### E CONOMIC 

### A NALYSIS FOR THE 

### P ROPOSED 

### R ULE 

### : A QUATIC 

### L IFE 

### C RITERIA
FOR 

### C OPPER AND 

### C ADMIUM IN 

### O REGON

March 15 , 2016

Prepared for:

United States Environmental Protection Agency

Office of Water Office of Science and Technology 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460Prepared by:

Horsley Witten Group, Inc.

In Partnership with:

Abt Associates and Tetra Tech

Horsley Witten Contract Number: EP

- C

- 12

- 006i March 15, 2016 

### T ABLE OF 

### C ONTENTS

ES. Executive Summary

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

- 1 1.0 Introduction

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

- 1 1.1 Background

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

- 1 1.2 Purpose and Scope of the Analysis

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

- 1 1.3 Report Organization

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

- 2 2.0 Baseline for the Analysis

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

- 1 2. 1 Water Quality Criteria and Implementation Procedures

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

- 1 2.2 Sources of Cadmium and Copper to Surface Waters

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

- 1 2.2.1 Municipal and Industrial Dischargers

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

- 2 2.2.2 Stormwater

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

- 4 2.2.3 Agricult ure and Forestry

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

- 5 2.2.4 Mines

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

- 6 2.2.5 Atmospheric Deposition

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

- 6 2.3 Water Quality

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

- 6 3.0 Proposed R evised Criteria

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

- 1 3.1 Acute Cadmium Criterion

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

- 1 3.2 Acute and Chronic Copper Criteria

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

- 1 3.2.1 Economic Analysis Criteria for Copper

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

- 3 4.0 Method for Estimating Potential Costs: Point Sources

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

- 1 4.1 Identification of Potentially Affected Permittees

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

- 1 4.2 Determining Reasonable Potential

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

- 2 4.3 Projecting Effluent Limits

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

- 5 4.4 Identifying Control Scenarios

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

- 7 4.4.1 Process Optimization

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

- 7 4.4.2 Source Controls

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

- 8 4.4.3 End

- of

- Pipe Treatment

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

- 11 4. 4.4 Alternative Compliance Mechanisms

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

- 12 4.4.5 Summary of Unit Control Costs

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

- 16 5.0 Method for Estimating Potential Costs: Nonpoint Sources

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

- 1 5.1 Available Data

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

- 1 5.2 Identifying Exceedances

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

- 1 5.2.1 Cadmium

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

- 2 5.2.2 Copper

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

- 2 5.3 Identifying Po tential Control Actions and Costs

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

- 5 6.0 Potential Costs

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

- 1 6.1 Point Sources

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

- 1 6.2 Nonpoint Sources and Stormwater

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

- 3 6.3 Government Regulatory Costs

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

- 4 6.4 Uncertainties in the Analysis

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

- 4 6.4.1 Data Limitations

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

- 4 6.4.2 Load Reductions

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

- 5 6.4.3 Resp onse to Revised Requirements

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

- 5 7.0 References

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

- 1ii March 15, 2016

Appendix A: Facility Analyses Appendix B: Pollution Prevention Programs and Costs Appendix C: End

- of

- Pipe Treatment Controls and Costs Appendix D: Variance Procedures Based on Adverse Eco nomic Impacts Appendix E: Best Management Practices and Unit Costs for Nonpoint Sourcesiii March 15, 2016 

### L IST OF 

### E XHIBITS

Exhibit ES

- 1. Summary of Potential Annual Point Source Costs (millions of $2015)

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

- 5 Exhibit 2

- 1. NPDES Permitted Direct Dischargers in Oregon

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

- 3 Exhibit 2

- 2. Summary of Oregon’s 303(d) List of Impaired Waters (2010 Approved List and 2012 Proposed List)

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

- 7 Exhibit 3

- 1. Map of Nine Level III Ecoregions in Oregon

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

- 2 Exhibit 3

- 2. Estimates of 10th Percentile Values for BLM Input Parameters

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

- 3 Exhibit 3

- 3. Summary of Defaul t Values for OR Level III Ecoregions

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

- 3 Exhibit 3

- 4. Estimates of Acute and Chronic BLM

- based Copper Criteria Concentration Values by Ecoregion

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

- 4 Exhibit 4

- 1. NPDES Permitted Facilities Potentially Affected by the Proposed Rule

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

- 2 Exhibit 4

- 2. Baseline Copper Criteria

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

- 3 Exhibit 4

- 3. Potential Copper Criteria u nder Proposed Rule

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

- 4 Exhibit 4

- 4. Results of Reasonable Potential Analysis

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

- 5 Exhibit 4

- 5. Estimated Copper WQBELs for Facilities Potentially Affected by the

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

- 6 Baseline Aquatic Life Criteria

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

- 6 Exhibit 4

- 6. Estimated Copper WQBELs for Facilities Potentially Affected by the

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

- 7 Proposed Aquatic Life Criteria

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

- 7 Exhibit 4

- 7. Summary of Potential End

- of

- Pipe Treatment Technologies for Copper Removal

.....

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

- 11 Exhibit 4

- 8. Summary of Costs for Potential End

- of

- Pipe Treatment Technologies

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

- 12 Exhibit 4

- 9. Potential Level of Effort to Investigate Technological Feasibility

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

- 13 Exhibit 4

- 10. RPA Using 10 th Percentile Ecoregional DOC Data

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

- 15 Exhibit 4

- 11. RP A Using 50 th Percentile Ecoregional DOC Data

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

- 16 Exhibit 4

- 12. Estimated One

- Time Costs of Alternative Compliance Mechanisms by Dis charge Flow Category ($2015)

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

- 16 Exhibit 5

- 1. Summary of Select Ambient Monitoring Data 1

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

- 1 Exhibit 5

- 2. Number of Exceedances Based on Copper Monitoring Data

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

- 2 Exhibit 5

- 3. Stations by Exceedance Category and 2010 Assessment Status

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

- 3 Exhibit 5

- 4. Sampling Station Exceedance Results for Proposed BLM

- Based Copper WQC Compared to Approved 2010 Water Quality Attainment Status

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

- 4 Exhibit 5

- 5. Stations by Exceedance Category and 2012 Assessment Status

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

- 4 Exhibit 5

- 6. Sampling Station Exceedance Results for Proposed BLM

- Based Copper WQC Compared to Proposed 2012 Water Quality Attai nment Status

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

- 5 Exhibit 6

- 1. Summary of Point Source Cost Estimates for End

- of

- Pipe Treatment (3% discount rate; millions of $201 5)

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

- 1 Exhibit 6

- 2. Summary of Point Source Cost Estimates for End

- of

- Pipe Treatment (7% discount rate; millions of $2015)

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

- 2 Exhibit 6

- 3. Summary of Point Source Cost Estimates for P2 Programs (3% discount rate; in $2015)

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

- 2 Exhibit 6

- 4. Summary of Point Source Cost Estimates for P2 Programs (7% discount rate; in $2015)

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

- 3 Exhibit A

- 1. RPA under Baseline Criteria for City of Astoria WWTP

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

- 1 Exhibit A

- 2. RPA under Revised Criteria for City of Astoria WWTP

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

- 2 Exhibit A

- 3. Summary of Potential Costs (3% discount rate) , City of Astoria WWTP

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

- 2iv March 15, 2016

Exhibit A

- 4. Summary of Potential Costs (7% discount rate), City of Astoria WWTP

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

- 3 Exhibit A

- 5. RPA under Revised Criteria for Kellogg Creek WWTP

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

- 4 Exhibit A

- 6. Summary of Potential Costs (3% discount rate), Kellogg Creek WWTP

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

- 4 Exhibit A

- 7. Summary of Potential Costs (7% discount rate), Kellogg Creek WWTP

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

- 5 Exhibit A

- 8. RPA under Baseline Criteria for City of McMinnville WRF

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

- 6 Exhibit A

- 9. RPA under Revised Criteria for City of McMinnville WRF

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

- 6 Exhibit A

- 10. Summary of Potential Costs (3% discount rate), City of McMinnville WRF

..... A

- 7 Exhibit A

- 11. Summary of Potential Costs (7% discount rate), City of McMinnville WRF

..... A

- 7 Exhibit A

- 12. RPA under Revised Criteria for City of Salem Willow Lake WPCF

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

- 8 Exhibit A

- 13. Summary of Potential Costs (3% discount rate), City of Salem Willow Lake WPCF

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

- 9 Exhibit A

- 14. Summary of Potential Costs (7% discount rate), City of Salem Willow Lake WPCF

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

- 9 Exhibit A

- 15. RPA under Baseline Criteria for Tri

- City Service District

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

- 10 Exhibit A

- 16. RPA under Revised Criteria for Tri

- City Service District

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

- 10 Exhibit A

- 17. Summary of Potential Costs (3% discount rate), Tri

- City Service District

....... A

- 11 Exhibit A

- 18. Summary of Potential Costs (7% discount rate), Tri

- City Service District

....... A

- 11 Exhibit A

- 19. RPA under Revised Criteria for Woodburn WWTP

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

- 12 Exhibit A

- 20. RPA under Revised Criteria for Blue Heron Paper Company

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

- 13 Exhibit A

- 21. RPA under Revi sed Criteria for City of Corvallis WWTP

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

- 14 Exhibit A

- 22. RPA under Revised Criteria for City of Wilsonville WWTP

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

- 15 Exhibit A

- 23. Summary of Potential Costs (3% discount rate), City of Wilsonville WWTP

.. A

- 16 Exhibit A

- 24. Summary of Potential Costs (7% discount rate), City of Wilsonville WWTP

.. A

- 16 Exhibit A

- 25. RPA under Revised Criteria for West Linn Paper Company

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

- 17 Exhibit A

- 26. Summary of Potential Costs (3% discount rate), West Linn Paper Company

... A

- 18 Exhi bit A

- 27. Summary of Potential Costs (7% discount rate), West Linn Paper Company

... A

- 18 Exhibit A

- 28. RPA under Revised Criteria for RUSA Roseburg WWTP

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

- 19 Exhibit A

- 29. Summary of Potential Costs (3% discount rate), RUSA Roseburg WWTP

...... A

- 20 Exhibit A

- 30. Summary of Potential Costs (7% discount rate), RUSA Roseburg WWTP

...... A

- 20 Exhibit A

- 31. RPA under Revised Criteria for Cascade Pacific Pulp

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

- 21 Exhi bit A

- 32. RPA under Revised Criteria for Georgia

- Pacific Halsey Mill

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

- 21 Exhibit A

- 33. RPA under Revised Criteria for City of Medford RWRF

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

- 22 Exhibit A

- 34. Summary of Potential Costs (3% discount rate), City of Medford RWRF

....... A

- 23 Exhibit A

- 35. Summary of Potential Costs (7% discount rate), City of Medford RWRF

....... A

- 23 Exhibit B

- 1. Potential P2 Program Costs for Municipal Facilities

– Initial and Annual ($2015)

....

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

- 6 Exhibit B

- 2. Summary of Potential Annual Indirect Costs Associated with Copper P2 Programs

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

- 9 Exhibit C

- 1. Parameters Provided for Costing RO and Ion Exchange Systems for Wastewater C

- 2 Exhibit C

- 2.Cost Estimates for Reverse Osmosis System

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

- 3 Exhibit C

- 3. Compa rison of Evaporation and Precipitation Rates in Western Oregon

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

- 4 Exhibit C

- 4. Assumptions for Affordability Evaluation

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

- 5 Exhibit C

- 5. Affordability Estimates for McMinnville and Roseburg facilities

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

- 5 Exhibit C

- 6. Cost Estimates for Ion Exchange System

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

- 7 Exhibit D

- 1. Secondary Indicators

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

- 3 Exhibit D

- 2. Substantial Impacts Matrix

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

- 3v March 15, 2016

Exhibit E

- 1. Examples of Erosion Control Practices and EQIP Financial Assistance

................ E

- 2 Exhibit E

- 2. Summary of Stormwater Infiltration Systems

................................ ......................... E

- 4 Exhibit E

- 3. Summary of Stormwater Detention Systems

................................ ......................... E

- 5 Exhibit E

- 4. Summary of Stormwater Filtration Systems

................................ .......................... E

- 6 Exhibit E

- 5. Summary of Stormwater Vegetated Syste ms

................................ .......................... E

- 6 Exhibit E

- 6. Summary of Copper Removal Effectiveness for Structural Stormwater Controls E

- 7 Exhibit E

- 7. Portland

- Area Stormwater BMP Costs

................................ ................................ .. E

- 8vi March 15, 2016 

### A CRONYMS AND 

### A BBREVIATIONS

AADT Annual average daily traffic AML Average monthly limitation AWQMP Agricultural Water Quality Management Program BAPPG Bay Area Pollution Prevention Group BES Bureau of Environmental Services BLS Bureau of Labor Statistics BLM Biotic Ligand Model BMP Best management practice CCCSD Central Contra Costa Sanitary District CFR Code of Federal Regulations CWA Clean Water Act D Dilution factor DOC Di ssolved organic carbon EBMUD East Bay Municipal Utilities District EPA Environmental Protection Agency EQC Environmental Quality Commission EQIP Environmental Quality Incentives Program FPA Forest Practices Act FPR Forest Practice Rules ft foot ICIS

- NPDES Integrated Compliance Information System for NPDES program I&I Inflow and infiltration LASAR Laboratory Analytical Storage and Retrieval LTA long

- term average MDL Maximum daily limitation MBR Membrane bio

- reactor mgd million gallons per day mg/L milligrams per liter MOU Memorandum of Understanding MS4 Municipal separate storm sewer system MVSD Mount View Sanitary District NA Not applicable NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NRCS National Resources Conservation Service NWIS National Water Information System O&M Operation and Maintenance OAR Oregon Administrative Rules ODA Oregon Department of Agriculture ODEQ Oregon Departm ent of Environmental Quality ODF Oregon Department of Forestry POTW Publicly owned treatment work s P2 Pollution preventionvii March 15, 2016

ppb parts per billion PSA Public Service Announcement RMZ Regulatory mixing zone RO Reverse osmosis RP Reasonable potential RPA Reasonable potential analysis RWQCP Regional Water Quality Control Plant RWRF Regional Water Reclamation Facility SMWTP San Mateo Wastewater Treatment Plant STP Sewage Treatment Plant SW P CP Stormw ater P ollution Control Plan SWMP Stormw ater Management Progr am TMDL Total Maximum Daily Load TSD Technical support document μg/L micrograms per liter UIC Underground Injection Control UPC Universal Plumbing Code UV Ultraviolet WLA Wasteload allocations WPCF Water Pollution Control Facility W QBEL Water quality based effluent limit WQC Water quality criteri a WQS Water quality standards WRF Water Reclamation Facility WWTP Wastewater treatment plant ZID Zone of initial dilutionES

- 1 March 15, 2016



### ES. Executive Summary

The United States Environmental Protection Agency (EPA) is proposing to update the current criteria applicable to waters under jurisdiction of the state of Oregon , to protect freshwater aquatic life from acute exposure to cadmium and copper and chronic exposure to copper . This report provides estimates of the potential incremental control actions and costs that may be associated with the proposed regulation.

Background

In May 2004, the Oregon Environmental Quality Commission (EQC) adopted revisions to Oregon Administrative Rules (OAR) covering wate r quality criteria (WQC) (OAR 340

- 041

- 0033). The EQC revised the freshwater aquatic life criteria for metals including cadmium and copper. On July 8, 2004, ODEQ submitted the revised crite ria to EPA Region 10 for review and approval. Under Section 303(c) of the Clean Water Act (CWA)

, EPA d isapproved the acute aquatic life criterion for cadmium and the acute and chronic aquatic life criteria for copper in 2013.

Scope of Analysis

The purpose of this analysis is to identify, using available water quality and discharge data and information, the potential incremental actions and costs that publicly owned treatment works (POTWs) or wastewater treatment plants (WWTPs) and industrial point source di schargers may incur as a result of proposed 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 lim its (WQBELs). EPA estimates the incremental impacts of the proposed rule against a baseline of full implementation of currently approved criteria.

E PA is proposing an acute cadmium criterion that uses ambient hardness data to determine the protective leve l at a given site, and copper criteria based on the Biotic Ligand Model (BLM), which uses ambient data for several water quality parameters such as pH, dissolved organic carbon, and temperature. Therefore, there is uncertainty regarding wh ich data Oregon w ould use to apply WQC at each site . Consequently , for the purpose of this cost analysis, EPA developed hypothetical applications of cadmium and copper WQC using conservative (i.e., low) estimates for hardness and the BLM inputs, respectively. The applicati ons of WQC that EPA derived for this cost analysis are likely different from and possibly lower than the actual WQC applications that Oregon would derive using ambient data from each site

. Although the focus of this analysis is control costs for wastewater point sources, the revised standards may also result in a need for incremental controls by municipal stormw ater and nonpoint sources discharging to surface waters. However, the data and information needed to evaluate those potential c ontrol needs are more limited. Thus, EPA identified the types of controls and costs that may be incurred for these sources but d id not develop statewide control cost estimates. There may be some incremental regulatory program costs associated with an incre ased number of impaired waters and TMDL development.ES

- 2 March 15, 2016

Social costs are accompanied by the social benefits resulting from the control actions. Similarly, adverse economic impacts (municipal and industrial expenditures) are accompanied by increased employment and revenues in sectors supplying control technologies and services (which may be within or external to Oregon). The scope of this analysis is limited to an evaluation of potential control costs; this report does not pr ovide estimates of potential benefits of revised standards or an economic impact analysis.

Baseline for the Analysis

In 2004, Oregon adopted EPA’s 2001 304(a) recommendation for the freshwater acute cadmium aquatic life criterion and EPA’s 1995 304(a) reco mmendations for the freshwater acute and chronic copper aquatic life criteria

. EPA disapproved the acute cadmium criterion and acute and chronic copper criteria in January 2013, therefore , the previously EPA

- approved criteria are currently applicable (see OAR 340

- 041

- 8033 Table 30 ). The currently applicable criteria, expressed as the total recoverable form of the metal, are:

EPA approved Oregon’s 2004 proposed chronic cadmium criterion, which was also based on the EPA’s 2001 304(a) recommendation . EPA is not proposing revisions to the chronic cadmium criterion. The equation for the dissolved chronic cadmium criterion is:

Cadmium and copper can be introduced to surface water through point sources (e.g., municipal and industrial effluents), stormw ater discharges, and n onpoint sources (e.g., agricultural runoff, forestry, mines, and atmospheric deposition). Oregon regulates p oint source and stormw ater discharges under the NPDES permit program , and addresses n onpoint sources through various management plans and policies

. When WQC are not met, Oregon develops TMDL load and wasteload allocations . Because the baseline criteria for cadmium a nd copper, as well as other contaminants, may not be fully implemented, it is difficult to discern the need for incremental reductions in copper and cadmium to achieve revised WQC.

P roposed Revised Criteria

The acute cadmium criterion is based on EPA’s 2016 Update of Ambient Water Quality Criteria for Cadmium 1

. EPA’s proposed acute cadmium criterion is an equation based on the ambient hardness :

1 EPA expects the final national updated 304(a) recommended cadmium criteria to be published in the Federal Register in April 2016. See: http://www.epa.gov/wqc/aquatic

- life

- criteria

- cadmiumES

- 3 March 15, 2016

The proposed acute and chronic copper criteria are based on the BLM as described in Copper Ambient Wate r Quality Criteria for the Protection of Aquatic Life (U.S. EPA, 2007). The BLM incorporates copper speciation and the effects of certain site

- specific physico

- chemical parameters on copper bioavailability and toxicity (Di Toro et al., 2001).

Because the proposed WQC are dependent on site

- specific ambient water conditions , EPA is not proposing a specific numeric concentration for either cadmium or copper . Oregon will either collect ambient data or use conservative default inputs for deriving criteria conce ntration s based on applying the releva nt equation or model

. Method for Evaluating Effect on Point Sources

To evaluate the potential effect of the proposed WQS on NPDES permit conditions and control actions for wastewater point sources, EPA used available e ffluent and ambient data obtained from ODEQ for the facilities reporting monitoring results for cadmium or copper. EPA first conduct ed a reasonable potential analysis (RPA) for baseline criteria, determining limits and identifying controls (or alternative compliance measures) and associated costs (Appendix A)

. Then, EPA evaluated the incremental permit limit reductions that would be needed under the revised criteria, and estimated incremental control actions and costs.

To conduct a n RPA for the proposed criteria, EPA needed equation and model input values . EPA estimated these values using available data. For the acute cadmium criterion, EPA used the minimum hardness valu e contained in the fact sheet for the existing discharger permi t package or the minimum reported in available monitoring data. For the acute and chronic copper criteria, EPA used the BLM with conservative estimates for ten input parameters. It is important to note that the se derived numeric criteria concentration valu es are purely illustrative for the purpose of estimating costs for this analysis . Oregon may use different hardness values or BLM input parameters to derive site

- dependent WQC. To highlight that the cadmium and copper criteria concentration values in this analysis are conservative applications of the actual WQC being proposed (which are an equation and a model) , EPA refers to the se values as the “ economic analysis criteria ”

. ODEQ (20 12d ) procedures provide permit writers instructions for determining whether dischargers have reasonable potential ( RP ) to cause or contribute to an excursion of WQS, and how to calculate effluent limits for those pollutants with RP. EPA used these procedures in determining RP and effluent limits under the baseline as well as for the economic analysis criteria

. The potential control actions are based on likely sources of the pollutants in an effluent and the effectiveness of different methods to reduce effluent concentrations. There are a number of potential alternatives for meeti ng effluent limits for these pollutants, including:

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

- 4 March 15, 2016  Source control (e.g., pollution prevention program, in flow and infiltration reductions, more stringent pretreatment standards) (Appendix B) ;

 Installing end

- of

- pipe treatment technology (e.g., reverse osmosis or ion exchange) (Appendix C) ; and

 Alternative compliance mechanisms (e.g., site

- specific criterion, t otal maximum daily load ( TMDL ) , or variance) (Appendix D)

. Dischargers typically pursue the lowest cost means available for meeting effluent limits. However, for the proposed revised criteria , technical feasibility may a lso be an issue. For copper, the potentially low permit limits based on the economic analysis criteria may not be readily achievable through end

- of

- pipe treatment.

Method for Evaluating Effect on Nonpoint Sources

Unlike point sources, ODEQ typically does not require nonpoint sources and municipal
stormw ater dischargers to achieve numeric WQBELs for metals. In theory, t he regulatory baseline for evaluating the potential impact of the revised criteria includes consid eration of requirements for nonpoint sources and stormw ater dischargers to implement BMPs and load allocations as part of TMDLs for waters already identified as impaired for cadmium or copper under current criteria. Oregon has not yet developed TMDLs for e ither metal

. Thus, the extent of incremental impairment for cadmium or copper beyond baseline impairment is uncertain

.
Nevertheless, i nstream monitoring data can be used to assess which waters may not attain the proposed criteria and thus, where there may be a need for additional controls for waters impaired based on the proposed criteria yet not impaired using current criteria. Although not representative of all surface waters, ODEQ’s Laboratory Analytical Storage and Retrieval (LASAR) database contains w ater quality monitoring data for cadmium and copper. LASAR contains 1,581 cadmium and 1,737 copper water column observations collected between 2000 and 2012 for which there is either a reported value or detection limit. EPA compared monitoring data against the economic analysis criteria

. T he locations for which monitoring data exceed economic analysis criteria are candidates for incremental listings of impaired waters for the purpose of estimating impacts.

Results

Baseline costs are associated with implemen tation of permit limits, plans, and policies that reflect existing criteria. Incremental costs are associated with actions or controls to meet the proposed criteria above and beyond those needed to meet baseline requirements. Incremental costs are the focu s of this economic analysis.

Point Source Costs

Exhibit ES

- 1 provides a summary of the potential incremental annual statewide costs for controls
to achieve the permit limits based on the economic analysis criteria . T he revised acute cadmium criterion does not result in lower permit limits because the baseline permit limits reflect the approved chronic cadmium criterion , which results in more stringent limits . The economic analysis criteria for copper resulted in permi t limits below current effluent levels, indicat ing that the proposed criteria may result in control costs.ES

- 5 March 15, 2016

Should treatment to low permit l evels for copper be infeasible, EPA also presents annualized

c o st estimates for pollution prevention (P2) programs t hat could be required with adoption of a variance

. In addition, one

- time expenditures associated with variance applications could range from $ 0.4 million to $ 1.7 million under the proposed criteria , and are not included in the annualized costs in Exhibit E S

- 1

. These are cost estimates for the major dischargers potentially affected by the proposed criter ia. EPA did not identify minor dischargers that might be affected by the proposed criteria.

Exhibit ES

- 1. Summary of Potential Annual Point Source Costs (mi llions of $2015)

Scenario 3% Discount Rate 7% Discount Rate

End

- of

- Pipe Treatment $18.2 $22.6 P2 programs $0. 1 $0. 1 Indirect dischargers to municipal wastewater treatment plants could also incur costs associated with the proposed criteria if the municipality imposes more stringent pretreatment standards or requirements on these dischargers in an effort to reduce efflu ent loads. In addition to these costs, EPA estimated costs to indirect dischargers to municipal wastewater treatmen t plants under a copper P2 program (provided in Appendix B ). However EPA was unable to estimate how many

o f those indirect dischargers would be affected by the proposed criteria so those costs are not included in Exhibit ES

- 1 above

. Nonpoint Source and St ormw ater Costs Under the baseline, control costs for nonpoint sources (e.g., agricultural and forest operations; contamination from historic mining sites) and municipal stormw ater include those needed to reduce instream pollutant levels to baseline criteri a or TMDL targets. There could also be incremental costs to nonpoint and stormw ater sources associated with meeting new or revised load allocations of incremental TMDLs that result from the proposed revised criteria (Appendix E ) . For any situation in which controls beyond those required under the baseline are necessary, controls could include:

 Agricultural and forest lands

– pesticide controls, sediment and erosion controls beyond those specified under existing state and federal regulations and plans ;

 Minin g

– 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 ; and

 Stormw ater discharges

– increased or additional nonstructural best management practices ( BMPs ) (e.g., institutional, education al , or pollution prevention practices designed to limit generation of runoff or reduce the pollutant load in runoff); and
str uctural controls (e.g., engineered and constructed systems designed to provide water quantity or quality control).

Government Regulatory Costs ODEQ already has implementation procedures for hardness

- based criteria such as the proposed acute cadmium criter ion, but may need to adopt new implementation procedures to support useES

- 6 March 15, 2016

of the BLM

- based criteria. EPA assumed that ODEQ would adopt streamlined procedures that rely largely on existing technical and guidance documents as well as past and on

- going ODEQ

ana lyses of copper criteria. Therefore, EPA assumed the incremental costs of new procedures are de minimis for the purpose of this cost analysis. EPA derived partial estimates for some regulatory activities. The cost estimates for variances noted above includes the costs for ODEQ application review (see Section 4.4.4 )

. If ODEQ develops incremental TMDLs for copper, then it may incur incremental costs; EPA did not identify incremental impairment for the acute cadmium criterion. If, for exampl e, average TMDL development costs range from $3 7 ,000 to $ 40 ,000 (U.S. EPA 2001)

, then incremental costs could range from $1.3 million to $3.0 million for 36 to 74 incremental listings of impaired
waters . I t may be possible to combine TMDLs for common water bodies and reduce development costs . TMDL development costs are one

- time costs that would be spread out over several years (e.g., five

- or ten

- year time period).

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 address the proposed revised requirements and permit conditions that affect the estimated costs.

EPA is proposing aquatic life criteria for cadmium (acute) based on ambient water hardness and criteria for copper (acute and chronic) determined by the copper BLM that requires ambient water chemistry input data

. ODEQ will need to collect representative ambient data to derive cadmium or copper criteria that are tailored to the water body conditions at each site , or utilize conservative default values . For the purpose of this analysis, EPA used a conservative approach based on data aggregated across ecore gions, rather than site

- specific ambient data , which may differ from the approach ODEQ would employ. Therefore, ODEQ may arrive at different criteria concentration values than the economic analysis criteria estimates EPA used for the RPA and water quality impairment analyses.

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

 Data are limited for some of the sample facilities making it difficult to determine which facilities are potentially affected by revised criteria, whether an affected facility is meeting baseline standards, and whether incremental controls would be needed to meet proposed criteria. Thus, costs coul d be higher or lower than shown.

 In establishing the baseline, facility permits and evaluation reports do not provide detailed information on the extent of controls and activities already underway. Thus, estimates of incremental costs could be overestimated because facilities may already be implementing controls , such as P2 programs, to add ress issues.

