## Economic **An aly** **sis for**  **the Rev ision of**  **Certain Federal Water Quality**  **Criteria Ap**  **plicable to**  **Washington**

**Contract # EP**  **- C**  **- 13**  **- 03** 
August 1 7 , 2 01 5 Prepared for: **U nited**  **S tates**  **Environmental**

**Protection A**

**gency** 1200 Pennsylvania Ave., N W Wa shington, D.C. 20460

Submitted by: **Ab t A**  **ssociates** 4550 Montgomery Avenue

Suite 800 North Bethesda, MD 20814 **In Partnership with:** PG Environmental, LLC

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**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. i**  

## Contents **Contents ................................**  **................................ ................................**  **................................ ....**  **i Exhibits**  **................................ ................................**  **................................ ................................**  **... vi**  **Acronym List ................................**  **................................ ................................**  **......................... vii**  **Executive Summary ................................**  **................................ ................................**  **............... ix**  Background and Potential Revised Criteria
................................ ................................ . ix Point Source Compliance Costs
................................ ................................ ................... ix Nonpoint Source Controls
................................ ................................ .............................. x **1. I**  **ntroduction ................................**  **................................ ................................**  **.................. 1**  1.1 Background
................................ ................................ ................................ ........... 1 1.2 Purpose and Scope of the Analysis
................................ ................................ ....... 2 1.3 Organization of Report
................................ ................................ ......................... 2 **2. Baseline for the Analysis**  **................................ ................................**  **............................. 4**  2.1 Water Quality

Criteria and Implementation Procedures
................................ ....... 4 2.2 Sources of Toxic Pollutants to Surface Waters
................................ ..................... 7 2.2.1 Municipal and Industrial Dischargers
................................ ....................... 8 2.2.2 Urban Stormwater
................................ ................................ ..................... 8 2.2.3 Agriculture and Forestry
................................ ................................ ........... 9 2.2.4 Atmospheric Deposition
................................ ................................ ........... 9 2.2.5 Contaminated Sediments
................................ ................................ ........ 10 2.3 Water Quality
................................ ................................ ................................ ...... 10 **3. Potential Revised Criteria**  **................................ ................................**  **......................... 14**  **4. Method for Estimating Potential Costs: Point Sources**  **................................ ..........**  **19** 4.1 Major Dischargers
................................ ................................ ............................... 19 4.1.1 Sample Selection
................................ ................................ ..................... 19 4.1.2 Reasonable Potential Analysis
................................ ................................ 21 4.1.3 Projecting Effluent Limitations
................................ ............................... 22 4.1.4 Id entifying Compliance Scenarios and Costs
................................ ......... 25 4.1.5 Summary

of Unit Control Costs
................................ ............................. 33 4.1.6 Extrapolation to All Major Dischargers
................................ .................. 34

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**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. ii**  

### 4.2 Minor Dischargers
................................ ................................ .............................. 34 **5. Methods for Identifying Potential Costs: Nonpoint Sources**  **................................ .**  **36** 5.1 Id entifying Exceedances
................................ ................................ ..................... 36 5.2 Id entifying Compliance Actions and Costs
................................ ........................ 38 **6. Potential Compliance Costs**  **................................ ................................**  **...................... 40**  6.1 Point Sources
................................ ................................ ................................ ...... 40 6.2 Nonpoint Sources
................................ ................................ ................................ 40 6.3 Uncertainties and Quality Assurance
................................ ................................ .. 41 **7. References**  **................................ ................................**  **................................ ...................**  **43 Appendix A** 

**– Facility Analyses**  **................................ ................................**  **............................ 46**  A.1 Chambers Creek Regional Wastewater Treatment Facility ................................ 46 A.1.1 Treatment Processes
................................ ................................ ................ 46 A.1.2 Effluent Data
................................ ................................ ........................... 46 A.1.3 Receiving Water
................................ ................................ ...................... 46 A.1.4 Baseline Scenario
................................ ................................ .................... 47 A.1. 5 Policy

Scenario
................................ ................................ ....................... 47 A.2 King County South WWTP and CSO System ................................ .................... 47 A.2.1 Treatment Processes
................................ ................................ ................ 47 A.2.2 Effluent Data
................................ ................................ ........................... 47 A.2.3 Receiving Water
................................ ................................ ...................... 49 A.2.4 Baseline Scenario
................................ ................................ .................... 49 A.2. 5 Policy

Scenario
................................ ................................ ....................... 52 A.3 King County West Point WWTP and CSO System ................................ ............ 53 A.3.1 Treatment Processes
................................ ................................ ................ 53 A.3.2 Effluent Data
................................ ................................ ........................... 53 A.3.3 Receiving Water
................................ ................................ ...................... 54 A.3.4 Baseline Scenario
................................ ................................ .................... 55 A.3.5 Policy

Scenario
................................ ................................ ....................... 57 A.4 Pasco Wastewater Treatment Works
................................ ................................ .. 58 A.4.1 Treatment Processes
................................ ................................ ................ 58 A.4.2 Effluent Data
................................ ................................ ........................... 59 A.4.3 Receiving Water
................................ ................................ ...................... 59 A.4.4 Baseline Scenario
................................ ................................ .................... 59

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**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. iii** 



### A.4.5 Policy

Scenario
................................ ................................ ....................... 61 A.5 Puyallup WWTP
................................ ................................ ................................ . 62 A.5.1 Treatment Processes
................................ ................................ ................ 62 A.5.2 Effluent Data
................................ ................................ ........................... 63 A.5.3 Re ceiving Water
................................ ................................ ...................... 63 A.5.4 Baseline Scenario
................................ ................................ .................... 63 A.5.5 Policy

Scenario
................................ ................................ ....................... 64 A.6 Redondo WWTP
................................ ................................ ................................ . 64 A.6.1 Treatment Processes
................................ ................................ ................ 64 A. 6.2 Effluent Data
................................ ................................ ........................... 64 A.6.3 Receiving Water
................................ ................................ ...................... 67 A.6.4 Baseline Scenario
................................ ................................ .................... 67 A.6.5 Policy

Scenario
................................ ................................ ....................... 69 A.7 Salmon Creek WWTP
................................ ................................ ......................... 7 0 A.7.1 Treatment Processes
................................ ................................ ................ 70 A. 7.2 Effluent Data
................................ ................................ ........................... 70 A.7.3 Receiving Water
................................ ................................ ...................... 71 A.7.4 Baseline Scenario
................................ ................................ .................... 72 A.7.5 Policy

Scenario
................................ ................................ ....................... 73 A.8 BP Cherry

Point Refinery
................................ ................................ ................... 74 A.8.1 Treatment Processes
................................ ................................ ................ 74 A.8.2 Effluent Data
................................ ................................ ........................... 75 A.8.3 Receiving Water
................................ ................................ ...................... 77 A.8.4 Baseline Scenario
................................ ................................ .................... 78 A.8.5 Policy

Scenario
................................ ................................ ....................... 79 A.9 Cosmo Specialty

Fibers
................................ ................................ ...................... 80 A. 9.1 Treatment Processes
................................ ................................ ................ 81 A.9.2 Effluent Data
................................ ................................ ........................... 81 A.9.3 Receiving Water
................................ ................................ ...................... 81 A.9.4 Baseline Scenario
................................ ................................ .................... 81 A.9.5 Policy

Scenario
................................ ................................ ....................... 82 A.10 Intalco Aluminum Corporation
................................ ................................ ........... 82 A.10.1 Treatment Processes
................................ ................................ ................ 82 A.10.2 Effluent Data
................................ ................................ ........................... 82 A.10.3 Receiving Water
................................ ................................ ...................... 83

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**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. iv** 



### A.10.4 Baseline Scenario
................................ ................................ .................... 84 A.10 .5 Policy

Scenario
................................ ................................ ....................... 85 A.11 Quincy

Industrial Wastewater Treatment Facility ................................ .............. 86 A.11.1 Treatment Processes
................................ ................................ ................ 86 A.11.2 Effluent Data
................................ ................................ ........................... 86 A.11.3 Receiving Water
................................ ................................ ...................... 86 A.11.4 Baseline Scenario
................................ ................................ .................... 87 A.11 .5 Policy

Scenario
................................ ................................ ....................... 87 A.12 Steelscape Inc.
................................ ................................ ................................ ..... 87 A.12.1 Treatment Processes
................................ ................................ ................ 87 A.12.2 Effluent Data
................................ ................................ ........................... 87 A.12.3 Receiving Water
................................ ................................ ...................... 88 A.12.4 Baseline Scenario
................................ ................................ .................... 88 A.12.5 Policy

Scenario
................................ ................................ ....................... 88 A.13 Sonoco Products
................................ ................................ ................................ .. 88 A.13.1 Treatment Processes
................................ ................................ ................ 88 A.13.2 Effluent Data
................................ ................................ ........................... 89 A.13.3 Receiving Water
................................ ................................ ...................... 89 A.13.4 Baseline Scenario
................................ ................................ .................... 89 A.13.5 Policy

Scenario
................................ ................................ ....................... 91 A.14 Tesoro Refining and Marketing LLC
- Anacortes
................................ .............. 92 A.14.1 Treatment Processes
................................ ................................ ................ 92 A.14.2 Effluent Data
................................ ................................ ........................... 92 A.14.3 Receiving Water
................................ ................................ ...................... 95 A.14.4 Baseline Scenario
................................ ................................ .................... 95 A.14.5 Policy

Scenario
................................ ................................ ....................... 97 A.15 TransAlta Centralia Generating Station
................................ .............................. 98 A.15.1 Treatment Processes
................................ ................................ ................ 98 A. 15.2 Effluent Data
................................ ................................ ........................... 98 A.15.3 Receiving Water
................................ ................................ .................... 101 A.15.4 Baseline Scenario
................................ ................................ .................. 101 A.15.5 Policy

Scenario
................................ ................................ ..................... 103 A.16 TransAlta Centralia Mining
................................ ................................ .............. 104 A.16.1 Treatment Processes
................................ ................................ .............. 104 A.16.2 Effluent Data
................................ ................................ ......................... 104

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**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. v** 



### A.16.3 Receiving Water
................................ ................................ .................... 104 A.16.4 Baseline Scenario
................................ ................................ .................. 105 A.16.5 Policy

Scenario
................................ ................................ ..................... 106 A.17 U.S. Oil & Refining Corporation
................................ ................................ ...... 107 A.17.1 Treatment Processes
................................ ................................ .............. 107 A.17.2 Effluent Data
................................ ................................ ......................... 108 A.17.3 Receiving Water
................................ ................................ .................... 108 A.17.4 Baseline Scenario
................................ ................................ .................. 109 A.17.5 Policy

Scenario
................................ ................................ ..................... 110 A.18 References and Sources
................................ ................................ .................... 111 **Appendix B**

**– Sample Facility Results and Statewide Extrapolation**  **............................. 113**  B.1 Baseline Scenario Extrapolation
................................ ................................ ....... 113 B.2 Policy

Scenario Extrapolation
................................ ................................ ........... 115

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**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. vi**  

## Exhibits Exhibit 2
- 1. Baseline Freshwater and Marine Water Quality Criteria for Toxic Pollutants in Washington 1

................................ ................................ ................................ ................................ ..... 4 Exhibit 2
- 2. Number of Dischargers in Washington by Category
................................ .......................... 8 Exhibit 2
- 3. 2015 Proposed Category 4 and 5 Listings for Toxic Pollutants
................................ ....... 11 Exhibit 2
-4. Summary of TMDLs for Toxic Pollutants in Waters in Washington 1

............................. 12 Exhibit 3
- 1. Summary of Key Assumptions for Calculating Human Health Criteria
.......................... 15 Exhibit 3
- 2. Proposed Human Health Criteria ( μg/L)
................................ ................................ .......... 15 Exhibit 4
- 2. Summary of Major Discharger Sample
................................ ................................ ............ 20 Exhibit 4
- 3. Summary of Projected Effluent Limitations and Incremental Load Reductions under the Proposed Criteria
................................ ................................ ................................ ........................... 24 Exhibit 4
-4. Summary of Potential End
- of
- Pipe Treatment Technologies
................................ ........... 30 Exhibit 4
- 5
. Estimated Unit Costs of Compliance Mechanisms (2014$)
................................ ............. 33 Exhibit 5
- 1. Potential Incremental Impairments 1

................................ ................................ ................. 37 Exhibit 6
- 1. Total Annual Costs by Discharger Type
................................ ................................ .......... 40 Exhibit 6
- 2. Uncertainties in Analysis of Costs
................................ ................................ ................... 41

