ECONOMIC ANALYSIS FOR THE PROPOSED RULE: AQUATIC LIFE CRITERIA

FOR COPPER AND CADMIUM IN OREGON

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. 20460
Prepared by:

Horsley Witten Group, Inc.

In Partnership with:

Abt Associates and Tetra Tech

Horsley Witten Contract Number: EP-C-12-006
i March 15, 2016

TABLE OF CONTENTS

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 Agriculture 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 Revised 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 Potential 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 Response to Revised Requirements....................................................................... 6-5

7.0 References......................................................................................................................... 7-1
ii 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 Economic Impacts

Appendix E: Best Management Practices and Unit Costs for Nonpoint Sources
iii March 15, 2016

LIST OF EXHIBITS

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 Default 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 under 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 10th Percentile Ecoregional DOC Data............................................. 4-15

Exhibit 4-11. RPA Using 50th Percentile Ecoregional DOC Data............................................. 4-16

Exhibit 4-12. Estimated One-Time Costs of Alternative Compliance Mechanisms by Discharge 

Flow Category ($2015)...................................................................................................... 4-16

Exhibit 5-1. Summary of Select Ambient Monitoring Data1....................................................... 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 Attainment Status .......................................... 5-5

Exhibit 6-1. Summary of Point Source Cost Estimates for End-of-Pipe Treatment (3% discount 

rate; millions of $2015)........................................................................................................ 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-2
iv 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 Revised 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

Exhibit 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

Exhibit 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 WastewaterC-2

Exhibit C-2.Cost Estimates for Reverse Osmosis System.......................................................... C-3

Exhibit C-3. Comparison 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-3
v 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 Systems..........................................................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-8
vi March 15, 2016

ACRONYMS AND ABBREVIATIONS

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 Dissolved 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 Department of Environmental Quality

ODF Oregon Department of Forestry

POTW Publicly owned treatment works

P2 Pollution prevention
vii 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

SWPCP Stormwater Pollution Control Plan

SWMP Stormwater Management Program

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

WQBEL Water quality based effluent limit

WQC Water quality criteria

WQS Water quality standards

WRF Water Reclamation Facility

WWTP Wastewater treatment plant

ZID Zone of initial dilution
ES-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 water 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 criteria to EPA Region 10 for review and 

approval. Under Section 303(c) of the Clean Water Act (CWA), EPA disapproved 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 dischargers 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 limits (WQBELs). EPA estimates the 

incremental impacts of the proposed rule against a baseline of full implementation of currently 

approved criteria. 

EPA is proposing an acute cadmium criterion that uses ambient hardness data to determine the 

protective level 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 which data Oregon would 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 applications 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 stormwater and 

nonpoint sources discharging to surface waters. However, the data and information needed to 

evaluate those potential control needs are more limited. Thus, EPA identified the types of 

controls and costs that may be incurred for these sources but did not develop statewide control 

cost estimates. There may be some incremental regulatory program costs associated with an 

increased 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 provide 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) recommendations 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), stormwater discharges, and nonpoint sources (e.g., agricultural runoff, 

forestry, mines, and atmospheric deposition). Oregon regulates point source and stormwater 

discharges under the NPDES permit program, and addresses nonpoint 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 and 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.

Proposed Revised Criteria

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

for Cadmium1. 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-cadmium
ES-3 March 15, 2016

 

 

 

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). 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 concentrations based 

on applying the relevant 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 effluent and ambient data obtained 

from ODEQ for the facilities reporting monitoring results for cadmium or copper. EPA first 

conducted 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 an 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 value contained in the fact sheet for the existing discharger permit 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 these derived numeric criteria concentration values 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 these values as the “economic 

analysis criteria”.

ODEQ (2012d) 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 meeting 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, inflow 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, total 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 also 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 

stormwater dischargers to achieve numeric WQBELs for metals. In theory, the regulatory 

baseline for evaluating the potential impact of the revised criteria includes consideration of

requirements for nonpoint sources and stormwater 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 either metal. Thus, the extent of 

incremental impairment for cadmium or copper beyond baseline impairment is uncertain. 

Nevertheless, instream 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 water 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. The 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 implementation 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 focus 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. The 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 permit limits below current effluent levels, indicating that

the proposed criteria may result in control costs. 
ES-5 March 15, 2016

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

cost estimates for pollution prevention (P2) programs that 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 ES-1. These are cost estimates for the major dischargers potentially 

affected by the proposed criteria. EPA did not identify minor dischargers that might be affected 

by the proposed criteria.

Exhibit ES-1. Summary of Potential Annual Point Source Costs (millions 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 effluent loads. In addition to these costs, 

EPA estimated costs to indirect dischargers to municipal wastewater treatment plants under a 

copper P2 program (provided in Appendix B). However EPA was unable to estimate how many 

of those indirect dischargers would be affected by the proposed criteria so those costs are not 

included in Exhibit ES-1 above. 

Nonpoint Source and Stormwater Costs

Under the baseline, control costs for nonpoint sources (e.g., agricultural and forest operations; 

contamination from historic mining sites) and municipal stormwater include those needed to 

reduce instream pollutant levels to baseline criteria or TMDL targets. There could also be 

incremental costs to nonpoint and stormwater 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;

 Mining – cleanup and remediation including excavation and onsite capping of 

contaminated soils, capping of onsite solid waste mining debris, regrading of tailings 

to mitigate mass wasting and off-site migration, and abatement and mitigation of 

physical hazards; and

 Stormwater discharges – increased or additional nonstructural best management 

practices (BMPs) (e.g., institutional, educational, 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). 

Government Regulatory Costs

ODEQ already has implementation procedures for hardness-based criteria such as the proposed 

acute cadmium criterion, but may need to adopt new implementation procedures to support use 
ES-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 

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. 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 example, average 

TMDL development costs range from $37,000 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. 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).

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 ecoregions, 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 could 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 address issues.

 Lack of available in-stream monitoring data limits the estimation of potential 

statewide costs associated with reductions 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 addressed by one TMDL.
ES-7 March 15, 2016

 Implementation 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 guarantee 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 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 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 Background

The Clean Water Act (CWA) directs states, 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, state WQS must include: (1) designated uses for 

all water bodies within their jurisdictions, (2) water quality criteria sufficient to protect the most 

sensitive of the uses, and (3) an antidegradation policy consistent with the regulations at 40 CFR 

131.12. The CWA also requires states to hold public hearings once every three years for the 

purpose of reviewing applicable WQS and, as appropriate, modifying and adopting standards.

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 criteria 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 

information, 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. The estimates of statewide control costs 

in this analysis reflect the potential 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 also 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, EPA identified the types 
1-2 March 15, 2016

of controls and costs that may be incurred for these sources, but did 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 from the control actions. 

Similarly, adverse economic impacts (municipal and industrial expenditures financed through 

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

profits to sectors supplying treatment 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 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 – describes 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: Proposed Revised Criteria – outlines 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. Oregon will determine site-dependent WQC.

Section 4: Method for Estimating Potential Costs: Point Sources – describes the method for 

estimating point source control costs for potential revisions to NPDES permits to meet proposed

criteria.

Section 5: Method for Estimating Potential Costs: Nonpoint Sources – describes the method 

for identifying control costs associated with proposed criteria for nonpoint sources.

Section 6: Potential Control 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 references used in the analysis.

The appendices provide detailed analyses and additional information:

Appendix A: provides data and information on individual facilities, and analyses of potential 

impacts under the different scenarios.
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Appendix B: describes pollution prevention programs and estimated costs.

Appendix C: provides details for various end-of-pipe treatment technologies, including 

estimated costs, where available.

Appendix D: describes the applicable analyses for obtaining a temporary variance from 

WQBELs based on economic factors.

Appendix E: provides descriptions and costs for best management practices for nonpoint 

sources and stormwater 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 impairments in Oregon waters.

2.1 Water Quality Criteria and Implementation Procedures

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. The equation for the dissolved criterion is: 

 

 

 

OAR 340.041 specifies the procedures for applying water quality criteria. 

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, stormwater 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 generally 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). Stormwater near municipal and 

industrial facilities 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 heavy
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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 (ICIS-NPDES) database indicates 

that there are individual NPDES permits for 362 municipal and industrial dischargers in Oregon.

Exhibit 2-1 shows the number of facilities by type (major/minor) and industrial category 

specified in ICIS-NPDES.
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Exhibit 2-1. NPDES Permitted Direct Dischargers in Oregon

SIC SIC Category Title1 Majors Minors

09 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 Specified2- 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. Excludes facilities with Water Pollution Control Facility (WPCF) permits, 

which are applicable to facilities that do not discharge, as well as general permits. Facility list also excludes 18 sewerage 

entities currently classified as ‘unpermitted’ in the ICIS-NPDES database.