 Lack of available in

- stream monitoring data limits the estimation of potential statewide costs associated with re ductions in pollutant loads from nonpoint sources.

 An assumption that the net increase in the estimate of impaired monitoring locations represents the net increase in the number of TMDLs may overstate the impact if several monitoring locations can be addre ssed by one TMDL.ES

- 7 March 15, 2016  I mplementation of point source controls or BMPs to address other pollutants could also result in attainment of the proposed criteria for copper and cadmium

. For point sources, it is uncertain whether any particular control option would g uarantee criteria
are met . For example, the effluent reductions achievable through P2 activities and the level of effort needed for controls are highly site

- specific and cannot be estimated without a detailed analysis of the facility’s service area and exi sting plant processes and operations.

In addition, the costs of controls are likely facility

- specific and may be higher or lower than shown. Thus, it is uncertain how much system rehabilitation will cost until a source identification study is complete.1

- 1 March 15, 2016



### 1.0 Introduction

The United States Environmental Protection Agency (EPA) is proposing to update the current criteria applicable to waters under jurisdiction of the state of Oregon , to protect freshwater aquatic life from acute exposure to cadmium and copper and chronic exposure to copper . This report provides estimates of the potential incremental control actions and costs that may be associated with the proposed regulation.

1.1 Backgr ound

The Clean Water Act (CWA) directs s tates, with oversight by the EPA, to adopt water quality standards ( WQS ) to protect the public health and welfare, enhance the quality of water, and serve the purposes of the CWA. Under Section 303, s tate WQS must in clude: (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 re quires s tates to hold public hearings once every three years for the purpose of reviewing applicable WQS and, as appropriate, modifying and adopting standards. EPA must approve or disapprove any new or revised standards.

In 2004, Oregon adopted EPA’s 2001 304(a) recommendation for the freshwater acute cadmium aquatic life criterion and EPA’s 1995 304(a) recommendations for the freshwater acute and chronic copper aquatic life criteria

, which were the most recent ones available in 2004

. On July 8, 2004 , ODEQ submitted the revised WQS to EPA Region 10 for review and approval. EQC resubmitted the revised WQS standards with corrections to EPA for review on April 23, 2007 and again on July 21, 2011. EPA disapproved the acute cadmium criterion and acute and chronic copper criteria in January 2013, therefore , the previously EPA

- approved criteria are currently applicable (see OAR 340

- 041

- 8033 Table 30 ).

EPA is proposing three new freshwater aquatic life criteria: an acute criterion for cadmium, and acute and chronic c riteria for copper. This document provides an analysis of the potential impacts of the proposed criteria on dischargers.

1.2 Purpose and Scope of the Analysis

The purpose of this analysis is to identify, using available water quality and discharge data and inf ormation, the potential incremental control actions and costs that publicly or privately owned treatment works (POTWs) or wastewater treatment plants (WWTPs)

, and industrial point source dischargers may incur as a result of the proposed criteria. The proposed criteria may result in new water quality based effluent limits (WQBELs) contained in the National Pollutant Discharge Elimination System (NPDES) permit for these facilities

. T he estimates of statewide control costs in this analysis reflect the po tential impacts on dischargers that could be affected by the proposed criteria , as indicated by publicly available water quality monitoring data

. Although the focus of this analysis is control costs for wastewater point sources, the proposed criteria may a lso result in a need for incremental controls by municipal stormwater and nonpoint sources discharging to surface waters. Quantitative evaluation of the potential control needs for nonpoint sources is not possible given the limited available data

. Thus, EP A identified the types1

- 2 March 15, 2016

of controls and costs that may be incurred for these sources, but d id not develop statewide cost estimates.

Total social costs include costs to both private entities and to the government. For changes to water quality criteria within an existing water quality standards and NPDES permitting program, control costs for point source dischargers likely represent the major component of total potential social costs. There may be some incremental programmatic costs and nonpoint source control costs associated with an increased number of impaired waters and total maximum daily load (TMDL) development. For the most part, however, data are not sufficient to estimate these costs.

Social costs will be accompanied by the social benefits resulting fr om 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 treatment technologi es and services (which may be within or external to Oregon). The scope of this analysis is limited to an evaluation of potential control costs; this report does not provide estimates of potential benefits of revised standards or an economic impact analysis

.
1.3 Report Organization

This remainder of this report is organized as follows:

Section 2 : Baseline for the Analysis

– d escribes the current applicable aquatic life criteria and ODEQ procedures for implementing the criteria in NPDES permits , sources of cadmium and
copper to surface waters, current water quality impairments from cadmium and copper , and ongoing efforts to reduce and eliminate these impairments.

Section 3: P roposed Revised Criteria

– o utlines the changes to existing water quality standards proposed by EPA

. This section also describes the method EPA used to derive “ economic analysis criteria ” for the purpose of this analysis. EPA is not proposing the economic analysis criteria values as the WQC. Ore gon will determine site

- dependent WQC.

Section 4: Method for Estimating Potential Costs: Point Sources

– d escribes the method for estimating point source control costs for potential revisions to NPDES permits to meet proposed criteria

.

Section 5: Method fo r Estimating Potential Costs: Nonpoint Sources

– describes the method for identifying control costs associated with proposed criteria for nonpoint sources.

Section 6: Potential Co ntrol Costs

– provides estimates of potential costs to comply with the proposed water quality standards, and discusses the uncertainties associated with the estimates.

Section 7 : References

– provides the re ferences used in the analysis

. The appendices provide detailed analyses and additional information:

Appendix A: provid es data and information on individual facilities, and analyses of potential impacts under the different scenarios.1

- 3 March 15, 2016

Appendix B: describes pollution prevention programs and estimated costs

. Appendix C: provides details for various end

- of

- pipe treatment techn ologies, 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 nonpo int sources and stormw ater discharges

.2

- 1 March 15, 2016



### 2.0 Baseline for the Analysis

This section describes the applicable baseline for evaluating the incremental costs associated with EPA’s proposed cadmium and copper water quality criteria . It includes information on
current or baseline water quality criteria, potential sources of the pollutants of concern, and identified impairment s in Oregon waters

.

2.1 Water Quality Criteria and Implementation Proced ures

In 2004, Oregon adopted EPA’s 2001 304(a) recommendation for the freshwater acute cadmium aquatic life criterion and EPA’s 1995 304(a) recommendations for the freshwater acute and chronic copper aquatic life criteria

. EPA disapproved the acute cadmium and acute and chronic copper criteria in January 2013. Therefore , the previously EPA

- approved criteria are applicable (see OAR 340

- 041

- 8033 Table 30 ). The criteria, expressed as the total recoverable form of the metal, are:

EPA approved Oregon’s 2004 proposed chronic cadmium criterion, which was based on the EPA’s 2001 Section 304(a) recommendation . EPA is not proposing revisions to the chronic cadmium criterion. Th e equation for the dissolved criterion is:

OAR 340.041 specifies the procedures for applying water quality cr iteria.

2.2 Sources of Cadmium and Copper to Surface Waters

Cadmium and copper can be introduced to surface waters through human activities, including municipal and industrial effluents, stormw ater discharges, agricultural runoff, forestry (chemical application), and mining. Both metals are naturally occurring, although anthropogenic activities increase the mobility and global cycling of these two metals.

Cadmium and copper concentrations are gener ally highest in urban and industrialized regions, where municipal facilities release wastewater and sludge from sewer systems or industrial facilities release contaminated water (Irwin et al., 1997a, 1997b). Stormw ater near municipal and industrial facilit ies can also introduce cadmium and copper into surface waters, including the delivery of dusts from smelters and brake friction material that deposits on roadways during brake use. Cadmium and copper are also used in agricultural and forestry applications in fertilizers and pesticides (Wuana and Okieimen, 2011), which may result in surface water contamination from surface runoff or groundwater transport. Mining and smelting of heavy2

- 2 March 15, 2016

metals (particularly copper and lead

- zinc mines) can introduce cadmium and copper to surface waters via runoff and atmospheric deposition.

2.2.1 Municipal and Industrial Dischargers

EPA’s Integrated Compliance Information System for NPDES (I C I S

- NPDES ) database indicates that there are individual NPDES permits for 3 62 municipal and industrial dischargers in Oregon. Exhibit 2

- 1 shows the number of facilities by type (major/minor) and industrial category specified in I C I S

- NPDES

.2

- 3 March 15, 2016 Exhibit 2

- 1 . NPDES Permitted Direct Dischargers in Oregon

SIC SIC Category Title 1 Majors Minors 0 9 Fishing, Hunting, and Trapping

- 6 10 Metal Mining

- 3 15 General Building Contractors 1

- 20 Food and Kindred Products 2 11 24 Lumber and Wood Products 1 28 26 Paper and Allied Products 10 3 28 Chemicals and Allied Products 1 8 32 Stone, Clay, and Glass Products

- 3 33 Primary Metal Industries 3 3 34 Fabricated Metal Products

- 1 35 Industrial Machinery and Equipment

- 1 36 Electronic and Other Electronic Equipment

- 3 37 Transportation Equipment

- 3 38 Instruments and Related Products

- 1 42 Trucking and Warehousing

- 2 45 Transportation by Air

- 2 46 Pipelines, Except Natural Gas

- 1 49 Electric, Gas, and Sanitary Services; except 4952 1 22 4952 Sewerage Services (Municipal Wastewater) 50 134 50 Wholesale Trade

- 6 65 Real Estate

- 4 70 Hotels and Other Lodging Places

- 7 76 Miscellaneous Repair Services

- 1 79 Amusement and Recreation Services

- 3 82 Educational and Social Services

- 6 87 Engineering and Management Services

- 4 92 Public Administration

- 1 95 Environmental Quality and Housing

- 2 96 Administration of Economic Programs

- 1 99 Nonclassifiable Establishments

- 1

- Not Specified 2

- 23 Total 69 293

“

- “ = None. 1. Based on 2

- digit standard industrial classification (SIC) code, except 4952. Source: U.S. EPA (2016); Accessed January 8, 2016. E xcludes facilities with Water Pollution Control Facility (WPCF) permits, which are applicable to facilities that do not discharge, as well as general permits. Facility list a lso excludes 18 sewerage entities currently classified as ‘unpermitted’ in the ICI S

- NPDES database. 2. The NPDES

- permitted entities without SIC code identifiers are municipal separate stormw ater systems

ODEQ issues NPDES general permits for a wide variety of discharger categories, including cooling water/heat pumps, filter backwash, fi sh hatcheries, log ponds, boiler blowdown, seafood processing, suction dredges, stormw ater from gravel mining, construction activities , industrial
stormw ater, oily stormw ater runoff

, tank cleanup and treatment of ground water, washwater

, noncontact geotherm al water , and small municipal separate storm sewer system s (MS4)

. Currently there are no specific effluent limits or monitoring requirements for cadmium and copper in these permits

. A draft general permit for irrigation districts and entities previously2

- 4 March 15, 2016

co vered by an individual permit for the application of aquatic pesticides contains a WQBEL limit for copper that applies to entities using copper

- based pesticides. The draft permit contains a copper limit of 12 μ g/L that applies to areas outside the pesticide treatment area and outside the treatment period (ODEQ, 2012 b )

. ODEQ has also proposed revisions to the general permit for discharge of stormw ater from gravel mining facilities . The proposed revisions , which have yet to be finalized, include a req uirement for discharge monitoring for copper if the discharge is to waters impaired for copper , and new dischargers must demonstrate no potential to contribute to impairment (ODEQ, 2012 c )

.

2.2.2 S tormw ater

Stormw ater discharges are generated by precipitation and runoff from land, pavements, building rooftops

, and other surfaces. Urban stormw ater from municipal and industrial areas may contribute metals such as cadmium and copper to surface waters.

Potential sources o f copper in urban stormw ater include copper worn from automobile brake pads, leache d from architectural materials or drinking water distribution systems (e.g., via landscape watering), or settle d on surfaces through out the watershed via air deposition. Oth er sources include soil erosion and copper

- based pesticide use.

ODEQ regulates stormw ater discharges from MS4s through general permits

. The MS4 permits require the discharger to develop and implement a stormw ater management program ( SWMP )

, with the goal of controlling pollutant discharge s to the maximum extent practicable (MEP). O DEQ 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 ho usekeeping. Permittees implement BMPs through an adaptive management or iterative approach.

ODEQ has issued four area

- wide “Phase I” MS4 permits (ODEQ

, 2016 a , 2016b )

. Phase I MS4s are those systems serving populations equal to or greater than 100,000. “Ph ase II” (or “small”) MS4s are those systems serving municipalities with populations less than 100,000 located within Census Bureau

- defined urbanized areas. There are 1 9 jurisdictions in Oregon covered by 15 “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 generation

, as well a s scrap yards, landfills, certain sewage treatment plants, and hazardous waste management facilities may have stormw ater requirements in their NPDES permits. ODEQ requires industrial stormw ater dischargers to develop a Stormw ater Pollution Control Plan (SWPCP) that inclu des a monitoring plan and discussion of the site controls that the discharger will implement to prevent stormw ater pollution (ODEQ, 2004). As noted above, ODEQ has proposed revisions to the general permit for stormw ater discharges from gravel mining , and t hese revisions include copper monitoring and new source limitations when discharges are to waters classified as impaired for copper. EPA considers these in

- progress revisions as baseline requirements.2

- 5 March 15, 2016

2.2.3 Agriculture and Forestry Cadmium and copper may be pres ent in agricultural fertilizers or pesticides and can reach surface waters through irrigation return flow, stormw ater runoff

, and soil erosion. Oregon’s Department of Agriculture (ODA) reports that copper compounds appeared among the top five active ingredients reported in pesticides applied in Lower Columbia and the Southern Oregon Coastal basins ODA (2009) . Copper compounds also appear among the top five pesticides used in aquatic and urban

- indoor application sites. Overall, more than 1 milli on pounds of copper

containing active ingredi e nts were applied as pesticides across the state in 2008 (ODA, 2009). Fertilizers, which may contain cadmium, are regulated under Oregon’s Fertilizer Law (ORS 633) . Under this statute, fertilizer products must b e registered for sale or distr i b ut ion (ODA, 2011). Registration application requirements include providing laboratory data on total levels of metals such as cadmium, and ODA has established maximum cadmium concentrations that vary with the percent of phosp horus or other micronutrients (ODA, 2011).

ODA ’s Agricultural Water Quality Management Program (AWQ M P) is charged with assisting the agriculture industry in reducing pollution from agricultural sources. The legal foundation of the AWQ M P is the 1993 Agricu ltural Water Quality Management Act (SB1010) (ODA, 20 14 ). 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.

ODA has identified 3 8 watershed

- based agricultural water quality management areas. Within each management area is a local advisory committee consisting of water quality specialists, local farmers, ranchers, and community leaders. All 3 8 local advisory committee s have approved Agricultural Water Quality Management Area Plans along with enforceable administrative rul es to ensure all landowners do their part to avoid and resolve water quality problems. These plan s must describe a program to achieve water quality standards and ensure that landowners will prevent and control water pollution from agricultural activities and soil erosion.

Pesticides are also applied to forestlands. For example, t o meet requirements for rapid reforestation after harvesting, forest landowners in Oregon

-- both large industrial companies and small family forestland owners

– apply herbicides to protect tree seedlings from competing plants (ODF, 2009 ). 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 Practi ces 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, 2014 ). 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 water2

- 6 March 15, 2016  Operator must conduct mixing, transfer, and staging of chemical applications in loc ations 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 groun d applications; 60 feet for aerial applications of herbicides, rodenticides, and biological insecticides; and 100 feet for aerial applications of fungicides and nonbiological insecticides) (ODF, 2007).

2.2.4 Mines Both currently active and abandoned/inactive min e sites can contribute to elevated cadmium and
copper concentrations in surface waters. Mining activities require large amounts of water to process ore, which results in discharged effluent, seepage from tailings storage facilities, and accidental releases . In addition to this direct contamination, exploratory act ivities such as road building and erosion of mineralized overburden during mine construction can also contribute to the contamination of surface water by heavy metals (Jennings et al., 2008). The l eeching of heavy metals from excavated rock is especially problematic when mine wastes with high acid

generating pot ential are oxidized through exposure to surface conditions. Abandoned and inactive mines exist throughout Oregon, including 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 150 mines in Or egon for possible further investigation or cleanup, and have initiated assessment of about 95 mines (ODEQ, 2012 a ). For example, at the Formosa Mine Superfund site, acid mine drainage contributes to elevated heavy metal concentrations, negatively affecting downstream water quality and fisheries in the Middle Creek (U.S. EPA, 2008). Controls at mine sites may be required to meet TMDLs to address baseline impairment for cadmium and copper

.

2.2.5 Atmospheric Deposition Atmospheric deposition may be a potential nonpo int source to surface waters through either direct or indirect deposition. Direct deposition occurs when pollutants are deposited directly on surface waters from the atmosphere. Indirect deposition reflects the process by which metals deposited on the land surface are washed off during storm events and enter surface water through
stormw ater runoff. Atmospheric deposition is not directly addressed through any existing regulation, but is indirectly addressed through TMDLs.

2.3 Water Quality

ODEQ (2011) classifies all surface waters into one of following categories, based on available monitoring data: 2

 Category 2: Available data and information indicate that some designated uses are supported and the wat er quality standard is attained

.

2 Oregon does not classify waters as Category 1 (attaining all uses) because no water body has sufficient data or information on all desig nated uses and water quality standards to justify this classification (ODEQ, 2011)

.2

- 7 March 15, 2016  Category 3: Insuffi cient data to determine whether a designated use is supported. Oregon further sub

- classifies waters if warranted as:

o 3B: Insufficient data to determine use support but some data indicate non

attainment of a cr iterion and a potential concern

. o 3C: Impairing pollutant unknown

.

 Category 4: Data indicate that at least one designated use is not support ed but a TMDL is not needed. This includes:

o 4A: TMDLs that will result in attainment of water quality stan dards have been approved

. o 4B: Other pollution control requ irements are expected to address pollutants and will result in attain ment of water quality standards

. o 4C: Impairment is not caused by a pollutant (e.g., flow or lack of flow are not considered pollu tants)

.

 Category 5: Data indicate a designated use is not supported or a water quality standard is not attained and a TMDL is needed. This category constitutes the Section 303(d) list that EPA will approve or disap prove under the Clean Water Act

. Cadmium and copper criteria exceedances account for a small portion of the more than 1,000 surface waters assessed as impaired by ODEQ. Exhibit 2

- 2 summarizes the number of water bodies impaired for each pollutant

. The summary includes both the approve d 303(d) li s t based on the 2010 assess ment and the proposed 303(d) list based on the 2012 water quality assessment. To assess the potential impacts of the proposed r ule, this analysis uses as t he baseline the 2010 approved 303(d) list of impaired waters based on baseline water quality criteria. Given that this approved list shows fewer water bodies impaired because of copper concentrations as compared to the more recent 2012 303(d) proposed list, the 2010 baseline is likely to under

- represent the extent of impairment based on current criteria.

E xhibit 2

- 2

. Summary of Oregon’s 303(d) List of Impair ed Waters (2010 Approved List and 2012 Proposed List)

Pollutant / and Impairment List Number of Water Bodies Number of River

Miles Number of Lake

Acres Cadmium

– 2010 Approved List 3 33.1 NA Cadmium

– 2012 Proposed List 3 33.1 NA Copper

– 2010 Approved List 14 111.5 * Copper

– 2012 Proposed List 26 640.7* * Source: O DEQ (2016b and 2016c ). NA = not applicable

* Missing acreage or river miles for one or more water bodies.

To date, none of the TMDLs completed for impaired waters in Oregon contain load allocations for cadmium or copper (ODEQ

, 2016d, 2016e). Nevertheless, because TMDLs may be needed to address baseline cadmium and copper impairments, the ba seline conditions include future TMDL efforts for the waters identified as impaired in the 2010 approved 303(d) list. This baseline is conservative (i.e., potentially minimizing the extent of baseline impairments) , thus potentially overestimating the incre mental costs of the proposed rule

.3

- 1 March 15, 2016



### 3.0 Proposed Revised Criteria

EPA is proposing revis ions to three of Oregon’s freshwater aquatic life criteria: the acute cadmium criteri on , the acute copper criteri on , and the chronic copper criterion . The acute

c admium criterion is based on EPA ’s 2016 Update of Ambient Water Quality Criteria for Cadmium 3

, while the acute and chronic copper follow the U.S. EPA ’s 2007 304(a) recommended criteria

, which are ba sed on the BLM ( U.S. EPA , 2007 ). The sections below provide description s of each criterion

.
3.1 Acute Cadmium Criterion

EPA’s proposed acute cadmium criterion is dependent on the hardness of the ambient water. The site

- dependent criterion is calculated using the fol lowing formula:

For example, at hardness values of 25, 50, 100, and 200 mg/L as CaCO 3 the one

- hour average

conce ntrations or acute criteria are 0.4 9

, 0.94

, 1.8

, and 3.4 μg/L dissolved cadmium

, respectively

. NPDES permit limits for metals are expressed as total recoverable metal. Therefore, to derive numeric values to assess potential impacts of the proposed acute cadmium criterion on permitted effluent limits for point source dischargers that demonstrated reasonable potential, maximum daily permit limits for cadmium were calculated using the exponential expression:

In applying the total recoverable acute cadmium criterion equation for purposes of the point source analysis

, EPA used ambient hardn ess values, the minimum h ardness value contained in the f act s heet of the existing permit packag e , or the minimum reported in available monitoring data

. To apply criteria for the nonpoint source analysis, EPA used a hardness value of 25 mg/L

, consistent wi th EPA’s proposal to use 25 mg/L as a default value when no ambient data are available. This assumption results in a potentially conservative (i.e., low) value for the acute cadmium criterion. In this document, EPA refers to these criteria concentration va lues as the “economic analysis criteria”

.

3.2 Acute and Chronic Copper Criteria

The proposed acute and chronic copper criteria are based on the BLM as described in Copper Ambient Water Quality Criteria for the Protection of Aquatic Life ( U.S. EPA , 2007 ). Calculating

3 EPA expects the final national updated 304(a) recommended cadmium criteria to be published in the Federal Register in April 2016. See: http://www.epa.gov/wqc/aquatic

- life

- criteria

- cadmium3

- 2 March 15, 2016

concentration expressions for the acute and chronic copper criteria us ing the BLM requires ten input parameters char acterizing ambient water conditions . Parameter values can be based on observed data or protective defaults

. Using site

- specific data for all BLM input parameters results in the most accurate and protective aquatic life criteria. EPA recommends using measured site

- specific values for temperature, dissolved organic carbon (DOC), and pH in particular, because pH an d temperature are highly variable and routinely monitored, and copper toxicity and BLM predictions are highly sensitive to pH and DOC levels (U.S. EPA, 2016a). For the other input parameters, EPA provides conservative ( i.e., 10 th percentile) Level III ecor egion

- based values that are acceptable to use in the model for a given site in the absence of site

- specific ambient data ( U.S. EPA , 2016 a ). There are nine Level III ecoregions in Oregon : 1, 3, 4, 9, 10, 11, 12, 78, and 80 as shown below in Exhibit 3

- 1

.
Exhibit 3

- 1

. Map of Nine Level III E coregions in Oregon

Source: http://archive.epa.gov/wed/ecoregions/web/html/or_eco.html

For the purpose of applying BLM criter ia to illustrate the potential for impacts and costs, EPA used available water quality data provided by ODEQ. The data included ambient stream sampling results from the Oregon Laboratory Analytical Storage and Retrieval (LASAR) system, toxicity test s repor ted to ODEQ, and the U.S. Geological Survey’s National W ater Information System (NWIS). For purposes of this analysis, and to be conservative in assessing potential impact, EPA aggregated the data by ecoregion and computed the 10 th percentile values for
te mperature, pH, and DOC for each ecoregion ( Exhibit 3

- 2 )

.3

- 3 March 15, 2016 Exhibit 3

- 2

. Estimates of 1 0th P ercentile Values for BLM Input Parameters

Ecoregion Name (#) Temperature (°C) pH (su) Dissolved Organic Carbon (mg/L) Coast Range (1) 6.1 7.1 1.0 Willamette Valley (2) 6.1 7.1 1.0 Cascades (4) 4.5 7.2 0.1 Eastern Cascades Slopes and Foothills (9) 3.1 7.5 1.0 Columbia Plateau (10) 5.0 7.8 1.47 Blue Mountains (11) 2.0 7.7 1.3 Snake River Plain s (12) 4.8 8.0 2.9 Klamath Mountains (78) 5.5 7.1 1.0 Northern Basin and Range (80) 3.8 7.6 1.1 Source: 10 th percentile estimates based on water quality data provided by ODEQ.

For the remaining water quality parameters, EPA used the 10 th percentile Level III ecoregional default values ( U.S. EPA , 2016 a )

. Exhibit 3

- 3 provides the default values for the Level III ecoregions in Oregon. U sing 10 th percentile ecoregion

- level data potentially results in criteria output s that are more conservative than using site

- specific data for many waters within an ecoregion. Therefore, it is likely that the impact analysis over estimates the potential impact of the proposed copper criteria.

Exhibit 3

- 3 . Summary of D efault V alues f or OR Level III Ecoregions

Ecoregion Ca (mg/L) Mg (mg/L) Na (mg/L) K (mg/L) Alk (mg/L as CaCO 3 ) SO 4 (mg/L) Cl (mg/L)

1 3.6 1.0 2.0 0.2 15 2.2 1.6 3 7.1 2.5 4.3 0.8 29 2.8 4.6 4 3.5 1.0 2.8 0.4 16 0.8 0.8 9 5.5 0.8 2.4 0.5 22 2.2 0.9 10 8.6 3.2 4.0 0.9 33 3.1 1.4 11 3.7 0.8 1.6 0.7 16 0.7 0.3 12 13 2.5 4.9 1.2 40 3.8 2.2 78 7.9 3.2 4.0 0.6 36 2.4 2.1 80 15 5.7 4.1 0.8 54 9.3 2.0 Notes: Ca = calcium; Mg = magnesium; Na = sodium; K = potassium; Alk = Alkalinity; SO 4 = sulfate; Cl = chloride. Source: U.S. EPA, 2015

.

3.2.1 Economic Analysis Criteria for Copper Using the BLM and the input parameter values shown in the previous section, EPA estimated acute and chronic copper criteria concentration value outputs for each Oregon ecoregion. Exhibit 3

- 4 shows the resulting acute and chronic copper criteria concentrati on value estimates

. In this report, EPA refers to these values as economic analysis criteria

. EPA used these values to evaluate reasonable potential and potential effluent limits for each affected discha r ger . EPA also used these values to evaluate the pote ntial for incremental impaired waters

.3

- 4 March 15, 2016

Exhibit 3

- 4

. Estimates of A cute and C hronic BLM

- based C opper C riteria Concentration Values by Ecoregion

Ecoregion Acute Copper Criteria ( Cu, μg/L) Chronic Copper Criteria ( Cu, μg/L) 1 2.13 1.32 3 2.08 1.29 4 0.26 0.16 9 3.54 2.20 10 7.28 4.52 11 6.06 3.76 12 17.34 10.77 78 2.09 1.30 80 4.58 2.85

It is important to note that EPA is not proposing the values in Exhibit 3

- 4 as the new copper criteria. EPA is proposin g that ODEQ use the BLM with a preference for site

- specific ambient data . The method EPA employ ed for this analysis is intended to produce a conservative estimate of impacts

. The 10 th percentile of e coregion

- based BLM inputs may be significantly lower than site

- dependent BLM inpu ts . For the purpose of impact and cost analysis, more stringent criteria estimates will tend to result in overestimates of impacts and costs. Also note that it is possible for a BLM

- based criterion to produce values less stringent than the baseline (i.e., ODEQ’s existing hardness

- based criterion for copper) . Therefore, using the BLM approach will not necessarily result in more stringent copper criteria at all sites in Oregon

.4

- 1 March 15, 2016



### 4.0 Me thod for Estimating Potential Costs: Point Sources

This section describes the method for estimating the potential costs to point sources associated with the proposed criteria. 4 Co ntrol costs for municipal and industrial point sources may result from change s to individual NPDES permit requirements.

4.1 Identification of Potentially Affected Permittees

Factors that may affect the potential magnitude of co ntrol costs include flow and facility type. Larger flows are typically associated with the largest treatment c osts, although per

- unit costs may decrease due to economies of scale. A n industrial facility may incur different costs than municipal wastewater facilities. Minor dischargers typically do not have monitoring requir ements for toxic pollutants, and may not c ontribute 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 the proposed criteria is low.