### AC **RONYM LIST**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. vii**  

## Ac **rony m**  **List** AML Average monthly effluent limit BMP Best management practices CWA Clean Water Act DMR Discharge monitoring report Ecology Washington Department of Ecology EIM Environmental Information Management EPA United States Environmental Protection Agency FCR Fish consumption rate I& I In flow and infiltration MDL Maximum daily effluent limit MEC Maximum effluent concentration MEP Maximum extent practicable MERA Mercury

Education and Reduction Act MS4 Municipal separate storm sewer s ys tems NPDES National Pollutant Discharge Eliminati on System NTR National Toxics Rule P2 Pollution prevention PARI S Permitting and Reporting Information System POTW Publicly

owned treatment works QL Quantitation level SMS Sediment management standards SWMP Stormwater management p rogram SWPP P Stormwater pollution prevention plan TMDL Total maximum daily load WAC Washington Administrative Code WLA Waste load allocation WQBEL s Water quality based effluent limitations WQS Water quality standards

### AC **RONYM LIST**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. viii**  

### WWTF Wastewater treatment facility

### EXECUTIV **E SUMMARY**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. ix**  

## Executive Summary The United States Environmental Protection Agency (EPA) is proposing to update the current federal human health criteria applicable to waters under jurisdiction of the S tate of Washington, to protect Washington residents from exposure to toxic pollutants. This report provides estimates of the potential incremental compliance actions and costs that may be associated with the proposed regulation
. **Background and Potential Revised Criteria** EPA promulgated existing criteria for the protection of human health for waters in the State of Washington in 1992 as part of the National Toxics Rule (NTR) (40 Code of Federal Regulations 131.36). The NTR was necessary to bring all s tates into compliance with the requirements of Clean Water Act (CWA) section 303(c)(2)(B). EPA derived the criteria in the NTR using a fish consumption rate (FCR) of 6.5 grams per day (g/day) based on national surveys. The best available data now demonstrate that fish consumer s in Washington, including tribes with treaty-protected rights, consume much more fish than 6.5 g/day . There are also new data and scientific information available to update the toxicity and exposure parameters used to calculate human health criteria. Therefore, EPA proposes to revise the federal human health criteria applicable to waters under jurisdiction of the state of Washington to take into account the best available science, including local and regional information, as well as applicable EPA policies , guidance, and legal requirements, to protect human health. Although the proposed rule does not establish any requirements directl y applicable to regulated entities or other sources of pollution, state implementation may result in new or revised National Pollutant Discharge Elimination System (NPDES) permit conditions for point source dischargers and additional controls on nonpoint sources of pollutant loadings. This analysis provides information on the potential for increment al costs to be associated with such incremental requirements necessary to assure attainment of state water quality designated uses protected by the criteria in the proposed rule. **Point Source Compliance Cost** **s** EPA identified approximately 406 point source facilities that could ultimately be affected by the rule. Of these potentially affected facilities, 73 are classified as major dischargers, and 333 are minor dischargers. Minor facilities are unlikely to incur costs as a result of implementation of the rul e. Minor facilities are typ ically those that discharge less than one million gallons per day

(mgd) and do not discharge toxics in toxic amounts. Although lower human health criteria could potentially change this characterization (effluent monitoring could indicate concentrations at levels of concern) , EPA did not have effluent data on toxic pollutants to evaluate any minor dischargers for this preliminary anal ys is. Additionally , EPA also did not have data to evaluate general permits (e.g., stormwater discharges ) for which

### EXECUTIV **E SUMMARY**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. x**  

### permit conditions ty

pically focus on best management practices rather than pollutant
- specific limits derived from numeric water quality criteria. Of the 73 potentially

affected major dischargers , EPA evaluated a sample of 17 major facilitie s. EPA evaluated the 2 major municipal facilities with design flows greater than 100 mgd, and the largest industrial facility , in attempt to capture potential for the largest costs. For the remaining major facilities, EPA evaluated a random sample of facil ities to represent discharger typ e and category . For all sample facilities, EPA evaluated existing baseline permit conditions, reasonable potential to exceed human health criteria based on the proposed rule, and potential to exceed projected effluent limitations based on the last three ye ars of effluent monitoring data (if available). Analysis of the available data for the sample of facilities indicates that there are likel y to be exceedances of projected effluent limits for arsenic and mercury . In instanc es of baseline effluent limitations not being reflective of baseline criteria, EPA estimated baseline effluent limitations, compliance actions, and costs. In instances of exceedances of projected effluent limitations under the proposed rule, EPA determined the likely compliance scenarios and costs. Only

compliance actions and costs that would be needed above the baseline level of controls are attributable to the proposed rule. EPA assumed that dischargers will pursue the least cost means of compliance with water quality based effluent limits. Incremental compliance actions attributable to the proposed rule may include pollution prevention, end
- of
-pipe treatment, and alternative compliance mechanisms (e.g., variances). EPA annualized capital costs, including study (e.g., variance) and program (e.g., pollution prevention) costs , over 20 years using a 7% discount rate to obtain total annual costs per facility
. 1 

### For the random sample, EPA extrapolated the annualized costs based on the sampling weight for each sample facility . To obtain an estimate of total costs to point sources, EPA added the results for the certainty sample to the extrapolated random sample costs. For the 73 major dischargers in the state, EPA estimates that the total annual cost may be approximately $13 million. All of these costs are attributable to industrial dischargers, primarily for treatment of arsenic. Overall, compliance with revised human health criteria for arsenic accounts for 99% of the costs, while compliance with revised human health criteria for mercury

accounts for the remaining 1%. **Nonpoint Source Co**  **ntrols** Revised human health criteria could also have implications for nonpoint sources. However, it is difficult to model and evaluate the potential costs impacts of this rule to those sources because they

are intermittent, variable, and occur under hydrologic or climatic conditions

1 EPA updated unit cost estimates that it developed previously using a 7% discount rate (see Section 4.1.4 ) and as such used the same discount rate for this analysis. Note that using a lower discount rate (e.g., 3%) wo uld yield lower compliance costs.

### EXECUTIV **E SUMMARY**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. xi**  

### associated with precipitation events . Also, data on instream and discharge levels of the pollutants of concern after dischargers have implemented controls to meet current water quality standards, total maximum daily loads for impaired waters, or other water quality improvement plans, are not available. Therefore, determining which sources would need an incremental level of control attributable to the revised human health criteria after complying with existing regulations and policies may not be possible. EPA identified potential incremental exceedances of the revised human health criteria based on available data in the State of Washington Department of Ec ology (Ecology) Environmental Information Management S ys tem (EIM). According to the state’s Water Quality Program Policy

(Ecology , 2012c), Ecology generall y uses the last ten years of data to determine impairment status of surface waters. EPA used availabl e surface water monitoring data on pollutants of concern from EIM for the ye ars 2005 to 2014. For each monitoring station and parameter, EPA compared the pollutant concentration to both the existing baseline human health criteria and the revised human health criteria. Station results that would indicate impair

ment under EPA’s proposed criteria but not under the existing baseline criteria may

represent potential incremental impairments. 2 

### Using the baseline criteria, monitoring data indicate potential impairm ent on the basis of human health criteria exceedances in the water column at 205 stations. Under the revised criteria, there are 254 exceedances , for a total of 49 potential incremental impairments (or a 24% increase compared to the baseline).

2 Note that these results may not reflect the actual listed impairment status of the waterbody. EPA compared identified impairments to Ecology’s current draft impairment listings; however, data limitations (e.g. the ability to match monitoring stations to e xisting impairment status at the waterbody level across data sets) largely preclude matching of monitoring stations to specific waterbody impairments.

### INTRODUCTION

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 1**  

## 1. **Introduction** The United States Environmental Protection Agency (EPA) is proposing to update the current federal human health criteria applicable to waters under jurisdiction of the state of Washington, to protect Washington residents from exposure to toxic pollutants. This report provides estimates of the potential incremental compliance actions and costs that may be associated with the proposed regulation. **1.1 Background**  The Federal Water Pollution Control Act (as amended through P.L
. 107

–303, November 27, 2002), also known as the Clean Water Act (CWA), sets the basic structure for regulating pollutant discharges into the waters of the United States. In the CWA, Congress established the national objective to “restore and maintain the ch emical, phys ical, and biological integrity of the Nation’s waters,” and to achieve “wherever attainable, an interim goal of water quality which provides for the protection and propagation of fish, shellfish, and wildlife and for recreation in and on the water” (CWA sections 101(a) and 101(a)(2)). The CWA establishes the basis for the current water quality standards (WQS) regulation and program. CWA section 303 addresses the development of state and authorized tribal WQS. WQS reflect the CWA national objectives for each water body. The core components of these standards are designated uses, water quality criteria, and antidegradation requirements. Designated uses establish the environmental objectives for a water body, while water quality criteria define the minimum conditions necessary to achieve those environmental objectives. The antidegradation program complements designated uses and criteria b y providing a framework for maintaining and protecting water quality
. After states, authorized tribes, territories , and the District of Columbia (hereafter, states and authorized tribes) designate the uses of waters under their jurisdiction, they must establish water quality criteria that protect those designated uses. EPA’s regulation at §131.11(a)(1) provides that that such criteria “must be based on sound scientific rationale, and must contain sufficient parameters or constituents to protect the designated use.” States and authorized tribes must also adopt antidegradation policies to protect and maintain high quality waters and existing uses of all waters, and identify specific methods to implement those policies (§131.12). The CWA also requires states and authorized tribes to hold public hearings once every three ye ars for the purpose of reviewing applicable WQS and , as appropriate, modifying and adopting standards. The results of this triennial review must be submitted to EPA, and EPA must approve or disapprove any new or revised standards. CWA Section 303(c)(4)(B) authorizes the Administrator to determine, even in the absence of a state submission, that a new or revised standard is needed to meet CWA requirements.

### INTRODUCTION

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 2**  

### EPA promulgated existing criteria for the protection of human health for waters in the State of Washington in 1992 as part of the National Toxics Rule (NTR) (40 Code of Federal Regulations 131.36). The NTR was necessary to bring all s tates into compliance with the requirements of CWA section 303(c)(2)(B). EPA derived the criteria in the NTR using a fish consumption rate (FCR) of 6.5 grams per day (g/day) based on national surveys. The best available data now demonstrate that fish consumers in Washington, including tribes with treaty-protected rights, consume much more fish than 6.5 g/day
. There are also new data and scientific information available to update the toxicity and exposure parameters used to calculate human health criteria. Therefore, EPA proposes to revise the federal human health criteria applicable to waters under jurisdiction of the state of Washington to take into account the best available science, including local and regional information, as well as applicable EPA policies, guidance, and legal requirements, to protect human health. **1.2 Purpose and Scope of the A**  **naly sis**  The purp ose of this analysis is to identify, using available water quality and discharge data and information, the incremental compliance actions and costs that publicly owned wastewater treatment works (POTWs) and industrial point source dischargers may incur as a result of EPA’s proposed criteria. EPA did not consider potential costs associated with new or expanding facilities. Although the proposed rule does not establish any requirements directly applicable to regulated entities or other sources of pollution, s tate implementation may result in new or revised National Pollutant Discharge Elimination System (NPDES) permit conditions for point source dischargers to incorporate revised water quality based effluent limits (WQBELs). Due to the large number of pollutants of concern, the estimates of statewide compliance costs reflect the extrapolation of results for a sample of major dischargers. The revised standards may also result in incremental determinations that waters exceed WQS . As such, Ecology

may need to deve lop additional total maximum daily loads (TMDLs) for impaired waters. There may also be incremental controls and costs associated with load allocations for nonpoint sources under such TMDLs to attain standards. However, the data and information needed to evaluate potential control needs are more limited. For this preliminary

anal ys is, EPA identif

ied the potential for incremental impairment, and thus incremental controls and costs for nonpoint sources, but did not develop statewide cost estimates. **1.3 Organizati**  **on of Report** This remainder of this report is organized as follows: **Section 2: Baseline for the Analysis**

– describes the current applicable toxic criteria and Ecology procedures for implementing the criteria in NPDES permits, sources of toxic

### INTRODUCTION

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 3**  

### pollutants to surface waters, water quality impairments from toxic pollutants, and ongoing efforts to reduce and eliminate these impairments. **Section 3: Potential Revised Criteria**

– outlines the changes to existing water quality standards. **Section 4: Method for Estim ating Potential Costs: Point Sources** 

– describes the method for estimating compliance costs associated with baseline and revised criteria for point sources in terms of revisions to NPDES permits. **Section 5: Method for Identifying**  **Potential Costs: Nonpoint Sources**

– describes the method for identifying potential for incremental impairment and compliance costs associated with baseline and revised criteria for nonpoint sources. **Section 6: Potential Compliance Costs**

– provides estimates of potential costs to comply with the revised WQS , and discusses the uncertainties associated with the estimates. **Section 7: References**

– provides the references used in the anal ys is. **Appendices** provide data and information on individual sample facil ities, and anal ys es of potential impacts under the proposed r ule
.