2. The NPDES-permitted entities without SIC code identifiers are municipal separate stormwater systems

ODEQ issues NPDES general permits for a wide variety of discharger categories, including

cooling water/heat pumps, filter backwash, fish hatcheries, log ponds, boiler blowdown, seafood 

processing, suction dredges, stormwater from gravel mining, construction activities, industrial 

stormwater, oily stormwater runoff, tank cleanup and treatment of groundwater, washwater, 

noncontact geothermal water, and small municipal separate storm sewer systems (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 previously 
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covered 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 μg/L that applies to areas outside the pesticide treatment area and outside the 

treatment period (ODEQ, 2012b). ODEQ has also proposed revisions to the general permit for 

discharge of stormwater from gravel mining facilities. The proposed revisions, which have yet to 

be finalized, include a requirement 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, 2012c).

2.2.2 Stormwater

Stormwater discharges are generated by precipitation and runoff from land, pavements, building 

rooftops, and other surfaces. Urban stormwater from municipal and industrial areas may 

contribute metals such as cadmium and copper to surface waters.

Potential sources of copper in urban stormwater include copper worn from automobile brake 

pads, leached from architectural materials or drinking water distribution systems (e.g., via 

landscape watering), or settled on surfaces throughout the watershed via air deposition. Other 

sources include soil erosion and copper-based pesticide use. 

ODEQ regulates stormwater discharges from MS4s through general permits. The MS4 permits 

require the discharger to develop and implement a stormwater management program (SWMP), 

with the goal of controlling pollutant discharges to the maximum extent practicable (MEP).

ODEQ interprets the MEP requirement to require all controls that are reasonable and available.

The management programs specify the best management practices (BMPs) that will be used in 

the following areas: public education and outreach; public participation and involvement; illicit 

discharge detection and elimination; construction runoff control; post-construction runoff 

control; and pollution prevention and good housekeeping. Permittees implement BMPs through 

an adaptive management or iterative approach.

ODEQ has issued four area-wide “Phase I” MS4 permits (ODEQ, 2016a, 2016b). Phase I MS4s 

are those systems serving populations equal to or greater than 100,000. “Phase II” (or “small”) 

MS4s are those systems serving municipalities with populations less than 100,000 located within 

Census Bureau-defined urbanized areas. There are 19 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 as scrap yards, landfills, certain sewage treatment 

plants, and hazardous waste management facilities may have stormwater requirements in their 

NPDES permits. ODEQ requires industrial stormwater dischargers to develop a Stormwater 

Pollution Control Plan (SWPCP) that includes a monitoring plan and discussion of the site 

controls that the discharger will implement to prevent stormwater pollution (ODEQ, 2004). As 

noted above, ODEQ has proposed revisions to the general permit for stormwater discharges from 

gravel mining, and these 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.
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2.2.3 Agriculture and Forestry

Cadmium and copper may be present in agricultural fertilizers or pesticides and can reach 

surface waters through irrigation return flow, stormwater 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 million pounds of coppercontaining active ingredients 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 be registered for sale or distribution (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 phosphorus or other micronutrients (ODA, 2011). 

ODA’s Agricultural Water Quality Management Program (AWQMP) is charged with assisting 

the agriculture industry in reducing pollution from agricultural sources. The legal foundation of 

the AWQMP is the 1993 Agricultural Water Quality Management Act (SB1010) (ODA, 2014).

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 38 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 38 local advisory committees have approved 

Agricultural Water Quality Management Area Plans along with enforceable administrative rules 

to ensure all landowners do their part to avoid and resolve water quality problems. These plans 

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, to 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 Practices Act (FPA). ODF administers forest practice chemical rules to 

ensure that chemicals used on forestland do not enter surface waters in quantities that would 

degrade water quality or be harmful to the overall maintenance of terrestrial wildlife or aquatic

life (ODF, 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 water
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 Operator must conduct mixing, transfer, and staging of chemical applications in 

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

water 

 Chemical label requirements must be followed 

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

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

herbicides, rodenticides, and biological insecticides; and 100 feet for aerial 

applications of fungicides and nonbiological insecticides) (ODF, 2007).

2.2.4 Mines

Both currently active and abandoned/inactive mine 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 activities 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 leeching of 

heavy metals from excavated rock is especially problematic when mine wastes with high acidgenerating potential 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 Oregon for possible further investigation or cleanup, 

and have initiated assessment of about 95 mines (ODEQ, 2012a). 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 nonpoint 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 

stormwater 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 water 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 designated uses and water quality standards to justify this classification (ODEQ, 2011).
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 Category 3: Insufficient 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 nonattainment of a criterion and a potential concern.

o 3C: Impairing pollutant unknown.

 Category 4: Data indicate that at least one designated use is not supported but a 

TMDL is not needed. This includes:

o 4A: TMDLs that will result in attainment of water quality standards have been 

approved.

o 4B: Other pollution control requirements are expected to address pollutants 

and will result in attainment of water quality standards.

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

considered pollutants).

 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 disapprove 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 approved 303(d) list based on 

the 2010 assessment and the proposed 303(d) list based on the 2012 water quality assessment. To 

assess the potential impacts of the proposed rule, this analysis uses as the 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. 

Exhibit 2-2. Summary of Oregon’s 303(d) List of Impaired 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: ODEQ (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 baseline 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 incremental costs of the proposed rule.
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3.0 Proposed Revised Criteria

EPA is proposing revisions to three of Oregon’s freshwater aquatic life criteria: the acute 

cadmium criterion, the acute copper criterion, and the chronic copper criterion. The acute 

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

Cadmium3, while the acute and chronic copper follow the U.S. EPA’s 2007 304(a) recommended 

criteria, which are based on the BLM (U.S. EPA, 2007). The sections below provide descriptions

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 following formula:

 

 

 

For example, at hardness values of 25, 50, 100, and 200 mg/L as CaCO3 the one-hour average 

concentrations or acute criteria are 0.49, 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 hardness values, the minimum hardness value contained in 

the fact sheet of the existing permit package, 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 with 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 values 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-cadmium
3-2 March 15, 2016

concentration expressions for the acute and chronic copper criteria using the BLM requires ten

input parameters characterizing 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 and 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., 10th percentile) Level III ecoregion-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, 2016a). 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 Ecoregions in Oregon

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

For the purpose of applying BLM criteria 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 tests reported to ODEQ, and the U.S. Geological Survey’s National Water 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 10th percentile values for 

temperature, pH, and DOC for each ecoregion (Exhibit 3-2). 
3-3 March 15, 2016

Exhibit 3-2. Estimates of 10th Percentile 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 Plains (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: 10th percentile estimates based on water quality data provided by ODEQ.

For the remaining water quality parameters, EPA used the 10th percentile Level III ecoregional 

default values (U.S. EPA, 2016a). Exhibit 3-3 provides the default values for the Level III 

ecoregions in Oregon. Using 10th percentile ecoregion-level data potentially results in criteria

outputs that are more conservative than using site-specific data for many waters within an 

ecoregion. Therefore, it is likely that the impact analysis overestimates the potential impact of 

the proposed copper criteria.

Exhibit 3-3. Summary of Default Values for OR Level III Ecoregions

Ecoregion Ca (mg/L) Mg (mg/L) Na (mg/L) K (mg/L) Alk (mg/L 

as CaCO3)

SO4 (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; SO4 = 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 concentration 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 discharger. EPA also 

used these values to evaluate the potential for incremental impaired waters.
3-4 March 15, 2016

Exhibit 3-4. Estimates of Acute and Chronic BLM-based Copper Criteria 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 proposing that ODEQ use the BLM with a preference for site-specific ambient 

data. The method EPA employed for this analysis is intended to produce a conservative estimate 

of impacts. The 10th percentile of ecoregion-based BLM inputs may be significantly lower than 

site-dependent BLM inputs. 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 Method 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 Control costs for municipal and industrial point sources may result 

from changes to individual NPDES permit requirements.

4.1 Identification of Potentially Affected Permittees

Factors that may affect the potential magnitude of control costs include flow and facility type. 

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

may decrease due to economies of scale. An industrial facility may incur different costs than 

municipal wastewater facilities. Minor dischargers typically do not have monitoring 

requirements for toxic pollutants, and may not contribute significantly to instream loads even if 

such pollutants were present in the effluent from these facilities. Thus, the potential for minor 

facilities to incur costs as a result of the proposed criteria is low.

As shown in Exhibit 2-1, there are 69 major (50 municipal and 19 industrials) and 293 minor 

(134 municipal and 159 industrials) individually permitted wastewater discharges to waters for 

which the proposed cadmium and copper criteria would apply. EPA uses the designation of 

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

discharges with a major rating code (based on the presence of toxics and size of discharge flow) 

over a specified value (U.S. EPA, 2016b).