As shown in Exhibit 2

- 1 , there are 69 major (50 municipal and 19 industrials) and 2 93 minor (1 34 municipal and 1 59 industrials) individually permitted wastewater discharges to waters for which the proposed cadmium and copper criteria would apply. EPA uses the designation of “major” for munici pal 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)

o ver a specified value (U.S. EPA, 20 16 b ).

EPA initially used ICIS

- NPDES to identify f acilities in Oregon whose NPDES permits contain effluent limitations and/or monitoring requirements for cadmium and /or copper . ODEQ currently has a large number of NPDES permits that are administratively continued

. During evaluation of these facilities, th ere were not sufficient or adequate data available for most of those facilities to conduct a RPA. ODEQ responded to a supplemental data request by providing all cadmium and copper sampling data available from NPDES facilities in Oregon. EPA excluded biosol ids data, facilities where all reported results were non

- detect, facilities with less than three data po ints, and others where there were insufficient or in adequate data to perform the analysis

. Based on this review, EPA proceeded with evaluating 33 facili ties, representing 48 percent of all major facilities in Oregon.

ODEQ has a two

- tiered approach to conducting the RPA for facilities. A description of this approach is in ODEQ’s Internal Management Directive Reasonable Potential Analysis Process for Toxic Pollutants Version 3.1 ( ODEQ , 2012 d ). Sampling for toxic metals is required for facilities that meet certain parameters. EPA further screened the 33 facilities to exclude MS4 permits. MS4s include ditches, curbs, gutters, storm sewers, and similar means o f collecting or conveying runoff that do not connect with a wastewater collection system or treatment plant. These were excluded based on the frequency, nature, common pollutants found in stormw ater (pesticides, fertilizers, oils, salt, sediment, litter an d other debris) and program requirements (control measures separate from end of pipe treatment systems). Appendix A provides facility

-

4 It should be noted that none of the facilities ev aluated in this analysis have copper effluent limits in their cu rrent NPDES permits.4

- 2 March 15, 2016

specific reasonable potential results and additional information on the specific data sources used for each facility.

EPA also reviewed the permits and fact sheets of minor facilities to determine if additional facilities had copper or cadmium effluent limitations or monitoring requirements. No facilities examined had either requirement.

Exhibit 4

- 1 provides a list of the facilities identified for a reasonable potential evaluation.

Exhibit 4

- 1 . NPDES Permitted Facilities Potentially Affected by the Proposed Rule

NPDES Number Name Major/ Minor Type OR0001341 Georgia

- Pacific Toledo Major Industrial OR0026361 City of Corvallis Major Municipal OR0022764 City of Wilsonville WWTP Major Municipal OR0000787 West Linn Paper Company Major Industrial OR0000566 Blue Heron Paper Company Major Industrial OR0027561 City of Astoria WWTP Major Municipal OR0033405 Halsey Mill Major Industrial OR0001074 Cascade Pacific Pulp Major Industrial OR0031356 R.U.S.A. Roseburg WWTP Major Municipal OR0026221 Kellogg Creek WWTP Major Municipal OR0026263 City of Medford RWRF Major Municipal OR0034002 City of McMinnville WRF Major Municipal OR0026409 City of Salem Willow Lake WPCF Major Municipal OR0031259 Tri

- City Service District Major Municipal OR0020001 Woodburn Major Municipal Source: U.S. EPA (2015a) and ODEQ supplemental cadmium and copper monitoring data

.

4.2 Determining Reasonable Potential

ODEQ (2012 d ) provides permit writers with instructions for determining whether dischargers have reasonable potential (RP) to cause or contribute to an exceedance of WQS

. O DEQ developed RPA and water quality

- based effluent limitations calculation tools to assist permit writers in conducting the RPA evaluation. EPA used these tools to conduct the RPA for the potentially affected facilities utilizing the economic analys is criteria as proxy values for the proposed criteria for copper and acute cadmium . For all the facilities evaluated, EPA incorporated approved regulatory mixing zone dilution factors along with hardness values derived from monitoring data or specified in the fact sheet of the facility’s NPDES permit.

For each facility, the RPA uses data on effluent cadmium and c opper concentrations, receiving water characteristics, ambient parameter concentrations, and dilution factors. EPA gathered these data from a vari ety of sources, including:

 Facility

- specific permit fact sheets ;

 Monitoring data available from ODEQ ; and

 Other facility documentation such as inspection reports and permit applications available from ODEQ

.4

- 3 March 15, 2016

In this analysis, copper was the only parameter where the revised aquatic life criteria indicated RP and resulted in possible new WQBELs

.

Exhibit 4

- 2 shows the baseline copper criteria utilizing the hardness

- based criterion equations for each facility. Or egon Administrative Rule (OAR) 340

- 041

- 0053 allows for regulatory mixing zones (RMZs) typically consisting of a “chronic” and an “acute” mixing zone. The chronic mixing zone is the area encompassed by the entire RMZ. Water quality criteria for both aquatic life and human health must be met outside the RMZ. The acute mixing zone or “Zone of Immediate Dilution” (ZID), is the area immediately surrounding the outfall and within the RMZ. In this area, the acute and chronic aquatic life criteria may be exceeded h owever it must be sized so that the drift time for aquatic organisms passing through the ZID is below levels that cause lethality. For each facility examined, existing RMZ and ZID dilution factors were used in the analysis. In addition, the hardness values within the RMZ and ZID were utilized, consistent with ODEQ’s procedures, to determine the applicable hardness

- based criterion. The acute and chronic criterion values are shown for two mixing zone boundaries: the ZID and the a pproved RMZ

.
Exhibit 4

- 2 . Baseline Copper Criteria

Facility NPDES Number Eco

- Region Acute (ug/L) hardness based criteria ZID Chronic (ug/L)

hardness based criteria RMZ

City of Corvallis OR0026361 3 5.00 3.60 City of Wilsonville WWTP OR0022764 3 6.40 3.60 West Linn Paper Company OR0000787 3 13.00 6.40 Blue Heron Paper Company OR0000566 3 5.50 3.90 City of Astoria WWTP OR0027561 3 5.20 3.70 Halsey Mill OR0033405 3 8.90 6.20 Cascade Pacific Pulp OR0001074 3 8.90 6.20 R.U.S.A. Roseburg WWTP OR0031356 3 9.40 5.30 Kellogg Creek WWTP OR0026221 3 6.60 3.90 City of Medford RWRF OR0026263 78 4.80 3.60 City of McMinnville WRF OR0034002 3 9.20 5.60 City of Salem Willow Lake WPCF OR0026409 3 5.30 3.70
Tri

- City Service District OR0031259 3 8.90 4.10
Woodburn OR0020001 3 16.00 9.00

Exhibit 4

- 3 shows the economic analysis copper criteria using the ecoregion

- based inputs reported above.4

- 4 March 15, 2016 Exhibit 4

- 3 . Potential Copper Criteria under Proposed Rule

Facility Acute (ug/L) Chronic (ug/L) City of Corvallis 2.09 1.30 City of Wilsonville WWTP 2.09 1.30 West Linn Paper Company 2.09 1.30
Blue Heron Paper Company 2.09 1.30 City of Astoria WWTP 2.09 1.30 Halsey Mill 2.09 1.30 Cascade Pacific Pulp 2.09 1.30 R.U.S.A. Roseburg WWTP 2.09 1.30 Kellogg Creek WWTP 2.09 1.30 City of Medford RWRF 2.09 1.30 City of McMinnville WRF 2.09 1.30 City of Salem Willow Lake WPCF 2.09 1.30
Tri

- City Service District 2.09 1.30
Woodburn 2.09 1.30

For the RPA, EPA projected the maximum effluent concentration of c admium and copper for each facility. For these projections, EPA applied multipliers to the maximum observed effluent concentration to determine a statistical maximum expected concentration of the pollutant. (U.S. EPA, 1991; Tables 3

- 1 and 3

- 2). The fewer number of data poi nts available for the analysis, the larger the multiplying factor.

When the projected maximum effluent concentration is less than both the acute and chronic criteria , there is no RP. If the concentration is greater than either the ac ute or chronic criteri a , the permit writer must determine whether a mixing zone is appropriate.

Where a RMZ is appropriate, the ODEQ’s RPA tool allows for two methods of incorporating the available dilution. The first is to use a factor derived from a mixing zone study and the second is to use a default factor calculated directly from the ratio of discharge and stream flow rates

. All of the facilities evaluated have conducted a mixing zone study to determine the available dilutions at the edge of the z one of initial dilution and the edge of the mixing zone.

Exhibit 4

- 4 summarizes the RPA for the potentially affected facilities ; Appendix A provides the details of the analyses

. As shown in the exhibit, under the baseline copper criteria

, three discharger s have RP. The economic analysis a cute cadmium criterion does not result in RP. Under the economic analysis copper criteria, these three also have RP, as do seven additional dischargers.4

- 5 March 15, 2016 Exhibit 4

- 4 . Result s of Reasonable Potential Analysis

Facility NPDES Number RP Baseline Copper RP

Baseline Acute Cadmium RP

Proposed Copper RP

Proposed Acute Cadmium City of Corvallis OR0026361 N N N N City of Wilsonville WWTP OR0022764 N N Y N West Linn Paper Company OR0000787 N N Y N
Blue Heron Paper Company OR0000566 N N Y N City of Astoria WWTP OR0027561 Y N Y N Halsey Mill OR0033405 N N N N Cascade Pacific Pulp OR0001074 N N N N R.U.S.A. Roseburg WWTP OR0031356 N N Y N Kellogg Creek WWTP OR0026221 N N Y N City of Medford RWRF OR0026263 N N Y N City of McMinnville WRF OR0034002 Y N Y N City of Salem Willow Lake WPCF OR0026409 N N Y N
Tri

- City Service District OR0031259 Y N Y N

Woodburn OR0020001 N N N N

4.3 Projecting Effluent Limits

When there wa s RP, EPA used Oregon DEQ’s method to calculate average monthly and maximum daily effluent limits. The O regon DEQ methodology was developed from EPA’s 1991 Technical Support Document (TSD) to calculate wasteload allocations ( WLAs ) and WQBELs to be protective of applicable water quality criteria in the receiving water. This methodology accounts for the allowable dilution, ambient concentration, effluent variability, and sampling frequency to calculate a WQBEL.

EPA calculated the WLAs (chronic and acute, respectively) using the following equations:

WLA chronic = D mzx x (WQC chronic – C b ) + C b
and

WLA acute = D mzx x (WQC acute – C b ) + C b where,

WLA = Wasteload allocation D mzx = Dilution factor (Q eff + Q recevingwater) /Q eff WQC = Water quality criterion C b = Ambient background concentration.

A corresponding long

- term average (LTA) is calculated from each WLA using the following equations:4

- 6 March 15, 2016

LTA a = WLA acute x e [0.5σ 2

– zσ]
LTA c = WLA chronic x e [0.5 σ42

– zσ 4 ]

w here:

σ 2 = ln(CV 2 +1) where CV is the c oefficient of variation

σ 4 2 = ln(CV 2 /4 +1) Z=1.645 for 95 th percentile probability basis (chronic), and Z= 2.2326 for 99 th percentile probability basis (acute)

EPA selected the lowest LTA for each facility to calculate the maximum daily effluent limitation and average monthly effluent limitations.

For those facilities demonstrating reasonable potential using the baseline aquatic life criteria for copper, EPA calculated the potential WQBELs , includi ng the average monthly limitation (AM L ) and the ma ximum daily limitation (MD L), shown in Exhibit 4

- 5

.

Exhibit 4

- 5

. Estimated Copper WQBELs for Facilities Potentially Affected by the

Baseline Aquatic Life Criteria

Facility AM L under Baseline Criteria (ug/ L) MD L under Baseline Criteria (ug/L) City of Wilsonville WWTP NA NA West Linn Paper Company NA NA
Blue Heron Paper Company NA NA City of Astoria WWTP 22.7 45.5 R.U.S.A. Roseburg WWTP NA NA Kellogg Creek WWTP NA NA City of Medford RWRF NA NA City of McMinnville WRF 7.55 13.3 City of Salem Willow Lake WPCF NA NA
Tri

- City Service District 6.25 17.9 NA = Not applicable

For those facilities demonstrating RP using the economic analysis aquatic life criteria for copper, EPA calculated the potential WQBELs shown in Exhibit 4

- 6.4

- 7 March 15, 2016 Exhibit 4

- 6

. Estimated Copper WQBELs for Facilities Potentially Affected by the

Proposed Aquatic Life Criteria

Facility AM L under Proposed Criteria (ug/L) MD L under Proposed Criteria (ug/L) City of Wilsonville WWTP 1.04 2.09 West Linn Paper Company 5.21 10.5
Blue Heron Paper Company 1.16 1.79 City of Astoria WWTP 9.35 18.76 R.U.S.A. Roseburg WWTP 3.59 4.07 Kellogg Creek WWTP 1.06 2.15 City of Medford RWRF 2.59 4.39 City of McMinnville WRF 1.04 2.09 City of Salem Willow Lake WPCF 4.96 9.96
Tri

- City Service District 1.07 2.1

4.4 Identifying Co ntrol Scenarios

Analysis of the available data for facilities indicates the potential for new effluent limits for copper, but not for cadmium. EPA identified the following potential alternatives for controls to
meet revised effluent limits for copper:

 Optimizing treatment processes (e.g., adding chemicals to increase flocculation or filtration effi ciency) to increase pollutant removal efficiencies

 Source control (e.g., pollution prevention program, and more stringent pretreatment standards)

 Installing end

- of

- pipe treatment technology (e.g., reverse osmosis or ion exchange )

 Alternative compliance mec hanisms (e.g., site

- specific criterion, dilution credit , or variance)

. Dischargers typically pursue the lowest cost means of meeting effluent limits. However, for the proposed BLM criteria, technical feasibility at an affordable cost may be an issue. Hence, there may be a need for al ternative compliance mechanisms.

4.4.1 Process Optimization 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 t reatment 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 qual ity, maintenance activities, automation,4

- 8 March 15, 2016

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 pollutan t removal efficiencies, process modifications could include adjusting coagulant doses to increase settling, equalizing flow if pollutant concentrations change 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 b y the process analysis study.

Process optimization costs depend on the pollutant needing reductions and existing treatment processes and operations. The effectiveness of process optimization largely depends on the efficiency of current operations, the exis ting treatment processes, and the fate and transport of copper through the treatment train. For example, if a facility is already well maintained and operated, implementing process optimization may not result in additional copper reductions because the exi sting 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 copper if it exists primarily in dissolved form. Given the available information for the affected 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 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 o ption. 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 copper. For example, certain industrial processes may use coppe r, or copper may be a bi

- product of other processes. Thus, for municipal facilities treating such industrial waters, a feas ible source control option could be regulating indirect industrial dischargers through pretreatment permits. However, municipalities for which the main sources of copper are commercial and residential wastewater (e.g., pipe corrosion), a facility may coordinate with the water utility (e.g., control acidity in the drinking water) and may need to concentrate efforts on public outreach and education or a sewer use ordinance. In addition, copper may be present in groundwater

, and reducing inflow and infiltration (I&I) or treating source water may be necessary.

Costs for source control activities depend on the measures or controls implemente d. P2 programs can be a cost

- effective means of reducing copper in wastewater effluents. However, as contributing sources are identified and controlled, the cost

- effectiveness and efficacy that a P2 program would provide will diminish, and a discharger may need to pursue additional compliance mechanisms.4

- 9 March 15, 2016

EPA estimated a range of source control actions and costs for control of copper that include P2 programs, I&I reduction programs, and variances. In some areas of Oregon, copper may be present in groundwate r in relatively high concentrations. For example, groundwater sampling conducted in the Willamette Basin by ODEQ ( 2004) showed copper concentrations exceeding the economic analysis criteria, despite being well below drinking water standards. This could be a significant source of copper within municipal wastewater systems, as contaminated groundwater leaks into sewer systems

. While I&I controls may help some facilities comply with the proposed standards for copper, many of the facilities have I&I programs as part of their NPDES permit requirements, so EPA estimated that the associated costs of these I&I programs would not change as a result of this rule. For this analysis, EPA estimated that the sample facilities would primarily pursue P2 programs to reduce c opper concentrations in effluents.

4.4.2.1 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

– p referably composed of representatives from government, industry, community, and environmental organizations that are either familiar with P2 strategies or familiar with copper ;

 Define program goals

– including a statement of how the municipality intends to reduce copper levels in its effluent, the purpose for doing so, and a timeline 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 c ontrol 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 p rogram

– 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) through out the duration of the program;

 Provide follow

- up

– necessary to ensure P2 measures continue to be implemented ; and

 Develop a contingency plan

– including a description of actions to be taken i f plan efforts are unsuccessful

. The focus and approach of the program will be different for each community an d sector targeted. As such, plans vary in complexity and in the resources necessary to achieve the goals set forth.

The reductions in copper achievable through P2, and thus the ability to meet numeric effluent limits using P2 alone, will vary based on exi sting treatment processes, the makeup and size of the service area (e.g., number of potential copper sources), and the level of P2 already being implemented in the community. Large municipal facilities with numerous potential copper sources may see signifi cant reductions after implementation of a measure that targets a major influent copper source, such as requiring a pre

- treatment permit from a sheet metal manufacturer,4

- 10 March 15, 2016

or encouraging the main drinking water utilities in the service area to adjust pH level s in drin k ing
water to the extent feasible

. 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 or controllable sources contributing to t he influent copper load. For example, s ources 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 as well as residential water pipes

. S maller municip alities are likely to receive most of their inflow from the residential sector

.

T here is little information available on the cost of P2 programs for individual pollutants in general, and copper in particular, because facilities typically do not account fo r pollutant

- specific P2 costs as a budget item that can be verified apar t from other base program costs. However, the experiences of facilities that have already developed P2 programs provide some information on likely program components and costs.

Commun ity size is likely to be a factor affecting P2 program costs. For example, it is unlikely that a minor facility would need the same resources for program development and outreach efforts as a large major municipal facility because the minor facility’s serv ice 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, EPA assumed that P2 program costs for copper may be approximately $ 7,300 per year for a small municipal facility ( 1 mgd to 5 mgd ) , $ 14,600 for a medium

- sized municipal facility ( ≥5 mgd to 20 mgd), and to $ 21,900 per year for a large municipal facility (> 20 mgd). Appendix B discusses the basis for these estimates

.

EPA was unable to estimate total pretreatment or P2 costs to indirect dischargers for copper

w ithout specific information on the types of industrial di schargers in each service area.

4.4.2.2 I&I Reduction Projects

As previously discussed, existing groundwater copper levels may be below drinking water standards, but not necessarily below the economic analysis criteria for copper ( O DEQ, 2004) across the state. A discharger experiencing higher copper concentrations during wet weather flows may benefit from investigating whether an I&I reduction program could be used as a potential control mechanism to prevent groundwater from entering their sewer system . Some dischargers in the state , such as the City of Portland, are already investigating I&I programs (City of Portland , undated ), including most facilities evaluated for end of pipe treatment costs.

The following five mu ni cipal facilities identify and discuss their ongoing I&I reduction program in their most recent permit fact sheet:

 Kellogg Creek WWTP ;

 City of Salem Willow Lake WPCF ;

 City of Wilsonville WWTP ;

 R.U.S.A. Roseburg WWTP ; and

 City of Medford RWRF.4

- 11 March 15, 2016

I&I reduction prog rams are not discussed in the permit fact sheets for the remaining three municipal facilities ( City of Astoria WWTP

, City of McMinnville WRF , and Tri

- City Service District ) , but these fact sheets are dated 2003 to 2011, and may be outdated. These facilitie s do report addressing combined sewer overflows issues by disconnecting stormwater discharges from the sewer system , and/or experiencing high levels of I&I.

All wastewater treatment facilities treating domestic wastewater are required to report annually

o n their collection system activities, which includes maintenance , potential collection system failure, as well as efforts to reduce I&I ( ODEQ , 2016 f ). U nder OAR 340

- 041

- 0061(9), dischargers with a separate sanitary sewer system experiencing significantly h igher flows during wet weather months than dry weather months are allowed to discharge those higher flows. However, they are also required to implement an I&I program acceptable to ODEQ. The ODEQ program targets inflow , because identifying and remediating inflow is usually relatively cost

effective compared to infiltration ( ODEQ , 2016 f ).

Therefore, it is highly likely that the remaining three facilities either have recently started implementing an I&I program, or will do so to comply with their permit renew al. Most facilities

are either already implementing an I&I program as part of their permit requirements, or are likely to be required to do so in the future, independent of the revised BLM criteria. Therefore , EPA estimated the cost of implementing an I&I program as part of the baseline cost for these facilities. It does not represent an incremental cost related to the revised copper BLM criteria.

4.4.3 End

- of

- Pipe Treatment If process optimization or source control would not be sufficient to meet the proposed cr iteria, alternative discharge options or end

- of

- pipe treatment technologies may be necessary. However, the lowest levels of copper achievable through end

- of

- pipe treatment are somewhat uncertain due to the fact that no other dischargers have been required to treat to such low levels and performance data are not available. In addition, preliminary estimates indicate that some of the technologies may be cost

- pro hi bitive (Appendix C).

Exhibit 4

- 7 summarizes some of the end

- of

- pipe treatment technologies that could be used to remove copper. Note that although these technologies should theoretically be able to achieve the levels needed to meet the baseline and revised criteria, there is no evidence that any po int source discharger to surface waters has actually implemented such controls to meet similar copper effluent limits.

Exhibit 4

- 7 . Summary of Potential End

- of

- Pipe Treatment Technologies for Copper Removal
Technology Considerations Reverse Osmosis Pretreatment (e.g., microfiltration) to prevent fouling Ion Exchange System would have to be optimized for removal of copper to achieve low effluent levels.
Chemical Precipitation Pre

- oxidation likely necessary to achieve low effluent levels; removal rat es may be

highly dependent on pH and other wastewater characteristics

Appendix C provides detailed information on each treatment technology as well as available unit
costs. It also provides a preliminary analysis indicating that reverse osmosis may not be economically feasible for many of these facilities. Therefore, EPA assumes that when necessary to meet effluent limits, ion exchange will be the preferred technology. Exhibi t 4

- 8 summarizes4

- 12 March 15, 2016

the ion exchange treatment costs for upgrading an existing 5 MGD per day plant, with an expected life span of at least 20 years, and discount rates of 3 and 7%.

Exhibit 4

- 8 . Summary of Costs for Potential End

- of

- Pipe Treatment Technologie s End of Pipe Annual Costs (5MGD) Ion Exchange Cost ($Million) Annualized over 20 years at 3% $ 0.92 Annualized over 20 years at 7% $ 1.14

4.4.4 Alternative Compliance Mechanisms If none of the control options discussed above would result in meeting the proposed effluent limitations for copper, or if the costs of available treatment would be prohibitive, dischargers would likely need some form of relief from the requirements. EPA estimated costs for the following three alternative compliance mechanis ms: variances, applying criteria with site

specific inputs , and dilution credits.

4.4.4.1 Variances

OAR 340

- 041

- 00 59 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
att ainment 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 pollutio n 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 t o 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, cove r, flow, depth, pools, riffles, and unrelated to water quality preclude attainment of aquatic life protection uses ; or

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. Dischargers and the state are most likely to pursue a variance based on economic infeasibility (i.e., “factor 6”)

. The analysis to support such an application likely begins with a technical feasibility analysis. Exhib it 4

- 9 provides estimates of levels of effort that may be associated with technological feasibility analyses.4

- 13 March 15, 2016 Exhibit 4

- 9

. Potential Level of Effort to Investigate Technological Feasibility

Component H ou rs Cost 1 Lit erature search 180 $ 22,5 00 Write up and evaluation of theory and performance data from search 100 $ 12,500 Evaluat ion of existing treatment performance 40 $ 5,000 Total 320 $ 40,000 * Based on a labor rate of $125/hr, reflecting the average wage rage for an environmental engineer in Oregon escalated to September 2015 dollars ($40.81; BLS, 2014; 2015 a ) and multiplied by a factor of 3.03 to account for overhead, benefits, and profit (PSMJ, 2007).

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 pub lic 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 on the discharger and, if so, whether that impact would cause widespread adverse impacts on the surrounding community.

EPA estimated the cost associated with individual applications demonstrating adverse economic and social impacts as including the cost of a pr eli minary engineering analysis ( pre

- conceptual design; detailed design work is not necessary) and subsequent financial analysis. This level of engineering analysis, in conjunction with the financial impact analyses (described in Appendix D) may vary based on facility size (l arger facilities may have more alternatives and issues to evaluate, and more capabilities com pared to smaller facilities). To provide some indication of the potential magnitude of such costs, EPA assumed that dischargers will likely comp lete the studies and variance application w ithin 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 $340,000 (at an average hourly wage rate of $1 25

, including benefits, overhead, and fee 5 ). EPA assumed that the level of effort involved in completing studi es and applications would be one

- third less for medium

- sized facilities (>5 mgd and <20 mgd) (i.e., approximately $226,000), and two

- thirds less (i.e., approximately $114,000) for small

- sized facilities (>1 mgd to 5 mgd).

ODEQ would also have to review any requests for variances. A ssuming the State’s review of the engineering cost and financial impact analysis could require up to 100 hours 6 and the average

5 Labor costs are based on average wage rates for an environmental engineer in the State of Oregon [escalated from 2014 dollars to 2015 dollars using Bureau of Labor Statistics (BLS) employment cost index] (BLS, 2014; 2015a; 2015b )

. 6 EPA assumed that t he 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. Base d on time estimates to review and respond to comments on an individual permit issue to a single concentrated animal feeding operation (U.S. EPA, 2000 b ), EPA assumed that, on average, the notification and response to comments activities would require an ave rage of 68 hours. Thus, the total time requirement for each request is 100 hours.4

- 14 March 15, 2016

hourly wage rate for an environmental engineer at ODEQ is approximately $47 including benefits (ODEQ, 2010; BLS, 2015 a ) 7 , per

- review cost to ODEQ could be approximately $4,700.

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 like ly to be minimal. In addition, this analysis does not address costs associated with implementing controls necessary to meet the highest attainable condition, which may be intermediate between current performance and fully meeting the WQBEL associated with the proposed WQS.

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, EPA assumed that facilities would need to implement a P2 prog ram as part of a variance.

4.4.4.2 Dilution Credits

Under ODEQ’s Regulatory Mixing Zone Internal Management Directive, facilities may apply for, and update their RMZs. RMZs may be established when a discharger has applied all known and reasonable treatment and a m ixing zone analysis has been performed. Once approved, dilution credits can reflect no more than the level of effluent and ambient receiving water mixing which occurs under critical conditions. Dilution credits are used to account for the assimilative
capa city of the receiving water when computing the waste load allocation applicable to a specific parameter and associated effluent limitations. A number of NPDES permits already include mixing zones, but the permittees could still apply for a revision of thei r mixing zone.

Dischargers who cannot readily comply with end

- of

- pipe effluent limitations based on the proposed BLM copper criteria and who do not currently possess an approved RMZ, may elect to pursue approval of a RMZ as a means of meeting effluent lim itations.

When applying for a RMZ, a specific study is required to estimate and document the level of mixing which is likely to be present in the receiving water under applicable critical conditions. A study of this type will typically require data collec tion and the mathematical modeling of the discharge and ambient receiving environment. In developing costs associated with developing a dilution special study, EPA estimated that approximately 320 hours would be required of an environmental engineer to dev elop and interpret the model, and an additional 50 hours by an environmental engineer at ODEQ to review the model. EPA assumed the costs to obtain modeling software would be negligible, as EPA distributes software appropriate to this application (i.e., Vis ualPlumes) free of charge. Labor costs are based on average wage rates for an environmental engineer in the State of Oregon [escalated from 2014 dollars to 2015 dollars using Bureau of Labor Statistics (BLS) employment cost index] (BLS, 2014; 2015a; 2015b) , i.e. $125/hour.

7 The 2010 average hourly rate across salary levels for an environmental engineer is $26.97, i.e., $28.71 when adjusted to 2015. Benefits are an additional $18.16 an hour, fo r a total of $46.87, or approximately $47.4

- 15 March 15, 2016

It should be noted that the NPDES dischargers evaluated as having RP to exceed the revised copper criteria already have approved mixing zones . While they may conduct a study to support a mixing zone change, this discussion mostly applies to other permit holders who might be affected but were not identified as such for the cost analysis.