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 4**  

## 2. **Baseline for the Anal**  **ys is**  This section describes the applicable baseline for evaluating the incremental costs associated with the revised WQS , including current water quality criteria and associated implementation procedures , potential sources of the pollutants of concern, the current level of impairment , and listing procedures
. **2.1 Water Quality** 

**Criteria and Implementation Procedures**  Exhibit 2
- 1 shows the applicable baseline criteria for toxic pollutants for which there are human health criteria . Ecology designates all surface waters for the protection of both aquatic life and human health. 3 

### EPA did not consider further those p ollutants for which the aquatic life criteria are more stringent than the proposed revised human health criteria because the more stringent criteria coupled with th e implementing procedures (e.g., allowable dilution factors) would always result in more stringent effluent limitations. Therefore the proposed rule would not lead to additional compliance costs for these pollutants. **Exhibit 2**  **- 1**  **. Baseline**  **Freshwater and Marine Water Quality Criteria for Toxic**  **Pollutants in Washington 1** 

**Parameter Freshwater**  **Aq uatic Life**  **(μg/L) Ma**  **rine A quatic** 

**Life (μg/L)**  **Human Health (μg/L)**  **Acute Chronic**  **Acute Chronic**  **Water and Fish**  **Fish Only**  1,1,2,2 - Tetrachloroethane 0.17 11 1,1,2 - Trichloroethane 0.6 42 1,1 - Dichloroethylene 0.057 3.2 1,2,4 - Trichlorobenzene 1,2 - Dichlorobenzene 2700 17000 1,2 - Dichloroethane 0.38 99 1,2 - Dichloropropane 1,2 - Diphenylhydrazine 0.04 0.54 1,2 - Trans - Dichloroethylene 1,3 - Dichlorobenzene 400 2600 1,3 - Dichloropropene 10 1700 1,4 - Dichlorobenzene 400 2600 2,3,7,8 - TCDD (Dioxin) 0.000000013 0.000000014

3 Section 173
- 201A
- 600 specifies that all surface waters of the state that do not have specific listing s in Table 602 are “to be protected for the designated uses of: Salmonid spawning , rearing, and migration; primary contact recreation; domestic, industrial, and agricultural water supply; stock watering; wildlife habitat; harvesting; commerce and navigatio n; boating; and aesthetic values.”

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 5**  **Exhibit 2**  **- 1**  **. Baseline**  **Freshwater and Marine Water Quality Criteria for Toxic**  **Pollutants in Washington 1** 

**Parameter Freshwater**  **Aq uatic Life**  **(μg/L) Ma**  **rine A quatic** 

**Life (μg/L)**  **Human Health (μg/L)**  **Acute Chronic**  **Acute Chronic**  **Water and Fish**  **Fish Only**  2,4,6 - Trichlorophenol 2.1 6.5 2,4 - Dichlorophenol 93 790 2,4 - Dim ethylphenol 2,4 - Dinitrophenol 70 14000 2,4 - Dinitrotoluene 0.11 9.1 2 - Chloronaphthalene 2 - Chlorophenol 2 - Methyl - 4,6 - d initrophenol 13 765 3,3' - Dichlorobenzidine 0.04 0.077 4,4' - DDD 0.00083 0.00084 4,4' - DDE 0.00059 0.00059 4,4' - DDT 0.00059 0.00059 Acenaphthene Acrolein 320 780 Acrylonitrile 0.059 0.66 Aldrin 0.00013 0.00014 alpha - BHC 0.0039 0.013 alpha - e ndosulfan 0.93 2 Anthracene 9600 110000 Antimony 14 4300 Arsenic 360 190 69 36 0.018 0.14 Asbestos 2 7000000 Benzene 1.2 71 Benzidine 0.00012 0.00054 Benzo(a) a nthracene 0.0028 0.031 Benzo(a) p yrene 0.0028 0.031 Benzo(b) f luoranthene 0.0028 0.031 Benzo(k) f luoranthene 0.0028 0.031 beta - BHC 0.014 0.046 beta - e ndosulfan 0.93 2 Bis(2 - c hloroethyl) e ther 0.031 1.4 Bis(2 - c hloroisopropyl) e ther 1400 170000 Bis(2 - ethy lhex yl) p hthalate 1.8 5.9

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 6**  **Exhibit 2**  **- 1**  **. Baseline**  **Freshwater and Marine Water Quality Criteria for Toxic**  **Pollutants in Washington 1** 

**Parameter Freshwater**  **Aq uatic Life**  **(μg/L) Ma**  **rine A quatic** 

**Life (μg/L)**  **Human Health (μg/L)**  **Acute Chronic**  **Acute Chronic**  **Water and Fish**  **Fish Only**  Bromoform 4.3 360 But yl benzyl p hthalate Carbon t etrachloride 0.25 4.4 Chlordane 2.4 0.0043 0.09 0.004 0.00057 0.00059 Chlorobenzene 680 21000 Chlorodibromomethane 0.41 34 Chloroform 5.7 470 Chrysene 0.0028 0.031 Copper 4.8 3.1 Cyanide 22.0 5.2 1.0 700 220000 Dibenzo(a,h) a nthracene 0.0028 0.031 Dichlorobromomethane 0.27 22 Dieldrin 2.5 0.0019 0.71 0.0019 0.00014 0.00014 Diethyl p hthalate 23000 120000 Dim ethyl p hthalate 313000 2900000 Di - n - but yl p hthalate 2700 12000 Endosulfan s ulfate 0.22 0.056 0.034 0.0087 0.93 2 Endrin 0.18 0.0023 0.037 0.023 0.76 0.81 Endrin a ldehyde 0.76 0.81 Eth yl benzene 3100 29000 Fluoranthene 300 370 Fluorene 1300 14000 Hex achlorocyclohexane (gamma - BHC; l indane) 2.0 0.08 0.16 0.019 0.063 Heptachlor 0.52 0.0038 0.053 0.0036 0.00021 0.00021 Heptachlor Epoxide 0.0001 0.00011 Hexachlorobenzene 0.00075 0.00077 Hexachlorobutadiene 0.44 50 Hexachlorocyclopentadiene 240 17000 Hexachloroethane 1.9 8.9 Indeno(1,2,3 - cd) p yr ene 0.0028 0.031 Isophorone 8.4 600 Methyl b romide 48 4000

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 7**  **Exhibit 2**  **- 1**  **. Baseline**  **Freshwater and Marine Water Quality Criteria for Toxic**  **Pollutants in Washington 1** 

**Parameter Freshwater**  **Aq uatic Life**  **(μg/L) Ma**  **rine A quatic** 

**Life (μg/L)**  **Human Health (μg/L)**  **Acute Chronic**  **Acute Chronic**  **Water and Fish**  **Fish Only**  Methylene c hloride 4.7 1600 Nickel 74.0 8.2 610 4600 Nitrobenzene 17 1900 N - Nitrosodimethylamine 0.00069 8.1 N - Nitrosodi - n - p ropy lamine N - Nitrosodiphenylamine 5 16 Pentachlorophenol (PCP) 13.0 7.9 0.28 8.2 Phenol 21000 4600000 Polychlorinated b iphenyls (PCBs) 2.0 0.0014 10.0 0.03 0.00017 0.00017 Py rene 960 11000 Selenium 20.0 5.0 290 71.0 Tetrachloroethylene 0.8 8.9 Thallium 1.7 6.3 Toluene 6800 200000 Toxaphene 0.73 0.0002 0.21 0.0002 0.00073 0.00075 Trichloroethylene 2.7 81 Vin yl c hloride 2 525 Zinc 90.0 81.0 Mercury 2.1 0.012 1.8 0.025 0.14 0.15 Source: Ecology (2014 a ) and W AC 173 - 201A- 240. 1. Metals criteria are in dissolved form; blanks indicate no baseline criteria. 2. Asbestos criteria are in fibers/L. 

### Section 173
- 201A
- 260 of the Washington Administrative Code (WAC) specifies the procedures for appl ying water quality criteria. As part of these procedures, the s tate addresses how to handle situation s when natural and irreversible human conditions cause a receiving water to not meet applicable criteria. In those instanc es, Section 173
- 201A
- 260 (1)(a) stipulates that the natural conditions constitute the water quality criteria. **2.2 Sources of Toxic Pollutants to Surface Waters**  Toxic pollutants can be introduced to surface water through natural and human activities, including municipal and industrial effluents, stormwater discharges, agricultural runoff, forestry (chemical application), atmospheric deposition , and contaminated sediments.

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 8**  **2.2.1 Municipal and Industrial Dischargers**  

### Ecology ’s Water Quality Permitting and Reporting Infor mation System (PARI S) indicates that there are 406 major and minor NPDES permitted dischargers in Washington. Exhibit 2
- 2 shows the number of facilities by typ e (major/minor) and category (based on SIC codes provided in PARI S and facility
- specific fact sheets). Exhibit 2 - 2 . Number of Dischargers in W ashington by Category Category Minor Major All Agriculture, Fishing, and Forestry 14 0 14 Mining 4 1 5 Construction 4 0 4 Food and Kindred Products 30 1 31 Lum ber and W ood Products, Except Furniture 11 0 11 Paper and Allied Products 1 12 13 Chemicals and Allied Products 10 1 11 Petroleum Refining and Related Industries 4 5 9 Stone, Clay, Glass, and Concrete Products 5 0 5 Prim ary Metal Industries 6 4 10 Fabricated Metal Products, except Machinery and Transportation Equipment 1 0 1 Transportation Equipment 19 0 19 Transportation & Public Utilities (except POTW s) 19 1 20 POTW 184 48 232 Wh olesale Trade 10 0 10 Retail Trade 2 0 2 Services 7 0 7 Public Administration 2 0 2 **Total 333**  **73 406**  S ource : based on data from the Wa shington Department of Ecology W ater Quality Permitting and Reporting Information System (PARIS) database, and supplementary data from facility fact sheets. Categorizations based on 2 - digit SIC codes. 

### Ecology issues general NPDES permits for 18 different discharger categories, including industrial (e.g. lumber and wood products, petroleum refining, metal manufacturing, and construction) and municipal, with over half of permitted dischargers being municipal POTWs
. **2.2.2 Urban Stormwater**  

### Stormwater discharges are generated b y precipitation and runoff from land, pavements, building rooftops, and other surfaces. Stormwater from municipal and industrial areas may contribute pollutants (including toxic pollutants) to surface waters (for example, see Eco logy ,

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 9**  

### 2012a) . Ecology

regulates stormwater discharges from municipal separate storm sewer systems (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). According to Ecology , an SWMP involves planning, public education and involvement, illicit discharge detection programs, and passing appropriate ordinances to reduce stormwater pollution (Ecology , 2014b ). 4 

### Ecology has issued a Phase I permit ( Ecology , 201 5 a), which covers 6 jurisdictions (Seattle and Tacoma, and unincorporated King, Pierce, Snohomish, and Clark counties), each serving more than 100,000 people. The Phase II general permits cover those s ys tems serving municipalities with populations less than 100,000 located within Census Bureau
- defined urbanized areas. There are two Phase II stormwater permits; one for the eastern part (Ecology , 2012b ) of the state and one for the western pa rt (Ecology , 201 4 c )
. Industrial dischargers, including those engaged in manufacturing, transportation, mining, and steam electric power industries, scrap yards, landfills, certain sewage treatment plants, and hazardous waste management facilities may have stormwater requirements in their NPDES permits. Additionally , Ecology issue s an Industrial Stormwater general permit (Ecology , 2014 d), which requires industrial stormwater dischargers to develop a Stormwater Pollution Prevention Plan (SWP P P) that includes best management practices (BMPs) to prevent, control, and treat stormwater pollution, a monitoring plan and discussion of the site controls that the discharger will implement to prevent stormwater pollution. **2.2.3 Ag**  **riculture and Forestry**  

### Pesticides applied to agricultural or forestry lands can reach surface waters through irrigation return flow, stormwater runoff, and erosion of soils. The Department of Ecology works with farmers in Washington to incentivize and implement BMPs on agricultural land to reduce runoff of pollutants from agricultural lands. Washington regulates forestry activities on State and private lands through the Washington Forest Practices Act (chapter 76.09 RCW) and the associated forest practices rules (Title 222 WAC). The Washington Forest Practices Board (the authority empowered to enforce forest practices rules) designed and adopted the forest practice rules, in part, to meet the requirements of the CWA and State water quality standards. The rules cover a variety of forestry activities, including timber harvesting, thinning, road construction, fertilization, and chemical application. **2.2.4 At**  **mospheric Deposition** 