EPA initially used ICIS-NPDES to identify facilities 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, there 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 biosolids data, 

facilities where all reported results were non-detect, facilities with less than three data points, and 

others where there were insufficient or inadequate data to perform the analysis. Based on this 

review, EPA proceeded with evaluating 33 facilities, 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, 2012d). 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 of 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 stormwater 

(pesticides, fertilizers, oils, salt, sediment, litter and 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 evaluated in this analysis have copper effluent limits in their current 

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 (2012d) provides permit writers with instructions for determining whether dischargers 

have reasonable potential (RP) to cause or contribute to an exceedance of WQS. ODEQ 

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 analysis 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 copper concentrations, receiving 

water characteristics, ambient parameter concentrations, and dilution factors. EPA gathered these 

data from a variety 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. Oregon 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 however 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 approved 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 cadmium 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 points 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 acute or chronic criteria, 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 zone 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 

dischargers have RP. The economic analysis acute 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. Results 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 was RP, EPA used Oregon DEQ’s method to calculate average monthly and 

maximum daily effluent limits. The Oregon 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:

WLAchronic= Dmzx x (WQCchronic – Cb) + Cb

and

WLAacute= Dmzx x (WQCacute – Cb) + Cb

where,

WLA = Wasteload allocation

Dmzx = Dilution factor (Qeff + Qrecevingwater)/Qeff

WQC = Water quality criterion

Cb = Ambient background concentration.

A corresponding long-term average (LTA) is calculated from each WLA using the following 

equations:
4-6 March 15, 2016

LTAa = WLAacute x e[0.5σ2 – zσ]

LTAc = WLAchronic x e[0.5σ42 – zσ

4

]

where:

σ

2 = ln(CV2

+1) where CV is the coefficient of variation

σ4

2

= ln(CV2/4 +1)

Z=1.645 for 95th percentile probability basis (chronic), and 

Z= 2.2326 for 99th 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, including the average monthly limitation (AML) 

and the maximum daily limitation (MDL), shown in Exhibit 4-5.

Exhibit 4-5. Estimated Copper WQBELs for Facilities Potentially Affected by the 

Baseline Aquatic Life Criteria

Facility AML under Baseline Criteria (ug/L) MDL 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 AML under Proposed Criteria (ug/L) MDL 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 Control 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 efficiency) 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 mechanisms (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 alternative 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 treatment process as a result 

of chemical additions or treatment techniques. 

Process optimization usually involves process analysis and process modifications. Process 

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

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

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

operator training, response to changes in wastewater quality, maintenance activities, automation, 
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 pollutant 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 by 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 existing 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 existing treatment processes are already performing at their feasible limits. Also, 

because most conventional treatment technologies are designed to maximize removal of 

suspended solids, process optimization aimed at increasing those removal efficiencies may not 

result in significant reductions for 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 option. 

Source control could be used alone, or in conjunction with process optimization. The feasibility 

of source control efforts depends on the makeup of the influent and potential sources of copper. 

For example, certain industrial processes may use copper, or copper may be a bi-product of other 

processes. Thus, for municipal facilities treating such industrial waters, a feasible 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 implemented. 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 groundwater 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 copper 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 – preferably 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 control the 

source, time required to produce desired results), whether efforts will be voluntary or 

regulatory, and who will execute each program effort;

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

costs;

 Implement program – starting with the most cost-effective measures and modifying 

activities and approach based on measured results;

 Assess progress – including both successes and failures (i.e., lessons learned) 

throughout the duration of the program;

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

and

 Develop a contingency plan – including a description of actions to be taken if plan 

efforts are unsuccessful.

The focus and approach of the program will be different for each community and sector targeted. 

As such, plans vary in complexity and in the resources necessary to achieve the goals set forth. 

The reductions in copper achievable through P2, and thus the ability to meet numeric effluent 

limits using P2 alone, will vary based on existing treatment processes, the makeup and size of the 

service area (e.g., number of potential copper sources), and the level of P2 already being 

implemented in the community. Large municipal facilities with numerous potential copper

sources may see significant 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 levels in drinking 

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 the influent copper load. For example, sources 

from the residential sector are not as easy to identify as those from industrial and commercial 

sectors since they may originate from a wide range of products as well as residential water pipes. 

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

There 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 for pollutant-specific 

P2 costs as a budget item that can be verified apart from other base program costs. However, the 

experiences of facilities that have already developed P2 programs provide some information on 

likely program components and costs.

Community size is likely to be a factor affecting P2 program costs. For example, it is unlikely 

that a minor facility would need the same resources for program development and outreach 

efforts as a large major municipal facility because the minor facility’s service area is smaller and 

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

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

program development and outreach materials.

For this analysis, 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 

without specific information on the types of industrial dischargers 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 (ODEQ, 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 municipal 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 programs 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 facilities 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 

on their collection system activities, which includes maintenance, potential collection system 

failure, as well as efforts to reduce I&I (ODEQ, 2016f). Under OAR 340-041-0061(9), 

dischargers with a separate sanitary sewer system experiencing significantly higher 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 costeffective compared to infiltration (ODEQ, 2016f).

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 renewal. 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 criteria, 

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-prohibitive (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 point 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 rates 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. Exhibit 4-8 summarizes
4-12 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 Technologies

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 mechanisms: variances, applying criteria with sitespecific inputs, and dilution credits.

4.4.4.1 Variances

OAR 340-041-0059 allows the state’s EQC to grant point source dischargers variances from 

meeting water quality standards if attaining the water quality standard is not feasible for one of 

the following reasons:

1. Naturally occurring pollutant concentrations prevent the attainment of the use;

2. Natural, ephemeral, intermittent, or low flow conditions or water levels prevent the 

attainment of the use, unless these conditions may be compensated for by the discharge 

of sufficient volume of effluent discharges to enable uses to be met without violating 

state water conservation requirements;

3. Human-caused conditions or sources of pollution prevent the attainment of the use and 

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

in place;

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

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

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

5. Physical conditions related to the natural features of the water body, such as the lack of a 

proper substrate, cover, flow, depth, pools, riffles, and unrelated to water quality preclude 

attainment of aquatic life protection uses; 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. Exhibit 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 Hours Cost1

Literature search 180 $22,500

Write up and evaluation of theory and performance data from search 100 $12,500

Evaluation 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; 2015a) 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 public and private sector entities. Following EPA (1995), dischargers conduct a 

two-step analysis, first determining whether the control costs would have a substantial adverse 

financial impact 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 preliminary 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 (larger facilities may have more alternatives and issues to 

evaluate, and more capabilities compared to smaller facilities). To provide some indication of the 

potential magnitude of such costs, EPA assumed that dischargers will likely complete the studies 

and variance application within a relatively short time period (e.g., 4 months) with contract labor.

Assuming that the scope of a study for large facilities (>20 mgd) could warrant a level of effort 

equivalent to approximately 4 full time consultants over this amount of time (e.g., 680 hours per 

consultant), costs would be approximately $340,000 (at an average hourly wage rate of $125, 

including benefits, overhead, and fee5). EPA assumed that the level of effort involved in 

completing studies and applications would be one-third less for medium-sized facilities (>5 mgd 

and <20 mgd) (i.e., 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. Assuming the State’s review of the 

engineering cost and financial impact analysis could require up to 100 hours6and 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 the review process could take 32 hours, including validating source data, checking calculations, 

and evaluating the engineering design and the conclusions regarding potential financial and community impacts.

ODEQ’s variance procedures also require a notification and public comment period. Based on time estimates to 

review and respond to comments on an individual permit issue to a single concentrated animal feeding operation 

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

require an average of 68 hours. Thus, the total time requirement for each request is 100 hours.
4-14 March 15, 2016

hourly wage rate for an environmental engineer at ODEQ is approximately $47 including 

benefits (ODEQ, 2010; BLS, 2015a)

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 likely 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 program 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 mixing 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 

capacity 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 their 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 limitations. 

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 collection 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 develop 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., VisualPlumes) 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, for 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 10th percentile of ecoregional 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 analysis criteria based on the 50th percentile ecoregional

value for DOC for eight municipal facilities and reanalyzed the discharges for reasonable 

potential. The economic analysis criteria developed using the 50th percentile ecoregional DOC 

values resulted in two POTWs (City of Medford RWRF and Kellogg Creek WWTP) that had 

reasonable potential to exceed the copper criteria using the conservative 10th percentile 

ecoregional data no longer having reasonable potential and not requiring final effluent limitations 

for copper (Exhibit 4-11). The remaining six facilities would continue to require final effluent 

limitations for either the acute or chronic copper criterion. However, in 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 highly sensitive to DOC 

concentrations. The tables below summarize the findings:

Exhibit 4-10. RPA Using 10th Percentile Ecoregional 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

AML 

(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 2.39
4-16 March 15, 2016

Exhibit 4-11. RPA Using 50th Percentile Ecoregional 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

AML 

(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 that 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. Estimated 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 $230,000 $345,000
5-1 March 15, 2016

5.0 Method for Estimating Potential Costs: Nonpoint Sources

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, the 

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 instream monitoring data to assess the potential impacts that changes in cadmium and 

copper criteria may have on water quality attainment. The data came from ODEQ’s LASAR 

database (ODEQ, 2016a). Although it is not representative of all the state’s surface waters, 

LASAR contains 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 database 

for the period from January 1, 2000 to December 31, 2012. This is a reasonable timeframe to 

potentially include all of the state’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 state’s nine ecoregions (Exhibit 3-2). Exhibit 5-1 provides a 

summary of the data.