4.4.4.3 Criteria Based on Site

- Specific Ambient Data

To illustrate the potential impacts and costs of revised copper criteria, EPA estimated criteria using the 10 th percentile of ecoregion al data. This approach may result in overly conservative (i.e., low) criteria compared to criteria based on site

- specific ambient data (Exhibit 4

- 10). For example, EPA recalculated economic a nal ysis criteria based on the 50 th perc entile ecoregion al value for DOC for eight municipal facilities and reanalyzed the discharges for reasonable potential. The economic analysis criteria developed using the 50 th percentile ecoregion al DOC values resulted in two POTWs ( City of Medford RWRF an d Kellogg Creek WWTP) that had reasonable potential to exceed the copper criteria using the conservative 10 th percentile ecoregion al data no longer having reasonable potential and not requiring final effluent limitations for copper (Exhibit 4

- 11). The rema ining six facilities would continue to require final effluent limitation s for either the acute or chronic copper criterion

. However, i n several instances the maximum predicted effluent concentration at the boundary of the applicable mixing zone is close
to the recalculated economic analysis criteria value. Additional monitoring (a more robust data set) or a revised mixing zone study may result in effluent limitations not being required. As stated in EPA’s proposed rule, EPA recommends that Oregon prioritize collecting ambient data by site to derive the most precise and protective copper criteria. This is especially important for DOC data because copper toxicity and BLM predictions are hig hly sensitive to DOC concentrations. The tables below summarize the findings:

Exhibit 4

- 10

. RPA Using 10 th Percentile Ecoregion al DOC Data

Facility Acute

Copper Criteria Chronic

Copper Criteria Maximum

Concentration at Boundary of ZID (acute) Maximum

Concentration at Boundary of RMZ (chronic ) Reasonable

Potential Y/N AM L

(μg/L) MDL (μg/L)

City of Wilsonville WWTP 2.09 1.3 8.88 2.98 Y (both) 1.04 2.08
City of Astoria WWTP 2.09 1.3 7.83 1.91 Y (both) 9.12 18.3
RUSA Roseburg 2.09 1.3 7.22 3.86 Y (both) 2.86 4.05 Kellogg Creek WWTP 2.09 1.3 2.05 1.46 Y (chronic only) 1.05 2.14
City of Medford RWRF 2.1 1.3 2.2 0.33 Y (acute only) 2.59 4.39
City of McMinnville WRF 2.09 1.3 7.36 6.24 Y (both) 1.11 1.95
City of Salem Willow Lake WPCF 2.09 1.3 5.5 3.21 Y (both) 4.68 10.66

Tri

- City Service District 2.09 1.3 27.95 6.4 Y (both) 0.84 2.394

- 16 March 15, 2016 Exhibit 4

- 11

. RPA Using 50 th Percentile Ecoregion al DOC Data

Facility Acute

Copper Criteria Chronic

Copper Criteria Maximum

Concentration at Boundary of ZID (acute) Maximum

Concentration at Boundary of RMZ (chronic ) Reasonable

Potential Y/N AM L

(μg/L) MDL (μg/L)

City of Wilsonville WWTP 5.3 3.3 8.88 2.98 Y (acute only) 5.81 11.66
City of Astoria WWTP 5.3 3.3 7.83 1.91 Y (acute only) 23.19 46.53
RUSA Roseburg 5.3 3.3 7.22 3.86 Y (both) 7.28 10.28 Kellogg Creek WWTP 5.3 3.3 2.05 1.46 N

-- -- City of Medford RWRF 4.2 2.6 2.2 0.33 N

-- -- City of McMinnville WRF 5.3 3.3 7.36 6.24 Y (both) 2.82 4.97
City of Salem Willow Lake WPCF 5.3 3.3 5.5 3.21 Y (acute only) 22.53 51.34

Tri

- City Service District 5.3 3.3 27.95 6.4 Y (both) 3.53 10.07

If dischargers suspect that the characteristics in the vicinity of their discharge warrant alternative application of copper criteria (e.g., resulting in less stringent effluent limitations in their permit), they may work to collect representative ambient data. EPA estimated that the level of effort required for collecting and analyzing ambient data would be similar to th at of a dilution study, including a review by ODEQ.

4.4.5 Summary of Unit Control Costs

Exhibit 4

- 12 summarizes EPA ’s unit costs for mechanisms other than end of pipe treatment, including site

- specific criteria , dilution credits, and variances

. In addition, EPA estimated annual P2 program costs as approximately $10,400 for facilities with 1

- 5 mgd flows, $16,800 for facilities with 5

- 20 mgd flows, and $23,200 for facilities with flows in excess of 20 mgd.

Exhibit 4

- 12 . Estimat ed One

- Time Costs of Alternative Compliance Mechanisms by Discharge Flow Category ( $ 2015 )

Alternative Compliance Mechanism 1

- 5 mgd 5

- 20 mgd >20 mgd Site specific criteria $42,350 $42,350 $42,350 Dilution credits $42,350 $42,350 $42,350 Variance $ 120 ,000 $2 30 ,000 $3 4 5,0005

- 1 March 15, 2016



### 5.0 Method for Estimating Potential Costs: Nonpoint Source s

Unlike point sources, ODEQ typically does not require nonpoint sources and municipal
stormwater dischargers to achieve numeric WQBELs for metals

. As discussed in Section 2, t he regulatory baseline for evaluating the potential impact of the revised criteria includes some requirements for nonpoint sources and stormwater dischargers to implement BMPs and wasteload allocations as part of future TMDLs. Although ODEQ has not developed TMDLs for cadmium or copper, it would be developing TMDLs for the waters identified as impaired under baseline criteria (Exhibit 2

- 2 ). Because the TMDLs needed under baseline criteria have not been completed , the pollutant loading reductions and discharge concentrations that will be achieved through implementation of BMPs is uncertain. There is also uncertainty in the extent of incremental controls that could be required under the proposed criteria.

5.1 Available Data

EPA used i nstream monitorin g data to assess the potential impact s that changes in cadmium and copper criteria may have on water quality attainment . The data came from ODEQ ’ s LASA R database (ODEQ, 2016a). Although it is not representative of all the s tate ’ s surface waters, LASAR cont ain s water quality monitoring data for the pollutants of concern in all ecoregions.

EPA obtained all total recoverable cadmium and copper, dissolved cadmium and copper, and cadmium and copper (assumed total recoverable) chemistry results from the LASAR da tabase for the period from January 1, 2000 to December 31, 2012

. T his is a reasonable timeframe to potentially include all of the s tate ’s regularly monitored waters and be relevant in characterizing current conditions. The Agency’s data review and validation included conversions to transform the sample results into units comparable to the proposed water quality criteria and to map each sample station into one of the s tate ’ s nine ecoregions (Exhibit 3

- 2)

. Exhibit 5

- 1 prov ides a summary of the data.

Exhibit 5

- 1 . Summary of Select Ambient Monitoring Data 1

Pollutant Number of Stations Total Number of Samples Samples with Detected Levels Cadmium 327 1,581 49 Copper 421 1,737 995 NA = not applicable 1. Source: ODEQ (20 16 a ); data from 2000 to 2012 . Does not include stations directly downstream of point

sources.

5.2 Identifying Exceedances

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 (2011) indicates that the water should be classified as one of potential concern (Category 3B)

. EPA applied the same approach when it compared the LASAR water quality monitoring data to the acute cadmium criterion of 0.49 μ g/L and the ecoregion

-5

- 2 March 15, 2016

specific copper criteria estimates for the proposed rule shown in Exhibit 3

- 4 . Based on this comparison, EPA assign ed each sampling station to one of the following categories :

 Potentially impaired: two or more sample result s collected on different sampling dates exceeded the proposed criteria ;

 Impairment uncertain: only one sample result exceeded proposed cr iteria ; and

 Impairment unlikely: no sample result exceeded proposed criteria

. To estimate the potential impact of the proposed rule on nonpoint sources, EPA compared the exceedance results with Oregon’s approved 2010 baseline water body 303(d) listing , and the state’s proposed 2 012 list.

5.2.1 Cadmiu m
The LASAR dataset that EPA obtained did not contain samples that exceeded baseline criteria for cadmium ; baseline impairment decisions made in 2002 and 2004 were likely based on older data

. Nevertheless, samples th at exceed baseline criteria are likely to also exceed the proposed criteria. Therefore, the water bodies currently listed as impaired for cadmium would continue to be listed as impaired because the baseline chronic cadmium criterion will be lower than the site

dependent acute criterion. Therefore, all TMDL development and implementation costs for cadmium are baseline costs.

5.2.2 Copper

There are 53 samples (of 995 detects) in the monitoring dataset that exceed the baseline criteria (Exhibit 5

- 2) . In 2010, Oreg on identified 14 waters as impaired for copper and proposed to expand the list of waters impaired for copper to 26 in 2012.

Up to 623 samples exceed the economic analysis chronic criteria for copper ; exceedance estimates for acute criteria are lower

. Because many monitoring stations have multiple samples and the listing criteria require a station to have at least two exceedances to be categorized as impaired, the corresponding number of stations exceeding criteria is 82.

Exhibit 5

- 2

. Number of Exceedances Based on Copper Monitoring Data

Criterion Samples Exceeding

Baseline Criteria Samples Exceeding Proposed Criteria Stations Exceeding Proposed Criteria Acute 34 372 56 (13%)
Chronic 53 623 82 (19%) Source: ODEQ (2016 a ); data from 2000 to 2012. Does not include stations directly downstream of point sources.

T o better assess the potential changes in Oregon water body listing status, EPA paired the sampling stations with a water quality status from the 2010 approved assessment results and from the 2012 proposed assessment results. To accomplish the pairings, EPA used GIS to measure the straight

- line distance between each sampling station and the nearest water body in either assessment year

. For distances up to 1.2 miles, EPA paired the water body with the station. For sampling stations that were more than 1.2 miles away from a water body in the 2010 or 2012 assessment database, EPA did not identify a pairing

.5

- 3 March 15, 2016

Exhib it 5

- 3 provides a comparison of the exceedance status of the 421 monitoring stations with copper data with the 2010 water quality assessment status of the paired water bodies

. Of the 82 stations exceedi ng the proposed criteria, only five were identified as impaired in 2010; the others were either unclassifiable or classified as attaining criteria. More than half of the monitoring stations in EPA’s dataset were not paired with a water bod y in the 2010 assessment. Exhibit 5

- 4 provides a map with the location of the monitoring stations and the 2010 water body assessment results, showing several of the stations classified as potentially impaired are in the Willamette basins.

Exhibit 5

- 3 . Stations by Exceedance Cat egory and 2010 Assessment Status
Impact Analysis Exceed a nce category 303(d) listed (Category 5) Insufficient data

(Category 3) Attaining

(Category 2) No Pairing

Identified Potentially impaired 5 23 20 34 Impairment uncertain 0 11 0 14 Not potentially impaired 3 118 18 175 Based on this comparison, there is a net change in attainment status for 74 stations (82 potentially impaired minus five classified as impaired in 2010 and three reclassified as not potentially impaired). Without additional information about how Oregon might categorize stations into individual water bodies for the purpose of defining reaches impaired for copper

, EPA assumed that the 74 incremental stations represe nt an upper bound on the number of incremental TMDLs. It is possible that water bodies have multiple monitoring stations such that there are fewer than 82 impaired water bodie s ; 48 of the 82 sampling stations occur along 15 rivers. The number of TMDLs pote ntially needed to address exceedances at all 48 stations is not known.5

- 4 March 15, 2016

Exhibit 5

- 4 . Sampling S tation E xceed a nce R esults for P roposed BLM

- Based C opper WQC

Compared to Approved 2010 Water Quality Attainment S tatus

Source: ODEQ (2016c) for attainment status and ODEQ (2016a) for station data

Exhibit 5

- 5 shows the pairing results for the 2012 water quality assessment. The results show substantially more station

- to

- water body pairings compared to 2010. They also show a larger overlap with regard to impairment status. Nevertheless, the comparison indicates a net change in attainment status for 36 stations (82 potentially impaired minus 20 c lassified as impaired in 2012, three reclassified as impairment uncertain, and 23 classified as not potentially impaired for
copper ). Although the 2012 proposed impairment list has not been approved, it potentially provides a more comprehensive picture of overall water quality throughout the state because it contains additional monitoring data.

Exhibit 5

- 5

. Stations by E xceed a nce C ategory and 2012 Assessment Status
Impact Analysis Exceed a nce category 303(d) listed (Category 5) Insufficient data

(Category 3) Attaining

(Category 2) No Pairing

Identified Potentially impaired 20 16 41 5 Impairment uncertain 3 4 15 3 Not potentially impaired 23 108 89 945

- 5 March 15, 2016

The map in Exhibit 5

- 6 juxtaposes the station

- level water quality results and the water body assessment results for 2012 , which incorporates information for more water bodies than 2010, along with notable consistencies in impairment results in the John Day and Snake river basin s along with additional proposed 303(d) listed waters in the Willamette basin

.
Exhibit 5

- 6 . Sampling S tation E xceed a nce R esults for P roposed BLM

- Based C opper WQC

Compared to Proposed 2012 Water Quality Attainment Status

Source: ODEQ (2016b) for attainment status and ODEQ (2016a) for station data

5.3 Identifying Potential Control Actions and Costs

D ata are too limited to reliably estimate the extent of incremental nonpoint source and
stormwater controls needed to comply with the proposed criteria

. Nonpoint sources and
stormwater may be at least partially responsible for these potential impairments.

If the proposed criteria for Oregon lead to surface waters being added to the state’s 303(d) list for exceedances of aquatic life water quality criteria, the magnitude of cost impacts to nonpoint sources depends on the extent to which additional practices are needed to meet the potential revisions in comparison to meet existing baseline standards.

If nonpoint sources are the primary cause of some incremental impairments, then the revised criteria may result in some costs to nonpoint sources, including:5

- 6 March 15, 2016  Agricultural and forest lands

– changes in fertilizer or pesticide use and/or sediment and erosion c ontrols beyond those specified under existing state an d 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 haz ards ; and

 Stormwater discharges

– increased or additional nonstructural BMPs (e.g., institutional, education al , or P2 practices designed to limit gene ration of runoff or reduce the pollutant load in runoff); and structural controls (e.g., engineered and constructed systems designed to provide water quantity or quality control).

Control of nonpoint sources of the pollutants of concern could reduce cost s to point sources. In the context of a TMDL, load and wasteload allocations reflecting the source of the pollutant could result in less stringent limits for point sources than anticipated through the analysis of the sample facilities as described in Secti on 4.

If there is incremental water quality impairment under the proposed revised criteria, there could be incremental costs for TMDL development. U.S. EPA (2001) reports that the average cost to develop a TMDL for a single source of impairment ranges fro m $27,000 to $29,000 (in 2000 dollars) or $37,000 to $40,000 (in 2015 dollars). 8 EPA’s analysis of the impact of the BLM

based copper criteria defined using ecoregion al estimates indicated potential for a net increase in the number of monitoring stations m eeting criteria for Category 5

– impaired waters. If the net increase in stations (36 to 74) is any indication of the potential increase in the number of TMDLs, then the costs for TMDL development could range fro m $1.3 million (36 TMDLs x $37,000) to $3.0 million (74 TMDLs x $40,000).

Appendix E provides examples of applicable BMPs and unit costs for nonpoint sources and
storm water discharges.

Ongoing efforts to reduc e copper loadings may affect future nonpoint source costs. One effort of particular note pertains to copper from brake pad use. To reduce copper loadings to impaired waters, the n eighboring states of Washington and California adopted laws in 2010 that limit the amount of copper in brake pads. Although similar legislation in Oregon did not pass in 2011

, ongoing efforts at the national level may make it unnecessary for the state to incur the costs of adopting and implementing brake pad limits. In January 2015, multiple organizations 9 signed a Memorandum of Understanding (MOU) that established the Copper

- free Brake Initiative, which is a voluntary, national effort to minimize the content of copper and other metals in brake pad lining in an effort to mitigate wat er quality impacts caused by brake use. The objective of the initiative is to define and coordinate roles to efficiently and effectively implement the Copper

-

8 EPA used the Consumer Price Index (CPI) to escalate costs. The annual CPI for 2000 is 172.2 and the annual value for 2015 is 237.017 (BLS, 2016).
9 Signatories included EPA, the Motor and Equipment Manufacturers Association, the Automotive Aftermarket Suppliers Association, the Brake Manufacturers Council, the Heavy Duty Manufactu rers Association, the Auto Care Association, the Alliance of Automobile Manufacturers, the Association of Global Automakers, Inc., the Truck and Engine Manufacturers Association, and the Environmental Council of the States.5

- 7 March 15, 2016

free Brake Initiative. The MOU outlines the roles of auto manufacturers, brake manufacturers, afte rmarket industries, the EPA, and states to achieve milestones for phasing out copper in brake friction material (5% copper by weight by 2021 and 0.5% by 2025). Because replacing copper in brake friction material requires extensive research and testing to i dentify substitutes with similar braking properties, a key element of the MOU is s haring information on research and testing of replacement brake friction materials. Other elements include product labeling and educational outreach. Although t he potential i mpact of the Copper

- free Brake Initiative on Oregon water quality attainment is unknown , it could reduce copper concentrations in the future and may affect copper waste load allocations under future TMDLs

.6

- 1 Marc h 15, 2016



### 6.0 Potential Costs

This section summarizes the esti mates of potential costs of the proposed revised criteria , and discusses the limitations and uncertainties associated with the analysis.

6.1 Point Sources

Baseline costs are associated with implementation of permit limits, plans, and policies that reflect exis ting criteria. Incremental costs are associated with actions or controls to meet the proposed criteria above and beyond those needed to meet baseline requirements.

NPDES permits for facilities in Oregon may not currently include WQBELs reflecting the basel ine criteria. Appendix A provides facility

- specific information on baseline control assumptions and cost estimates.

T he analysis of the potentially affected dischargers also indicated that an incremental level of control may be needed to achieve proposed B LM

- based copper criteria. EPA identified the most likely control scenarios for the revised criteria to include ion exchange treatment . Reverse osmosis was evaluated as another possible technology, but costs are likely prohibitive for the proposed facilities (discussed in Appendix C).

Exhibit 6

- 1 and Exhibit 6

- 2 provide summaries of the potential annual costs for the 3% and 7% discount rates, respectively. Each exhibit includes the incremental cost estimates to implement end

- of

- pipe treatment , which is proposed as an ion exchange system. The incremental costs of the proposed criteria revisions are the difference between the baseline cost estimates and the cost estimates for the proposed criteria. Because these were the only facilities identified as p otentially being affected by the proposed rule, these costs reflect statewide costs to point source dischargers. The incremental annualized costs for treatment to comply with the proposed rule could be as high as $ 18.2 million using a 3% discount rate or $ 22.6 million using a 7% discount
rate.

Exhibit 6

- 1 . Summary of Point Source Cost Estimates for End

- of

- Pipe Treatment (3% discount rate; millions of $2015)
Facility Incremental Cost City of Astoria WWTP $0.92 Kellogg Creek WWTP $1.47 City of McMinnville WRF $0 City of Salem Willow Lake WPCF $9.19 Tri

- City Service District $0 Blue Heron Paper Company N/A City of Wilsonville WWTP $0.55 West Linn Paper Company $0.92 R.U.S.A. Roseburg WWTP $1.47 City of Medford RWRF $3.68 Total $18.26

- 2 Marc h 15, 2016 Exhibit 6

- 2 . Summary of Point Source Cost Estimates for End

- of

- Pipe Treatment (7% discount rate; millions of $2015)
Facility Incremental Cost City of Astoria WWTP $1.14 Kellogg Creek WWTP $1.83 City of McMinnville WRF $0.00 City of Salem Willow Lake WPCF $11.44 Tri

- City Service District $0.00 Blue Heron Paper Company N/A City of Wilsonville WWTP $0.69 West Linn Paper Company $1.14 R.U.S.A. Roseburg WWTP $1.83 City of Medford RWRF $4.58 Total $22.6

Because the feasibility of achieving the effluent limits needed to meet the BLM

- based copper economic analysis criteria is uncertain and the incremental cost s of the treatment process are high, it is possible that the affected facilities will pursue alternative compliance mechanisms such as a variance. The cost associated with pursuing alternative compliance mechanisms is uncertain because the particular mechan ism is unknown. For this analysis, EPA estimated incremental 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. EPA assumes that variance adoption will likely require facilities to implement a P2 program. Exhibit s 6

- 3 and 6

- 4 provide summaries of the potential annual costs of the P2 programs for the 3% and 7% discount rates, respectively

. In addition, one

- time expenditures associat ed with variance applications could range from $ 0.4 million to $ 1.7 million under the revised criteria , and are not included in Exhibits 6

- 3 and 6

- 4

. Annualized costs for P2 programs would be approximately $ 0.1 million under the proposed criteria.

Exhibit 6

- 3 . Summary of Point Source Cost Estimates for P2 Programs

( 3% discount rate; in $2015)
Facility Incremental Cost City of Astoria WWTP $10,000 Kellogg Creek WWTP $16,000 City of McMinnville WRF $0 City of Salem Willow Lake WPCF $22,000 Tri

- City Service District $0 Blue Heron Paper Company $0 City of Wilsonville WWTP $10,000 West Linn Paper Company $10,000 R.U.S.A. Roseburg WWTP $16,000 City of Medford RWRF $16,000 Total $100,0006

- 3 Marc h 15, 2016 Exhibit 6

- 4. Summary of Point Source Cost Estimates for P2 Programs

(7% discount rate; in $2015)
Facility Incremental Cost City of Astoria WWTP $10,400 Kellogg Creek WWTP $16,800 City of McMinnville WRF $0 City of Salem Willow Lake WPCF $23,200 Tri

- City Service District $0 Blue Heron Paper Company $0 City of Wilsonville WWTP $10,400 West Linn Paper Company $10,400 R.U.S.A. Roseburg WWTP $16,800 City of Medford RWRF $16,800 Total $104,800

Point source control 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 specify when effluent limits are effective. The “a nnual” control 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 meet the economic analysis crite ria

. These estimates do not include costs for minor dischargers because there are no copper limits or monitoring requirements for these dischargers. If ODEQ adopts implementation procedures that result in copper permit limits for minor dischargers, then t hese facilities are likely to pursue either individual variances or a statewide variance if there are several affected facilities that have similar conditions on which to base a variance request.

If any municipal wastewater treatment plant implements a P2 program, indirect dischargers could also incur costs associated with the proposed criteria if the municipality imposes more stringent pretreatment standards or requirements on these dischargers. Appendix B provides estimates for potential costs to indirec t dischargers

.
6.2 Nonpoint Sources and Stormwater

Under the baseline, control costs for nonpoint sources (e.g., agricultural and forest operations; contamination from historic mining sites) and municipal stormw ater include those needed to reduce instream pollutant levels to baseline criteria or TMDL targets. There could also be incremental costs to nonpoint and stormw ater sources associated with meeting new or revised load allocations of incremental TMDLs that result from the proposed revised criteria (Ap pendix E)

. For any situation in which controls beyond those required under the baseline are necessary, controls could include:

 Agricultural and forest lands

– pesticide controls, 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 tailings6

- 4 Marc h 15, 2016 to mitigate mass wasting and off

- site migration, and abatemen t and mitigation of physical hazards ; and

 Stormw ater discharges

– increased or additional nonstructural best management practices ( BMPs ) (e.g., institutional, education al , or pollution prevention practices designed to limit generation of runoff or reduce the pollutant load in runoff); and structural controls (e.g., engineered and constructed systems designed to provide water quantity or quality control).

6.3 Government Regulatory Costs

ODEQ already has implementation procedures for hardness

- based criteria suc h as the proposed acute cadmium criterion, but may need to adopt new implementation procedures to support use of the BLM

- based criteria. EPA assumed that ODEQ would adopt streamlined procedures that rely largely on existing technical and guidance documents as well as past and on

- going ODEQ analyses of copper criteria. Therefore, EPA assumed the incremental costs of new procedures are de minimis for the purpose of this cost analysis. EPA derived partial estimates for some regulatory activities.

If ODEQ deve lops incremental TMDLs for copper, then it may incur incremental costs; EPA did not identify incremental impairment for the acute cadmium criterion. If, for example, average TMDL development costs range from $37,0 00 to $40 ,000 (U.S. EPA 2001), then increme ntal costs could range from $1. 3 million to $3.0 million for 36 to 74 incremental listings of impaired waters. It may be possible to combine TMDLs for common water bodies and reduce development costs. TMDL development costs are one

- time costs that would be spread out over several years (e.g., five

- or ten

- year time period).

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 wo uld respond to proposed revised requirements and permit conditions that affect the estimated costs

.

6.4.1 Data Limitations The lack of available data for both point and nonpoint sources adds uncertainties to the analysis of potential costs associated with meeti ng the revised criteria.

6.4.1.1 Proposed Criteria

EPA used a conservative approach to estimate the concentration criteria value outputs of the equation and model based criteria (the economic analysis criteria) based on available data, which may differ from the a pproach ODEQ would employ. Therefore, ODEQ may apply the criteria differently from the estimates EPA used for the RPA and water quality impairment analyses.

6.4.1.2 Point Sources

Data are not available for cadmium and copper for all NPDES

- permitted facilities. Wit hout data, EPA is not able to determine whether the facility meets baseline standards and whether6

- 5 Marc h 15, 2016

incremental controls would be needed to meet the revised criteria. Thus, costs could be higher than sh own if additional data indicate a need for pollutant red uctions.

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. If the available data do not reflect typical loadings of copper, then the control costs could be either over or under stated.

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, incremental costs could be overestimated because facilities may already be implementing controls to address issues such as P2 programs. Without such information, it is difficult to determine whether P2 or stricter pretreatment controls would effectively reduce pollutant concentratio ns.

6.4.1.3 Nonpoint Sources

The lack of available in

- stream monitoring data for some water bodies and the use of ecoregion

specific criteria values instead of site

- dependent copper criteria prevent reliable estimation of incremental impairment and, therefore, est imation of potential statewide costs associated with incremental TMDLs and subsequent reductions in pollutant loads from nonpoint sources. There

are also a lack of data regarding potential copper reductions for programs underway such as the Copper

- free Bra ke Initiative.

An assumption that the net increase in the estimate of impaired stations represents the net increase in the number of TMDLs may overstate the impact if several stations can be addressed by one TMDL.

6.4.2 Load Reductions There is uncertainty re garding the pollutant loading reductions that would result from meeting the revised criteria. The feasibility of meeting the revised effluent limitations is uncertain because the feasibility of end

- of

- pipe treatment to achieve the permit limits has not bee n demonstrated. If the controls are not effective, then the pollutant load reductions may be minimal.

6.4.3 Response to Revised Requirements For point sources, it is uncertain whether any particular control option would guarantee meeting the revised criteria . For example, the effluent reductions achievable through P2 activities and the level of controls needed 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 addition, the costs of controls are likely facility

- specific and may be higher or lower than shown. Thus, it is uncertain how much system rehabilitation will cost until the source identification study is complete.7

- 1 March 15, 2016



### 7.0 References

Bureau of Labor Statistics (BLS). 2014

. State Occupational Employment and Wage Estimates Oregon

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

.

Bureau of Labor Statistics (BLS). 2015 a. Employment Cost Index Historical Listing. Current

dollar March 2001

– September 2015. Table 11. Employment Cost Index for wages and salaries, for State and local government workers, by occupational group and industry (Not sea sonally adjusted), Management, professional, and related

. Online at http://www.bls.gov/web/eci/echistrynaics.pdf

.

Bureau of Labor Statistics (BLS). 2015 b. 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 2015

, Management, p rofessional and related. Online at http://www.bls.gov/news.release/pdf/ecec.t03.htm

. City of Portland. Undated. Southwest Portland Inflow and Infiltration (I & I) Pilot Projects. Online at: https://www.portlandoregon.gov/bes/61869

Di Toro, D.M., H. Allen, H. Bergman, J. Meyer, P. Paquin, R. Santore. 2001. “A Biotic Ligand Model of the Acute Toxicity of Metals: I. Technical Basis.” Environmental Toxicology and Chemistry , 20(10) : 2383

- 2396.

HydroQual. 2005. The Biotic Ligand Model Windows Interface 2.2.3: User’s Guide and Reference Manual

. Mahwah, NJ : HydroQual, Inc.

Irwin, R.J., M. Van Mouwerik, L. Stevens, M.D. Seese, and W. Basham. 1997a. Environmental Contaminants Encyclopedi a: Cadmium Entry. National Parks Service, Water Resources Division, Fort Collins, CO. July 1. Available: http://www.nature.nps.gov/water/ecencyclopedia/assets/ contaminant

- pdfs/cadmium.pdf . Last accessed 1/22/2016.