### Atmospheric deposition may be a potential nonpoint source to surface waters through either direct or indirect dep osition. Direct deposition occurs when pollutants are deposited directl y

4 SWMPs do not include numeric WQBELs.

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 10**  

### on surface waters from the atmosphere. Indirect deposition reflects the process by which metals and other pollutants such as pesticides deposited on the land surface are washed off during storm events and enter surface water through stormwater runoff. Atmospheric deposition is not directly

addressed through any

existing regulation, but may be indirectl y addressed through TMDLs. **2.2.5 Contaminated Sediments**  

### When pollutants enter a waterbody through runoff, precipitation, or other means, they can accumulate in sediments and contribute to poor water quality for many ye ars (U.S. EPA, 2012) . Many waterbody sediments are contaminated by legacy pollutants including DDT, PCBs, and other pesticides. T o address sediment contamination, Washington implemented the Washington State Sediment Management Standards (SMS) Chapter 173
- 204 WAC to reduce and ultimately

eliminate sediment contamination in Washington waterbodies. 5 

### The SMS set numeric and narrative criteria for sediments, apply the standards to reduce pollutant discharges, and provide a decision process for the cleanup of contaminated sites. **2.3 Water Quality**  Ecology classifie s all surface waters into one of five categories, based on available monitoring data, as follows:

 

### Category

1 waters are those for which sufficient monitoring data are available to determine that the water is below all applicable criteria (i.e., it is not impaired)

 

### Category

2 waters are “waters of concern,” which means that there i s on e observation exceeding the criteria or two or more observations exceeding the criteria but not within a 3
- ye ar period

 

### Category

3 waters for which there are in sufficient data to determine whether it is impaired

 

### Category

4 waters are impaired but Ecology is not pursuing TMDL s for them because a) there is an EPA
- approved TMDL , b) there is a pollution control program in place, or c) it is impaired by

a cause other than a pollutant

 

### Category

5 waters are impaired and a TMDL or pollution control plan is required ; to be placed into Category

5 on the basis of water concentrations, there must be two or more exceedances of criteria within a 3
- ye ar period. Waters can also be placed into Category 5 on the basis of fish tissue concentrations, if the mean of the three highest available resident fish tissue observations exceed the fish tissue criteria , which are back
- calculated from surface water concentrations using bioconcentration factors from the NTR
.

5 See: http://www.ecy.wa.gov/programs/tcp/smu/sed_standards.htm
. EPA has not taken a CWA action on the 2013 revisions the SMS.

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 11**  

### Ecology recently conduct ed a public review of the latest updated Water Quality Assessment and 303(d) List for Washington State (the public comment period for the review ended on May 15, 2015) . This a ssessment updates fresh water listings based on data collected as of the end of Dec ember 2010. 6 

### The integrated report identifies impaired waters and reports on the status of water quality

statewide. Exhibit 2
- 3 summarizes the proposed Category 4 and 5 listings for each of the pollutants of interest. Exhibit 2
- 4 summarizes existing TMDLs targeting or including toxic pollutants in waters in Washington. 7 Exhibit 2 - 3 . 2015 Proposed Category 4 and 5 Listings for Toxic Pollutants

Parameter Wa terbodies Lake/Marine Square Kilometers River Kilometers 2,3,7,8 - TCDD ( d ioxin) 65 50 52 4,4' - DDD 31 3 97 4,4' - DDE 93 14 182 4,4' - DDT 64 4 184 Aldrin 4 2 7 alpha - BHC 10 6 7 Arsenic 12 3 18 Benzo(a) a nthracene 25 11 0 Benzo(a) p yrene 23 9 0 Benzo(b) f luoranthene 28 11 0 Benzo(k) f luoranthene 23 10 0 beta - BHC 3 2 0 Bis(2 - e thy lhex yl) p hthalate 3 1 0 Chlordane 13 5 16 Chrysene 34 14 0 Copper 19 1 32 Dibenzo(a,h) a nthracene 11 3 0 Dieldrin 54 25 78 Heptachlor e poxide 2 0 7 Hexachlorobenzene 10 11 23 Indeno(1,2,3 - cd) p yr ene 16 5 0 Toxaphene 19 11 20 Zinc 12 0 47 Mercury 29 8 37 Source: Based on data from the Proposed Draft Assessment Database (available at: https://fortress.wa.gov/ecy/wats/SearchList.aspx ).

6 See: http://www.ecy.wa.gov/programs/wq/303d/freshwtrassessmnt/index.html
. 7 Additionally, there is a TMDL for sediment contamination in Bellingham B ay (see Ecology, 2001).

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 12**  Exhibit 2 - 4 . Summary of TMDLs for Toxic Pollutants in Wa ters in Wa shington Wa terbody Parameter(s) Status and Notes Source Stillaguamish Basin Dissolved oxygen,

fecal coliform, me rcury , pH, temperature Mercury levels exceeding aquatic life criteria

are rare (occurring during high - flow events) and attributable to natural background sources without contribution from anthropogenic sources; l oad allocation for total suspended solides expected to reduce occurrences of mercury concentrations higher than aquatic life criteria. Ecology (2005)

Snohomi sh River Area Dioxin Exceedances of human health criteria attributed to a point source discharge. Ecology (1992a) Commence me nt Bay Dioxin Exceedances of human health criteria attributed to a point source discharge. Ecology (1992b) Deschutes River Wa tershed Dissolved oxygen,

fecal coliform, PCB, pH, phosphorus, temperature TMDL is under development

. Ecology (2014e)
Wa lla W alla River Wa tershed Chlorinated

pesticides, PCBs, fecal coliform, pH, dissolved oxygen, temperature E xceedances of human health criteria for

chlorinated pesticides and PCBs attributed to historical application of chlorinated pesticides to soils and crops in agricultural areas of the watershed

. Ecology (2006 a )

Palouse River Chlorinated

pesticides and PCBs Exceedances of human health criteria for

chlorinated pesticides and PCBs; TMDL includes waste load allocations for WWTP s and nonpoint sources. Ecology (2007 a )
Yakima River Wa tershed Toxics and

Pesticides Exceedances of human health and aquatic life

criteria are attributed to historical applications

. Ecology (2012 c ; 2010 ) Wa natchee River Area DDT Exceedances of human health criteria are attributed to historical applications. Ecology (2007b) Lake Chelan DDT and PCBs Exceedances of human health criteria are attributed to historical applications Ecology (2006b) Lower Ok anogan River Basin DDT and PCBs Exceedances of human health and aquatic life criteria are attributed to historical applications

. Ecology (2004a) Lower Sim ilkameen River Arsenic Exceedances of human health criteria for arsenic attributed to historic mining practices and natural sources. Ecology (2004b) Spokane River Dissolved metals Exceedances of aquatic life criteria for dissolved metals attributed to point sources in Idaho (upstream) and W ashington

. Ecology (1999)

### BA**SELINE FOR THE A NA**  **LYSIS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 13**  Exhibit 2 - 4 . Summary of TMDLs for Toxic Pollutants in Wa ters in Wa shington Wa terbody Parameter(s) Status and Notes Source S ource : i nformation from the Department of Ecology W ater Quality Improvement Projects database (available at: http://www.ecy.wa.gov/programs/wq/tmdl/TMDLsby Wr ia/TMDLby

Wr ia.htm l ) TMDL = total maximum daily load WWTP = wastewater treatment plant

### POTENTIA **L REVISED CRITERIA**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 14**  

## 3. **Potential Revised Criteria** EPA is proposing changes to several inputs in the equation for calculating human health criteria. The criteria are calculated as follows (EPA, 1980):

= ( × ) × + ( × )

= 10 1 ∗ × + ( × ) where, AWQC = amb ient water quality criterion (mg/L) BW = human body weight (kg) RfD = reference dose based on noncancer human health effects (mg/kg BW
- day) RSC = relative source contribution (%) DI = drinking water intake (L/day) FI = human fish consumption (kg fish/day) B AF = bio accumulation factor ( L/kg fish) q1* = cancer potency factor in (kg BW
- day

/mg )
. The criteria from the NTR are the applicable existing AWQC for each pollutant of concern. EPA is proposing updated values for BW, RfD, RSC, DI , FI, BAF and q1*. These updates come from EPA (2014 ( as available); 2002), with a FI specifically proposed for Washington. In 2001, EPA published a revised methylmercury criterion based on the concentration of methylmercury

in fish tissue, calculated using the following equation (EPA, 2001a):

= × (
− ) ∑ where, TRC = tissue residual concentration in mg methylmercury/kg fish FIi 

### = human fish consumption of trophic level i (kg fish/day) RSC = relative source contribution in mg methylmercury /kg body weight
- day
. Exhibit 3
- 1 summarizes the key assumptions that EPA made to calculate hum an health criteria
.

### POTENTIA **L REVISED CRITERIA**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 15**  **Exhibit 3**  **- 1**  **. Summary of**  **Key As**  **sumptions for Calculating Human Health Criteria**  **Variable Value**  Fish consumption rate (FCR; g/day) 175 Bod y weight (BW; k g) 80 Drinking water intake (D WI ; L/day) 2.4 Excess cancer risk level (RL) 10 - 6 Relative source contribution (RSC) 0.2 to 0. 8 Toxicity factors basis U.S. EPA (2014) Mercury criteria basis U.S. EPA (2001 a ) 

### Exhibit 3
- 2 summarize s the human health criteria for the pollutants of concern derived using the assumptions in Exhibit 3
- 1 . The exhibit also show s Ecology ’s quantification limits (QL s) which represent the minimum level to which dischargers need to measure each pollutant. Compared with the proposed criteria , the state’s freshwater and marine aquatic life criteria are more stringent for selenium, while the marine aquatic life criteria are more stringent for copper , nickel, and zinc (see Exhibit 2
- 1 ). Because the aquatic life criteria are more stringent, EPA did not analy

ze discharges of these pollutants in relevant areas
. Exhibit 3 - 2 . Proposed Human Health Criteria ( μg /L )

Parameter Freshwater Criteria Marine Criteria Quantification Limit 1,1,1 - Trichloroethane 8000 20000 2.0 1,1,2,2 - Tetrachloroethane 0.1 0.3 2 1,1,2 - Trichloroethane 0.35 0.9 0 2 1,1 - Dichloroethylene 300 2000 2 1,2,4 - Trichlorobenzene 0.036 0.037 0.6 1,2 - Dichlorobenzene 300 300 7.6 1,2 - Dichloroethane 8.9 73 2 1,2 - Dichloropropane 0.72 3.3 2 1,2 - Diphenylhydrazine 0.01 0.02 20 1,2 - Trans - Dichloroethylene 100 400 2 1,3 - Dichlorobenzene 0.9 1 7.6 1,3 - Dichloropropene 0.22 1.2 2 1,4 - Dichlorobenzene 70 80 17.6 2,3,7,8 - TCDD (Dioxin) 5.8 E - 10 5. 9 E - 10 0.000005 2,4,6 - Trichlorophenol 0.25 0.28 4 2,4 - Dichlorophenol 4 6 1 2,4 - Dim ethylphenol 90 300 1 2,4 - Dinitrophenol 10 40 2 2,4 - Dinitrotoluene 0.039 0.18 0.4

### POTENTIA **L REVISED CRITERIA**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 16**  Exhibit 3 - 2 . Proposed Human Health Criteria ( μg /L )

Parameter Freshwater Criteria Marine Criteria Quantification Limit 2 - Chloronaphthalene 100 100 0.6 2 - Chlorophenol 20 80 2 2 - Methyl - 4,6 - Dinitrophenol 1 3 NR 3,3' - Dichlorobenzidine 0.012 0.015 1 3 - Methyl - 4 - Chlorophenol 200 200 NR 4,4' - DDD 7.9E - 6 7.9E - 6 0.05 4,4' - DDE 8.8E - 7 8.8E - 7 0.05 4,4' - DDT 1.2E - 6 1.2E - 6 0.05 Acenaphthene 10 10 0.4 Acrolein 3 50 10 Acrylonitrile 0.058 0.85 2 Aldrin 4.1E - 8 4.1E - 8 0.05 alpha - BHC 4.8E - 5 4.8E - 5 0.05 alpha - Endosulfan 3 3 0.05 Anthracene 40 40 0.6 Antimony 2. 5 3 7 1 Arsenic 1 0.0045 0.0059 0.5 Asbestos 2 7000000 NC NR Benzene 3 0.44 1.7 2 Benzidine 0.00013 0.0012 24 Benzo(a) Anthracene 0.00016 0.00016 0.6 Benzo(a) Py rene 1.6E - 5 1.6E - 5 1 Benzo(b) Fluoranthene 0.00016 0.00016 1.6 Benzo(k) Fluoranthene 0.0016 0.0016 1.6 beta - BHC 0.0013 0.0014 0.05 beta - Endosulfan 4 4 0.05 Bis(2 - Chloroethyl) Ether 0.027 0.24 1 Bis(2 - Chloro - 1 - Methy lethy l) Ether8 200 400 0.6 Bis(2 - Ethylhexyl) Phthalate 0.045 0.046 0.5 Bromoform 4.6 12 2 But yl benzyl Phthalate 0.013 0.013 NR Carbon Tetrachloride 0.2 0.5 2 Chlordane 0.000022 0.000022 0.05 Chlorobenzene 50 80 2 Chlorodibromomethane 0.6 0 2.2 2 Chloroform 50 200 2