Exhibit 5-1. Summary of Select Ambient Monitoring Data1

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 (2016a); 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 μg/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 assigned each sampling station to one of the following categories:

 Potentially impaired: two or more sample results collected on different sampling 

dates exceeded the proposed criteria;

 Impairment uncertain: only one sample result exceeded proposed criteria; 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 2012 list. 

5.2.1 Cadmium

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 that 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 sitedependent 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, Oregon 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 (2016a); data from 2000 to 2012. Does not include stations directly downstream of point sources. 

To 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

Exhibit 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 exceeding 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 body 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 Category and 2010 Assessment Status

Impact Analysis 

Exceedance 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 represent 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 bodies; 48 of the 82 sampling stations occur along 15 

rivers. The number of TMDLs potentially needed to address exceedances at all 48 stations is not 

known.
5-4 March 15, 2016

Exhibit 5-4. Sampling Station Exceedance Results for Proposed BLM-Based Copper WQC 

Compared to Approved 2010 Water Quality Attainment Status

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 classified 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 Exceedance Category and 2012 Assessment Status

Impact Analysis 

Exceedance 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 94
5-5 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 basins 

along with additional proposed 303(d) listed waters in the Willamette basin.

Exhibit 5-6. Sampling Station Exceedance Results for Proposed BLM-Based Copper 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

Data 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 controls beyond those specified under existing state and federal 

regulations and plans;

 Mining – cleanup and remediation including excavation and onsite capping of 

contaminated soils, capping of onsite solid waste mining debris, regrading of tailings 

to mitigate mass wasting and off-site migration, and abatement and mitigation of 

physical hazards; and

 Stormwater discharges – increased or additional nonstructural BMPs (e.g., 

institutional, educational, or P2 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). 

Control of nonpoint sources of the pollutants of concern could reduce costs 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 Section 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 from $27,000 to $29,000 (in 2000 

dollars) or $37,000 to $40,000 (in 2015 dollars).8EPA’s analysis of the impact of the BLMbased copper criteria defined using ecoregional estimates indicated potential for a net increase in 

the number of monitoring stations meeting 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 from $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 

stormwater discharges.

Ongoing efforts to reduce 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 neighboring 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 organizations9signed 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 water 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 Manufacturers 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, 

aftermarket 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 identify substitutes with similar 

braking properties, a key element of the MOU is sharing information on research and testing of 

replacement brake friction materials. Other elements include product labeling and educational 

outreach. Although the potential impact 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 March 15, 2016

6.0 Potential Costs

This section summarizes the estimates 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 existing 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 

baseline criteria. Appendix A provides facility-specific information on baseline control 

assumptions and cost estimates.

The analysis of the potentially affected dischargers also indicated that an incremental level of 

control may be needed to achieve proposed BLM-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 potentially 

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 $18.2
6-2 March 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 costs 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 mechanism 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. Exhibits 

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 associated 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 $100,000 
6-3 March 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 “annual” 

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 criteria. 

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 these 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 indirect 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 stormwater include those needed to 

reduce instream pollutant levels to baseline criteria or TMDL targets. There could also be 

incremental costs to nonpoint and stormwater 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;

 Mining – cleanup and remediation including excavation and onsite capping of 

contaminated soils, capping of onsite solid waste mining debris, regrading of tailings 
6-4 March 15, 2016

to mitigate mass wasting and off-site migration, and abatement and mitigation of 

physical hazards; and

 Stormwater discharges – increased or additional nonstructural best management 

practices (BMPs) (e.g., institutional, educational, 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 such 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 develops 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 $37,000 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. 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 would 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 meeting 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 approach 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. Without data, 

EPA is not able to determine whether the facility meets baseline standards and whether 
6-5 March 15, 2016

incremental controls would be needed to meet the revised criteria. Thus, costs could be higher 

than shown if additional data indicate a need for pollutant reductions.

For several facilities with effluent data, the data available are limited. For example, there is only 

one data point for each pollutant for Oregon Steel Mills. 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 concentrations.

6.4.1.3 Nonpoint Sources

The lack of available in-stream monitoring data for some water bodies and the use of ecoregionspecific criteria values instead of site-dependent copper criteria prevent reliable estimation of 

incremental impairment and, therefore, estimation 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 Brake 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 regarding 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 been 

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

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adjusted), Management, professional, and related. Online at 

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Bureau of Labor Statistics (BLS). 2015b. Employer Costs for Employee Compensation. Table 3. 

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compensation: State and local government workers, by major occupational and industry group, 

September 2015, Management, professional and related. Online at 

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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 Encyclopedia: 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. July 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 

Agricultural Water Quality Management Program. Online at 

http://www.oregon.gov/ODA/shared/Documents/Publications/NaturalResources/WaterQualityan

dAgriculture.pdf.
7-2 March 15, 2016

Oregon Department of Agriculture (ODA). 2011. Oregon Fertilizer Program Guide. Online at 

http://www.oregon.gov/ODA/shared/Documents/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 Storage 

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 Quality (ODEQ). 2016b. Oregon’s 2012 Integrated Report 

and 303(d) List. Online geodatabase. Available: 

http://www.deq.state.or.us/wq/assessment/docs/WQ2012IntegratedReportV1.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 

Jonathan 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). 2012a. 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). 2012b. 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). 2012c. 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 

Environmental Quality, Updated February 13, 2012.

Oregon Department of Environmental Quality (ODEQ). 2011. Methodology for Oregon’s 2010 

Water Quality Report and 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.

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Preparation of the NPDES Strom Water Pollution Control Plan. Online at 

http://www.deq.state.or.us/wq/stormwater/docs/nwr/swpcpguide.pdf.

Oregon Department of Forestry (ODF). 2014. Oregon Department of Forestry Forest Practice 

Administrative Rules and Forest Practices Act. Online at 

http://www.oregon.gov/ODF/Documents/WorkingForests/FPARulebook.pdf.

Oregon Department of Forestry (ODF). 2009. Forest Facts: Herbicide Use and Forestry. Online 

at http://www.oregon.gov/ODF/Documents/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 Financial Performance Survey, 27th Edition: CEO 

Snapshot.

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Document: Recommended Estimates for Missing Water Quality Parameters for Application in 

EPA’s Freshwater Copper Biotic Ligand Model. EPA 820-R-15-106. Washington, D.C.: EPA

Office of Water.
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United States Environmental Protection Agency (U.S. EPA). 2016b. ICIS-NPDES.

United States Environmental Protection Agency (U.S. EPA). 2008. Superfund Fact Sheet: 

Formosa Mine Superfund Site, 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.

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

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http://nptwaterresources.org/wp-content/uploads/2014/01/1986-goldbook.pdf.

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Sources, Chemistry, Risks and Best Available Strategies for Remediation. International 

Scholarly Research Network Ecology. 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) facility as a major discharger. The facility discharges 

treated effluent into the Columbia River at river mile 18.0. The facility does not treat effluent 

from any categorical or significant industrial users, and therefore is not required to have a federal 

pretreatment program. However, ODEQ requested that the facility conduct an industrial waste 

survey that determined there are no industrial sources.

A.1.2 Treatment Process

The treatment 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 million gallons) 

and 5.8 acres (18.9 million gallons) each and are operated in series. There is also a 7.6 acre 

polishing lagoon. The permit indicates that 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 copper.

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 

Zone2(μg/L)

Water Quality 

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(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 sampling data. 
A-2 March 15, 2016

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

Parameter

Highest

Effluent 

Conc.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge of 

Mixing Zone2

(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(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 existing procedures, the applicable AML is 9.35 μg/L and the MDL 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 Exhibits 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), City of Astoria WWTP

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

Baseline  None, or P2 program  $0 - $10,000 NA

BLM

 Site-specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)

 $0

 $10,000 

 $0.92 million

 $0

 $0 - $10,000 

 $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 

criteria).
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 Costs2

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 represent the 

difference between total annual 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 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. 
A-4 March 15, 2016

Exhibit A-5. RPA under Revised Criteria for Kellogg Creek WWTP

Parameter

Highest

Effluent 

Conc. (μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge 

of Mixing 

Zone2(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(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 existing procedures, the applicable AML is 1.06 μg/L and the MDL is 2.15 μg/L.

A.2.4 Summary

Exhibits A-6 and A-7 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 

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 Exhibits A-6 and A-7, the discharger would also incur onetime 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 Costs2

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

 $16,000 

 $1.47 million

 $0

 $16,000 

 $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 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 Costs2

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 represent the 

difference between total annual 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 14 emergency overflow 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 filters, 

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 

Zone2(μg/L)

Water Quality 

Criterion (μg/L) Reasonable 

Potential

AML 

(ug/L)

MDL

(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.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge 

of Mixing 

Zone2(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML 

(ug/L)

MDL

(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 existing procedures, the applicable AML is 1.12 μg/L and the MDL is 1.97 μg/L.