Irwin, R.J., M. Van Mouwerik, L. Stevens, M.D. Seese, and W. Basham. 1997b. Environmental Contaminants Encyclopedia: Copper Entry. National Parks Service. Water Resources Division. Fort Collins, CO. Ju ly 1. Available: http://www.nature.nps.gov/water/ecencyclopedia/assets/contaminant

- pdfs/copper.pdf. Last accessed 1/22/2016

. Jennings, S.R., D.R. Neuman, and P.S. Blicker. 2008. Acid Mine Drainage and Effects on Fish Health and Ecology: A Review. Reclamation Research Group Publication, Bozeman, MT.

Oregon Department of Agriculture (ODA) . 2014. A Landowner’s Guide to Oregon’s Agr icultural Water Quality Management Program. Online at http://www.oregon.gov/ODA/shared/Documents/Publications/NaturalResources/WaterQualit yan dAgriculture.pdf

.7

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Oregon Department of Agriculture (ODA) . 2011. Oregon Fertilizer Program Guide. Online at http://www.oregon.gov/ODA/shared/D ocuments/Publications/PesticidesPARC/FertilizerProgram Guide.pdf

. Oregon Department of Agriculture (ODA) . 2009. Pesticide Use Reporting System, 2008 Annual Report. Online at http://www.oregon.gov/ODA/shared/Documents/Publications/PesticidesPARC/Pesticideuserepor tingsystemAnnualreport2008.pdf

. Oregon Department of Environmental Quality (ODEQ ) . 2016a. Laboratory Analytical Storag e and Retrieval (LASAR) Web Application v 1.34. Oregon Department of Environmental Quality. Available: http://deq12.deq.state.or.us/lasar2/ . Last accessed 1/16/2016.

Oregon Department of Environmental Qual ity (ODEQ )

. 2016b. Oregon ’ s 2012 Integrated Report and 303(d) List. Online geodatabase. Available: http://www.deq.state.or.us/wq/assessment/docs/WQ2012IntegratedReport V1.zip

. Last accessed 1/16/2016.

Oregon Department of Environmental Quality (ODEQ )

. 2016c. Oregon ’ s 2010 Integrated Report and 303(d) List. Online geodatabase. Available: http://www.deq.state.or.us/wq/assessment/docs/WQ2010IntegratedReportV3.zip . Last accessed 1/16/2016

. Oregon Department of Environmental Quality (ODEQ )

. 2016d. Oregon TMDLs Approved by EPA

– 1991 through 1999 (Table). http://www.deq.state.or.us/wq/tmdls/approved90s.htm . Last accessed 2/22/2016.

Oregon Department of Environmental Quality (ODEQ )

. 2016e. Oregon TMDLs Approved by EPA

– May 2000 through February 116 [sic] (online Table). http://www.deq.state.or.us/wq/tmdls/approved.htm . Last accessed 2/22/2016.

Oregon Department of Environmental Quality (ODEQ )

. 2016f . Personal communication with Jonat han Gasik regarding ODEQ permit requirements for addressing I&I. January.

Oregon Department of Environmental Quality (ODEQ )

. 2015. TABLE 30: Aquatic Life Water Quality Criteria for Toxic Pollutants; Effective April 18, 2014. Available online at http://arcweb.sos.state.or.us/pages/rules/oars_300/oar_340/_340_tables/340

- 041

- 8033_1

- 7

- 15.pdf

. Oregon Department of Environmental Quality (ODEQ )

. 2 012a. Fact Sheet: Cleanups of Abandoned Mines in Oregon Complicated by High Cost and Lack of Funding. Land Quality Division Environmental Cleanup & Emergency Response Section, Portland, Oregon. September 4. Available: http://www.deq.state.or.us/lq/pubs/factsheets/cu/AbandonedMines.pdf . Last accessed 1/22/2016.

Oregon Department of Environmental Quality (ODEQ )

. 2012 b . General Permit, National Pollutant Discharge Elimination System Waste Discharge Permit (2000J). Proposed July 20,7

- 3 March 15, 2016

2012. Online at http://www.deq.state.or .us/wq/wqpermit/docs/general/npdes2000j/Proposed2000jPermit.pdf

. Oregon Department of Environmental Quality (ODEQ )

. 2012 c . Summary of changes to 1200

- A Permit Requirements. http://www.deq.state.or.us/wq/stormwater/docs/1200ASummaryChanges.pdf

Oregon Department of Environmental Quality (ODEQ )

. 2012d. Internal Management Directive, Reasonable Potential Analysis Process for Toxic Pollutants Version 3.1, Oregon Department of Env ironmental Quality, Updated February 13, 2012.

Oregon Department of Environmental Quality (ODEQ )

. 2011. Methodology for Oregon’s 2010 Water Quality Report a nd List of Water Quality Limited Waters. Online at http://www.deq.state.or.us/wq/assessment/docs/2010AssessmentMethodology.pdf

Oregon Department of Environmental Quality (ODEQ) . 2010. Salary Schedule. Online at http://www.deq.state.or.us/msd/hr/salaryschedule.pdf

. Oregon Department of Environmental Quality (ODEQ )

. 2007. Use Attainability Analysis and Site

- Specific Criteria Internal Management Directive. April.

Oregon Department of Environmental Quality (ODEQ )

. 2004. Guidance Document for Preparation of the NPDES Strom Water Pollution Control Plan. Online at http://www.deq.state.or.us/wq/stormwater/docs/nwr/swpcpguide.p df

. Oregon Department of Forestry (ODF). 20 14

. Oregon Department of Forestry Forest Practice Administrative Rules and Forest Practices Act. Online at http://www.oregon.gov/OD F/Documents/WorkingForests/FPARulebook.pdf

. Oregon Department of Forestry (ODF). 2009. Forest Facts: Herbicide Use and Forestry. Online
at http://www.oregon.gov/ODF/Docume nts/AboutODF/HerbicideUseFactsheet.pdf

. Oregon Department of Forestry (ODF). 2007. Forest Practice Notes: Chemicals and Other Petroleum Products. August. Online at http://www.oregon.gov/ODA/shared/Documents/Publications/PesticidesPARC/ForestPraticeNot esChemicals.pdf

. Oregon Department of Environmental Quality (ODEQ). 2004. Groundwater Quality Report for the Willamette Basin, Oregon. March. Online at www.deq.state.or.us/lab/techrpts/groundwater/WBGroundwater/WBGroundwaterQualityRpt.pdf

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

United States Environmental Protection Agency (U.S. EPA). 2016 a

. Technical Support Document: Recommended Estimates for Missing Water Quality Parameters for Application in EPA’s Freshwater Copper Biotic Liga nd Model . EPA 820

- R

- 15

- 106. Washington, D.C.: EPA Office of Water.7

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United States Environmental Protection Agency (U.S. EPA). 2016 b . ICIS

- NPDES.

United States Environmental Protection Agency (U.S. EPA). 2008. Superfund Fact Sheet: Formosa Mine Superfund Sit e, Douglas County Oregon. U.S. Environmental Protection Agency, Seattle, WA. August. Available: http://www3.epa.gov/region10/pdf/sites/formosamine/Formosa_Mine_FS _Aug_2008.pdf

. United States Environmental Protection Agency (U.S. EPA). 2007. Aquatic Life Ambient Freshwater Quality Criteria

– Copper 2007 Revision . EPA

- 822

- R

- 07

- 001. Washington, D.C.: EPA Office of Water.

United States Environmental Protection Agency (U.S. EPA). 2001. 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). 1995. Interim Economic Guidance for Water Quality Standards Workbook. EPA 823

- B

- 95

- 002. March.

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). 1986. Quality Criteri a for Water 1986 . EPA 440/5

- 86

- 001. Washington, D.C.: EPA Office of Water. Online at http://nptwaterresources.org/wp

- content/uploads/2014/01/1986

- goldbook.pdf

. Wuana, R.A. and F.E. Okieimen. 2011. Heavy Metals in Contaminated Soils: A Review of Sources, Chemistry, Risks and Best Available Strategies for Remediation. International Scholarly Research Network Ecolog y. Volume 2011:402647. pp. 1

– 20 Available: http://www.hindawi.com/journals/isrn/2011/402647/ . Last accessed 1/22/2016.A

- 1 March 15, 2016 

## A. Appendix A

– Facility Analyses

A.1 City of Astoria Wastewater Treatment Plant

A.1.1 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, but the canneries are no longer in service. ODEQ classifies this 4.2 mgd (ADWDF) f acility as a major discharger

. The facility discharges treated effluent i nto the Colu mbia 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 requested that the facility conduct an industrial waste survey that determined there are no industrial sources.

A.1.2 Treatment Process

The trea tment process consists of a 3

- cell facultative lagoon with 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 milli on 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 biosolids have not been removed from the lagoons in several years.

A.1.3 Reasonable Potential Analysis

Exhibit A

- 1 summarizes the RPA results for cadmium and copper under the baseline criteria. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. The discharge has RP to exceed the baseline water quality criteria for copp er.

Exhibit A

- 1. RPA under Baseline Criteria for City of Astoria WWTP

Parameter Highest

Effluent Conc. (μg/L) Ambient

Conc. 1 (μg/L) Conc. at Edge

of Mixing Zone 2 (μg/L) Water Quality

Criterion (μg/L) Reasonable

Potential AM L

(ug/L) MD L

(ug/ L) ZID RMZ acute chronic Copper 69 0 7.83 1.91 5.2 3.7 Yes 22.7 45.5

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.

Exhibit A

- 2 summarizes the RPA results for cadmium and copper under the revised BLM criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium . Values from the discharger’s mixing zone study were used in the analysis while hardness values were obtained from sampli ng data.A

- 2 March 15, 2016 Exhibit A

- 2. RPA under Revised Criteria for City of Astoria WWTP

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge of

Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute chronic Cadmium 0.44 0 0.05 NA 0.5 NA No NA NA Copper 69 0 7.83 1.91 2.1 1.3 Yes 9.35 18.76

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.

As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 9.35 μg/L and the MD L is 18 .76 μg/L.

A.1.4 Summary

Exhibits A

- 3 and A

- 4 provide a summary of the potential range in annual costs associated with the baseline and revised BLM criteria for copper. The facility’s current monthly average effluent concentration is 22.95 μg/L. Under the baseline criteria, the facility is required to meet an average of 22.7 μg/L, which represents a reduction of around 1% in its effluent copper concentration . The facility may be able to meet its baseline criteria without incurring any major
costs , and at most the cost of a limited P2 program. For the revised criteria , the incremental costs represent the costs above and beyond those needed to meet baseline criteria. In addition to the annual costs listed in Exhibit s A

- 3 and A

- 4 , the discharger would also incur one

- time expenditures of approximately :

 $ 45,000 to $120,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application.

Exhibit A

- 3. Summary of Potential Costs (3% discount rate)
, C ity of Astoria WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  None, or P2 program  $ 0

- $ 10

, 0 00 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 10, 0 00

 $ 0.92 million  $0

 $ 0

- $10 ,0 00

 $ 0.92 million NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed 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 to meet baseline crit eria).A

- 3 March 15, 2016

Exhibit A

- 4

. Summary of Potential Costs (7% discount rate)
, City of Astoria WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  None, or P2 program  $0

- $ 10 ,400 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 10,400

 $ 1.14 million  $0

 $ 0

- $10,400

 $ 1.14 million NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O& M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total ann ual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

A.2 Kellogg Creek Wastewater Treatment Plant

A.2.1 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.

A.2.2 Treatment Process

The treatment process consist of the headworks, influent pump station, bar screens with mechanical rakes and grit removal, primary clarification, four 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.

A.2.3 Reasonable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 5 summarizes the RPA results under the revised BLM criteria for cadmium and for copper

. EPA evaluated acute and chronic criteria fo r copper, as well as the acute criterion for cadmium . Values from the discharger’s mixing zone study were used in the analysis. Hardness values were obtained from the current NPDES permit.A

- 4 March 15, 2016 Exhibit A

- 5

. RPA under Revised Criteria for Kellogg Creek WWTP

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge

of Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute chronic Cadmium 0.24 0.05 0.09 NA 0.7 NA No NA NA Copper 4.52 1.3 2.05 1.46 2.1 1.3 Yes 1.06 2.15

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.
As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 1

. 06 μg/L and the MD L is 2

. 15 μg/L.

A.2.4 Summary

Exhibits A

- 6 and A

- 7 provide a summary of the potentia l range in annual costs associated with the baseline and revised BLM criteria. There are no baseline costs associated with this facility because the facility does not have RP to exceed the current water quality criteria for either copper or cadmium. For th e revised criteria, the incremental costs are the same as the total annual costs under the revised BLM criteria because the cost to meet baseline criteria is zero . In addition to the annual costs listed in Exhibit s A

- 6 and A

- 7 , the discharger would also in cur one

time expenditures of approximately :

 $45,000 to $230,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.
Exhibit A

- 6 . Summary of Potential Costs (3% discount rate) , Kellogg Creek WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16, 0 00

 $ 1. 47 million  $0

 $ 16, 0 00

 $ 1. 47 million NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baselin e criteria represent the costs needed 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 to meet baseline criteria).A

- 5 March 15, 2016

Exhibit A

- 7 . Summary of Potential Costs (7% discount rate) , Kellogg Creek WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16,800

 $ 1.83 million  $0

 $ 16,800

 $ 1.83 million NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O& M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total ann ual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

A.3 City of McMinnville Water Reclamation Facility

A.3.1 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

. The facility also has 1 4 emergency o verflow outfalls authorized in the NPDES permit.

A.3.2 Treatment Process

The treatment process consists of an off

- site raw influent pump station and screen, headworks, activated sludge oxidation ditches, secondary clarifiers, tertiary clarifiers, single media f ilters, UV disinfection, and effluent reaeration. Biosolids are 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 provides the stored liquid biosolids to local farms for land application during the summer.

A.3.3 Reasonable Potential Analysis

Exhibit A

- 8 summarizes the RPA results for cadmium and copper under the baseline criteria. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. The discharge has RP to exceed the baseline water quality criteria for copper.A

- 6 March 15, 2016 Exhibit A

- 8

. RPA under Baseline Criteria for City of McMinnville WRF

Parameter Highest

Effluent Conc. (μg/L) Ambient

Conc. 1 (μg/L) Conc. at Edge

of Mixing Zone 2 (μg/L) Water Quality

Criterion (μg/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute chronic Copper 10.71 4.0 7.36 6.24 9.2 5.6 Yes 7.55 13.3

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.

Exhibit A

- 9 summarizes the RPA results for cadmium and for copper under the revised BLM criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium . Values from the discharger’s mixing zone study were used in the analysis. Hardness values were obtained from the current NPDES permit.

Exhibit A

- 9 . RPA under Revised Criteria for City of McMinnville WRF

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge

of Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute chronic Cadmium 0.25 0.5 0.38 NA 1.0 NA No NA NA Copper 10.71 4.0 7.36 6.24 2.1 1.3 Yes 1.12 1.97

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.
As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 1

. 12 μg/L and the MD L is 1

. 97 μg/L.

A.3.4 Summary

Exhibit s A

- 10 and A

- 11 provide a summary of the potential range in annual costs associated with the baseline and revised criteria for copper. The Control Scenario for the baseline criteria may include a combination of process optimization and upgrade to the facility , but the cos ts of optimization for this scenario cannot be estimated without a detailed facility analysis . Ion exchange is one available technology that will meet the baseline criteria for copper, but there may be more cost

- effective alternatives that cannot be evalua ted without a better knowledge of the facility. For the revised BLM criteria, the incremental costs represent costs above and beyond those needed to meet baseline criteria

. In addition to the annual costs listed in Exhibit s A

- 10 and A

- 11 , the discharger w ould also incur one

- time expenditures of approximately :

 $45,000 to $230,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.A

- 7 March 15, 2016

Exhibit A

- 10 . Summary of Potential Costs (3% discount rate)
, City of McMinnville WRF

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16, 0 00

 $1. 1 million NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16, 0 00

 $ 1. 1 million  $0

 $ 0

 $ 0 NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O& M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total ann ual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

Exhibit A

- 11 . Summary of Potential Costs (7% discount rate)
, City of McMinnville WRF

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $16,800

 $1.37 million NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16,800

 $ 1.37 million  $0

 $ 0

 $ 0 NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet basel ine criteria).

A.4 City of Salem Willow Lake Water Pollution Control Facility

A.4.1 Facility Description

The City of Salem Willow Lake Water Pollution Control Facility (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 nort h 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 discharge s effluent through a 72

- inch outfall to the Willamette River at river mile 78.4.A

- 8 March 15, 2016

A.4.2 Treatme nt Processes

The 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 co ntact 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 d ewatered biosolids, a t 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.

A.4.3 Reasonable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 12 summarizes the RPA results for cadmium and for copper under the revised baseline criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium . Values from the discharger’s mixing zone study were used in the analysis. Hardness values were obtained from monitoring data.

Exhibit A

- 12 . RPA under Revised Criteria for City of Salem Willow Lake WPCF

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge

of Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute chronic Cadmium 0.05 5 0.38 NA 0.5 NA No NA NA Copper 49 1.1 5.5 3.21 2.1 1.3 Yes 4.68 10.66 1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.

As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 4

. 68 μg/L and t he MD L is 10

. 66 μg/L.

A.4.4 Summary

Exhibit s A

- 1 3 and A

- 14 provide a summary of the potential range in annual costs associated with the baseline and revised criteria for copper. There are no baseline costs associated with this facility because the facility does not have RP to exceed the current water quality criteria for either copper or cadmium. For the revised criteria, the incremental costs are the same as the total annual costs under the revised BLM criteria because the cost to meet baseline criteria is zero

. In addition to the annual costs listed in Exhibit s A

- 1 3 and A

- 14 , the discharger would also incur

one

- time expenditures of approximately :A

- 9 March 15, 2016  $45,000 to $345,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.
Exhibit A

- 1 3 . Summary of Potential Costs (3% discount rate)
, City of Salem Willow Lake W PCF

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 22,000

 $ 9.19 million  $0

 $ 22,000

 $ 9.19 million NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O &M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total an nual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

Exhibit A

- 1 4 . Summary of Potential Costs (7% discount rate)
, City of Salem Willow Lake W PCF

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 23,200

 $ 11.44 million  $0

 $ 23,200

 $ 11.44 million NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represen t the costs needed 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 to meet baseline criteria).

A.5 Tri

- City Service District

A.5.1 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 d ischarger, 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.

A.5.2 Treatment Process

The treatment sys tem consists of an activated sludge secondary treatment plant and a newer parallel membrane bio

- reactor (MBR) system . The two treatment systems function independently and effluent from the treatment trains are commingled prior to discharge into the receivi ng water. The activated sludge treatment system consists of an influent pump station,A

- 10 March 15, 2016

headworks, primary clarification, four 639,000 gallon aeration basins with an anoxic zone at the front of each basin, secondary clarification, and c hlorine disinfection ; sludge is a naerobic ally digest ed.

The MBR system includes a fine screenings building, aeration basins, blower building, membrane filtration building, and ultraviolet (UV) disinfection.

A.5.3 Reasonable Potential Analysis

Exhibit A

- 1 5 summarizes the RPA results for cadmium and copper under the baseline criteria. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. The discharge has RP to exceed the baseline water quality criteria for copper.

Exhibit A

- 1 5

. RPA under Bas eline Criteria for Tri

- City Service District

Parameter Highest

Effluent Conc. (μg/L) Ambient

Conc. 1 (μg/L) Conc. at Edge of

Mixing Zone 2 (μg/L) Water Quality

Criterion (μg/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute C hronic Copper 53 1.3 27.95 6.40 8.8 4.1 Yes 6.25 17.9

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.

Exhibit A

- 1 6 summarizes the RPA results for cadmium and for copper

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. EPA used values from the discharger’s mixing zone study in the analysis, and hardness values from the NPDES permit

.

Exhibit A

- 1 6 . RPA under Revised Criteria for Tri

- City Service District

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge of

Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute chronic Cadmium 0.17 0.05 0.13 NA 0.9 NA No NA NA Copper 53 1.3 27.95 6.40 2.1 1.3 Yes 0.84 2.39

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.
As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AML is 0.84 μg/L and the MD L is 2.39 μg/L.

A.5.4 Summary

Exhibit s A

- 1 7 and A

- 18 provide a summary of the potential range in annual costs associated with the baseline and revised criteria for copper. The Control Scenario for the baseline criteria may include a combination of process optimization and upgrade to the facility , but th e costs of optimization for this scenario cannot be estimated without a detailed facility analysis . Ion exchange is one available technology that will meet the baseline criteria for copper, but there may be more cost

- effective alternatives that cannot be e valuated without a better knowledge ofA

- 11 March 15, 2016

the facility. For the revised BLM criteria, the incremental costs represent costs above and beyond those needed to meet baseline criteria

. In addition to the annual costs listed in Exhibit s A

- 1 7 and A

- 18 , the dischar ger would also incur one

- time expenditures of approximately :

 $45,000 to $230,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.
Exhibit A

- 1 7 . Summary of Potential Costs (3% discount rate) , Tri

- City Serv ice District

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $16, 0 00

 $ 3.31 million NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16, 0 00

 $ 3.31 million  $0

 $ 0

 $ 0 NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O& M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total ann ual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

Exhibit A

- 1 8 . Summary of Potential Costs (7% discount rate) , Tri

- City Service District

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $16,800

 $4.12 million NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16,800

 $ 4.12 million  $0

 $ 0

 $ 0 NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

A.6 Woodburn Wastewater Treatment Plant

A.6.1 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

.A

- 12 March 15, 2016

Treated wastewater flows through Outfalls 001A and 001B into the Pudd ing River at river mile 21.4. Reclaimed w astewater at Outfall 002 is distributed on land for dissipation by evapotranspiration and controlled seepage. There are th r ee other outflows used for emergency overflow s

.

A.6.2 Treatment Processes

The 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.

A.6.3 Reasonable Potential Analysis

This facility h as no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 1 9 summarizes the RPA results for cadmium and for copper under the revised BLM criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. EPA used values from the discharger’s mixing zone study in the analysis, and hardness values from the NPDES permit

.

Exhibit A

- 1 9 . RPA under Revised Criteria for Woodburn WWTP

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge of Mixing Zone 2 ( μ g/L) Water Quality Criteri on ( μ g/L) Reasonable Potential ZID RMZ acute chronic Cadmium ND 0 ND NA 1.7 NA No Copper 0.4 0 0.5 0.4 2.1 1.3 No 1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit. As shown in the exhibit, the discharger does not have RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is less than the applicable criterion.

A.6.4 Summary

Since this facility does not have RP to exceed either the baseline or the revised BLM criteria, EPA estimated the cost to this facility as zero under both scenarios.

A.7 Blue Heron Paper Company, Oregon City

A.7.1 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 OR00 00566 ) . 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 fromA

- 13 March 15, 2016

the process, steam plant, and bleach plant, along with any stormwater runoff is treated and discharged th rough 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 facili ty total 9.7 mgd.

A.7.2 Treatment Processes

The 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.

A.7.3 Reasonable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 20 summarizes the RPA results for cadmium and for copper under the revised BLM criteria

. Both acute and chronic criteria for c opper were evaluated as was the acute criterion for cadmium. Values from the discharger’s mixing zone study were used in the analysis. Hardness values were obtained from monitoring data.

Exhibit A

- 20 . RPA under Revised Criteria for Blue Heron Paper Compan y

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at

Edge of Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L)

ZID RMZ acute chronic Cadmium 1.0 0.01 0.06 NA 0.57 NA No NA NA Copper 5.7 1.3 1.5 1.4 2.09 1.3 Yes 1.16 1.79 1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit. As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 1.16 μg/L and the MD L is 1

. 79 μg/L.

A.7.4 Summary

While the Blue Heron Paper Company ’s facility has RP to exceed the revised BLM criteria, the Blue Heron Paper Company filed for bankruptcy in 2011 (Mayes, 2011), and was purchased by a developer in 2014 (Mayes, 2014). The currently proposed master plan for the 23

- acre site does not appear to include a wastewater treatment facility, and the clarifier may be potentially removed (Bamesberger, 2014). Therefore, EPA estimated as zero the cost to meet both baseline and revised BLM criteria for this facility.A

- 14 March 15, 2016

A.8 City of Corvallis Wastewater Treatment Plant

A.8.1 Fa cility Description

The City of Corvallis Wastewater Treatment Plant (NPDES permit number OR0026 361 ) treats domestic, commercial, and industrial wastewater from the Corvallis area. The NPDES permit covers discharges from the treatment plant as well as combined sewer overflows from the collection system. ODEQ classifies this 9.7 mgd (ADWDF) facility as a major discharger

. The facility discharge s effluent to the Willamette River at ri ver mile 130.8

.

A.8.2 Treatment Process

The NPDES permit for the facility lists current treatment processes as primary screening and grit removal, primary settling, trickling filters with activated sludge secondary treatment, and secondary clarification. The eff luent is disinfected with chlorine and is dechlorinated prior to discharge. The facility thickens biosolids in gravity thickeners and then pumps the biosolids to anaerobic digesters. The stabilized biosolids are stored in two facultative lagoons prior to

s preading on application sites.

A.8.3 Reasonable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 21 summarizes the RPA results for cadmium and for copper under th e revised BLM criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. EPA used values from the discharger’s mixing zone study in the analysis, and hardness values from the NPDES permit

.

Ex hibit A

- 21 . RPA under Revised Criteria for City of Corvallis WWTP

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge of Mixing Zone 2 ( μ g/L) Water Quality Criteri on ( μ g/L) Reasonable Potential ZID RMZ acute chronic Cadmium 0 .021 0 NA NA 0.5 NA No Copper 30.8 0 2.05 0.79 2.1 1.3 No 1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.

As shown in the exhibit, the discharger does not have RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is less than the applicable criterion.

A.8.4 Summary

Since this facility does not have RP to exceed eith er the baseline or the revised BLM criteria, EPA estimated the cost to this facility as zero under both scenarios.A

- 15 March 15, 2016

A.9 City of Wilsonville Wastewater Treatment Plant

A.9.1 Facility Description

The City of Wilsonville Wastewater Treatment Plant (NPDES permit number OR0022764) treats domestic, commercial, and industrial wastewater. The service population is approximately 17,000. ODEQ classifies this 2.25 mgd (ADWDF) facility as a major discharger. The facility discharges effluent to the Willamette River at river mile 38.6.

A.9.2 Treatment Processes

The NPDES permit for the facility describes the treatment process as an activated sludge system utilizing a plug flow configuration. During dry weather months, sand filters are used to achieve better than secondary treatment leve ls. An odor control tower and a biofilter have been added to mitigate plant odors. A facility expansion was to be completed in 2014. Waste activated sludge is thickened and then digested in two anaerobic digesters. Digested biosolids can either be land
app lied or dewatered with centrifuges for transport to land application sites located further away.

A.9.3 Reasonable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 22 summarizes the RPA results for cadmium and for copper under the revised BLM criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. EPA used values from the discharger’s mixing zone study in the analy sis, and hardness values from the NPDES permit

.

Exhibit A

- 22 . RPA under Revised Criteria for City of Wilsonville WWTP

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at

Edge of Mixing Zone 2 ( μ g/L) Water Quality

Criteri o n ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L)

ZID RMZ acute C hronic Cadmium 0.13 0.06 0.14 NA 0.7 NA No NA NA Copper 10.2 2.1 8.9 2.98 2.1 1.3 Yes 1.04 2.09

1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit. As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 1

. 04 μg/L and the MD L is 2

. 09 μg/L.

A.9.4 Summary

Exhibit s A

- 23 and A

- 24 provide a summary of the potential range in annual costs associated with the baseline and revised BLM criteria for copper. There are no baseline costs associated with this facility because the facility does not have RP to exceed the current water quality criteria for either copper or cadmium. For the revised criteria, the incremental costs are the sam e as the total annual costs under the revised BLM criteria because the cost of to meet baseline criteria is zero

.A

- 16 March 15, 2016

In addition to the annual costs listed in Exhibit s A

- 23 and A

- 24 , the discharger would also incur

one

- time expenditures of approximately :

 $45, 000 to $120,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.
Exhibit A

- 23 . Summary of Potential Costs (3% discount rate)
, City of Wilsonville WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 10, 0 00

 $ 0. 55 million  $0

 $ 10, 0 00

 $ 0. 55 million NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed 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 to meet baseline criteria).

