protects the waterproofing and structural components of a roof, which extends the 

life of a conventional roof. 

Exhibit E-10 provides a summary of various storm 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 

Area Treated Cost Benefit 

(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 (Caltrans). 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. Stormwater 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 Quality (ODEQ). 2006b. Assessment Methodology for 

Oregon’s 2004/2006 Integrated Report on Water Quality Status. 

National Resources Conservation Service (NRCS). 2007a. FY08 Environmental Quality 

Incentives Program (EQIP) – Oregon. October. 

Portland Bureau of Environmental Services (BES). 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.com/bes/index.cfm?c=44463&. 

Portland Bureau of Environmental Services (BES). 2005b. SW 12th Avenue Green Street 

Project. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&. 

Portland Bureau of Environmental Services (BES). 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 (BES). 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 (BES). 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 (BES). 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 (BES). 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. Preliminary Data Summary 

of Urban Storm Water Best Management 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 Temperature 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 shows 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 Facilities: Baseline Criteria 

(millions 2007$) 

June 2008 Appendix F. Sample 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 reducing 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 Municipal1 $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. Sample Facility Results and Statewide Extrapolation F-2

Exhibit F-2. Potential Annual 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 

Facilities1 

Extrapolated Annual 

Cost 

Certainty Sample 

Multiple2 $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 Annual 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 

Facilities1 

Extrapolated Annual 

Cost 

Certainty Sample 

Multiple2 $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 incremental (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 control arsenic in municipal sewer systems, respectively, associated 

with the revised criteria scenarios that incorporate alternative fish consumption rates. 

Exhibit F-4. Potential Annual Incremental 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 - $0.050 
June 2008 Appendix F. Sample Facility Results and Statewide Extrapolation F-3

Exhibit F-4. Potential Annual Incremental 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 Compliance Costs for Sample Facilities Excluding I&I 

Costs: 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 - $0.050 

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 Industrials 
June 2008 Appendix F. Sample Facility Results and Statewide Extrapolation F-4

Exhibit F-5. Potential Annual Incremental Compliance Costs for Sample Facilities Excluding I&I 

Costs: 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 

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 incremental compliance costs for the random 

sample, and addition to the certainty sample results, for the revised criteria scenarios, with and 

without I&I costs to control arsenic 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 requirements for toxic pollutants for 

these facilities. 

Exhibit F-6. Potential Annual Incremental Statewide 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 

Facilities2 

Extrapolated Annual 

Cost 

63.2 gpd 

Certainty Sample3 $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 Sample3 $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 Sample3 $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 Sample3 $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 - $1.82 
June 2008 Appendix F. Sample 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 Statewide 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 

Facilities2 

Extrapolated Annual 

Cost 

63.2 gpd 

Certainty Sample3 $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 Sample3 $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 Sample3 $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 Sample3 $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 current regulations) variance costs to the sample 

facilities. 

Exhibit F-8. Potential Baseline and Incremental 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 $0 
June 2008 Appendix F. Sample Facility Results and Statewide Extrapolation F-6

Exhibit F-8. Potential Baseline and Incremental 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 Municipal1 $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 and incremental one-time variance costs for 

the random sample facilities, and addition to the certainty sample results. There are no costs 

associated with 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 requirements for toxic pollutants for 

these facilities. 

Exhibit F-9. Potential Baseline and Incremental Statewide One-Time Variance Costs 

(millions of 2007$)

Sample Statewide 

Category Total One-Time 

Cost 

Number of 

Facilities 

Average Cost 

per Facility 

Number of 

Facilities1 

Extrapolated OneTime Cost 

Baseline Criteria 

Certainty Sample2 $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 Sample2 $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 - $2.68 
June 2008 Appendix F. Sample 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 review, baseline costs could be approximately 

$159,000, with incremental costs of approximately $65,000 under the revised criteria.