A.3.4 Summary

Exhibits 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 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 evaluated 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 Exhibits A-10 and 

A-11, 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-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 Costs2

Baseline

 Site-specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)

 $0

 $16,000 

 $1.1 million

NA

BLM

 Site-specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)

 $0

 $16,000 

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

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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 represent the 

difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet baseline 

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 north plant and the south plant. The two plants can be 

run in series or parallel. ODEQ classifies this 35 mgd (ADWDF) facility as a major discharger.

The facility discharges effluent through a 72-inch outfall to the Willamette River at river mile 

78.4.
A-8 March 15, 2016

A.4.2 Treatment 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 contact tank. The south plant has two 

primary clarifiers, a pure-oxygen activated sludge process, four secondary clarifiers, a chlorine 

contact chamber, an additional gravity thickener, and four anaerobic digesters. The facility loads 

dewatered biosolids, at approximately 19% total solids, into dump trucks for hauling to 

application sites.

The facility is currently being expanded to treat an additional capacity of 100 mgd. The 

expansion includes four new circular primary clarifiers, two new gravity thickeners for 

thickening primary sludge, expanded WAS thickening and biosolids dewatering facility, 

permanent chlorination and dechlorination facilities, an additional pass on the existing chlorine 

contact basin, and a new parallel outfall and diffuser structure.

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.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge 

of Mixing 

Zone2(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML 

(ug/L)

MDL

(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 existing procedures, the applicable AML is 4.68 μg/L and the MDL is 10.66 μg/L.

A.4.4 Summary

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

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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 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 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 discharger, with an ADWDF of 8.4 mgd.

The facility discharges treated effluent through Outfall 001 into the Willamette River at river 

mile 0.2. The facility also has four other outfalls categorized as emergency overflows.

A.5.2 Treatment Process

The treatment system 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 

receiving 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 chlorine disinfection; sludge is anaerobically 

digested.

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-15 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-15. RPA under Baseline Criteria for Tri-City Service District

Parameter

Highest 

Effluent 

Conc. (μg/L)

Ambient 

Conc.1

(μg/L)

Conc. at Edge of 

Mixing Zone2

(μg/L)

Water Quality 

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(ug/L)

ZID RMZ acute Chronic

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-16 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-16. RPA under Revised Criteria for Tri-City Service District

Parameter

Highest

Effluent 

Conc. (μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge of 

Mixing Zone2

(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(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 existing procedures, the applicable AML is 0.84 μg/L and the MDL is 2.39 μg/L.

A.5.4 Summary

Exhibits A-17 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 the 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 evaluated without a better knowledge of 
A-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 Exhibits A-17 and 

A-18, 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-17. Summary of Potential Costs (3% discount rate), Tri-City Service District

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

Baseline

 Site-specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)

 $0

 $16,000 

 $3.31 million

NA

BLM

 Site-specific criteria or dilution credit

 Variance with a P2 program

 End of pipe treatment (ion exchange)

 $0

 $16,000 

 $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 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-18. Summary of Potential Costs (7% discount rate), Tri-City Service District

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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 represent 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 Pudding River at river mile

21.4. Reclaimed wastewater at Outfall 002 is distributed on land for dissipation by 

evapotranspiration and controlled seepage. There are three other outflows used for emergency 

overflows.

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 has no RP to exceed the baseline criteria; therefore, no costs are associated with the 

baseline scenario. Exhibit A-19 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-19. RPA under Revised Criteria for Woodburn WWTP

Parameter

Highest

Effluent Conc.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge of 

Mixing Zone2(μg/L)

Water Quality Criterion 

(μg/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 OR0000566). The facility manufactures 

newsprint and other similar types of papers from a mixture of recycled newspapers and 

magazines, wood chips, and purchased pulp. ODEQ classifies the facility as a major discharger. 

Wastewater from the facility is generated in five primary areas: the paper machine process, the 

deinking process, filter plant backwash, the steam plant, and the bleach plant. Wastewater from 
A-13 March 15, 2016

the process, steam plant, and bleach plant, along with any stormwater runoff is treated and 

discharged through outfall 001. Wastewater from the filter plant is discharged through outfall 

002. Outfalls 003, 004, and 005 are rarely used and handle only small discharges of 

miscellaneous wastewater. The facility’s permit indicates that total flows from the facility total 

9.7 mgd.

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 copper 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 Company

Parameter

Highest

Effluent Conc.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at 

Edge of 

Mixing Zone2

(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(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 existing procedures, the applicable AML is 1.16 μg/L and the MDL 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 Facility Description

The City of Corvallis Wastewater Treatment Plant (NPDES permit number OR0026361) 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 discharges effluent to the Willamette River at river 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 effluent 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 

spreading 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 

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-21. RPA under Revised Criteria for City of Corvallis WWTP

Parameter

Highest

Effluent Conc.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge of 

Mixing Zone2(μg/L)

Water Quality Criterion 

(μg/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 either 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 levels. 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 

applied 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 

analysis, and hardness values from the NPDES permit. 

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

Parameter

Highest

Effluent 

Conc. (μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at 

Edge of 

Mixing Zone2

(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(ug/L)

ZID RMZ acute Chronic

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 existing procedures, the applicable AML is 1.04 μg/L and the MDL is 2.09 μg/L.

A.9.4 Summary

Exhibits 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 same 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 Exhibits 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 Costs2

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

 $10,000 

 $0.55 million

 $0

 $10,000 

 $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 Costs2

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 

 $0.69 million

 $0

 $10,400 

 $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 represent the 

difference between total annual 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 OR0000787). 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 diameter 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 stormwater 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 primary 

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 scenario. Exhibit A-25 summarizes the RPA results for cadmium and for copper under 

the revised BLM criteria. Both acute and chronic criteria for copper were evaluated as was 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-25. RPA under Revised Criteria for West Linn Paper Company

Parameter

Highest

Effluent 

Conc. (μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at 

Edge of 

Mixing Zone2

(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(ug/L)

ZID RMZ acute Chronic

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 existing procedures, the applicable AML is 5.2 μg/L and the MDL is 10.4 μg/L.

A.10.4 Summary

Exhibits A-26 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 

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

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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

 $10,000 

 $0.92 million

 $0

 $10,400 

 $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 criteria).

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

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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 represent the 

difference between total annual cost and baseline costs (i.e., incremental costs above and beyond those needed to meet

baseline 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 OR0031356) treats domestic, commercial, and 

industrial wastewater. ODEQ classifies this 7.9 mgd (ADWDF) facility as a major discharger.

The facility discharges 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 months effluent is sent to the 

aeration basins. The facility has three aeration basins. In the winter, up to two basins are used for 
A-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-28 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-28. RPA under Revised Criteria for RUSA Roseburg WWTP

Parameter

Highest

Effluent 

Conc.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at 

Edge of 

Mixing Zone2

(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(ug/L)

ZID RMZ acute Chronic

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 existing procedures, the applicable AML is 2.88 μg/L and the MDL is 4.07 μg/L.

A.11.4 Summary

Exhibits A-29 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 

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 Exhibits A-29 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 Costs2

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

 $16,000 

 $1.47 million

 $0

 $16,000 

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

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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 represent the 

difference between total annual 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 Mill (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 consists 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 through 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 Mill’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 scenario. 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.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge of 

Mixing Zone2(μg/L)

Water Quality Criterion 

(μg/L) Reasonable Potential

ZID RMZ Acute 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.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge of 

Mixing Zone2(μg/L)

Water Quality Criterion 

(μg/L) Reasonable Potential

ZID RMZ Acute 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 exhibits, the dischargers 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 Reclamation Facility

(NPDES permit number OR0026263) 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 classifies this 20 mgd (ADWDF) facility as a 

major discharger. The facility discharges 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 activated 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 Reasonable 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 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-33. RPA under Revised Criteria for City of Medford RWRF

Parameter

Highest

Effluent 

Conc.

(μg/L)

Ambient

Conc.

1

(μg/L)

Conc. at Edge 

of Mixing 

Zone2(μg/L)

Water Quality

Criterion (μg/L) Reasonable 

Potential

AML

(ug/L)

MDL

(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 existing procedures, the applicable AML is 2.59 μg/L and the MDL is 4.39 μg/L.

A.13.4 Summary

Exhibits 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 Exhibits 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% discount rate), City of Medford RWRF

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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

 $16,000 

 $3.68 million

 $0

 $16,000 

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

Criteria Control Scenario Total Annual Costs 

($/yr) 1

Incremental Costs2

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 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-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: September 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 Quality. 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 OR0026361. 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. Permit Application Date: 

December 10, 2001.

Oregon Department of Environmental Quality. Kellogg Creek WWTP Fact Sheet and NPDES 

Wastewater Discharge Permit Evaluation. NPDES permit number OR0026221. Permit 

Application Date: July 1, 1997.

Oregon Department of 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 OR0026263. 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 Quality. West Linn Paper Company Fact Sheet and 

NPDES Wastewater Discharge Permit Evaluation. NPDES permit number OR0000787. Permit 

Application Date: August 24, 2010.