Exhibit A

- 24 . Summary of Potential Costs (7% discount rate)
, City of Wilsonville WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 10, 4 00

 $ 0. 69 million  $0

 $ 10, 4 00

 $ 0. 69 million NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O& M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total ann ual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

A.10 West Linn Paper Company, West Linn

A.10.1 Facility Description

The West Linn Paper Company owns a paper mill located on an island in the Willamette River with the Willamette Locks on the western side and the Willamette River on the eastern side of the mill (NPDES permit number OR0000 787 ) . The mill uses purchased dry pulp from outside sources and has three paper machines with an average production rate of 807 tons per day. ODEQ classifies the facility as a major discharger. Wastewater from the facility is discharged through one outfall. The outfall consists of a 2.5 foot di ameter pipe extending approximately 550 feet from the western bank of the Willamette River at river mile 27.4

.A

- 17 March 15, 2016

A.10.2 Treatment Processes

Production processes at the mill generate large volumes of wastewater. The NPDES permit for the facility indicates that storm water and a portion of process wastewater (what is not reused) is routed through a primary clarifier. Prior to entering the primary clarifier, the wastewater is dosed with chlorine dioxide for pH control and as an aid in flocculation. Effluent from the pri mary clarifier is sent to a 26 acre aerated stabilization basin before being discharged to the Willamette River.

A.10.3 Reasonable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline sce nario. Exhibit A

- 25 summarizes the RPA results for cadmium and for copper under the revised BLM criteria . Both acute and chronic criteri a for copper were evaluated as was the acute criterion for cadmium. EPA used values from the discharger’s mixing zone st udy in the analysis, and hardness values from the NPDES permit

.

Exhibit A

- 25 . RPA under Revised Criteria for West Linn Paper Company

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at

Edge of Mixing Zone 2 ( μ g/L) Water Q uality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L)

ZID RMZ acute C hronic Cadmium No data NA NA NA 1.34 NA No NA NA Copper 20 0 6.0 0.45 2.09 1.3 Yes 5.2 10.4 1. Zero if data are not available or if all values are non

- detect. 2. Dilution based on facility’s existing permit.

As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 5.2 μg/L and the MD L is 10

. 4 μg/L.

A.10.4 Summary

Exhibit s A

- 2 6 and A

- 27 provides a summary of the potential range in annual costs associated with the baseline and revised BLM criteria for copper. There are no baseline costs associated with this facility because the facility does not have RP to exceed the current water quality criteria for either copper or cadmium. For the revised criteria, the incremental costs are the same as the
tota l annual costs under the revised BLM criteria because the cost of to meet baseline criteria is

zero . In addition to the annual costs listed in Exhibit s A

- 2 6 and A

- 27 , the discharger would also incur one

- time expenditures of approximately :

 $45,000 to $120,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.A

- 18 March 15, 2016

Exhibit A

- 2 6 . Summary of Potential Costs (3% discount rate)
, West Linn Paper Company

Criteria Control Scenario Total Annual Costs ($/yr) 1 Increme ntal Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 10, 0 00

 $ 0.92 million  $0

 $ 10,4 0 0

 $ 0.92 million NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing con ditions; costs for revised criteria represent the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

Exhibit A

- 2 7 . Summary of Potential Costs (7% discount rate) , West Linn Paper Company

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 10,400

 $ 1.14 million  $0

 $ $10,400

 $ 1.14 million NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet bas eline criteria).

A.11 R.U.S.A. Roseburg Wastewater Treatment Plant

A.11.1 Facility Description

The Roseburg Urban Sanitary Authority (RUSA) owns and operates the Roseburg Wastewater Treatment Plant (NPDES permit number OR00 31356 ) treats domestic, commercial, and industrial wastewater. ODEQ classifies this 7.9 mgd (ADWDF) facility as a major discharger

. The facility discharge s effluent through a 36 inch open pipe outfall to the South Umpqua River at river mile 7 .65

.

A.11.2 Treatment Processes

The NPDES permit for the facility lists current treatment processes as follows: Influent flow passes through a manhole across from the WWTP. If flows are excessive, a portion will flow over a weir and discharge directly to the South Umpqua River bypassing the treatment plant. The headworks consists of two mechanical bar screens followed by grit removal. There are two primary clarifiers flowed by a biofilter. During the winter months, effluent from the biofilter is sent to the solids contact “selector” channel. During the summer mon ths effluent is sent to the aeration basins. The facility has three aeration basins. In the winter, up to two basins are used forA

- 19 March 15, 2016

biosolids storage with one in reserve for activated sludge treatment if necessary. In the summer, all basins are available for activated sludge treatment. Two secondary clarifiers are utilized and hypochlorite is added to the wastewater in the secondary clarifier. The effluent is not currently dechlorinated. Waste activated sludge is thickened on two gravity belt thickeners. The thickened sludge is anaerobically digested and land applied.

A.11.3 Reasonable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 2 8 summarizes the RPA results for cadmium and for copper under the revised BLM criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. EPA used values from the discharger’s mixing zone study in the analysis, and hardness values from the NP DES permit

.

Exhibit A

- 2 8 . RPA under Revised Criteria for RUSA Roseburg WWTP

Parameter Highest

Effluent Conc. ( μ g/L) Ambient Conc

. 1 ( μ g/L) Conc

. at

Edge of Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L)

ZID RMZ acute C hronic Cadmium 0.1 0 0.10 NA 1.0 NA No NA NA Copper 10.8 0 7.22 3.86 2.1 1.3 Yes 2.88 4.07 1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.

As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 2

. 88 μg/L and t he MD L is 4

. 07 μg/L.

A.11.4 Summary

Exhibit s A

- 2 9 and A

- 30 provide a summary of the potential range in annual costs associated with the baseline and revised BLM criteria. There are no baseline costs associated with this facility because the facility does not have RP to exceed the current water quality criteria for either

c opper or cadmium. For the revised criteria, the incremental costs are the same as the total annual costs under the revised BLM criteria because the cost of to meet baseline criteria is zero

. In addition to the annual costs listed in Exhibit s A

- 2 9 and A

- 30

, the discharger would also incur

one

- time expenditures of approximately :

 $45,000 to $230,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.A

- 20 March 15, 2016

Exhibit A

- 29 . Summary of Potential Costs (3% discount rate)
, RUSA Roseburg WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16, 0 00

 $ 1.47 million  $0

 $ 16, 0 00

 $ 1. 47 million NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet base line criteria).

Exhibit A

- 30 . Summary of Potential Costs (7% discount rate)
, RUSA Roseburg WWTP

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16,800

 $ 1.83 million  $0

 $ 16,800

 $ 1.83 million NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O &M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total an nual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

A.12 Halsey Mill and Cascade Pacific Pulp, Halsey

A.12.1 Facility Descriptions

The Georgia

- Pacific Halsey Mill (OR0033405) and Cascade Pacific Pulp (OR001074) are two pulp and paper mills that combine their effluent and discharge through a shared outfall to the Willamette River.

The Cascade Pacific Pulp, Halsey M ill (Cascade Pacific) is an integrated Kraft pulp mill that produces bleached and unbleached pulp for sale. The facility consists of a pulp mill, chlorine dioxide generator, power and recovery, recausticizing process, and water and wastewater
treatment.

The Georgia

- Pacific Halsey Mill (Halsey) consists of a paper mill, a converting operation, and a secondary fiber recycling plant. The mill is segregated into process buildings which include the paper mill, converting area, maintenance area, secondary fiber, and wastewater treatment

.A

- 21 March 15, 2016

ODEQ classifies both facilities as major dischargers. The commingled wastewater from the two facilities is discharged through one outfall. The outfall was moved recently to a deeper location in the Willamette River at river mile 147.4. The outfall consis ts of a 100 foot multiport diffuser.

A.12.2 Treatment Processes

Production processes at the mills generate large volumes of wastewater. The NPDES permit for the Cascade Pacific mill describes the wastewater flows generated at the mill and the process flows throu gh various forms of treatment. Alkaline process wastewater is combined with treated domestic wastewater and stormwater and is pumped to the primary clarifier. Effluent from the primary clarifier is combined with the acid sewer and flows into the east pond. Condensates from the digesters, evaporator, and non

- condensable gas are hard piped to the inlet line just prior to entering the east pond. Two aerated ponds, east and west, are operated in series. Treated water enters a secondary settling pond and is then commingled and discharged. Domestic wastewater is treated with a package plant activated sludge system and is disinfected and sent to the main sump and through the primary clarifier.

The Halsey M ill’s wastewater treatment system consists of two dissolved air flotation clarifiers, an aeration tank, a secondary clarifier, and sludge dewatering equipment.

A.12.3 Reasonable Potential Analysis

These two facilities have no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenar io. Exhibits A

- 31 and A

- 32 summarize the RPA results for cadmium and for copper under the revised BLM criteria

. EPA evaluated acute and chronic criteria for copper, as well as the acute criterion for cadmium

. EPA used values from the discharger’s mixing zone study in the analysis, and hardness values from the NPDES permit

.

Exhibit A

- 31 . RPA under Revised Criteria for Cascade Pacific Pulp

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge of Mixing Zone 2 ( μ g/L) Wat er Quality Criteri on ( μ g/L) Reasonable Potential ZID RMZ A cute chronic Cadmium 0 .107 0 0 .006 0 .003 0.92 NA No Copper 4.36 0 0.24 0.13 2.09 1.3 No

1. Zero if data are not available or if all values are non

- detect. 2. Dilution based on facility’s existing permit.

Exhibit A

- 32 . RPA under Revised Criteria for Georgia

- Pacific Halsey Mill

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge of Mixing Zone 2 ( μ g/L) Water Quality Criteri on ( μ g/L) Reasonable Potential ZID RMZ A cute chronic Cadmium No data NA NA NA 0.92 NA No Copper 20 0 0.46 0.26 2.09 1.3 No 1. Zero if data are not available or if all values are non

- detect. 2. Dilution based on facility’s existing permit.A

- 22 March 15, 2016

As shown in the exhibit s , the discharger s do not have RP to exceed the water quality criteria for cadmium or copper since the concentration at the edge of the mixing zone is less than the applicable criterion.

A.12.4 Summary

Since neither of these facilities have RP to exceed either the baseline or the revised BLM criteria, EPA estimated the cost to these two facilities as zero under both scenarios.

A.13 City of Medford Regional Water Reclamation Facility

A.13.1 Facility Description

The City of Medford owns and operates the Medford Regional Water Rec lamation Facility (NPDES permit number OR00 26263 ) which treats wastewater from the city of Medford, Central Point, Jacksonville, Talent, Phoenix, Eagle Point, the White City Sanitary District, and some unincorporated areas of Jackson County

. ODEQ classifie s this 20 mgd (ADWDF) facility as a major discharger

. The facility discharge s effluent through a 54 inch pipe outfall to the Rogue River at river mile 130.5

.

A.13.2 Treatment Process

The NPDES permit for the facility lists the major treatment process at the facility as trickling filter/activated sludge. Influent to the WWTP enters the headworks and flows through grit removal, primary treatment, trickling filter/activated sludge, secondary treatment consisting of
two ac tivated sludge aeration basins, secondary clarification, chlorine disinfection and dechlorination prior to discharge. Waste activated sludge is thickened on a gravity belt thickener. The thickened sludge is anaerobically digested, stored, and dried.

A.13.3 Reaso nable Potential Analysis

This facility has no RP to exceed the baseline criteria; therefore, no costs are associated with the baseline scenario. Exhibit A

- 33 summarizes the RPA results for cadmium and for copper under the revised BLM criteria

. EPA evaluate d acute and chronic criteria for copper , as well as the acute criterion for cadmium. EPA used values from the discharger’s mixing zone study in the analysis, and hardness values from the NPDES permit

.

Exhibit A

- 33 . RPA under Revised Criteria for City of M edford RWRF

Parameter Highest

Effluent Conc. ( μ g/L) Ambient

Conc

. 1 ( μ g/L) Conc

. at Edge

of Mixing Zone 2 ( μ g/L) Water Quality

Criteri on ( μ g/L) Reasonable

Potential AM L

(ug/L) MD L (ug/L) ZID RMZ acute chronic Cadmium 0.2 0 0.14 NA 0.5 NA No NA NA Copper 3.3 0 2.2 0.33 2.1 1.3 Yes 2.59 4.39 1. Zero if data are not available or if all values are nondetect. 2. Dilution based on facility’s existing permit.A

- 23 March 15, 2016

As shown in the exhibit, the discharger has RP to exceed the water quality criteria for copper since the concentration at the edge of the mixing zone is greater than the applicable criterion. Under existin g procedures, the applicable AM L is 2

. 59 μg/L and the MD L is 4

. 39 μg/L.

A.13.4 Summary

Exhibit s A

- 34 and A

- 35 provide a summary of the potential range in annual costs associated with the baseline and revised BLM criteria for copper. There are no baseline costs associated with this facility because the facility does not have RP to exceed the current water quality criteria for either copper or cadmium. For the revised criteria, the incremental costs are the same as the total annual costs under the revised BLM criteria because the cost of to meet baseline criteria is zero

. In addition to the annual costs listed in Exhibit s A

- 34 and A

- 35 , the discharger would also incur

one

- time expenditures of approximately :

 $45,000 to $230,000 for a variance application ; or

 $42,000 for a site specific criteria or dilution credit application

.
Exhibit A

- 34 . Summary of Potential Costs (3% di scount rate)
, City of Medford RWRF

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16, 0 00

 $ 3.68 million  $0

 $ 16, 0 00

 $ 3.68 million NA = Not applicable 1. Annual costs represent capital costs annualized at 3 % over 20 years plus O& M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under existing conditions; costs for revised criteria represe nt the difference between total ann ual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).

Exhibit A

- 35 . Summary of Potential Costs (7% discount rate)
, City of Medford RWRF

Criteria Control Scenario Total Annual Costs ($/yr) 1 Incremental Costs 2

Baseline  Facility currently meets baseline criteria  $0 NA

BLM  Site

- specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)  $0

 $ 16,800

 $ 4.58 million  $0

 $ 16,800

 $ 4.58 million NA = Not applicable 1. Annual costs represent capital costs annualized at 7% over 20 years plus O&M costs, and do not include one

- time costs associated with alternative compliance mechanisms. 2 . Annual costs for baseline criteria represent the costs needed under e xisting conditions; costs for revised criteria represent the difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline criteria).A

- 24 March 15, 2016

A.14 References

Oregon Department of Environmental Quality. Internal Management Directive, Reasonable Potential Analysis Process for Toxic Pollutants Version 3.1, Oregon Department of Environmental Quality, Updated February 13, 2012

. Oregon Department of Environmental Quality, RPAspreadsheetInd

– excel spreadsheet

Oregon Department of Environmental Quality, RPAdomR36(1)

– excel spreadsheet

Oregon Department of Environmental Quality. City of Astoria Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0027561 . Permit Application Date: Se ptember 20, 2006.

Oregon Department of Environmental Quality. Blue Heron District Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0000566 . Permit Application Date: January 31, 2006.

Oregon Department of Environmental Qu ality. Cascade Pulp Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR001074. Permit Application Date: December 22, 2014.

Oregon Department of Environmental Quality. City of Corvallis Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0026 361. Permit Application Date: December 31, 2003.

Oregon Department of Environmental Quality. Halsey Mill Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0033405. Per mit Application Date: December 10, 2001.

Oregon Department of Environme ntal Quality. Kellogg Creek WWTP Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0026221 . Permit Application Date: July 1, 1997.

Oregon Department o f Environmental Quality. City of McMinnville Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0034002 . Permit Application Date: December 31, 1997.

Oregon Department of Environmental Quality. City of Medford Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR00 26263. Permit Application Date: November 29, 1996.

Oregon Department of Environmental Quality. RUSA Roseburg Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0031356. Permit Application Date: July 9, 1997

.A

- 25 March 15, 2016

Oregon Department of Environmental Quality. City of Salem Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0026409 . Permit Application Date: August 25 , 1993.

Oregon Department of Environmental Quality. Tri

- City Service District Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0031259 . Permit Application Date: January 29, 1998.

Oregon Department of Environmental Qualit y. West Linn Paper Company Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0000 787. Permit Application Date: August 24, 2010.

Oregon Department of Environmental Quality. City of Wilsonville Fact Sheet and NPDES Wastewate r Discharge Permit Evaluation. NPDES permit number OR0022764 . Permit Application Date: June 28, 2010.

Oregon Department of Environmental Quality. Woodburn Fact Sheet and NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0020001 . Permit A pplication Date: September 6, 2002

.B

- 1 March 15, 2016



## B. Appendix B

- Pollution Prevention Programs and Costs

Pollution prevention (P2) is the most cost

- effective approach to reducing pollutants in wastewater. 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 di luted.

B.1 Municipal Copper P2

A number of municipalities have developed P2 programs and this provides a basis for estimating program components and costs. The costs to municipalities, industries, businesses, and households associated with a municipal P2 prog ram for copper will vary greatly based on a number of factors including the concentration of copper in the treatment plant influent, the community size and makeup, the extent of P2 efforts already underway, and the knowledge and experience of the municipal ity in this area. Copper enters wastewater from many sources such as: residences, commercial businesses (e.g., vehicle repair shops, printing shops, radiator shops, boatyards), industrial operations (e.g., electroplating/metal finishing facilities, transpo rtation equipment cleaning), infiltration/inflow of ground and surface water into the sewer system, and corrosion of water piping in buildings (EBMUD, 2014 and RWQCP, 2015). Based on these likely sources, m unicipalities would target plumbers, designers, ar chitects, facility managers and staff (e.g., at metal finishers and platers, and at vehicle repair shops) and residential homeowners, especially those with pools and fountains to reduce copper discharges to the treatment plant

. Program components could inc lude:

 Sampling and analysis

– to characterize copper at the facility and track treatment effectiveness ;

 P rogram development

– for source identification, materials development, program implementation, and management ;

 C onducting site visits and holding workshops and other forms of outreach ;

 Promoting the use of copper

- free product replacements, such as alternatives to
copper

- based algaecides in pools and fountains ;

 Advertising

– to promote and inform the community of various activities and events taking place ; and

 Website development

– to provide the community with additional resources and serve as another means of promoting P2 activities.

B.1.1 Sampling and Analysis

As part of the sampling and analysis task, municipalities should characterize copper inputs to the treatment plant and track program effectiveness . Characterization involves measuring copper influent, effluent, and sludge concentrations to develop a better understanding of the load entering the plant and treatment process removal efficiency. This e nable s the discharger to determine how much of the resulting effluent copper loading is due to treatment performance and removal efficiencies, and how much is the result of industrial, commercial, institutional, or residential discharges. Treatment plants should address any in plant sources or issues in addition to focusing efforts on potential influent sources.B

- 2 March 15, 2016

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 copper behavior within the plant. Therefore, on average, municipalities would likely sample on a monthly ba sis using Method 200.8 , which requires either a filtered (dissolved) or unfiltered (total recoverable) aqueous sample and allows for the determination of copper at a minimum level of either 0.02 ng/L (selection ion monitoring mode) or 0.5 ng/L (scanning mo de) for total recoverable copper (EPA, 1994)

. For solids the minimum level is 0.2 mg/kg. 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 m onth ).

Costs associated with sampling include both the analytical (lab) costs and the time required to take the sample and complete the paperwork (chain of custody form, packaging of sample bottles, and shipping ) . For a sample taken in isolation, the effo rt may be on the order of an hour, but facilities may save time by combining the effort with other sampling requirements. The average labor rate for a wastewater treatment plant operator in Oregon, including employer benefits is $43 per hour [escalated fro m 2014 dollars to 2015 dollars using Bureau of Labor Statistics (BLS) employment cost index] (BLS, 2014; 2015a; 2015b). Thus, costs would be about $43 per sample (1 hour per sample at an hourly wage rate of about $43), but potentially less. Laboratory anal ytical costs would be an additional $40 per sample (APEX Labs, 2016, Edge Analytical, 2016, NRC Labs, 2016). Therefore, total sampling costs may be approximately $8 3 per sample ($43 for operator labor + $40 for laboratory analysis = $83), or approximately $3

, 000 per year for 36 samples.

B.1.2 Program Development

P2 program development involves identifying potential copper sources, determining appropriate
or cost

- effective measures for targeting those sources, developing materials, implementing the
program , and ma naging and assessing progress/effectiveness of the program.

There are a large number of potential sources of copper to any POTW, but there are few data on these sources from which to accurately predict the copper load measured at the headworks of a facili ty. Nevertheless , several municipal dischargers have attempted to quantify their copper

sources. For example, the Palo Alto Regional Water Quality Control Plant (RWQCP ) estimates that 60% of its influent copper is from corrosion of water pipes, 13% is from residential and human waste, 7% is from the water supply, 5 % is from permitted industries, and the remaining 15% is from sources such as septage, stormwater inflow, cooling towers, circulating hot water systems, identified commercial sources and infiltra tion/permitted groundwater. This analysis is based on a mass loading study update completed by RWQCP in 2002. The original analysis began in 1992 and consists of extensive local sampling combined with a number of studies completed by RWQCP and others (RWQC P, 2015)

. East Bay Municipal Utilities Department ( EBMUD ) does not believe that corrosion of water pipes is their most significant source of copper (EBMUD, 2016). Rather, EBMUD issues permits and conducts inspections, as needed, to ensure ongoing implement ation of pretreatment requirements for facilities in the electroplating, metal finishing, and transportation equipment cleaning categories. Many of the plating shops are now zero dischargers however, finding it more effective to recycle or off

- haul their p rocess water (EBMUD, 2016). EBMUD also issuesB

- 3 March 15, 2016

P2 permits requiring implementation of permit specific BMPs for facilities in the vehicle repair, printing, radiator, and boatyard business types (EBMUD, 2014).

The San Mateo Wastewater Treatment Plant (SMWTP) in California estimates that approximately 49 % of their influent copper load is from corrosion of water pipes, 35% is from

non

- commercial uses, 11% is from commercial and industrial sources and 6% is from infiltration and inflow ( SMWTP , 20 16 ). Therefore, to reduce costs, facilities could use information collected and developed from these and other POTWs to identify potential sources of copper , as well as to roughly estimate influent copper contributions from those sources. Note, however, that th e only way to truly characterize influent loads would be through site

- specific sampling.

D etermin ing which P2 efforts to pursue requires evaluation of the contribution to total copper loadings, relative magnitude of loading, feasibility of control, and eff ectiveness of proposed efforts. Source control efforts could be implemented through existing pretreatment programs. P2 practices could include best management practices ( BMPs ) , production/process changes at industrial facilities, and public outreach and ed ucation programs targeting local businesses and industries (e.g., printing shops and electroplaters/metal finishers), consumers, and plumbers

. Currently, m ost municipal facilities use a combination of permits and outreach (such as EBMUD) to reduce copper contributions from the commercial sector. For the residential sector and some low

- impact commercial operations (e.g., pottery and art), outreach and education are typically the only efforts in place

. The Central Contra Costa Sanitary District (CCCSD) devel oped local discharge limits for copper

, allowing permitted industrial users to discharge up to 0.9 mg/L of copper in wastewater, and restricting unpermitted industrial users to 0.04 mg/L (CCCSD, 2007). The Mt. View Sanitary District (MVSD) and EBMUD each d evelop ed a brochure to educate homeowners about the impacts of copper associated with swimming pools and why swimming pools should be drained to the sewage system

. EBMUD encourages pool owners to consult with their “...pool maintenance service or local pool supply store for help in resolving persistent algae problems without using copper algaecides.” MVSD also encourages all its residents to drop off old copper plumbing materials and other copper

- containing waste at the community’s Household Hazardous Waste C ollection Facility (MVSD Copper Pollution Prevention Program).

One of the most significant sources of copper to a POTW is corrosion within copper plumbing and pipes. Most of the copper from th is source leaches out of these fixtures based on the water’s pH

. EBMUD already adjusts the pH of its water to reduce its aggressiveness (EBMUD, 2014). Municipalities may also develop materials or conduct workshops aimed at encouraging plumbers and others to implement BMPs that minimize the release of copper from pipes and plumbing

. For example, the Bay Area Pollution Prevention Group (BAPPG), comprised of 43 Bay Area wastewater agencies , provided presentations to plumbing unions and building inspector associations about plumbing installation BMPs. These presentations included the preliminary results of the 2014 BAPPG study regarding life cycle and worker safety of copper versus polyethylene ( PEX ) plumbing (BAPPG, 2015).

Public and professional outreach and education activities, however, do no t always result in noticea ble reductions in copper loads to the POTW. For example, many plumbing installation BMPs are virtually ignored due to fears of alternate product longevity and worker safety basedB

- 4 March 15, 2016

on fumes created when using alternative products during soldering. In additio n, some water suppliers are concerned that the compounds leached from materials such as PEX plumbing may be more harmful than the copper that is leached from conventional plumbing (RWQCP, 2015). To increase participation rates and make voluntary efforts mo re successful

, it would appear that more studies and data are needed to further support plumbing installation BMPs that reduce
copper

.

A n increasing number of municipalities are implementing non

- voluntary measures such as limits/requirements in pretreatme nt permits or sewer use ordinances that require implementation of specific treatment controls and/or BMPs to obtain more measurable reductions in copper loadings. For example, the Palo Alto RWQCP implemented a sewer use ordinance ( RWQCP, 2007 ) that require s all dischargers to the sewer system not to exceed 0.25 mg/L of copper in their wastewater. Certain users are allowed higher limits, such as a person wishing to empty a pool. In this situation, the water may contain up to 2.0 mg/L of copper. This same ord inance, under “Requirements for newly constructed, remodeled or converted multi

- residential, commercial and industrial facilities,” mandates that copper, copper alloys ..... shall not be used in sewer lines, connectors, or seals coming in contact with sewage except for domestic waste sink traps and short lengths of associated connecting pipes where alternate materials are not practical. Violators of RWQCP’s sewer ordinance are subject to both criminal and civil penalties. Civil penalties include:

 An amount no t to exceed two thousand dollars per day for failing or refusing to furnish technical or monitoring reports ;

 An amount not to exceed three thousand dollars per day for failing or refusing to comply in a timely fashion with the compliance s chedule establish ed by the City ;

 An amount not to exceed five thousand dollars per day of violation for discharges in violation of any waste discharge limitation, permit condition or req uirement issued by the City ; and

 An amount not to exceed ten dollars per gallon for dis charges in violation of any suspension, cease and desist order or other orders, or prohibition issued, reissued or adopted by the City (RWQCP, 2007)

. Similarly, as mentioned earlier, EBMUD issues permits and conducts inspections, as needed, to

ensure ongoing implementation of pretreatment requirements for facilities in the electroplating, metal finishing, and transportation equipment cleaning categories. EBMUD also issues P2 permits requiring implementation of permit specific BMPs for facilities in the vehicle repair, printing, radiator, and boatyard business types. Copper loading to the EBMUD MWWTP initially decreased with the issuance of these permit types and has remained approximately the same in the years after (EBMUD, 2014)

. Costs of program deve lopment vary based on the level of effort and size of the service area. The Palo Alto RWQCP ( dry weather permitted flow of 3 9 mgd) has a P2 program sector of its environmental compliance division. The staff works on various tasks and outreach efforts for a number of different pollutants including copper . The Watershed Protection Manager stated that two copper sources of concern to RWQCP are electroplating operations and plumbing corrosion. Establishing controls for electroplaters was relatively easy, since these customers were already participants in the pretreatment program. Much more effort was spent developing an outreachB

- 5 March 15, 2016

program for the plumbing community, trying to persuade that community to switch from using copper piping to alternative materials such as PEX. The Watershed Protection Manager estimates that approximately one half of one staff members’ time was spent working on copper

- related tasks with the plumbing community ( Palo Alto RWQCP , 20 1 5) . Assuming the work can be conducted by one of the WWTP o perators, this would translate in startup costs of approximately $ 4 5 ,000.

EBMUD believed that the costs to include copper in their pretreatment program would be relatively low (EBMUD, 2016), and therefore these costs were not tracked separately from othe r costs associated with the program. Like RWQCP, many of the identified potential producers of copper were already identified in their pretreatment program for other pollutants of concern. Most EBMUD costs associated with copper related to outreach for ind ustrial and commercial customers as well as a pool brochure (EID, 2010) developed for residential customers.

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 requireme nts for medium and small facilities will most likely be less than those of a larger facility. When researching costs for mercury

- related P2 programs (EPA, 2008), EPA established that costs for program development at medium

- sized facilities were about two

- t hirds of the effort of large facilities, and one third of the effort for small facilities. Since EPA could not obtain copper

- specific P2 program costs for small and medium sized facilities , the one and two third ratios will be used to evaluate P2 program c osts at those other facilities.