### POTENTIA **L REVISED CRITERIA**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 17**  Exhibit 3 - 2 . Proposed Human Health Criteria ( μg /L )

Parameter Freshwater Criteria Marine Criteria Quantification Limit Chrysene 0.016 0.016 0.6 Copper

4 , 5 1300 NC 2 Cyanide 4 50 10 Dibenzo(a,h) Anthracene 1.6E - 5 1.6E - 5 1.6 Dichlorobromomethane 0.73 2.8 2 Dieldrin 7.0E - 8 7.0E - 8 0.05 Diethyl Phthalate 80 80 7.6 Dim ethyl Phthalate 200 200 6.4 Di - n - Butyl Phthalate 3 3 1 Endosulfan Sulfate 4 4 0.05 Endrin 0.002 0.002 0.05 Endrin Aldehyde 0.1 0.1 0.05 Eth yl benzene 12 13 2 Fluoranthene 2 2 0.6 Fluorene 5 5 0.6 G amma - BHC; Lindane 0.43 0.43 NR Heptachlor 3.4E - 7 3.4E - 7 0.05 Heptachlor Epoxide 2.4E - 6 2.4E - 6 0.05 Hexachlorobenzene 5.0E - 6 5.0E - 6 0.6 Hexachlorobutadiene 0.01 0.01 1 Hexachlorocyclopentadiene 0.4 0.4 1 Hexachloroethane 0.02 0.02 1 Indeno(1,2,3 - cd) Pyrene 0.00016 0.00016 1 Isophorone 30 200 1 Methyl Bromide 100 1000 10 Methylene Chloride 10 100 10 Methylmercury6 0.033 Nickel 5 30 39 0.5 Nitrobenzene 10 60 1 N - Nitrosodimethylamine 0.0006 5 0.34 4 N - Nitrosodi - n - Propylamine 0.004 4 0.05 8 1 N - Nitrosodiphenylamine 0.62 0.6 9 1 Pentachlorophenol (PCP) 0.002 0.002 1 Phenol 4000 30000 4 Polychlorinated Biphenyls (PCBs) 7 7.3E - 6 7.3 E - 6 0.5 Py rene 3 3 0.6

### POTENTIA **L REVISED CRITERIA**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 18**  Exhibit 3 - 2 . Proposed Human Health Criteria ( μg /L )

Parameter Freshwater Criteria Marine Criteria Quantification Limit Selenium 5 25 95 1 Tetrachloroethylene 2.4 2.9 2 Thallium 0.048 0.05 4 0.36 Toluene 29 52 2 Toxaphene 6.6E - 5 6.6E - 5 0.5 Trichloroethylene 0.3 0.7 2 Vin yl Chloride 0.02 0 0.18 2 Zinc 5 45 0 580 2.5 NC = no criteria proposed NR = not reported 1. The c riteria for arsenic refer to the inorganic form of arsenic only. 2. The criterion for asbestos is expressed in fibers/L, and is the M aximum C ontaminant L evel G oal (MCLG) developed under the Safe Drinking W ater Act (56 FR 3526, January 30, 1991)

. 3

. EPA’s national 304(a) recommended criteria for benzene use a CSF range of 0.015 to 0.055 per mg/kg - day. EPA proposes to use the higher end of the CSF range (0.055 per mg/kg - day ) to derive the proposed benzene criteria. 4 . The criterion for copper is the MCL G developed under the Safe Drinking Wa ter Act (40 CFR 141.80, June 7, 1991). 5

. The existing aquatic life criteria are more stringent than the proposed freshwater and marine criteria for selenium, and the proposed marine criteria for copper, nickel, and zinc. As such, EPA did not analyze discharges of these pollutants. 6

. Th e criter ion for methylmercury is expressed as the fish tissue concentration of methy lm ercury (m g m ethylm ercury

/kg fish). See Water Quality Criterion for the Protection of Human Health: Methylmercury (EPA- 823 - R - 01 - 001, January 3, 2001) for how this value is calcula ted using the criterion equation in EPA's 2000 Human Health Methodology rearranged to solve for a protective concentration in fish tissue rather than in water. 7. The criteria for PCBs apply to total PCBs (e.g., the sum of all congener or isomer or homolog or Aroclor analyses). 8. Bis(2 - Chloro - 1 - Methy lethyl) Ether was previously listed as Bis(2 - Chloroisopropyl) Ether.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 19**  

## 4. **Method for Estimating Potential Costs: Point Sources** This section describes the method for estimating the potential costs to point sources a ssociated with compliance with the revised human health criteria. Compliance costs for municipal and industrial point sources may result from changes to NPDES permit requirements and associated effluent limitations
. **4.1 Major Dischargers**  EPA estimated costs to major municipal and industrial dischargers under the proposed criteria by

estimating costs to a representative sample of facilities, then extrapolating the results to the rest of the facilities (by category) . This section describes sample selection, the reasonable potential analysis, identification of limits under the revised criteria and comparison to existing criteria, estimation of costs to meet revised criteria, and extrapolation to all major dischargers
. Unless otherwise noted, EPA updated all cost estimates to 2014 ye ar dollars using the consumer price index. **4.1.1 Sample Selection**  

### Factors that may

affect the potential magnitude of compliance costs include flow and ty pe of facility . Larger flows are ty picall y associated with the largest treatment costs, although per
unit costs may

decrease due to economies of scale. Industrial category may also be indicative of the potential to incur costs. Treatment requirements differ for municipal and industrial discharges, and effluent quality may be similar across categories of facilities. As shown in Exhibit 2
- 2 , there are 406 total individually permitted dischargers, including 73 major dischargers (48 municipal POTWs and 25 industrial dischargers) and 333 minor dischargers (184 municipal POTWs and 149 industrial). To evaluate potential costs to major dischargers, EPA selected a representative sample of the major disch argers to evaluate potential costs in detail
. First, EPA selected a certainty sample of the two largest municipal facilities 8 

### and the largest industrial facility ; this certainty sample attempts to ensure that the high est potential for cost is captured in the anal ysis. From the remaining major discharger s, EPA selected a random sample of dischargers across categories. EPA then extrapolated the results of the sample evaluation to estimate costs across all major dischargers by category . Exhibit 4
- 1 provides a summary of major discharger categories and the distribution of the sample across those categories
.

8 The two largest facilities, the King County West Point POTW and the King County South POTW, represent 25% of all major discharger flow and 35% of major POTW flow
.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 20**  **Exhibit 4**  **- 1**  **. Summary of**  **Major Dischargers by**  **Industrial Category**

**Category Universe**  **Sample Facilities**  **Design Flow** 

**(mgd) Facilities**  **Design Flow**  **(mgd)** Food and Kindred Products 1 5 1 (100%) 5 (100%) Mining 1 0 1 (100%) 0 (NA) Paper and Allied Products 12 336 2 (17%) 24 (7%) Chemicals, P etroleum Refining , and Related Industries 6 27 3 (50%) 18 (67%) Prim ary Metal Industries 4 27 2 (50%) 8 (28%) POTW 48 1,019 7 (15%) 419 (41%) Transportation & Public Utilities (except POTW s) 1 12 1 (100%) 12 (100%) **Total 73**  **1,425 17 (23%)**  **486 (34%)** m gd = m illion gallons per day POTW = publicly owned treatment works 

### Exhibit 4
- 2 provides a summary of the sample for evaluation. Appendix A provides additional information on these facilities. Exhibit 4 - 2 . Summary of Major Discharger Sample NPDES Number Facility Name Category Design Flow (m gd) **Certainty Sample** WA0029581 King County South WW TP POTW 144.0 WA0029181 King County W est Point W WT P POTW 215.0 WA0022900 BP Cherry Point Refinery Petroleum Refining and Related Industries 13.0 **Random Sample** WA0039624 Chambers Creek STP POTW 28.7 WA0044962 Pasco WWTP POTW 3.5 WA0037168 Pu yallup STP POTW 14.0 WA0023451 Redondo WW TP POTW 5.6 WA0022772 Salm on Creek WWTP POTW 8.1 WA0037338 Transalta Centralia Mining Mining 5.0 WA0000884 Sonoco Products Company Paper and Allied Products 0.3 WA0000809 Cosmo Specialty Fibers, Inc. Paper and Allied Products 24.0 WA0001783 U.S. Oil & Refining Facility Petroleum Refining and Related Industries 0.6 WA0000761 Tesoro Refining & Marketing

Company LLC Petroleum Refining and Related Industries 4.3

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 21**  Exhibit 4 - 2 . Summary of Major Discharger Sample NPDES Number Facility Name Category Design Flow (m gd) WA0021067 Quincy Industrial Food and Kindred Products 4.9 WA0040851 Steelscape, Inc. Prim ary Metal Industries 0.2 WA0002950 Intalco Aluminum Corp Ferndale Prim ary Metal Industries 7.4 WA0001546 Transalta Centralia Generation Transportation & Public Utilities (except POTW s) 12.1
m gd = m illion gallons per day POTW = publicly owned treatment works WWTP = wastewater treatment plant STP = sewage treatment plant **4.1.2 Reasonable Potential A**  **nalys i**  **s** 

### For each facility

in the sample, EPA conducted a reasonable potential anal ysis to determine whether there is reasonable potential for the effluent to cause a water quality violation for any parameter. 9 

### For consistency with state implementation procedure s (Ecology , 2015c), EPA utilized Ecology ’s spreadsheet tool (PermitCalc) f or permit writers for determining reasonable potential. 10 

### For each facility

and parameter, the reasonable potential anal ys is uses data on effluent concentrations, receiving water characteristics, ambient parameter concentrations, and dilution factors. EPA gathered these data from a variety of sources, including :
 

### Facility- specific permit fact s heets, available from PARI S

 

### Discharge Monitoring Report (DMR) data available from PARI S

 

### Ambient pollutant concentrations from the Environmental Information Management ( EIM ) database

 

### Other facility

documentation such as inspection reports and permit applications, available from PARI S. There were not sufficient and adequate data available for all sample facilities to perform reasonable potential analyses for all parameters for which human health criteria have been speci fied. EPA did not assess reasonable potential f or parameters for which data were unavailable. 11 

### Appendix A provides facility- spec ific reasonable potential results (under both

9 Parameters for which the revised human health criteria are more stringent than aquatic life criteria. 10 Available at: http://www.ecy.wa.gov/programs/wq/permits/guidance.html 11 Effluent data for two facilities (Chambers Creek STP and Steelscape) were not available for any of the pollutants for which human health criteria are proposed, so EPA did not carry the analysis further for these facilities.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 22**  

### the baseline and policy

scenarios) and additional information on the specific data sources used for each facility
. **4.1.3 Projecting Effluent Limitations**  

### When EPA found reasonable potential, it calculated average mont hl y and maximum daily effluent limitations based on procedures contained in the PermitCalc tool. These procedures specify that the permit writer first derive a waste load allocation according to the following equation: WLA = D × WQC

– C b 

### × (D

– 1) where, WLA = w aste load allocation (in units of concentration) D = dilution factor WQC = w ater quality criterion concentration (applicable human health criterion) C b 

### = ambient background concentration (geometric mean). In instances where the receiving water i s impaired due to natural or irreversible anthropogenic conditions (i.e., C b 

### > WQC), EPA set the WLA equal to the WQC. 12 

### This approach is consistent with EPA guidance (see EPA, 1991). According to Chapter 7, Section 5.1 of the Washington Permit Writer’s Manual (Ecology , 2015c), the projected average monthly effluent limitation (AML) to protect human health is computed by

setting the AMLequal to the applicable WLA: AML= WLA (in units of concentration) Chapter 7, Section 5.1 of the Washington Permit Writer’ s Manual further states that the maximum daily

effluent limit (MDL) is calculated by multiplying the AML by a factor derived on the basis of the effluent variability and the anticipated number of monitoring and compliance samples collected per month (which is based on EPA, 1991; Table 5
- 3). In order to estimate compliance costs attributable to the proposed rule, EPA then compared the projected AML and MDL for each pollutant to the existing NPDES permit limitations for that pollutant. I f the projected AML and MDL are more stringent than existing NPDES permit limitations, EPA estimated the costs for the control mechanisms required to ensure compliance with the projected AML and MDL (see Section 4.1.4). However, the NPDES permits for the sampled facilities do not contain any WQBE Ls
.