Oregon Department of Environmental Quality. City of Wilsonville Fact Sheet and NPDES 

Wastewater 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 Application 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 diluted. 

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 program 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 municipality 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, transportation 

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, municipalities would target plumbers, designers, architects, 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 include:

 Sampling and analysis – to characterize copper at the facility and track treatment 

effectiveness;

 Program development – for source identification, materials development, program 

implementation, and management;

 Conducting 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 enables 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 basis 

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 mode) 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 month). 

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 effort 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 from 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 analytical costs would be an additional $40 per sample (APEX Labs, 2016, Edge 

Analytical, 2016, NRC Labs, 2016). Therefore, total sampling costs may be approximately $83

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 managing 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 

facility. 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 infiltration/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 (RWQCP, 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 implementation 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 process water (EBMUD, 2016). EBMUD also issues 
B-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, 2016). 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 the only 

way to truly characterize influent loads would be through site-specific sampling.

Determining which P2 efforts to pursue requires evaluation of the contribution to total copper

loadings, relative magnitude of loading, feasibility of control, and effectiveness 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 education programs targeting local businesses and 

industries (e.g., printing shops and electroplaters/metal finishers), consumers, and plumbers.

Currently, most 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) 

developed 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 developed 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 Collection 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 this 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 not always result in 

noticeable 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 based 
B-4 March 15, 2016

on fumes created when using alternative products during soldering. In addition, 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 more successful, it would appear that 

more studies and data are needed to further support plumbing installation BMPs that reduce 

copper.

An increasing number of municipalities are implementing non-voluntary measures such as 

limits/requirements in pretreatment permits or sewer use ordinances that require implementation 

of specific treatment controls and/or BMPs to obtain more measurable reductions in copper

loadings. For example, the Palo Alto RWQCP implemented a sewer use ordinance (RWQCP, 

2007) that requires 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 ordinance, 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 not 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 schedule established 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 requirement issued by 

the City; and

 An amount not to exceed ten dollars per gallon for discharges 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 development vary based on the level of effort and size of the service area. The 

Palo Alto RWQCP (dry weather permitted flow of 39 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 outreach 
B-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, 2015). Assuming the work can be 

conducted by one of the WWTP operators, this would translate in startup costs of approximately 

$45,000. 

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 other 

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 industrial 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, inhouse labor requirements 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-thirds 

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 costs at those other facilities. 

B.1.3 Workshops 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, 2015). Workshops can be used to provide target groups with sector-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 information 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 and 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 are 

relatively low-cost methods for distributing information. The PSA cost is for the time spent to 

prepare audio PSAs for radio broadcast use. For example, the price charged by Hispanic Radio 

Network to produce a 60-minute Spanish or English PSA under a General 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 different 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 requirements for an activity such as emptying a pool, links to copper fact sheets). 

However, larger municipalities may also target commercial and industrial dischargers. The cost 

of a website depends on its function, number of pages, and security requirements. Websites with 

less than 10 pages and no animation or custom graphics typically cost less than $1,000 

(Numatek, 2015). Due to the nature of P2 programs and the need to adapt efforts based on 

sampling and outreach results, frequent maintenance would be needed to keep the websites up to 

date. However, over the life of a program, website development and maintenance might average

approximately $1,000 per year. These costs do not include the cost of the website itself. Rather, 

facilities would likely add information on the P2 program to a preexisting website run by the 

municipality or sewer district.

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 annual 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) $15,000 $30,000 $45,000

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 addition 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 industrial 

operations and those individuals or organizations managing pools, spas and fountains. However, 

the program may not address all of these sectors immediately (i.e., in certain sectors,

implementation of controls may not occur for several years).

B.2.1 Plumbers 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 effluent. 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 products. 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 Universal Plumbing 

Code (UPC) standard for potable water, and one of the primary BMPs 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 transportation 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 relatively 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 their 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 modifications. During process analysis the discharger would identify pollutant uses 

and quantities within the facility (i.e., inventory facility), identify pollutant use and potential 
B-8 March 15, 2016

contamination in process streams, and identify P2 options for reducing the pollutant at the plant 

(e.g., on-going management of pollutants, recycling, and product and raw material substitutions).

After the process analysis step, the facility would need to implement the identified P2 options 

and make any necessary process modifications.

It is estimated that the costs to identify potential pollutant sources and sample process waste 

streams assuming a two-month study is approximately 320 hours. The hourly wage in Oregon for 

an environmental engineer is approximately $58 including employer benefits [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 

approximately $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 commercial 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 pretreatment 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-hauling 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 implementation 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 prevent 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 prevention, 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 costs 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 outreach.

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 P2 Programs

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 supplier 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 community 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 system 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 little 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 

what options may be available. Changes in the drinking water utility’s corrosion control program 
B-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 could 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 supplementing 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 spikes 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 California. 

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). 2015a. Employment Cost Index Historical Listing. Currentdollar 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 seasonally 

adjusted), Management, professional, and related. Online at 

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

Bureau of Labor Statistics (BLS). 2015b. 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, professional 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 Currentdollar 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 athttp://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 hour 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.centralsan.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). 2014. 2014 Pretreatment and Pollution 

Prevention Report.

Edge Analytical. 2016. Personal Communication with Mary Price and Thanh Phan. January. Lab 

ID. #OR100063

Edlund, Sven. 2016. 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 Copper Pollution Prevention Program. Online at 

http://www.mvsd.org/programs/pollution-prevention/#copper-pollution-prevention.

Neilson Research Corporation (NRC). 2015. Personal communication with Tammy Kreutzer. 

January. Lab ID# OR100016. http://www.nrclabs.com. 

Numatek Web Design. 2016. Web Design Price Estimates. Online at 

http://www.numatek.com/web-design/estimate.html. Accessed January 25, 2016.

Palo Alto Regional Water Quality Control Plant (RWQCP). 2016. Personal communication with 

Karin North, Watershed Protection Manager January 2016.

Palo Alto Regional Water Quality Control Plant. 2015. 2015 Pollution Prevention Plan.

Palo Alto Regional Water 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) Establishing 
B-12 March 15, 2016

Regulations to Reduce Discharges of Pollutants to the Sanitary Sewer and Storm Drainage 

Systems.

San Mateo Wastewater Treatment Plant (SMWTP). 2016. Personal Communication with Sven 

Edlund, Environmental Compliance Inspector.

Universal Plumbing Code. 2015. Online at http://codes.iapmo.org/home.aspx?code=UPC. 

United States Environmental Protection Agency (EPA). 2008. Cost of Compliance with Water 

Quality Criteria 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 

wastewater effluents. However, in general there is a lack of performance data available to show 

that advanced treatment technologies will result in the effluent levels necessary 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 compounds, to pass through its pores. The contaminated water is subjected to high 

pressures that force pure water through the membrane, leaving pollutants behind in a brine 

solution (NDWC, 1997).

Properly operated RO units will likely achieve 95% removal of copper (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, and 

therefore performance data is scarce. Because removal efficiencies are less than optimal when 

treating influents with low contaminant concentrations, performance testing using influent 

concentrations in the ppb (μg/L) range should be conducted on various types of wastewater to 

ensure that RO is capable of producing the appropriate effluent range.

Even if the necessary copper reductions are achievable with RO, it is important to consider the 

potential disadvantages and limitations of this technology, including:

 Capital and operating (including 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 treatment efficiency 

levels needed to achieve extremely low levels of pollutants (e.g., carbon prefilter for 

the reduction of chlorine, which can damage some types of chlorine sensitive RO 

membranes, sediment pre-filter or microfiltration to ensure that fine suspended 

materials do not clog the membrane);

 Membranes are prone to fouling (NDWC, 1997);

 The technology may not be feasible for treatment of large flows; and
C-2 March 15, 2016

 RO does not remove pollutants from the environment, rather transfers them to another 

medium (pollutants are concentrated in the reject discharge or brine).

The most limiting of these disadvantages, especially for larger systems, is the management and 

disposal of residuals. Most RO systems reject about 10% to 25% of influent water as a 

concentrated brine solution (U.S. EPA, 1996). This brine contains the contaminants removed 

from the wastewater, and must be treated prior to disposal. The more feasible residual disposal 

options for wastewater treatment plants include:

 Land disposal (e.g., evaporation pond, underground injection); and

 Treatment (e.g., brine concentrator, thermal evaporation) (Metcalf and Eddy, 2013).

The first option requires that the waste be classified as nonhazardous. Otherwise, the brine must 

be disposed of as a hazardous waste, which can be extremely costly, especially for larger 

volumes. By design, evaporation ponds require local precipitation rates to be lower than 

evaporation rates. The treatment through controlled evaporation is feasible, although operation

and maintenance costs may be extremely high. This approach is usually only employed where no 

other alternatives are available (Metcalf and Eddy, 2013).