B.1.3 Workshop s and Other Consultant Tasks

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 $ 15 ,000 per year on a private consultant to help them develop outreach materials and conduct copper education workshops and seminars for plumbers and plumber unions throughout their service area ( North , 20 1 5). Workshops can be used to provide target groups with se ctor

- specific information on copper sources, effective BMPs, and sources for alternative materials. The need for additional assistance varies depending on the number of different sources of copper to the plant and the size of the service area. For example, RWQCP funded the $5,000 Analysis of Copper versus PEX from Life Cycle and Worker Safety Perspectives Report (Hughes, 2014) to take a closer look at some of the health and safety concerns being raised by plumbers and plumber unions.

Based on in formation from Palo Alto, large facilities may spend about $15,000 per year on tasks related to program maintenance and material development performed by persons not directly employed by the municipality. Medium and smaller facilities, due to the nature an d size of their service areas would not have to spend as much, potentially on the order of two thirds and one third the cost, respectively (EPA, 2008).B

- 6 March 15, 2016

B.1.4 Advertising

Developing public service announcements (PSAs) and a website promoting copper P2 efforts ar e 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 60

- minute Spanish or English PSA under a Gen eral Services Agreement for the federal government (GSA contract GS

- 23F

- 0307M) is $5,250

. A five

- minute podcast for placement on a utility’s website is $5,000. Due to a large service area, large facilities could need a number of messages targeting differen t sources in different languages annually

. Since medium and small facilities have fewer sources to target, they may need fewer announcements

.

B.1.5 Website

Small municipalities may target primarily residential customers with a copper P2 website (e.g., permit re quirements for an activity such as emptying a pool, links to copper fact sheets)

. H owever, larger municipalities may also target commercial and industrial dischargers. The cost of a website depends on its function, number of pages, and security requireme nt s. Websites with less than 10 pages and no animation or custom graphics typically cost less than $1,000 ( Numatek, 2015 ). Due to the nature of P2 programs and the need to adapt efforts based on sampling and outreach results, frequent maintenance would be ne eded to keep the websites up to date. However, over the life of a program

, website development and maintenance might average

a pproximately $1,000 per year. These costs do not include the cost of the website itself. Rather, facilities would likely add infor mation on the P2 program to a preexisting website run by the municipality or sewer district.

B.1.6 Total Municipal P2 Costs

Exhibit B

- 1 summarizes potential program components and costs for municipal facilities , both for initial (one

- time) startup costs, and ann ual costs.

Exhibit B

- 1. Potential P2 Program Costs for Municipal Facilities

– Initial and Annual ($2015 )

Component Small (1

- 5 mgd) Medium (5

- 20 mgd) Large (> 20 mgd) Program Development (initial

– one

- time ) $1 5 ,000 $ 30 ,000 $4 5 ,000 Sampling and Analysis (annual) $3,000 $3,000 $3,000 Workshops, other Consultant Work (annual) $5,000 $10,000 $15,000 Website (annual) $1,000 $1,000 $1,000
Costs may be greater in the startup period than costs in subsequent years as the program becomes more established; the website and program development estimates represent upfront costs, while the sampling and analysis, and workshops and other consultant work estimates represent average annual program expenditures. Facilities will likely initially target the largest or most known sources of copper to the treatment plant, such as metal finishers or plumbers unions, and then move on to other potential sources such as automobile service stations and photo processors. Of course, this strategy will vary by community based on the actual facilities within that community served by the municipal treatment works. The estimates for conducting workshops and other consultant work reflect this sequential targeting of an equal number of sources in a given year.B

- 7 March 15, 2016

B.2 Indirect Dischargers

In addi tion to the cost of developing a P2 program, municipalities may require indirect dischargers to the sewer system to implement source controls or best management practices

. Municipalities would likely target plumbers and plumbers unions, commercial and indu strial operations and those individuals or organizations managing pools, spas and fountains

. However, the program may not address all of these sectors immediate ly (i.e., in certain sectors

, implementation of controls may not occur for several years).

B.2.1 Plum bers and Plumber Unions

Most copper seen in POTW effluent comes from corrosion in water pipes and plumbing. In theory, reducing the amount of copper products used in the plumbing trade would equate, through time, to significant reductions in copper in effl u ent. However, as discussed previously

, there are many obstacles and objections within the plumbing community to achieving this goal, despite the fact that alternative copper

- free plumbing materials do exist. Nevertheless, outreach should proceed with this group, as the objections encountered in California may not be encountered in Oregon. Monetary costs to this group related to switching to copper

- free materials mostly arise due to training and the time necessary to become knowledgeable in using these prod ucts. Many of the materials actually cost less than copper containing materials, so time spent learning about these products could be offset by the lower cost of these products. In addition, using materials such as water

- based flux (ASTM B

- 813) is the Univ ersal Plumbing Code (UPC) standard for potable water, and on e of the primary BM Ps for copper pipe installation (to minimize/avoid flux induced pipe corrosion) . Therefore, the costs for switching to
copper

- free plumbing materials can be partially attributed to the UPC, and not to revised copper standards in Oregon.

B.2.2 Commercial and Industrial Operations

These operations include activities such as electroplating and metal finishing shops, machine shops, boat yards automotive repair facilities, and transportatio n equipment cleaning and car washes. Fortunately, many of these operations are probably already identified within communities and are already actively participating in a pretreatment program. Therefore, adding copper to the pretreatment program should be r elatively easy to implement with low cost to the POTW. Much work has already been done in establishing copper limits from these dischargers in other areas (such as the San Francisco Bay area), and POTWs in Oregon could leverage this work as they modify the ir own sewer ordinances and establish copper BMPs. For some facilities, such as boat yards, Oregon has already developed BMPs and these could be readily incorporated into sewer ordinances and pretreatment programs. Costs for meeting requirements in new or updated sewer ordinances and pretreatment programs would be borne by the activity operator.

There is little information available on the cost of P2 programs for commercial and 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. However, it can be assumed that
most facilities will implement the basic components of a P2 program , including process analysis and process modificatio ns. During process analysis the discharger would identify pollutant uses and quantities within the facility (i.e., inventory facility), identify pollutant use and potentialB

- 8 March 15, 2016

contamination in process streams, and identify P2 options for reducing the pollutan t 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.

It is estimated that the costs to identify potential pollutant sources and sample process waste streams assuming a two

- month stu dy is approximately 320 hours. The hourly wage in Oregon for an environmental engineer is approximately $ 58 including employer b enefits [escalated from 2014 dollars to 2015 dollars using BLS employment cost index] (BLS, 2014; 2015c; 2015d)

. 10
This results in study costs of approximately $16,000 (320 × $50).

As discussed previously , analytical costs for measuring copper using Method 200.8 may be

a pproximately $83 per sample. It was 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 $4,000 (4 × 12 × 83). Thus, total process analysis for industrial facilities would be approximately $20,000 ($16,000 + $4,000). Process analysis costs will likely only be incurred during the first year.

There may also be inspection charges borne by an indirect comme rcial or industrial discharger. For example, RWQCP does not perform any site inspections solely for copper, but they do perform pretreatment inspections and inspections of facilities for implementation of BMPs. The utility employs two fulltime pretreatmen t staff and one fulltime inspector who visits auto repair shops, dentists, dry cleaners and other facilities where the use of BMPs is expected and encouraged. Plating shops in the EBMUD service area are mostly now zero dischargers (recycling or off

- haulin g their process water), but EBMUD still inspects and samples twice a year the few facilities that still discharge process water (EBMUD, 2016). The individual facility is charged $1,180 per inspection and another $100 in analytical costs. The facility is also required to self monitor approximately two times per year. EBMUD also conducts inspections of auto shops, boatyards, radiator shops and printers. Water quality analyses are not performed in conjunction with these inspections, which focus on the impl ementation and maintenance of BMPs.

B.2.3 Pools, Spas and Fountains

P2 measures for pools, spas and fountains include BMPs such as eliminating the use of copper containing algaecides and ensuring that the draining of these facilities for maintenance is accomplished via the sanitary sewer system. Alternative algaecides are readily available, and an outreach campaign to operators and owners of these facilities should raise awareness of the alternative products. Better yet, educating operators on how to pre vent algae growth in the first place could minimize the use of any algaecides. Sewer ordinances could be changed to reflect that the draining of any pool, spa or fountain needs to occur into the sanitary sewer system with a permit. This potentially allows for further reduction in copper in these waters prior to discharge

10 BLS (2014) describes an environmental engineer (standard occupations classification 17

- 2081) as one that can “design, plan, or perform engineering duties in the prev ention, control, and remediation of environmental health hazards utilizing various engineering disciplines” and “work may include waste treatment, site remediation, or pollution control technology.”B

- 9 March 15, 2016

into the environment. A permit allows for testing of the water prior to discharge, and an opportunity to collect a fee. The permit fee, if charged, could help a POTW to recoup some of the c osts associated with outreach and managing the program. In order for a permit program to be effective, outreach on how to locate a sewer cleanout will be necessary. Again, there are several examples of this kind of outreach (MVSD Pool & Spa Brochure) that could be leveraged by Oregon, thereby reducing the cost of outreach. And, some POTWs in Oregon may already have sewer cleanout location outreach in place for other reasons, and can simply add information about draining pools, spas, and fountains to this ou treach.

Other than some potential costs associated with permitting fees and water testing , implementing P2 activities is not likely to impose an objectionable cost burden on the operators and owners of pools, spas and fountains

.

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 Copper P 2 Program s

Sector Annual Cost

Plumbers and Plumber Unions Most likely minimal. Time spent learning about how to use copper

- free materials can be offset by the lower costs of many of these products. In addition, UPC mentions many of these products as “standards”, and therefore not all costs can be attributed to the rule.

Commercial and Industrial Operations Costs will vary widely based on current participation in pretreatment programs and BMPs already put in place by Oregon. Costs are expected, but payback periods can be demonstrated.
Pools, spas and fountains Minor. Copper

- free algaecides can be comparable (or less) in price to those containing copper, and a permit fee (if collected) would be a minor cost.

B.3 Copper from the Water Source and Stormwater/Groundwater

In most cases, copper in POTW effluent can be traced back to drinking water. This is because not only may the source of the drinking water contain copper, but also because the drinking water treatment process and resultant water chemistry can leach copper out of pipes and plumbing. So, there may be actions that a community’s drinking water supplie r can take to reduce copper that would greatly benefit any POTW looking to lower its effluent copper concentrations. These actions would probably cost the POTW very little, but could create significant costs for the drinking water system and potentially co mmunity residents if changes in the drinking water treatment process translate into higher water bills. On the part of the POTW, the only costs may be staff time to meet with the drinking water system to bring up the issue of copper in the drinking water s ystem and discuss potential ways to lower these levels.

POTWs need to be aware that the federal drinking water standard for copper is 1.3 mg/L, an order of magnitude higher than the effluent limitations under consideration in Oregon. Therefore, there is l ittle regulatory incentive for a drinking water utility to try and lower its copper concentration in the water it supplies to the order of parts per billion.

However, it is still worth a POTW reaching out to its drinking water utility counterpart to see wh at options may be available. Changes in the drinking water utility’s corrosion control programB

- 10 March 15, 2016

may help, and depending on the scope of the change, the cost may be reasonable. Typically, any changes in a drinking water utility’s treatment process will need state approval, so the process is not necessarily a quick fix, and more water quality monitoring may be required on the part of the drinking water utility to ensure that any change in its treatment process does not result in unintended consequences. A POTW could help to share costs on any potential treatment changes, like assisting with additional sampling and analysis or helping to fund any water quality studies that may need to be performed in advance of changes.

There may also be easier measures that cou ld be implemented as well. For example, the Palo Alto RWQCP observed spikes in copper in their influent in the summer months. While investigating the issue, RWQCP discovered that during the very dry months of summer, the drinking water system was supplemen ting the water supply by drawing water from a surface water reservoir. To maintain algae levels within the exposed reservoir, the drinking water facility had been using a copper

- based algaecide. Once the utility switched to a copper

- free algaecide, the spi kes of copper previously seen in the influent were absent (RWQCP, 2015).

Infiltration and inflow (I&I) can be another source of copper, and in Oregon it could be argued that this source is of much greater concern than in an area such as drought stricken C alifornia. Fortunately, many POTWs already have an I&I program in place. By implementing their current I&I program, POTWs will also be reducing their inputs of copper from stormwater and groundwater at no additional cost.

B.4 References

Apex Laboratories LLC. 2016. Personal Communication with Lisa Domenighini . January. Lab ID. #OR100062

Bay Area Pollution Prevention Group (BAPPG). 2015. 2015 Annual Report.

Bureau of Labor Statistics (BLS). 2014

. State Occupational Employment and Wage Estimates Oregon

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

.

Bureau of Labor Statistics (BLS). 2015 a. Employment Cost Index Historical Listing. Current

dollar March 2001

– September 2015. Table 11. Employmen t 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://ww w.bls.gov/web/eci/echistrynaics.pdf

.

Bureau of Labor Statistics (BLS). 2015 b. 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 governme nt workers, by major occupational and industry group, September 2015

, Management, p rofessional and related. Online at http://www.bls.gov/news.release/pdf/ecec.t03.htm

.

Bureau of Labor Statistics (BLS). 2015c. Employment Cost Index Historical Listing Current

dollar March 2001

– September 2015. 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/eci/echistrynaics.pdf

.B

- 11 March 15, 2016

Bureau of Labor Statistics (BLS). 2015d. Employer Costs for Employee Compensation. Table 5. Employer costs per ho ur worked for employee compensation and costs as a percent of total compensation: Private industry, by major occupational group and bargaining unit status, September 2015, Management, professional and related. Online at http://www.bls.gov/news.release/pdf/ecec.t05.htm

. Central Contra Costa Sanitary District Local Discharge Limits. 2007. Online at http://www.cent ralsan.org/documents/Local_Discharge_Limits_090107.pdf

. East Bay Municipal Utilities District (EBMUD). 2016. Personal Communication with Robert Newman, Senior Environmental Health & Safety Specialist.

East Bay Municipal Utilities District (EBMUD). 20 1 4. 2 0 1 4 Pretreatment and Pollution Prevention Report

. Edge Analytical. 2016. Personal Communication with Mary Price and Thanh Phan. January. Lab ID. #OR100063

E d l und

, Sven

. 20 16

. San Mateo Wastewater Treatment Plant Environmental Compliance Inspector

. Personal communication January 2016

. El Dorado Irrigation District (EID). 2010. Draining a Swimming Pool.

Hughes, Stephanie. 2014. Analysis of Copper versus PEX from Life Cycle and Worker Safety Perspectives Report

. Mt. View Sanitary District. Draining Pools & Spas. Online at http://www.mvsd.org/Newsletter/Pools%20Spa%20Brochure%20

- MVSD%20(Red%20Text).pdf

. Mt. View Sanitary District Coppe r Pollution Prevention Program

. Online at http://www.mvsd.org/programs/pollution

- prevention/#copper

- pollution

- prevention

. Neilson Research Corporation (NRC). 2015

. Personal communication w ith Tammy Kreutzer. January. Lab ID# OR100016. http://www.nrclabs.com

. Numatek Web Design. 2016. Web Design Price Estimates. Online at http://www.numatek.co m/web

- design/estimate.html . Accessed January 25, 2016.

Palo Alto Regional Water Qualit y Control Plant (RWQCP). 2016. Personal communication with Karin North, Watershed Protection Manager January 2016.

Palo Alto Regional Wat er Quality Control Plant . 2015. 2 015 Pollution Prevention Plan.

Palo Alto Regional Wat er Quality Control Plant

. 2007 . Ordinance No. 5084 Ordinance of the Council of the City of Palo Alto Repealing . Chapter 16.09 of the Palo Alto Municipal Code and Amending Title 16 to Adopt a New Chapter 16.09 (Sewer Use Ordinance) EstablishingB

- 12 March 15, 2016

Regulations to Reduce Discharges of Pollutants to the Sanitary Sewer and Storm Drainage Systems

.

San Mateo Wastewater Treatment Plant (SMWTP)

. 20 16

. Personal Communication with Sven Edlund, Environmental Compliance Inspector

. Universal Plumbing Code. 2015. Online at http://codes.iapmo.org/home.aspx?code=UPC

.

United States Enviro nmental Protection Agency ( EPA). 2008. Cost of Compliance with Water Quality Crite ria for Toxic Pollutants for Oregon Waters. Prepared by Science Applications International Corporation.

United States Environmental Protection Agency (EPA). 1994. Method 200.8, Revision 5.4: Determination of Trace Elements in Waters and Wastes by Inductively Coupled Plasma

– Mass Spectrometry.C

- 1 March 15, 2016



## C. Appendix C

- End

- of

- Pipe Treatment Controls and Costs

There are numerous end

- of

- pipe treatment technologies that can be used to reduce copper in
wastewa ter 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 to meet the revised BLM criteria.

C.1 Reverse Osmosis

Theoretically, reverse osmosis (RO ) can remove nearly all inorganic contaminants from water, as well as viruses and most organic contaminants , including some pesticides

. The process removes contaminants from water using a semi

- permeable membrane that permits water, and not dissolved compou nds, 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 will likely achieve 95 % removal of copp er (WestTech, 2016). 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 ; and

 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 copper concentrations to levels on the order of 1 μg/L through the use of end

- of

- pipe treatment

. The use of RO for treating wastewater is limited, an d therefore performance data is scarc e. Because removal efficiencies are less than optimal when treating influents with low contaminant concentrations, performance testing using influent concentrations in the ppb (μg/L) range should be conducted on various types of wastewater to ensure that R O is capable of producing the appropriate effluent range.

E ven if the necessary copper reductions are achievable with RO, it is important to consider the potential disadvantages and limitations of this technology, including:

 C apital and operating (includi ng energy) costs are high, and the latter increase with decreasing desired effluent concentrations ;

 Management and disposal of residuals (brine and media) is potentially costly and problematic ;

 Expensive pretreatment may be required to maintain the high tr eatment 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 pre

- filter or microfiltration to ensure that fine suspended materials do not clog the membrane) ;

 Membranes are prone to fouling (NDWC, 1997) ;

 The technology m ay not be feasible for treatment of large flows ; andC

- 2 March 15, 2016  RO d oes not remove pollutants from the environment, rather transfers them to another medium (p ollutants 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. M ost RO systems reject about 10% to 25% of influent water as a concentrated brine solution (U.S. EPA, 1996). T his 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) ; and

 Treatment (e.g., brine concentrator, thermal evapor ation) (Metcalf and Eddy, 2013)

.

T he first option requires that the waste be classified as nonhazardous. Otherwise, the brine must be disposed of as a hazardous waste, whi ch can be extremely costly, especially for larger volumes

. By design, e vaporation ponds require local precipitation rates to be lower than evaporation rates

. The treatment through controlled evaporation is feasible, although operati on and maintenance costs may be extremely high. This approach is usually only employed where no other alternatives are available (Metcalf and Eddy, 2 013)

. In addition, these disposal options do not guarantee that the pollutants in the residuals will not be

re

- released into the en vironment. 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 copper to levels on the order of 1 μg/L for discharges to surface waters, there is no information on installed costs. Nor is information available from similar industrial applications. However, EPA contacted RO system manufacturers to obtain price quotes on RO system configurations set up to meet these low copper levels . Exhibit C

- 1 summarizes the assumptions used by the manu facturer to price an RO unit.

Exhibit C

- 1. Parameters Provided for Costing RO and Ion Exchange Systems for Wastewater

Component Input Value Hardness 140 mg/L Alkalinity 140 mg/L pH 7.5 Temperature 20° C

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 ca pital 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 ha ve limited chlorine tolerance. Thus, prior to microfiltration, the wastewater should be dechlorinatedC

- 3 March 15, 2016

if chlorine is used in previous treatment units. Note that dechlorination may result in an increase in sulfate ions, which, as mentioned previously , could contribute to the scaling potential of the RO membranes. Costs may be higher than shown to account for these factors

.

C.1.1 Cost Estimates

Exhibit C

- 2 summarizes capital and O&M costs for a 5 MGD facility, as priced by a Massachusetts

- based manufacturer, and ad justed to Oregon costs (RSMeans, 2013 for Portland and Boston ). Annual costs represent capital costs annualized at 3% and 7% over 20 years plus O&M costs. The total capital costs include general site work, wet well, pump system with 60 psi, treatment build ing, microfiltration, reverse osmosis, and piping. The costs do not include residuals (brine) management, which are discussed separately below. The O&M cost includes the annual cost for maintaining the microfiltration, reverse osmosis, utilities, and labor cost.

Exhibit C

- 2.Cost Estimates for Reverse Osmosis System

Component Cost (2015) for 5 MGD facility Capital Costs General Site Work $ 300,000 Treating Building $ 3,180,000 Microfiltration $ 3,450,000 Reverse Osmosis $ 5,090,000 Pumps $594,000 Utilities $152,000 Total $ 15,466,000 0 O&M Costs 2 Microfiltration $ 170,000 R everse O smosis $255,000 Utilities $245,000 Labor $140,000 Total $ 810,000 Annual Costs Annualized Capital and O&M Costs (3% rate) $1.85 million Annualized Capital and O&M Costs (7% rate) $ 2.27 million

C.1.2 Brine Disposal Considerations and Costs

As discussed previously , the brine can either disposed through land disposal or treatment. One of the two land applications is a n evaporation pond, which requires that local precipita tion rates be lower than evaporation rates. This is not always the case in Western Oregon. A ccording to the National Oceanic and Atmospheric Administration (NOAA), Oregon is divided into two distinct rainfall zones by the Cascade Range , west of which annua l precipitation ranges from 40 to 140 inches , and east of which, annual precipitation ranges from 10 to 20 inches per year (NOAA, undated).

Exhibit C

- 3 compares evaporation to precipitation (WRCC, undated) for two stations of record

near Roseburg and Salem where two of the potentially affected facilities are located.C

- 4 March 15, 2016

Exhibit C

- 3. Comparison of Evaporation and Precipitation Rates in Western Oregon
NOAA Evaporation Station Closest Facility Evaporation Rate (inches per year) Rainfall (inches

per year) Snow (inches

per year)
Cottage Grove Dam Roseburg ~ 40 miles South of

station 38.46 47.57 4.7

Corvallis State Univ Salem ~ 30 miles North of

station 38.42 40.95 6.0

The e xhibit shows that if the weather patterns identified at these two stations apply in Roseburg and Salem, those facilities would not be able to use evaporation ponds for brine disposal. Data were not available in the immediate vicinity of all facilities, but all these facilities are located west of the Cascade Range, where precipitation rates are high, and potentially higher than evaporation rates. EPA assumed that evaporation ponds cannot be used for brine disposal.

The second land application of brine is t hrough underground injection, which requires an underground injection control (UIC) permit. The disposal of non

- hazardous wastewater falls under either Class I non hazardous, or Class V UIC wells. Class V wells are strictly for the injection of non

- hazardo us fluids into or above underground sources of drinking water, and brine disposal from a major municipal facility would fall under the Class I non

- hazardous program ( EPA, 2013 ). The State of Oregon has primacy over its UIC program for Class I through V wel ls (EPA, undated) . OAR 340

- 044

- 0015 prohibits Class I UIC injection, so that land application through injection is not an option for brine disposal.

If land applications are not feasible in Oregon, the remaining option is to treat the brine by concentrati ng it and thermally evaporating it (Metcalf and Eddy, 2013). Once concentrated, the effluent cannot be discharged into receiving waters, and EPA evaluated the cost of implementing a zero liquid discharge (ZLD) process, during which the brine is concentrate d and crystallized.

EPA did not identify wastewater treatment plants with installed RO systems that require brine concentration, but costs are available for water system applications, and were used as part of this analysis (WaterReuse Foundation, 2008). I n order to minimize final product water, EPA used costs related to the following treatment system : brine concentration by a thermal brine concentrator, followed by thermal crystallization, and minimal discharge to an evaporation pond (0 to 115,000 gallons per day). The solids produced by the thermal crystallization are discharged to a landfill. EPA averaged the unit capital and O&M costs (i.e., for treating one MGD of brine) for the three cases where the treatment generated no flow to an evaporation pond, a nd estimated an annualized cost for the system of $5.76 million per MGD of brine in 2015 dollars 11 at 7% over 20 years (WaterReuse Foundation, 2008, ENR, 2015).

The RO system costed in the previous section is expected to generate brine volumes between 20% and 30% of the initial feedwater (WesTech, 2016). A 5 MGD facility would generate between 1 and 1.5 MGD of brine, which would then be treated at an annualized cost of $5.76 million per MGD, or $ 5.76 to $ 8.64 million. This cost is about 2.5 to almost 4 time s the initial

11 The annualized average cost of those three cases was $ 4.69 million, adjusted from 2008 to 2015 dollars using the Engineering News Record Construction Index.C

- 5 March 15, 2016

RO system cost, and may result in an economic burden on the communities served by these facilities. Therefore, EPA estimated the share of the total RO cost (i.e., RO treatment + brine disposal systems) by residential customers.

EPA was able to estimate the number of households served by the following two municipal treatment systems: City of McMinnville WRF and R.U.S.A. Roseburg WWTP

. EPA used U.S. Census Bureau and Bureau of Labor Statistics data to estimate the number of househo lds served by each facility. According to its 1993

- 1998 NPDES permit, t he City of McMinnville Water Reclamation Facilities serves the entire city and includes no one outside the city boundary

. The City of Roseburg is similar, although it does serve some ho usehold s in its Urban Growth Boundary.

Exhibit C

- 4 summarizes the data used for the evaluation of income relative to cost to these two communities , in order to obtain a measure of affordability of the system upgrades

.

Exhibit C

- 4. Assumptions for Affordability Evaluation

Assumptions City of McMinnville WRF R.U.S.A. Rosebu rg WWTP Median household income, 2009

- 2013 $42,048 $38,963 Income adjusted to 2015 dollars $42,781 $39,642 Population (2014 estimate) 33,393 21,903 Persons per household, 2009

- 2013 2.66 2.17
Households 2014 12,554 10,094

EPA then estimated the total annualized cost of the RO system, including brine disposal, for the McMinnville and Rose burg facilities assuming a range of brine volume equivalent to 20 to 30% of feedwater flow. This total cost was then divided equally among the households. Exhibit C

- 5 summarized th os e calculations.

Exhibit C

- 5. Affordability Estimates for McMinnville and Roseb urg facilities

Estimates City of McMinnville WRF (5.6 MGD) R.U.S.A

. Roseburg WWTP (7.9 MGD) Brine as Percent of Feedwater 20% 30% 20% 30% WWTF brine flow (MGD) 1.12 1.68 1.58 2.37 Total annual RO cost ($2015 million) $9.17 $12.40 $12.73 $17.28
Total annual RO per household $731 $987 $1,014 $1,376
% of median household income 1.7% 2.3% 2. 4 % 3.2%

This exhibit shows that the total cost of the RO system with its brine disposal system could represent between 1.7 and 2.3% of the median household income in McMinnville; and between 2.4 and 3.2% of the median household income in Roseburg. These cost estim ates likely exceed thresholds for substantial economic impact , and do not even include the current sewer rates charged by these facilities. Therefore, EPA will not include RO technology as part of its cost estimates. Dischargers are likely to seek alternat ive compliance mechanisms.C

- 6 March 15, 2016

C.2 Ion Exchange

Ion exchange technology has been designed to remove dissolved and ionic forms of pollutants from wastewater using resins selected specifically for their contaminant removal properties

. The treatment system relies on adsorption and chemical bonding of ions through ion exchange, and works best when waste streams are pretreated to remove suspended and dissolved solids to enhance pollutant remov al and eliminate competing ions (NDW C, 1997)

. The ion exchange process consists of four operations: service, bac kwash, regeneration, and rinse

. 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 ste p 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 regen eration solution before the column is brought back online for the nex t service cycle

. Note that some sorbents cannot be regenerated, and once they are spent (i.e., there is no more capacity to adsorb copper ), they are disposed of and replaced with fresh me dia. Advantages of ion exchange technology include:

 A large variety of specific resins are available from manufacturers, tailored to remov al of specific contaminants ; and

 Contaminants can be recovered from most resins upon regeneration (NDWC, 1997)

.