12 It should be noted that the approach EPA used in instances when C b > WQC differs from the approac h used by Ecology. According to WAC 173
- 201A
- 260 (Natural conditions and other water quality criteria and applications), when the receiving water cannot meet applicable water quality criteria due to the natural conditions, the natural conditions represent the water quality criteria.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 23**  

### Based on E PA’s evaluation of the NPDES permit fact sheets for the sample facilities, it appears that the absence of WQBELs in the sample facility NPDES permits is due to a number of reasons . For example, in evaluating reasonable po tential for the sample facilities, EPA identified instances where background pollutant concentrations exceeded applicable water quality criteria and no WQBEL s were established based on Ecology ’s use of natural conditions as the water quality criteria. In o ther instances, it was not clear based on the data and information provided in the fact sheet. Particularly for arsenic, EPA noted discussions in several permit facts sheets that describe the lack of data to quantify the extent of the natural background co ncentrations of arsenic, and a lack of regulatory mechanism to deal with the issue. The lack of existing WQBELs may not accurate ly characterize the potential impacts attributable to the proposed revis ions to the human health criteria (i.e., compared to the NTR) because the lack of existing WQBEL s appears to be the result of implementing state - specific policies unrelated to EPA’s proposed rule that, should they continue to be applied in the context of revised criteria, would continue to result in a lack of W QBELs
. However, it is also possible that Ecology

would change these implementation policies and practices and develop and implement WQBELs. Therefore, a fair and reasonable approach to evaluate the potential upper-bound impact of EPA’s proposed rule is fo r EPA to evaluate reasonable potential based on the existing human health criteria as a baseline and determine whether a WQBEL w ould have been included in the permit were it not for the approach es and other policies used by Ecology
. EPA’s approach reflects the most conservative approach to compliance with 40 CFR 122.44(d)(1), which states that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality. ” Thus, in cases of no existing WQBELs under the baseline criteria and current Ecology

policies , EPA evaluated reasonable potential and projected baseline e ffluent limitations consistent with the approach described above
. For facility
- specific results, see Appendix A
. In all cases, an AML would be more stringent than the corresponding MDL. Therefore, EPA compared the baseline AMLto the projected AML to determine whether the discharger would be in compliance with the new effluent limitation. In the absence of a baseline effluent limitation (i.e., there was no reasonable potential to exceed existing human health criteria), EPA compared the maximum observed effluent concentration (MEC) to the projected AML to determine whether the discharger will be in compliance with the new effluent limitation. This method ensures facilities are discharging below applicable limitations. If the baseline AMLor MEC exceeds the projected AML, compliance actions and associated costs are likely
. A summary

of these determinations is provided in Exhibit 4
- 3
.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 24**  Exhibit 4 - 3 . Summary of Projected Effluent Limitations and Incremental Load Reductions under the P roposed Criteria

Facility Name 1 QL (μg/L) MEC or Baseline AML (μg/L) Projected

AM L (μg/L) Incremental

Reduction (lbs/year) **An timony**  Transalta Centralia Generation 0.21 2.0 2.5 0 **Arsenic** BP Cherry Point Refinery 0.5 19 0. 81 720 Intalco Aluminum Corporation 0.5 11 0.46 237 King County South WW TP 0.5 0.14 0.0059 0 King County W est Point W WT P 0.5 0.14 0.0059 0 Pasco WWTP 0.5 0.018 0.0045 0 Redondo WW TP 0.5 0.14 0.0059 0 Salm on Creek WWTP 0.5 0.14 0.0059 0 Sonoco Products Company 0.5 2.3 0.59 1.6 Tesoro Refining and Marketing Group 0.5 0.14 0.0059 0 Transalta Centralia Generation 0.5 0.018 0.0045 0 Transalta Centralia Mining 0.5 0.018 0.0045 0 US Oil & Refining 0.5 0.14 0.0059 0 **Me rcury**  Transalta Centralia Mining 0.0005 0.0029 0.00088 0.031 BP Cherry Point Refinery 0.0005 0.0114 0.00088 0.42 Tesoro Refining and Marketing Group 0.0005 0.44 0.017 0.24 AM L = average monthly effluent limitation MEC = maximum effluent concentration QL = quantitation l evel (as established by Ecology; see Attachment 1 - I (to Form 2C) or Appendix A of EPA/Ecology Form 2A at http://www.ecy.wa.gov/programs/wq/permits/forms.html ) WWTP = wastewater treatment plant 1. Includes sample facilities for which EPA found that there is reasonable potential to exceed the proposed criteria. Chambers Creek STP, Puyallup STP, Quincy Industrial, and Steelscape have no reasonable potential for any pollutants and are not incl uded here. See Appendix A for more details. 

### EPA estimated the incremental pollutant loading reduction based on the difference between the MEC and the AML (either baseline or projected), in most circumstances, according to the following equation: LR = 0.00834 × Q × (MEC

– AML) × 365 where, LR = load reduction (lbs/year)

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 25**  

### 0.00834 = conversion factor [(lbs)(L)/( μg)(mg) ] Q = effluent flow rate (mgd) MEC = maximum effluent concentration (μg/L) AML = average monthl y effluent limitation (μg/L)
When the AML was below the anal ytical limit of quantitation established by Ecology , EPA based the reduction on the difference between the MEC and the QL according to the following equation: LR = 0.00834 × Q ×(MEC

– QL) × 365 where, LR = load reduction (lbs/year) 13 

### 0.00 834 = conversion factor [(lbs)(L)/( μg)(mg) ] Q = effluent flow rate (mgd) MEC = maximum effluent concentration (μg/L) QL = quantitation level (μg/L). EPA calculated the incremental load reduction b y subtracting the load reduction due to the baseline AML (i. e., the baseline scenario) from the load reduction from the projected AML (i.e., the policy

scenario). ILR = LR

policy 

### – LR

baseline 

### where, ILR = incremental load reduction (lbs/year) LR policy 

### = load reduction to meet the policy scenario (lbs/year) LR bas eline 

### = load reduction to meet the baseline scenario (lbs/year). **4.1.4 Identifying Compliance Scenarios and Costs**  

### Analysis of the available data for the sample of facilities indicates that there are likel y to be exceedances of projected effluent limits for arsenic and mercury (i.e., instances where the projected effluent limits under the baseline criteria are less stringent then the projected effluent limits based on the proposed criteria). There are a number of potential alternatives for compliance with effluent limits for these pollutants, including:

 

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

13 In instances of a negative load reduction, EPA set the load reduction to zero.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 26**   

### Source control (e.g., pollution prevention (P2) program, inflow and infiltration ( I&I) reductions, more stringent pretreatment standards)

 

### Installing end
- of

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

 

### Alternative compliance mechanisms (e.g., site
- specific criterion, dilution credits, TMDL, or variance). Dischargers will pursue the lowest cost means of compliance with e ffluent limitations. However, for the proposed human health criteria, technical feasibility is also an issue, particularl y when projected effluent limitations are below analytical limits of quantification. Hence, there may

be a need for alternative compli ance mechanisms. For example, many projected effluent limitations based on the proposed arsenic human health criteria will be below anal ytical limits of quantification (i.e., dischargers will be unable to demonstrate compliance with the effluent limitation s). **Process Optimization** 

### The lowest cost option is likely the adjustment of existing treatment (process optimization). This option would be most feasible when 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 anal ys is is an investigation of the performance
- limiting facto rs of the treatment process and is a key factor in achieving optimum treatment efficiency . Performance
- limiting factors for common wastewater treatment processes (e.g., sedimentation, activated sludge, filtration) may include operator training, response to changes in wastewater quality , maintenance activities, automation, and process control testing. The cost of process analysis includes the cost of additional or continuous monitoring throughout the treatment process, and a treatment performance evaluation. These costs vary based on the number of treatment processes utilized and the magnitude of the reductions needed. Process modifications include activities short of adding new treatment technology units (conventional or unconventional) to the treatment train. For increasing pollutant removal efficiencies, process modifications could include adjusting coagulant doses to increase settling, equalizing flow if pollutant concentrations spike during wet weather events, increasing filter maintenance activities or backwash cycles, training operators, and installing automation equipment including necessary hardware and software. Several months of adjustments may

be needed to achieve a desired level of process optimization. In practice, the process modifications nece ssary would be determined by

the process anal ys is study
. Process optimization costs depend on the pollutant needing reductions and existing treatment processes and operations. For example, a facility could add a flocculent aid to secondary treatment to increase solids removal, and thus, the removal of any pollutants that adhere to particulates ( e.g., mercury) . In addition, chemicals used in wastewater treatment could

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 27**  

### contain contaminants (e.g., chlorine contaminated with low levels of mercury), and for certain pollutants (e.g., mercury) the use of such chemicals could result in exceedances. Thus, switching chemicals or the source of chemicals could be another low cost process optimization control option. The effectiveness of process optimization largely dep ends on the efficiency of current operations, the existing treatment processes, and the fate and transport of the pollutant through the treatment train. For example, if a facility is already

well maintained and operated, implementing process optimization m ay not result in sufficient pollutant reductions because the existing treatment processes are already performing at feasible limits. Also, because the design of most conventional treatment technologies maximizes removal of suspended solids, process optimiz ation aimed at increasing those removal efficiencies may not result in sufficient reductions for pollutants existing primarily in dissolved form. Given the available information for the sample facilities, it is generally not possible to determine the reductions achievable with process optimization; rather, a detailed, site
- specific study would be necessary
. **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 coul d be used alone, or in conjunction with process optimiz ation. The feasibility of source control efforts depends on the makeup of the influent and potential sources of the pollutant. For example, certain toxic pollutants are primarily used in industrial pro cesses. Thus, for a municipal facility , a feasible source control option would be regulating indirect industrial dischargers through pretreatment permits. However, for pollutants in which the main sources are commercial and residential wastewater (e.g., mercury), a facility would likely

have to concentrate efforts on public outreach and education or a sewer use ordinance . Other pollutants, such as arsenic, may be present in the wastewater due to natural sources (e.g., groundwater), and reducing I& I or treating source water may be necessary
. Costs for source control activities depend on the pollutant and the measures or controls implemented. P2 programs can be a cost - effective means of reducing mercury in wastewater effluents. However, as contributing sources are identified and controlled, the cost
effectiveness and efficacy that a P2 program w ould provide will diminish , and a discharger may need to pursue alternative compliance mechanisms (i.e., a variance ) if compliance with permit conditions has not been achieved
. EPA estimated a range of source control actions and costs for control of arsenic that include industrial P2 programs , I&I reduction programs, and variances. In Washington, arsenic occurs naturally

at high levels in s tate surface waters and groundw ater (see http://www.ecy .wa.gov/programs/wq/swqs/PolicyForum5Presentations.pdf#page=31 ) . These naturally occurring sources can be a significant source within municipal wastewater systems, as contaminated groundwater leaks into sewer s ystem s. I&I controls may enable compliance with baseline and revised criteria and EPA estimated the associated costs based on unit costs

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 28**  

### used in other cost anal ys es conducted within the region
. Note that these costs may be incurred independent of compliance with arsenic criteria or be partially off
- set by secondary benefits associated with I&I reduction activities ( i.e., reduce flow to treatment plant, which reduces treatment costs, and sewer overflows). **Pollution Prevention Program** 

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

 

### Id entify

sources
– particularly

sources that contribute the greatest load to the influent

 

### Form a workgroup

– preferabl y composed of representatives from government, industry , community , and environmental organizations that are either familiar with P2 strategies or familiar with the pollutant

 

### Define program goals

– including a statement of how the municipality intends to reduce pollutant levels in its effluent, the purpose for doing so, and a time line for completion

 

### Develop an approach

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

 

### Estimate program costs

– develop estimates and identify entities that will bear the costs

 

### Implement program

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

 

### Assess progress

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

 

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

 

### Develop a contingency plan

– including a description of actions to be taken if plan efforts are unsuccessful. The focus and approach of the program will be different for each community and sector targeted. As such, plans vary in complexity

and in the resources necessary to achieve the goals set forth. The reductions in mercury achievable through P2, and thus the ability to achieve compliance with numeric effluent limits using P2 alone, will vary ba sed on existing treatment processes, the makeup and size of the service area (e.g., number of potential mercury sources), and the level of P2 already being implemented in the community . For example, in 2003, the Washington State Legislature passed the Mercury Education and Reduction Act (MERA). MERA bans the sale of some mercury
- containing products, requires the labeling of mercury
containing light bulbs and lamps, and requires the removal of mercury from elementary

and high schools. The State may fine repeat violators of MERA up to $5000 per violation. Ecology also administers an automotive mercury switch removal program. Many automobiles made before 2003 contain mercury switches or other mercury
- containing