In addition, these disposal options do not guarantee that the pollutants in the residuals will not be 

re-released into the environment. The pollutant is simply transferred from the effluent to a 

residual brine that must be disposed of in some manner. If the brine is evaporated (either through 

an evaporation pond or flash/thermal evaporator), the pollutant could evaporate to the 

atmosphere and be redeposited into rivers and lakes.

Since no wastewater treatment plants in the country have installed RO to remove 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 manufacturer 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 capital and operating costs. If 

the concentration of barium or sulfate is higher than shown in the exhibit, or if silica is present, 

water recovery could be limited. 

Certain RO membranes are intolerant of free chlorine, and most microfiltration membranes have 

limited chlorine tolerance. Thus, prior to microfiltration, the wastewater should be dechlorinated 
C-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 adjusted 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 building, 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 $15,466,0000

O&M Costs2

Microfiltration $170,000

Reverse Osmosis $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 an evaporation pond, which requires that local precipitation rates be 

lower than evaporation rates. This is not always the case in Western Oregon. According to the 

National Oceanic and Atmospheric Administration (NOAA), Oregon is divided into two distinct 

rainfall zones by the Cascade Range, west of which annual 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 exhibit 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 through 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-hazardous 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 wells 

(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 

concentrating 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 concentrated 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). In 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, and estimated 

an annualized cost for the system of $5.76 million per MGD of brine in 2015 dollars11 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 times 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 households served 

by each facility. According to its 1993-1998 NPDES permit, the 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 households 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. Roseburg

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 Roseburg 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 those calculations.

Exhibit C-5. Affordability Estimates for McMinnville and Roseburg 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 estimates 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 alternative 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 removal and eliminate competing ions (NDWC, 1997).

The ion exchange process consists of four operations: service, backwash, 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 step is 

initiated to expand the bed and to remove fines that may be clogging the packed bed. The spent 

resin is regenerated using a concentrated solution of the original exchange ion, reversing the 

exchange process. Lastly, the rinse step removes excess regeneration solution before the column 

is brought back online for the next service cycle. 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 media. Advantages of ion exchange technology include:

 A large variety of specific resins are available from manufacturers, tailored to removal 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 

concentrations of the waste effluent;

 Effluent quality may be highly variable (depending on sorbent loading);

 To achieve low pollutant levels in wastewater, extensive pretreatment may be necessary; 

and

 Ion exchange units are sensitive to the presence of competing ions (NDWC, 1997).

For copper, historically, 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 cationic resins can also be used to remove copper 

because they have a high selectivity for copper. Another resin 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 removal can reach 95% removal (WesTech 2016).

Exhibit C-6 summarizes capital and O&M costs for a 5 MGD facility, as priced by a 

Massachusetts-based 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 Costs2

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 that more readily settle out. However, in order to achieve copper levels in the 

low μg/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 observed 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 levels may be achieved using chemical 

precipitation (Pang et al., 2009) and electro-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 reviewed for its applicability to copper 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 Sciences, 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. Tech 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. Northwest 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 Control Technologies, Indian Journal of Environmental Protection, Volume 29, No.,6, 

P. 552 – 560. 

United States Environmental Protection Agency (U.S. EPA). 2013. Final Permit - 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/uic-class-i-permit-newhall-landand-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 Protection 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 

Technologies for Water Utilities. Online at: 

http://www.waterrf.org/Pages/Projects.aspx?PID=4073
C-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: 

http://www.wrcc.dri.edu/htmlfiles/westevap.final.html#OREGON, http://www.wrcc.dri.edu/cgibin/cliMAIN.pl?or1902, and http://www.wrcc.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 (estimate 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 project. Public entities should 

consider a broad range of discharge management options including pollution prevention, 

end-of-pipe treatment, and upgrades or additions to existing treatment. Specific types of 

pollution prevention activities that should be considered are (EPA, 1995):

 public education;

 change in raw materials;

 substitution of process chemicals;

 change in process;

 water recycling and reuse; and

 pretreatment requirements.

EPA (1995) provides worksheets to summarize general information regarding the proposed 

pollution control project. 

Calculate Annualized Cost per Household

Since capital costs will be paid over several years, annualized costs are used to evaluate the 

economic burden to the community. The capital portion of project costs is financed by issuing a 

municipal debt instrument such as a general obligation bond or a revenue bond. Local 

governments may also finance capital costs using bank loans or state infrastructure loans (e.g., 

State Revolving Fund loans). State and federal grant funding may also be available for 

technology upgrades or other treatment options. EPA (1995) also provides a worksheet for 

calculating the total annualized cost of the project.
D-2 March 15, 2016

To assess the burden that pollution control costs are expected to have on households, an average 

annualized pollution control cost per household is calculated for all households in the community 

that would bear project costs. To evaluate substantial impacts, therefore, applicants should 

determine which households will actually pay for pollution control, as well as what proportion of 

the costs will be borne by households. These apportioned project costs are then added to existing 

pollution control costs paid by households. EPA (1995) provides worksheets for calculating the 

cost per household.

Municipal Preliminary Screener

Whether or not the community is expected to incur “substantial” economic impacts due to the 

pollution control project is determined by jointly considering the results of two tests. The first 

test is a “screener” to establish whether the community can clearly pay for the project without 

incurring any substantial impacts. The Municipal Preliminary Screener, or MPS, is the total 

annual pollution control costs per household (existing costs plus those attributable to the 

proposed project) as a percentage of MHI. EPA (1995) provides a worksheet for calculating and 

evaluating the MPS.

If the MPS value is less than 1.0, there is little potential for substantial impacts and the analysis 

can conclude with a determination of no substantial impact. Communities are expected to incur 

mid-range impacts when the ratio of total annual 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 financial burden on many of the households within the community. In either case, 

applicants move on to the Secondary Test to demonstrate substantial impacts. 

Secondary Test

The Secondary Test, which provides indication of the community’s ability to obtain financing 

and the socioeconomic health of the community, consists of six indicators for the community: 

 Debt Indicators

o Bond Rating - a measure of a jurisdiction’s ability to repay its debt; 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 of the income of the jurisdiction.

 Financial Management Indicators

o Property Tax Revenue as a Percent of Full Market Value of Taxable Property - a 

measure of the capacity to support debt based on the wealth of the jurisdiction; 

and

o Property Tax Collection Rate - a measure of the strength of the local government 

administration, and of the jurisdiction’s acceptance of property tax rates. 

Exhibit D-1 summarizes the indicators, and the scoring of the values following EPA (1995) 

guidance. EPA (1995) provides worksheets for calculating the secondary score.
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 

exhibit indicates that the impact is unclear. For results falling into either the “X” or “?” category, 

applicants proceed to determine whether the impacts would also be widespread. EPA (1995) 

provides further discussion of evaluating the results. 

Exhibit D-2. Substantial Impacts Matrix 

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 from the community but become business 

revenues and household incomes. Therefore, applicants must examine the estimated change in 

socioeconomic conditions that would result from meeting criteria (EPA, 1995).

At a minimum, the analysis should (EPA, 1995):
D-4 March 15, 2016

 define 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 is concentrated in the immediate 

community, then outlying communities dependent upon the immediate municipality for 

employment, goods, and services should also be included in the analysis.

To demonstrate that there will be widespread impacts, EPA (1995) recommends evaluating 

changes in the following indicators:

 MHI;

 community unemployment rate;

 overall net debt as a percent of full market value of taxable property;

 property values;

 percent of households below poverty line; and

 community development potential.

The first step in estimating the change in these indicators is to identify their precompliance 

values. Evaluation of baseline socioeconomic conditions is important because the extent to 

which estimated changes can be interpreted as significant depends on the health of the 

community before 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 unchanged, then widespread impacts have not been 

demonstrated. Alternatively, if the community is very healthy, the estimated change in the 

indicators listed above would have to be very large in order for widespread impacts to occur.

Note that expenditures for pollution controls also become increased household and business 

incomes (costs to one sector become revenues to another). EPA (1995) provides a worksheet for 

applicants to qualitatively describe estimated changes.

D.2 Analysis for Private Sector Entities

Private sector entities will evaluate whether the 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, liquidity, solvency, and 

leverage; compare to industry benchmarks; establish that the company would be forced to curtail 

operations or shut down), and whether such an impact would have widespread adverse economic 

and social impact (the loss of employment and incomes would have a widespread impact on the 

community).
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 conduct 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 control.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 three secondary measures of financial impacts:

 Primary Measure

o Profit—how much will profits decline due to pollution control expenditures?

 Secondary Measures

o Liquidity—how easily can an entity pay its short-term bills?

o Solvency—how easily can an entity pay its fixed and long-term bills?

o Leverage—how much money can the entity borrow?

Each type of test measures a different aspect of a discharger’s financial health. The primary 

measure evaluates the extent to which an applicant’s profit rate will change, and compares the 

profit level to typical profits in that industry. The secondary measures provide additional 

information about specific impacts that the discharger would bear if required to comply with 

WQBELs. Profit and solvency ratios are calculated both with and without the additional 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 the 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 would have a widespread impact on the surrounding 

community. The steps in the analysis are identical to those described above for public sector 

entities.