Use of ion exchange also has disadvantages:

 Management and disposal of spent media or regenerated brine can be costly , due to high

concen trations of the waste effluent ;

 Effluent quality may be highly variable (depending on sorbent loading) ;

 To achieve low pollu tant levels in wastewater , extensive pretreatment may be necessary ; and

 Ion exchange units are sensitive to the presence of competing ions (NDW C, 1997)

. For copper, h istorically, the use of sorbent resins has been limited to strong acid cationic resins applied to industrial wastewater containing inorganic copper and calcium. The selectivity of copper is less than that for calcium. Certain c ationic resins can also be used to remove copper because they have a high selectivity for copper

. Another res in that can be used to remove copper is a chelating resin, such as amidoxime chelating resin which is designed for removal of cations of metals, such as copper and iron from water at relatively low pH. Also, a typical ion exchange system is often designed with lead and lag vessels. When the treatment system is properly designed and maintained, the expected copper rem oval can reach 95% removal (Wes Tech 2016)

.

Exhibit C

- 6 summarizes capital and O&M costs for a 5 MGD facility, as priced by a Massachusetts

- bas ed manufacturer, and adjusted to Oregon costs (WesTech, 2016, RSMeans, 2013 for Portland and Oregon). Annual costs represent capital costs annualized at 3% and 7% over 20 years plus O&M costs.C

- 7 March 15, 2016 Exhibit C

- 6 . Cost Estimates for Ion Exchange System

Component Cost (2015) for 5 MGD facility Capital Costs General Site Work $ 185,000 Treating Building $ 4,260,000 Ion Exchange $ 2,850,000 Pumps $800,000 Utilities $189,000 Total $ 8,284,000 O&M Costs 2 Ion Exchange $ 250000 Utilities $25,000 Labor $85,000 Total $ 360,000 Annual Costs Annualized Capital and O&M Costs (3% rate) $0.92 million Annualized Capital and O&M Costs (7% rate) $ 1.14 million

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, 2013). Common precipitants for removal of heavy metals such as cadmium, copper, mercury and arsenic include hydroxide and sulfide (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, 2013).

Copper may be present in two forms in wastewater: ionic copper Cu(I) and Cu (II)

. These species of copper may bind to particulate matter in the wastewater to form physical agglomerates containing copper tha t more readily settle out. However, in order to achieve copper levels in the low μ g/L range, the dissolved and elemental forms of copper, as well as particulate copper, may need to be removed.

When copper is precipitated as sulfide, high copper residuals are often obse rved due to reduction of copper to elemental copper, which has a solubility in water of about 20 μg/L (Metcalf and Eddy , 2013), i.e., much greater than some of the estimated effluent limits.

The removal of copper from wastewater to μg/L leve ls may be achieved using chemical precipitation (Pang et al., 2009) and ele c tro

- coagulation (Dermentzis et al., 2014, Dermentzis et al., 2010) and adsorption (Shrivastavvs, 2005)

. For future consideration, electro

- coagulation could be an option and should be re viewed for its applicability to c opper removal ( Dermentzis et al., 2014, Dermentzis et al., 2010). Activated Carbon adsorption may represent another treatment possibility (Shrivastavvs, 2005) but was not considered for costing purposes

.C

- 8 March 15, 2016

C.4 References

Dermentzis, Konstantinos, Marmanis, Dimitrios, and Christoforidis, Achilleas, 2014. Remediation of Heavy Metal Bearing Wastewater by Photovoltaic Electrocooagulation, Second International Conference

– Water Resources and Wetalnds Proceeding, Romania, P 257

– 262.

Dermentzis, Konstantinos, Christiforidis, Achilleas, and Valsamidou, Evgenia, 2010. Removal of nickel, copper, zinc, and chromium from synthetic and industrial wastewater by electrocoagulation, Internation Jounral of Environmental Sci ences, Volume 1, No. 5 P. 697

- 710.

Engineering News Record (ENR). 2015. ENR Construction Index

Metcalf and Eddy. 2013. Wastewater Engineering: Treatment and Reuse. Fifth Edition. McGraw Hill: Boston.

National Drinking Water Clearinghouse (NDWC). 1997. T ech Brief: Ion Exchange and Demineralization. Online at http://www.nesc.wvu.edu/ndwc/pdf/OT/TB/TB4_IonExchange.pdf

. National Oceanic and Atmospheric Administration (NOAA). Undated. No rthwest River Forecast Center

– Hydrologic Cycle. Online at: http://www.nwrfc.noaa.gov/info/water_cycle/hydrology.cgi

Pang, Fong Moi, Teng, Sheau Ping, Teng, Tjoon Tow, and Omar, A.K. Mohd 2009. Heavy Metals Removal by Hydroxide Precipitation and Coagulation

- Flocculation Methods from Aqueous Solution, Water Quality Research Journal of Canada , Volume 44, No. 2.

RSMeans

. 2013 . Construction Cost Data. City Cost Indexes

Shrivastavvs, A.K., 2009, A Review on Copper Pollution and its Removal from Water Bodies by Pollution Co ntrol Technologies, Indian Journ al of Environmental Protection, Vo l ume 29, No.,6, P. 552

– 560.

United States Environmental Prot ection Agency (U.S. EPA) . 2013. Final Perm it

- Class I Nonhazardous Waste Injection Wells. Permit No. R9UIC

- CA1

- FY11

- 4. Issued to Newhall Land and Farming Company, Inc. Online at: http://www.epa.gov/uic/ui c

- class

- i

- permit

- newhall

- land

and

- farming

- company

- inc

United States Environmental Protection Agency (U.S. EPA). 1996. Capsule Report: Reverse Osmosis. EPA 625

- R

- 96

- 009. Office of Research and Development, Washington D.C.

United States Environmental Prot ection Agency (U.S. EPA) . Undated. Underground Injection Control website, and relevant pages. Online at: http://www.epa.gov/uic

. WaterReuse Foundation. 2008. Survey of High

- Recover and Zero Liquid Discharge Technologi es for Water Utilities. Online at: http://www.waterrf.org/Pages/Projects.aspx?PID=4073C

- 9 March 15, 2016

WesTech 2016. Personal communication with Jon Farrell and Lindsay Horsley. For pricing of Ion Exchange and RO systems

Western Regional Climate Center (WRCC). Undated. NOAA Evaporation and Precipitation Data for Cottage Grove Dam and Corvallis State Univ Stations. Online at: ht tp://www.wrcc.dri.edu/htmlfiles/westevap.final.html#OREGON

, http://www.wrcc.dri.edu/cgi

bin/cliMAIN.pl?or1902 , and http://www.wr cc.dri.edu/cgi

- bin/cliMAIN.pl?orcorv

.D

- 1 March 15, 2016



## D. Appendix D. Variance Procedures Based on Adverse

Economic Impacts

This appendix describes the analysis of the potential for control 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 control costs associated with WQBELs will impose a substantial financial impact (e stimate change in household sewer bills resulting from the control costs; evaluate financial health of the community), and whether such an impact would have widespread adverse economic and social impact.

D.1.1 Substantial Impacts

The analysis of whether control 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 proje ct. 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 consi dered are (EPA, 1995):

 public education ;

 change in raw materials ;

 substitution of process chemicals ;

 change in process ;

 water recycling and reuse ; and

 pretreatment requirements.

EPA (1995) provides worksheet s 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 financ ed 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 fundi ng 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.D

- 2 March 15, 2016

To assess the burden that pollution control costs are expected to have on household s, 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 po llution 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 househo ld.

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 o f no substantial impact. Communities are expected to incur mid

- range impacts when the ratio of total annual control 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 fin ancial 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 fi nancing and the socioeconomic health of the community, consists of six indicators for the community:

 Debt Indicators

o Bond Rating

- a measure of a jurisdict ion’s ability to repay its debt ; and

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 ; and

o MHI

- a measure o f 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 ; and

o Property Tax Collection Ra te

- 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.D

- 3 March 15, 2016 Exhibit D

- 1. Secondary Indicators

Indicator Evaluation Weak (score of 1 point) Mid

- Range

(score of 2 points) Strong (score of 3 points)

Bond Rating Below BBB (Standard and Poor’s) Below Baa (Moody’s) BBB (Standard and Poor’s) Baa (Moody’s) Above BBB (Standard and Poor’s) Above Baa (Moody’s) Overall Net Debt as Percent of Full Market Value of Taxable Property Above 5% 2%

- 5% Below 2%

Unemployment More than 1% above National average National average More than 1% below National average

MHI More than 10% below State median State median More than 10% above State median Property Tax Revenues as a Percent of Full Market Value of Taxable Property Above 4% 2%

- 4% Below 2%

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 “  ” indicates that the impact is not likely to be substantial. Finally, the “?” symbol in the

e xhibit indicates that the impact is unclear. For results falling into either the “X” or “?” category

, applicants p roceed to determine whether the impacts would also be widespread. EPA (1995) provides further discussion of evaluating the results.

Exhibit D

- 2. Substantial Impacts Matrix

Secondary Score Municipal Preliminary Screener 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  ? X Greater than 2.5   ? Source: See EPA (1995), Table 2

- 2.

D.1.2 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 fro m the community but become business revenues and household incomes. Therefore, applicant s must examine the estimated change in socioeconomic conditions that would result f rom meeting criteria (EPA, 1995).

At a minimum, the analysis should (EPA, 1995):D

- 4 March 15, 2016  defi ne the affected community (the geographic area where project costs pass through to the local economy) ;

 consider the baseline economic health of the community ; and

 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 i s 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.

T o 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 ; and

 community development potent ial.

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 implementing controls

. For example, if a community is in a weak condition before implementing controls but the evaluation of widespread impacts suggests that all of the indicators listed above will remain virtually un changed, 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 f

or 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 control 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, liqui dity, 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 in comes would have a widespread impact on the community).D

- 5 March 15, 2016

D.2.1 Substantial Impacts

To evaluate whether control costs will be substantial, private sector entities will verify project costs and calculate the annual cost of the pollution control project, and then co nduct a 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 con trol. 12

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 thre e 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 compa res 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 control 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 th e entity. EPA (1995) provides worksheets for evaluating the primary and secondary measures.

D.2.2 Widespread Impacts

Applicants that demonstrate that pollution control costs would have a substantial financial impact proceed to evaluate whether such an impact wo uld 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 1995

.

12 Note, however, that entities that pay corporate income taxes may be able to deduct interest payments from their

taxes.E

- 1 March 15, 2016



## E. Appendix E . BMPs and Unit Costs for Nonpoint Sources

As discussed above, some level of incremental controls may be needed for runoff an d erosion control from agricultural and forest lands, urban ar eas, and abandoned mine sites. This section provides a description of potential controls and associated unit costs, where available.

E.1 Agricultural and Forest Lands

Cadmium and copper loadings fro m agricultural and forest lands can arise because of pesticide or fertilizer use as well as soil erosion. Chemicals applied for pesticide control or nutri ent addition can occur in storm water runoff or adhere to soils that erode and eventually enter
waterwa ys. Cadmium and copper are also naturally occurring. Changes in pesticide and nutrient products can reduce cadmium and copper application and subsequent runoff. Such changes would result in incremental costs if the substitutes are more expensive or less ef fective.

There are several practices to control soil erosion. 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 ( ODF, 2014; ODA, 2014 ). Thus, an incremental level of control would only be required if implementation to meet existing water quality standards would not also achieve the revised criteria.

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 s treams, cooling instream temp eratures. As described in the Exhibit E

- 1 , buffers also slow runoff (reducing erosion), filter p ollutants, and trap sediment s. Thus, it is possible that controls being implemented to meet baseline standards for temperature coul d result in meeting the revised criteria.

In addition, if incremental controls are necessary, the United States Department of Agriculture ’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. Through EQIP, farmers and ranchers receive financial and technical assi stance 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

ava ilable for funding assistance. T hus, the cost of additional BMPs that may be needed under the revised criteria would likely be similar to the NRCS estimates . Exhibit E

- 1 shows some examples of BMPs that reduce soil erosion along with current compensation rates to illustrate potential cos ts.E

- 2 March 15, 2016

Exhibit E

- 1

. Examples of Erosion Control Practices and EQIP Financial Assistance

Practice Description 2016 Rate Conservation

cover Plant cover (as well as other covers such as mulch, bark dust, rock,

and concrete) protects soils from erosion. $115 to $13,761 per acre

Buffers Trees, shrubs, and/or grass slow water speed, filter pollutants, and

trap sediment. $82 to $560 per acre for grass filter strips $195 to $396 per acre for contour strips $692 to $3126 per acre for riparian forest buffers Conser vation tillage Reduce the amount of tillage and leave at least 30% cover from crop

residue after harvest and during winte r months. Soil loss is reduced by 50% compared to bare soil. $18 to $29 per acre for reduced till

Crop rotation Changes crops each yea r 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. $7 to $125 per acre

Grade Stabilization Structures Stabilize the grade and control erosion in natural or artificial

channels, to prevent the formation or advance of gullies, and to enhance environmental quality and reduce pollution hazards $21.8 per ton for check dams $48 per squar e foot for weir drop structures 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 gras s 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. $801 to $1,238 per acre

Source: USDA (2016)

E.2 Mining

Potential remedial actions to address the presence of cadmium or copper 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 ; and

 Abatement and mitigation of physical hazards represented by extant mine portals.

The cost of assessment and cleanup at abandoned mines varies widely . For example, ODEQ and federal agencies have spent more than $2 million for assess ment activities at the Formosa mine in southwestern Oregon, and cleanup activities could cost more than $20 million (BLM, no date)

. Furthermore, limited funding for cleanup and competing priorities among the more than 150 sites needing investigation or cle anup may hamper efforts to address this source of copper impairment (ODEQ, 2012).

E.3 Municipal Stormwater

Municipal stormwater BMPs control pollutants in runoff from urban roadways and developed residential and commercial areas. Urban areas can also include industrial sites, which alsoE

- 3 March 15, 2016

independent requirements to control pollutants in stormwater runoff. Municipalities and industr ial dischargers may need incremental BMP controls to reduce copper loadings in
stormwater runoff if baseline programs and future controls required under baseline total maximum daily loads ( TMDLs ) for a wide variety of contaminants including cadmium and
cop per are not sufficient to meet water quality criteria.

In general, all municipal separate stormwater sewer ( MS4 ) dischargers are already required to control pollutants to the maximum extent practicable (MEP) through their stormwater management programs (SW MP). ODEQ interprets the MEP requirement to require all controls that are reasonable and available. In some areas this level of control may be necessary to meet the baseline standards for cadmium and copper, in which case additional controls to meet revise d criteria would not be required because all reasonable and available controls are already being implemented. The same may be true of baseline efforts to minimize loadings of other metals such as mercury.

Another baseline activity has potential to further reduce copper loadings in stormwater . The national Copper

- free Brake Initiative seeks to substantially reduce the amount of copper in brake pad friction material by over an order of magnitude. This reduction could substantially reduce copper levels in urb an watersheds. Watershed modeling efforts for the San Francisco Bay simulated a wide variety of copper loadings sources throughout the watershed (Donigian and Bicknell, 2007). Median estimates of the contribution of brake pad use to copper loadings varied by watershed subregion, ranging from 15% to 57% of anthropogenic copper sources (excluding two remote, rural subregions with 0% brake pad loadings). Other anthropogenic sources in the study included direct releases to storm drains and surface waters (e.g., domestic water discharged to storm drains), releases to developed areas (copper

- containing pesticides, fertilizers, runoff from copper roof, gutters, copper

- biocides on composite roofs, and pressure

- treated wood), as well as background copper compounds na turally occurring in soils.

ODEQ (2014) identifies the most common copper sources at industrial sites as: vehicle brake pads, architectural copper, copper

- containing pesticides, marine antifouling coatings (especially at ship and boat building and repair yards), and vehicle servicing and cleaning. Thus, reductions in brake pad copper content will reduce stormwater loadings from industrial sites as well.

In a study of stormwater runoff from roadways, ODOT (2011) determined that runoff from urban sites with high annual average daily traffic (AADT) had consistently higher mean concentrations of measured dissolved and free forms of copper compared to non

- urban sites with lower AADT. Furthermore, ODOT determined that copper concentrations were consistently highe r in the f irst flush , indicating that BMPs targeting first flush may be important control measures for copper

.

Where baseline MEP controls or TMDL

- required controls are not sufficient to achieve water quality criteria, some incremental level of control may be necessary to meet the revised criteria. Thus, for any situation in which stormwater sources are specifically required to control cadmium or copper to levels that are lower than what would be necessary under the baseline, potential actions could include :E

- 4 March 15, 2016  I ncreased or additional nonstructural BMPs

– institutional, education, or pollution prevention practices designed to limit generation of runoff or reduce the pollutants load of runoff ; and

 S tructural controls

– engineered and constructed systems desig ned to provide water quantity or quality control.

E.3.1 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 tre atment or structural controls. In add ition to baseline efforts to reduce copper in brake pads, source controls may include: developing an outreach and education program to encourage substitutes to copper

- containing pesticides, nutrients, marine products, and building mate rials; adopting manda tory restri ctions on the use of such products; or increasing frequency, duration, or efficiency of maintenance practices such as pavement and street sweeping. The effectiveness of sweeping in reducing copper loadings may be relatively low, however (TCD Env ironmental, 2004). Furthermore, the cost

- effectiveness of changing sweeping practices may decline over time, however, as the copper content of brake pads decline.

The cost of outreach programs to encourage voluntary reductions in use of copper

- containing materials will vary by the research requirements, target audience size and type, and messaging content and delivery frequency. Similarly, costs for mandatory reduct ions are variable and higher because they can involve rule

- making efforts as well as ongoing compliance assurance measures.

E.3.2 Structural Controls

There are a variety of structural means to control the quantity and quality of stormwater runoff including in filtration systems, detention systems, retention systems, constructed wetlands, filtration s ystems, 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 a s 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 (fro m a few hours up t o 72 hours). However, t he primary drawback of infiltration systems is that they are not appropriate in areas where groundwater is us ed as a drinking water source. Additional constraints include identifying sites with appropriate soils and risk of failure d ue to clogging

. Exhibit E

- 2 summarizes the different types of infiltration systems.

Exhibit E

- 2

. Summary of Stormwater Infiltration Systems
System Type Description

Infiltration b asin Large capacity of infiltration systems.

Basins should be designed to drain within 72 hours in order to prevent mosquito breeding and possible odor. Removes pollutant and helps restore or maintain predevelopment hydrology.E

- 5 March 15, 2016 Exhibit E

- 2

. Summary of Stormwater Infiltration Systems
System Type Description

Porous p avement

s ystems Include porous asphalt, porous concrete, modular perforated concrete block, co bble pavers

with porous joints or gaps or reinforced/stabilized turf. 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 parki ng areas in commercial areas. Infiltration t renches and w ells 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 temporaril y retain it for later release. Detention systems do not retain a significant permanent pool o f water between runoff events. These systems provide quantity and quality control; however, re

- suspension of particulate matter often occurs. Exhibit E

- 3 summariz es the different types of detention systems.

Exhibit E

- 3 . Summary of Stormwater Detention Systems
System Type Description

Detention b asin Primary purpose is quantity control.

Typically designed to empty within 24 hours of a runoff event. 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).
Underground v aults, p ipes, and t anks Same primary purpose as basins

– storage to limit downstream effects due to high peak flow

rates. Limit ed 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 o f water between runoff events. The most common retention system i s a retention pond (wet pond). The primary pollutant remov al mechanism is sedimentation. These systems can also benefit from added biological an d biochemical pollutant removal mechanisms provided by aquatic plants and microorganisms. Compared to detention systems, re

- suspension 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 wat er surface area (for pond systems) or bottom (for meadow

- type systems) contains w etland 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 s ustain 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, microbi al de composition, and plant uptake. Pretreatment of runoff may be necessary for these systems (U.S. EPA, 1999).E

- 6 March 15, 2016

Filtration systems use some combination of a granular filtration media remove constituents found in runoff such as sand, soil, organic materia l, carbon, or membrane s. 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 Stormwater Filtration Systems
System Type Description

Surface s and f ilter Most common system is the Austin sand filter.

Runoff first enters a sedimentation basin where coarse particles are removed by gravity settling. The filter bed consists of sand with a gravel and perforated pipe under

- drain system to capture the treate d water. Underground v ault s and f ilter Common systems are the D.C. sand filter and the Delaware sand filter.

Basic design premise is the same as the surface sand filter.

Biofiltration/ b ioretention

s ystems Designed to mimic the functions of a natural forest ecosystem for treating stormwater runoff. 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 adsor ption, 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 she etflow (filter strips) runoff. Open channel vegetated systems are alternatives to the traditional curb

- and

- gutter and storm sewer conveyance systems. By conveying stormwater runoff in vegetated systems treatment, storage, and infiltration can be provided prior t o 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 Stormwater Vegetated Systems
System Type Description

Grass f ilter s trips Densely vegetated, uniformly graded areas that intercept sheet runoff from impervious surfaces

such as parking lots, highways, and rooftops. Designed to tra p sediments, to partially infiltrate runoff, and to reduce the velocity of the runoff. Frequently used as a pretreatment system prior to stormwater being treated by BMPs such as filters or bioretention systems.

Vegetated s wales Broad, shallow channels with a dense stand of vegetation covering the side slopes and channel

bottom. Designed to slowly convey stormwater 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 theE

- 7 March 15, 2016

drainage area, the level of watershed imperviousness, duration and volume of runoff, and the land use of contributing drainage areas. Ranges for measured copper remova l for various controls are summarized in Exhibit E

- 6. The implied removal efficiencies are generally less than 50% and higher for total copper than dissolved copper.

Exhibit E

- 6

. Sum mary of Copper Removal Effectiveness for Structural Stormwater Controls

BMP Type Dissolved Copper (influent / effluent μ g/L) Total Copper (influent / effluent μ g/L) Bioretention NA 18.0 / 9.3* Bioswale 8.9 / 7.9 12.0 / 7.7* Detenton Basin 5.3 / 4.8* 10.0 / 6.5* Filter Strip 11.1 / 5.3* 23.5 / 7.3* Media Filter 5.4 / 4.2 15.0 / 6.45* Porous Pavement 5.5 / 6.0 13.1 / 10.2* Retention Pond 7.5 / 5.0* 10.0 / 6.0* Wetland Basin 5.9 / 5.0 6.12 / 4.0* Wetland Channel NA 10.0 / 7.55 Source: Wright Water Engineers and Geosyntec Consultants (2011)

. NA=data not available *=statistically significant copper reduction

The cost of constructing stormwater controls depends on site conditions and drainage area. Furthermore, there are often economi es of scale, making it difficult to develop a unit construction cost. The Portland Bureau of Environmental Services (BES) has an extensive
stormwater BMP program (Portland BES, 2014) that includes demonstration projects aimed at reducing the volume of stormwater and pollutant loadings entering its combined sewer system. The project BMPs provide runoff volume control and water quality benefits, while improving the existing landscape:

 Ecoroof

- cover roof top with vegetation to absorb/retain stormwater ; roofscaping covers and protects the waterproofing and structural components of a roof, which extends the life of a conventional roof ;

 Curb extensions

– landscaped add

- ons to existing curbs designed to captu re runoff from streets and side walks; can increase pedestrian safety ;

 Stormwater planters

– vegetative landscaping added to parking gara ges and lots that capture and infiltrate runoff from paved surfaces; adds attractive green space to urban

areas ;

 Pervious pavers

– use of paving blocks (rather than impervious asphalt) that allow
stormwater infiltration ; and

 Landscape infiltration basin

– landscaped basin and captures stormwater

.

Exhibit E

- 7 provides a summary of various stormwater BMP demonstration projects im plemented throughout Portland. Portland BES and EPA grants funded some part of most of the p rojects.E

- 8 March 15, 2016 Exhibit E

- 7 . Portland

- Area Stormwater BMP Costs
BMP Description Unit Cost ($/square foot) Benefit Ecoroof $6 to $15 Reduces stormwater runoff from roof area

Curb extensions $1.83 to $3.64 Reduces peak flows and retains stormwater volumes to reduce combined sewer overflows Stormwater planters $1.68 to $4.65 Reduces peak flow and treats stormwater Pervious pavers $6.00 to $31.58 Complete onsite stormwater treatment Multiple integrated structures (infiltration basins, soakage trenches, swales, vegetated filter, and/or sand filter) $2.60 to $3.94 Complete or nearly complete onsite stormwater treatment

Sources: ESG (2014), Portland BES (2006; 2005a; 2005b; 2005c; 2004a; 2004b; 2003a; 2003b; 2002a; 2002b; 2002c; 2002d; 2002e; 200 2f; 2001; 1999).

E.4 References

Donigian, A.S. and B. R. Bicknell. 2007. Modeling the Contribution of Copper from Brake pad Wear Debris to the San Francisco Bay. Prepared for Association of Bay Area Governments and California Department of Transportation. Onl ine at http://www.suscon.org/bpp/pdfs/WatershedModelingFinalReport100207.pdf

. EcoMetrix Solutions Group (ESG). 2014. Cost Analysis for the Portland Ecoroof Incentive. Prepared for City of Portland Environmental Services. Online at http://www.portlandoregon.gov/bes/article/522380

. Oregon Department of Agriculture (ODA). 2014. A Landowner’s Guide to Oregon’s Agricultural Water Quality Management Program. Online at http://www.oregon.gov/ODA/shared/Documents /Publications/NaturalResources/WaterQualityan dAgriculture.pdf

. Oregon Department of Environmental Quality (ODEQ). 2014. Fact Sheet: Reducing Copper in Industrial Stormwater. Online at http://www.deq.state.or.us/wq/stormwater/docs/ReduceCopperIndSW.pdf

. Oregon Department of Environmental Quality (ODEQ). 2012. Fact Sheet: Cleanups of Abandoned Mines in Oregon Complicated by High Cost and Lack of Funding. Online at http://www.deq.state.or.us/lq/pubs/factsheets/cu/AbandonedMines.pdf

. Oregon Department of Forestry (ODF). 2014. Oregon Department of Forestry Forest Practice Administrative Rules and Fore st Practices Act. Online at http://www.oregon.gov/ODF/Documents/WorkingForests/FPARulebook.pdf

. Oregon Department of Transportation (ODOT). 2011. Copper Speciation in Highway Stormwater Runoff as Related to Bioavailability and Toxicity to ESA

- Listed Salmon. Final Report, SPR663. Online at http://www.oregon.gov/ODOT/TD/TP_RES/docs/reports/2 011/spr663copperspec.pdf

.E

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Portland Bureau of Environmental Services (BES). 2014. Stormwater Management Manual. Online at https://www.portlandoregon.gov/bes/64040

.

Portland Bureau of Environmental Servi ces (BES). 2006. East Holladay Park. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2005a. NE Fremont Street Green Street P roject. Online at h ttp://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.portlandon line.com/bes/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2005c. ReBuilding Center. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2004a. SE Ankeny Green Street Project. Online at http://www.portlandon line.com/bes/i ndex.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2004b. Mississippi Commons. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

.

Portland Bureau of Environmental Services (BES). 2003a. NE Siskiyou Green Street Project. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2003b . Multnomah Building Green Roof. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2002a. Liberty Centre Parking Garage. Onlin e at http://www.portlandonline.com/b es/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2002b. Oregon Natural Resources Council. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2002c. Barrington Square Apartments. Online at ht tp://www.portlandon line.com/bes/index.cfm?c=44463&

. Portland Bureau of Environmental Services (BES). 2002d. Page 19 LLC. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

.

Port land Bureau of Environmental Services (BES). 2002e. Natural Resource Program Eastside Field Office. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

.

Portland Bureau of Enviro nmental Services (BES). 2002f. Reed College Apartments. Online at http://www.portlandonline.com/bes/index.cfm?c=444 63&

. Portland Bureau of Environmental Services (BES). 2001. Wattles Boys a nd Girls Club. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

.E

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Portland Bureau of Environmental Services (BES). 1999. Hamilton West Apartments Ecoroof. Online at http://www.portlandon line.com/bes/index.cfm?c=44463&

. TDC Environmental. 2004. Copper Sources in Urban Runoff and Shoreline Activities.

U.S. Department of the Interior, Bureau of Land Management (BLM ). no date. Formosa Mine (fact sheet). Online at http://www.blm.gov /or/landsrealty/aml/formosa.php

. U.S. Department of Agriculture (USDA). 2016. 2016 EQIP Practice Payment Lists. Online at http://www.nrcs.usda.gov/wps/portal/nrcs/m ain/or/programs/financial/eqip/

. United States Environmental Protection Agency (U.S. EPA). 1999. Preliminary Data Summary of Urban Storm Water Best Management Practices. August.

Wright Water Engineers and Geosyntec Consultants. 2011. International Stormwater Best Management Practices (BMP) Database. Online at http://www.bmpdatabase.org

.