D.3 References

United States Environmental Protection Agency (U.S. EPA). 1995. Interim Economic Guidance 

for Water Quality Standards. EPA 823-B-95-002. March 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 and erosion 

control from agricultural and forest lands, urban areas, and abandoned mine sites. This section 

provides a description of potential controls and associated unit costs, where available.

E.1 Agricultural and Forest Lands

Cadmium and copper loadings from agricultural and forest lands can arise because of pesticide 

or fertilizer use as well as soil erosion. Chemicals applied for pesticide control or nutrient 

addition can occur in stormwater runoff or adhere to soils that erode and eventually enter 

waterways. 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 effective. 

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 streams, 

cooling instream temperatures. As described in the Exhibit E-1, buffers also slow runoff 

(reducing erosion), filter pollutants, and trap sediments. Thus, it is possible that controls being 

implemented to meet baseline standards for temperature could 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 assistance to implement structural and 

management conservation practices that optimize environmental benefits on working agricultural 

land. As part of EQIP, NRCS develops cost estimates for various BMPs in Oregon that may be 

available for funding assistance. Thus, the cost of additional BMPs that may be needed under the 

revised criteria would likely be similar to the NRCS estimates. Exhibit E-1 shows some 

examples of BMPs that reduce soil erosion along with current compensation rates to illustrate 

potential costs.
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

Conservation 

tillage

Reduce the amount of tillage and leave at least 30% cover from crop 

residue after harvest and during winter months. Soil loss is reduced 

by 50% compared to bare soil.

$18 to $29 per acre for 

reduced till

Crop rotation Changes crops each year in a certain order. A rotation that includes 

grasses, legumes, or small grains will break pest cycles and reduce 

erosion compared to continuous row crops that may build up pest 

populations and leave soil open to erosion.

$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 square 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 grass rather than tearing away soil and forming a gully. An 

outlet is often installed at the base of the drainage way to stabilize 

the waterway. 

$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 assessment 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 cleanup 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 also 
E-3 March 15, 2016

independent requirements to control pollutants in stormwater runoff. Municipalities and 

industrial 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 

copper 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 (SWMP). 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 revised 

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 urban 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 naturally 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 higher in the first 

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

 Increased or additional nonstructural BMPs – institutional, education, or pollution 

prevention practices designed to limit generation of runoff or reduce the pollutants load 

of runoff; and

 Structural controls – engineered and constructed systems designed 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 treatment or structural controls. In addition 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 materials; adopting mandatory restrictions 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 Environmental, 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 reductions 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 infiltration systems, detention systems, retention systems, constructed wetlands, 

filtration systems, and vegetated systems. The cost for any particular structure depends on the 

type of control, the quantity of water treated, and site-specific factors such as land cost. 

Infiltration systems capture runoff and allow it to infiltrate into the ground. These systems 

provide both water quality and quantity control. Typically, these systems infiltrate water into the 

ground relatively rapidly (from a few hours up to 72 hours). However, the primary drawback of 

infiltration systems is that they are not appropriate in areas where groundwater is used as a 

drinking water source. Additional constraints include identifying sites with appropriate soils and 

risk of failure due to clogging. Exhibit E-2 summarizes the different types of infiltration systems.

Exhibit E-2. Summary of Stormwater Infiltration Systems

System Type Description

Infiltration basin

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 pavement 

systems

Include porous asphalt, porous concrete, modular perforated concrete block, cobble 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 parking areas in commercial areas.

Infiltration trenches 

and wells

Typically designed to capture only a small volume of water (appropriate to capture first flush 

of a runoff event). 

Source: U.S. EPA (1999).

Detention systems capture runoff and temporarily retain it for later release. Detention systems do 

not retain a significant permanent pool of water between runoff events. These systems provide 

quantity and quality control; however, re-suspension of particulate matter often occurs. Exhibit 

E-3 summarizes the different types of detention systems.

Exhibit E-3. Summary of Stormwater Detention Systems

System Type Description

Detention basin

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 vaults, 

pipes, and tanks

Same primary purpose as basins – storage to limit downstream effects due to high peak flow 

rates.

Limited quality control.

Source: U.S. EPA (1999).

Retention systems capture runoff and retain it until it is displaced by the next runoff event, and

maintain a significant permanent pool volume of water between runoff events. The most 

common retention system is a retention pond (wet pond). The primary pollutant removal 

mechanism is sedimentation. These systems can also benefit from added biological and 

biochemical pollutant removal mechanisms provided by aquatic plants and microorganisms. 

Compared to detention systems, 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 water surface area (for pond systems) or bottom (for meadow-type systems) 

contains wetland vegetation. These systems can be effective in both quantity and quality control, 

but, as with natural wetlands, are relatively delicate and require a water balance to sustain the 

aquatic vegetation. Sedimentation can especially reduce the effectiveness of the system. 

Pollutant removal in wetlands can occur through a number of mechanisms including 

sedimentation, filtration, volatilization, adsorption, absorption, microbial decomposition, and 

plant uptake. Pretreatment of runoff may be necessary for these systems (U.S. EPA, 1999). 
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 material, carbon, or membranes. Often these systems treat 

only the first half inch to inch of runoff, and are common at small sites such as parking lots and 

developments, in areas with high pollution potential such as industrial areas, or in highly 

urbanized areas where land availability or costs preclude the use of other controls (U.S. EPA, 

1999). Exhibit E-4 summarizes the different types of filtration systems.

Exhibit E-4. Summary of Stormwater Filtration Systems

System Type Description

Surface sand filter

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 treated water.

Underground vault sand 

filter

Common systems are the D.C. sand filter and the Delaware sand filter.

Basic design premise is the same as the surface sand filter.

Biofiltration/bioretention 

systems

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 adsorption, filtration, 

volatilization, ion exchange, and decomposition.

Source: U.S. EPA (1999).

Vegetated systems (biofilters) such as swales and filter strips are designed to convey and treat 

either shallow flow (swales) or sheetflow (filter strips) runoff. Open channel vegetated systems 

are alternatives to the traditional curb-and-gutter and storm sewer conveyance systems. By 

conveying stormwater runoff in vegetated systems treatment, storage, and infiltration can be 

provided prior to discharge to the storm sewer system (U.S. EPA, 1999). Exhibit E-5 summarizes 

the different types of vegetated systems.

Exhibit E-5. Summary of Stormwater Vegetated Systems

System Type Description

Grass filter strips

Densely vegetated, uniformly graded areas that intercept sheet runoff from impervious surfaces 

such as parking lots, highways, and rooftops.

Designed to trap 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 swales

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

BMP Type

Dissolved Copper

(influent / effluent μg/L)

Total Copper

(influent / effluent μg/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 economies 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 capture runoff from 

streets and sidewalks; can increase pedestrian safety;

 Stormwater planters – vegetative landscaping added to parking garages 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 

implemented throughout Portland. Portland BES and EPA grants funded some part of most of 

the projects.
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; 2002f; 2001; 1999). 

E.4 References

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Wear Debris to the San Francisco Bay. Prepared for Association of Bay Area Governments and 

California Department of Transportation. Online 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 

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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 Forest Practices Act. Online at 

http://www.oregon.gov/ODF/Documents/WorkingForests/FPARulebook.pdf.

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Report, SPR663. Online at 

http://www.oregon.gov/ODOT/TD/TP_RES/docs/reports/2011/spr663copperspec.pdf.
E-9 March 15, 2016

Portland Bureau of Environmental Services (BES). 2014. Stormwater Management Manual. 

Online at https://www.portlandoregon.gov/bes/64040.

Portland Bureau of Environmental Services (BES). 2006. East Holladay Park. Online at 

http://www.portlandonline.com/bes/index.cfm?c=44463&.

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Project. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&.

Portland Bureau of Environmental Services (BES). 2005b. SW 12th Avenue Green Street 

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Portland Bureau of Environmental Services (BES). 2002d. Page 19 LLC. Online at 

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Field Office. Online at http://www.portlandonline.com/bes/index.cfm?c=44463&.

Portland Bureau of Environmental Services (BES). 2002f. Reed College Apartments. Online at 

http://www.portlandonline.com/bes/index.cfm?c=44463&.

Portland Bureau of Environmental Services (BES). 2001. Wattles Boys and Girls Club. Online at 

http://www.portlandonline.com/bes/index.cfm?c=44463&.
E-10 March 15, 2016

Portland Bureau of Environmental Services (BES). 1999. Hamilton West Apartments Ecoroof. 

Online at http://www.portlandonline.com/bes/index.cfm?c=44463&.

TDC Environmental. 2004. Copper Sources in Urban Runoff and Shoreline Activities. 

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(fact sheet). Online at http://www.blm.gov/or/landsrealty/aml/formosa.php.

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http://www.nrcs.usda.gov/wps/portal/nrcs/main/or/programs/financial/eqip/.

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of Urban Storm Water Best Management Practices. August.

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Management Practices (BMP) Database. Online at http://www.bmpdatabase.org.