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 29**  

### equipment. Ecology

offers auto recyclers up to $9 per mercury

- containing component. Dentists in the State must use and maintain a dental amalgam separator. Large municipal facilities with numerous potential mercury sources may

see significant reductions after implementation of a measure that targets a major influent mercury source. However, facilities with much smaller service areas may not be able to achieve the same effluent reductions with P2 due to a lower percent of easil y identifiable and controllable sources contributing to the influent mercury load. For example, sources from the residential sector are not as eas y to identify as those from industrial and commercial sectors since these may originate from a wide range of products and 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 because facilities ty

pically do not account for pollutant
- specific P2 costs as a budget item that can be verified apart from other bas e program costs. However, the experiences of facilities that have already developed P2 programs for pollutants such as mercury provide some information on likely

program components and costs. Community

size is likely to be a factor affecting P2 program c osts. For example, it is unlikely that a minor facility

would need the same amount of resources for program development and outreach efforts as a large major municipal facility because the service area is smaller and contains fewer households and commercial/industrial dischargers to target. Smaller facilities may

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

on program development and outreach materials. EPA (2008) 14 

### previously

estimated that P2 program costs for mercury may be approximately $58,000 per ye ar for a small municipal facility (1 mgd to 5 mgd), $109,000 for a medium

sized municipal facility

( ≥5 mgd to 20 mgd), and to $165,000 per ye ar for a large municipal facility (> 20 mgd). P2 program costs for pollutants with fewer potential sources would likel y be lower ($25,000 to $50,000). More recent information pertaining to program costs is not available, but P2 programs should become less costly over time as more jurisdictions adopt these programs and refine b est practices. EPA updated the labor rate components of these cost estimates to incorporate Washington
- specific labor rates (Bureau of Labor Statistics (BLS) , 2014) . In total, these estimates encompass costs for the following program components:
 

### Program pl anning and development

 

### Sampling and analysis of internal process waters and effluents

 

### Site visits and workshops

 

### Development of public
- service announcements, advertising, and a website to promote awareness of program activities and goals

14 All historical cost estimates are converted and presented in terms of 2014 dollar values.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 30**   

### Procurement and dis tribution of mercury free products (e.g., thermometers) to certain public and commercial sector entities. EPA also estimated costs to indirect dischargers to a municipal wastewater treatment plant (WWTP) under a mercury P2 program (see Appendix A). For other pollutants, identifying groups of indirect dischargers likel y to be contributing to the influent load at the treatment plant is more difficult because the pollutants are no longer activel y used (e.g., legacy pesticides), could be formed as a b yproduct of numerous processes (e.g., dioxin), or there is a lack of information available. Thus, it is not possible to estimate pretreatment or P2 costs to indirect dischargers for pollutants other than mercury without specific information on the ty pes of industri al dischargers in each service area. **End -**  **of -**  **Pipe Treatment** 

### If process optimization or source control would not be sufficient for compliance with the baseline or revised criteria, alternative discharge options or end
- of
-pipe treatment technologies may

be ne cessary . However, many of the criteria approach the limits of anal ytical capabilities (e.g., mercury) or fall below QL s (e.g., arsenic ). In addition, for some pollutants, the lowest levels achievable through end
- of
-pipe treatment are highl y uncertain due to the fact that dischargers have not been required to treat to such low levels and performance data are not available. For metals such as mercury and arsenic, technologies that primarily target the dissolved fraction of the pollutant are most likely to a chieve low effluent levels because most of the particulate fraction w ould already have be en removed with existing treatment controls designed to remove solids (see discussion of process optimization). Exhibit 4
- 4 summarizes the end
- of
-pipe treatment technologies that may be used to remove the pollutants of concern. Exhibit 4 - 4 . Summary of P otential End - of- Pipe Treatment Technologies

Technology Pollutants Removed Granular activated carbon Mercury Mem brane filtration Arsenic, mercury Reverse osmosis Arsenic 

### For this anal ys is, and as documented further in Appendix A (Facility Analyses), EPA determined that onl y end
- of
-pipe treatment for arsenic was necessary for ensuring compliance with projected effluent limits (i.e., there are compliance options other than treatment for mercury). Based on information contained in U .S. EPA 2008, EPA assumed the use of reverse osmosis as the treatment s ys tem for arsenic. Although less costly treatment options exist (e.g., membrane filtration), reverse osmosis can consistently reduce arsenic effluent concentrations to below anal ytical detection levels. EPA derived the costs for reverse osmosis treatment based on the costs documented in U.S. EPA, 2008.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 31**  **Al ternative Compliance Mechanisms**  

### If none of the control options discussed above would result in compliance with baseline or revised effluent limitations, or if the costs of available treatment would be prohibitive, dischargers would likely

need some form of relief from the requirements. **Site -**  **Specific Criteria** 

### If dischargers suspect that the conditions in the vicinity of their discharge warrant alternative (i.e., site
- specific) criteria values that would result in less stringent effluent limitations in their permit, they

may work to collect data to develop site
- specific criteria . Ecology may also develop site
- specific criteria as part of a TMDL process (i.e., identifying the appropriate target value). EPA must review and approve site
- specific criteria prior to implementation. Because additional data are likely required to assess the appropriateness of site
- specific criteria at a particul ar location, the extent of use of this mechanism by dischargers is uncertain. However, consideration within the context of a TMDLis likel y, and may or may not reflect an incremental increase in effort above that associated with current TMDL s (this ty pe of data collection and evaluation may already be a part of TMDL development efforts). **Intake Credits** 

### Under 40 CFR 122.45(g), EPA allows dischargers to request that technology
- based effluent limitations be adjusted to reflect credit for pollutants in the discharger’s intake water when certain conditions are met. However in terms of complying with WQBELs, the State of Washington does not yet have an approved intake credit policy and, therefore, does not provide intake credits for water quality-based effluent limitations. Therefore EPA did not consider intake credits as a valid compliance action for the proposed human health criteria. 15 **Variances** 

### Under WAC 173
- 201A
- 420, Ecology may temporarily modify criteria for individual facilities, or stretches of water, through the use of a variance. Variances may be approved when: (a) The modification is consistent with the requirements of federal law (currently 40 C FR 131.10(g) and 131.10(h)); (b) The water body is assigned variances for specific criteria and all other appl icable criteria must be met; and (c) Reasonable progress is being made toward meeting the original criteria. The decision to approve a variance is subject to a public and intergovernmental involvement process. Under the state’s current regulations, the dep artment may issue a variance for up to five years, and may

renew the variance after providing for another opportunity for public and intergovernmental involvement and review. Variances are not in effect until they have been

15 Washington proposed an intake credit policy on January 12, 2015. See http://www.ecy.wa.gov/programs/wq/ruledev/wac173201A/1203ov.html
.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 32**  

### adopted under s tate law and approved b y EPA. Factors for allowing variances under 40 CFR 131.10(g): 1. Naturall y 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 ty pes 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, pool s, riffles, and unrelated to water quality preclude attainment of aquatic life protection uses. 6. Controls more stringent than those required b y CWA s ections 301(b) and 306 would result in substantial and widespread economic and social impact. To demonstrate that any of the first five conditions above appl y as part of an application for a variance, dischargers would likely prepare documentation of the conditions warranting the variance. 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 anal ys is, first determining whether the control costs would have a substantial adverse financial impact and, if so, whether that impact would cause widespread adverse impacts on the surrounding community. Permitting authorities may require implementation of a P2 or source control program as part of the conditions for granting a variance. Thus, to be conservative (i.e., err on the side of overestimating costs), EPA assumed that facilities would need to implement a P2 program as part of a variance. **Dilution Credits** 

### Under WAC 173
- 201A
- 410, Ecology may implement mixing zones and associated dilution credits in NPDES permits. Regulatory mixing zones may

be established when a discharger has applied all known an d 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

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 33**  

### 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, as described in Section 4.1.3
. Dischargers who cannot readil y compl y with end
- of
-pipe effluent limitations based on the proposed human health criteria and who do not currentl y possess an approved regulatory mixing zone, may

elect to pursue appro val of a regulatory mixing zone as means of coming into compliance with the effluent limitations. When applying for a regulatory mixing zone, a special study is required to estimate and document the level of mixing which is likely to be present in the rec eiving water under applicable critical conditions. A special study of this ty pe will ty pically require data collection and the mathematical modeling of the discharge and ambient receiving environment. In developing costs associated with developing a diluti on 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 Ecology 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 median wage rates for an environmental engineer in the State of Washington (BL S, 2014)
. **4.1.5 Summary of Unit Control Costs**  

### EPA based unit costs for P2 programs, I&I reduction, alternative compliance mechanisms , and end
- of

-pipe treatment (i.e., reverse osmosis) on estimates previously developed for economic analysis of WQS for the State of Oregon (U.S. EPA, 2008)
. EPA u pdated these costs to reflect local labor rates and escalated to 2014 dollars using appropriate cost indices
. 16 

### EPA developed c osts associated with appl ying for dilution credits and for process optimization special studies as describe d in Section 4.1.4
. Exhibit 4
- 5 summarizes the unit costs utilized in the sample facility compliance cost anal ys es. Exhibit 4 - 5 . Estimated Unit Costs of Compliance Mechanisms (2014$) Compliance Mechanism Municipals Industrials 1 - 5 mgd 5 - 20 mgd >20 mgd Pollution prevention p rogram ($/year) $58,000 $110,000 $165,000 $28,000 Other p ollution p revention p rograms $60,000 $60,000 $60,000 $28,000 Dilution s tudy $50,000 $50,000 $50,000 $50,000 End - of- pipe treatment (reverse osm osis) 1 See note See note See note See note

16 EPA updated all costs to 2014$ using the consumer price index, except for pipeline rehabilitation costs; for these, E PA updated costs using the Engineering Ne ws Record Construction Cost Index.

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 34**  Exhibit 4 - 5 . Estimated Unit Costs of Compliance Mechanisms (2014$) Compliance Mechanism Municipals Industrials 1 - 5 mgd 5 - 20 mgd >20 mgd Variance $ 180 ,000 $300,000 $426,000 $180,000 I nflow and infiltration reduction ($/mile) 2 $69,000 $69,000 $69,000 See note Source: EPA (2008); updated to 2014 dollars using the Engineering News Record Construction cost Index for inflow and infiltration pipeline rehabilitation and the average annual Consumer Price Index for other components. Dilution study estimate based on best professional judgement using assumptions identified in the text

. mg d = m illion gallons per day 1. EPA did not ident ify a need for end - of- pipe treatment costs for municipal dischargers; for industrial end - of- pipe treatment costs, EPA derived the following linear regression equation f rom the data in EPA (2008) to estimate costs : y = [ (1.1 x10 6 )(x) ] + (1.63x10 6 ) where: y = Total annual project cost ($ millions; 7% and 20 years) x = Facility flow (mgd) 2. Inflow and infiltration reduction is applicable to municipal dischargers only. **4.1.6 Extrapolation to A**  **ll Major Dischargers** 

### To extrapolate the sample facility costs, EPA added the estimated compliance costs for the facilities in the certainty

sample to the sum of the estimated costs for each facility in the random sample multiplied by the facility

weight from the original sampling scheme. See Appendix B for details on this extrapolation. **4.2 Minor Dischargers**  Minor dischargers often 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 revised human health criteria is low. EPA reviewed data and information contained in the NPDES permit fact sheet s for two minor industrial dischargers to evaluate potential for impact under the p roposed rule [KB Alloys, LLC (WA0002976 ), and Sandvik Special Metals, LLC (WA0003701) ]. The primary pollutants of concern for which data were available are metals (e.g., aluminum, chromium, copper, cyanide, lead, nickel and zinc). For metals, aquatic life protection criteria are more stringent than the proposed human health criteria. For both facilities, due in part to the lack of background p ollutant data (i.e., background was set equal to zero) and the dilution factors applied to each facility discharge, there was no reasonable potential to exceed water quality criteria for the metals. The NPDES permits include technology
-based effluent limitation s for the metals of concern. Effluent data were not available for all other pollutants for which human health criteria are being proposed. In the fact sheets for each facility, Ecology had determined that discharges

### POINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 35**  

### from each facility

are unlikely

to contain chemicals regulated to protect human health. Additional data would be needed to confirm or dispute this finding under the proposed rule.

### NONPOINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 36**  

## 5. **Methods for Identif**  **yi ng**  **Potential Costs: Nonpoint Sources** Changes in water quality

criteria could result in incremental impact s on nonpoint sources of pollution, such as agriculture , urban areas, and forestry , through TMDLs or other pollution cleanup plans. Section 2.2 discusses the nonpoint sources of pollution, and Section 2.3 summarizes the process by which Ecology

categorizes waterbodies. Ambient water quality data can be used to determine the impact that a change in human health criteria may have on the attainment of the criteria and thus the potential for incremental control strategies and costs for nonpoint sources. **5.1 Identify**  **ing Exceedanc es**  EPA identified potential incremental impairments based on available data in EIM. According to the state ’s Water Quality Program Policy

(Ecology , 2012d), Ecology generall y uses the last ten years of data to determine impairment status of surface waters. EPA used available surface water monitoring data on pollutants of interest from EIM for the ye ars 200 5 to 2014. 17 

### EPA acknowledges that Ecology uses fish tissue equivalent concentrations to trigger waterbody impairments based on the human health criteria in their 303(d) listing methodology , whereas for the purposes of this analysis, EPA identified potential incremental impairments using water column concentrations
. For each monitoring station and parameter , EPA compared the pollutant concentration to both th e existing baseline human health criteria and the proposed criteria. Station results that would represent impair ment under the proposed criteria but not under the existing baseline criteria may represent potential incremental impairments. 18 

### Exhibit 5
- 1 shows the results of this analysis. Using the baseline criteria values , monitoring data indicate potential impairment on the basis of human health criteria exceedances in the water column at 205 stations. Using the proposed criteria, there would be exceedances in the

17 EPA did not include observations resulting from sampling at known contamination sites, cleanups, groundwater, and outfall monitoring stations. EPA acknowledges that Ecology may use such data to determine impairments. Additionally, EPA eliminated observations with the following data qualifiers: U (analyte was not detected at or above the reported result) and UJ/UJG/UJK (analyte was not detected at or above the reported estimate), REJ (data are unusable for all purposes), but kept observations with the following qualifiers: J (analyte was positively identified, reported result is an estimate), JL (analyte was positively identified, value may be less than reported, B (analyte detected in sample and method blank), T (result is below quantitation l evel but above MDL), JK (analyte was positively identified, reported result is an estimate with unknown bias), JT (analyte was positively identified, reported result is estimate below quantitation level but above MDL), C (not specified), and NTJ (evidence that analyte is present, estimate is below quantitation level but above MDL). 18 Note that these results may not reflect the actual listed impairment status of the waterbody. EPA compared identified impairments to Ecology’s current draft impairment listings; however, data limitations (e.g. the ability to match monitoring stations to existing impairment status at the waterbody level across data sets) largely preclude matching of monitoring stations to specific waterbody impairments.

### NONPOINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 37**  

### water column at 254 stations , for a total of 49 potential incremental exceedances (or a 24% increase compared to the baseline). **Exhibit 5**  **- 1**  **. Potential Incremental Impairments 1**  **Parameter Number of**  **Locations Potential Impair**  **ments**

**Baseline 2**  **Proposed 3**  **Incremental 4**  1,2 - Dichloropropane D 1,3 - Dichloropropene D 2,3,7,8 - TCDD (dioxin) D 4,4' - DDT 45 7 24 17 Acenaphthene 5 0 0 0 Anthracene 8 0 0 0 Antimony 49 0 0 0 Arsenic 178 167 167 0 Benzo(a) anthracene 16 5 7 2 Benzo(a) pyrene 10 5 7 2 Benzo(b) fluoranthene 10 6 7 1 Benzo(k) fluoranthene 15 4 5 1 Bis(2 - ethy lhex yl) phthalate 22 0 14 14 But yl benzyl phthalate 6 0 2 2 Chlordane D Chrysene 10 5 4 - 1 Copper5 238 0 0 0 Dibenzo(a,h) anthracene 6 2 3 1 Diethyl phthalate 6 0 0 0 Dim ethyl phthalate 2 0 0 0 Di - n - but yl phthalate 19 0 0 0 Fluoranthene 11 0 0 0 Fluorene 5 0 0 0 Indeno(1,2,3 - cd) py rene 15 4 6 2 Nickel 163 0 0 0 Polychlorinated biphenyls (PCBs) D Py rene 10 0 0 0 Thallium 6 0 0 0 Zinc 5 201 0 0 0 Mercury6 18 0 8 8

### NONPOINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 38**  **Exhibit 5**  **- 1**  **. Potential Incremental Impairments 1**  **Parameter Number of**  **Locations Potential Impair**  **ments**

**Baseline 2**  **Proposed 3**  **Incremental 4**  Source: Based on 2005 to 2014 surface water monitoring data from Wa shington’s Environmental Information Management System (EIM). D = EIM data are available, but all observations are unusable due to the study type (contaminated site), waterbody type (groundwater), or result qualifiers. 1. Blanks indicate that data are not available, or that EPA di d not use all observations due to study, location, or data quality reasons. 2. Number of s tations at which monitoring data indicate two or more exceedances of the baseline hum an health criteria within 3 years. 3. Number of s tations at which m onitoring data indicate two or more exceedances of the proposed hum an health criteria within 3 years. 4. Represents difference in results between baseline and proposed criteria

. 5. For zinc , nickel, and copper, includes only freshwaters since the aquatic life criteria a re mo re stringent than proposed human health criteria for marine waters. 6. Potential to exceed the proposed fish tissue criterion based on the projected water column target. 

### 5.2 **Identify ing Compliance A** **ctions and Costs** EPA does not have data on all p arameters for all waterbodies, or data on the sources of loadings to potentially

impaired waterbodies. Additionally, Ecology is currently

in the process of revising and updating its management plan for nonpoint source pollution (see Ecology , 2015b)
. Re duct ions in nonpoint source pollution loadings arising from this revised plan will occur in the absence of the proposed rule and represent baseline requirements
. If the revised criteria lead to additional waters being listed on the state ’s 303(d) list for exc eedances of human health based water quality criteria, the magnitude of cost impacts to nonpoint sources depends on the extent to which additional practices are needed for compliance with the potential revisions in comparison to compliance with existing ba seline 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 :
 

### Agricultural and forest lands

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

### Mining

– cleanup and remediation including excavation and onsite capping of contaminated soils, capping of onsite solid waste mining debris, regrading of tailings to mitigate mass wasting an d off
- site migration, and abatement and mitigation of physical hazards ; and

 

### Stormwater discharges

– increased or additional nonstructural BMPs (e.g., institutional, education, or P2 practices designed to limit generation of runoff or reduce the pollutants load of runoff); and structural controls (e.g., engineered and constructed s ystems designed to provide water quantity or quality

control).

### NONPOINT SOURCE COSTS: METHODS

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 39**  

### C ontrol of nonpoint sources of the pollutants of concern could reduce costs to point sources. In the context of a T MDL, load and wasteload allocations reflecting the source of the pollutant could result in less stringent limits for point sources than anticipated through the anal ys is of the sample facilities as described in Section 4
. If an additional number of TMDLs are needed under the revised criteria, there may be an increase in government regulatory costs. EPA (2001 b ) estimate s that TMDL development costs per water body typ ically range from under $26,000 to over $500,000 19 

### depending on the number of TMDLs, the level of complexity , and the extent to which impaired waters are clustered together for TMDLdevelopment
. 20

19 Not updated from original dollar years (2000$). 20 EPA ( 2001b) anticipates that in the future , states will increasingly adopt efficient practices when developing TMDLs , thus potentially reducing development costs
.

### COMPLIA **NCE COSTS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 40**  

## 6. **Potential Co mpliance Costs**  This section summarizes the potential costs to point sources and nonpoint sources, and discusses the limitations and uncertainties associated with the anal ys es. **6.1 Point Sources**  Costs for compliance with baseline criteria include costs associated with compliance with WQBEL s reflective of existing criteria. Incremental costs associated with the potential revised criteria represent the costs of any additional actions or controls needed for compliance with revised WQBEL s under the proposed rule. Exhibit 6
- 1 provides a summary of the potential total annual statewide costs. The low estimate represents the assumption that the projected co ntrol scenario will result in compliance with projected effluent limits ; the high estimate includes the estimated cost of also obtaining a variance under the assumption that control actions will not result in compliance with very low limits
. For the 73 majo r dischargers in the state, EPA estimates that the total annual cost may be in the range of $ 13 million
. 21 **Exhibit 6**  **- 1**  **. Total**  **An nual**  **Costs by Discharger Type**

**Discharger Type Statewide**  **An nual**  **Costs (millions;**  **2014$) Low**  **High** Municipal $0.00 $0.00 Industrial $ 13.03 $ 13.06 **Total $13.03**  **$13.06** 

### Of the costs shown in Exhibit 6
- 1 , all costs are attributable to industrial dischargers, primarily for treatment of arsenic. Overall , 99% of the costs are attributable to the revised human health criteria for arsenic while th e remaining 1% are attributable to the revised human health criteria for mercury
. **6.2 Nonpoint Sources**  Costs for compliance with baseline criteria include costs to nonpoint sources (e.g., agricultural and forest operations; contamination from historic mining s ites), and municipal stormwater sources associated with implementation of existing programs and TMDL s. In cremental costs associated with compliance with the potential revised criteria represent the costs of any actions or controls above and beyond those needed to meet baseline requirem ents. EPA did not estimate increm ental costs for nonpoint sources for this preliminary

anal ys is . However, if nonpoint sources are the primary source of the pollutants

21 These costs represent the proposed criteria scenario only. EPA estimated costs to come into com pliance with baseline criteria to be in the range of $46.4 million to $47.1 million. For a description of sample facility
- specific baseline and proposed criteria scenario costs, see Appendix A
.

### COMPLIA **NCE COSTS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 41**  

### of concern, control of nonpoint sources could result in less stringent limitations and lower costs than estimated for point sources. F or situations in which controls beyond those required under the baseline are necessary , controls could include the development and implementation of TMDLs
. **6.3 Uncertainties and Quality**  **A ssurance**  As noted previous ly , the proposed rule does not establish any requirements directly applicable to regulated entities or other sources of pollution . S tate implementation of the proposed rule may

result in new or revised NPDES permit conditions for point source dischargers , and incremental control requirements for nonpoint sources. For point sources , EPA has estimated these impacts as the difference between compliance with the existing human health criteria and compliance with the proposed human health criteria. However, there is substantial uncertainty associated with actual state implementation of the proposed rule. The proposed rule establishes human health criteria applicable to the waters in the state and as such there could be a need for additional controls on nonpoint sources of pollutant loadings to attain WQS
. EPA estimated potential incremental impairments using readily available ambient water quality data. However, data are limited to identify specific incremental control actions and costs that may be required of no npoint sources
. Exhibit 6
- 2 summarizes additional uncertainties and limitations in the analysis. **Exhibit 6**  **- 2**  **. Uncertainties in A naly** **sis of Costs Uncertainty/A** **ssumption Effect on Cost**  **Estimate Notes**  Sam ple facility costs are representative of all facilities in state (by category) Uncertain Could result in an overestimate or underestimate of statewide costs if sample facilities are higher or lower than average costs. Does not account for new /expanding facilities.

Baseline c ontrols Uncertain EPA did not conduct extensive site - specific review of facility plans and information for addressing baseline water quality issues; thus, facility analyses could under- or overstate baseline and incremental actions and costs. Means of addressing incremental im pairm ents Overestimate Under a TMDL, load and wasteload allocations may result in less stringent requirements for point sources if nonpoint sources are the cause of impairments

. Zero compliance costs for two sam ple facilities for which effluent data are not available Underestim ate If these facilities do need to take actions to com ply with the revised requirements, the total cost of compliance would be greater than that estimated here

.

### COMPLIA **NCE COSTS**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 42**  **Exhibit 6**  **- 2**  **. Uncertainties in A naly** **sis of Costs Uncertainty/A** **ssumption Effect on Cost**  **Estimate Notes** 
Total arsenic and dissolved arsenic monitoring data represent only the inorganic fraction of a rsenic Overestimate Effluent and ambient monitoring data available for the analysis are in terms of total and dissolved arsenic; if some fraction of arsenic measured is in the organic form then this may result in an overestimate of costs since the proposed criterion is in terms of the inorganic form, which is more toxic than other forms. 

### EPA conducted quality assurance checks on the data , anal ys es, and results, consistent with the programmatic and project
- specific quality assurance plans. In addition, the Agency used Ecology ’s permit
- writing tool, ensuring consistency with state permitting approaches and calculations. EPA also used Washington
- specific data sources as available , and for all data entry , EPA confirmed the accuracy of data sources and docum entation following procedures described in the quality

assurance plans. These procedures include check s on all inputs and calculations , and using multiple approaches to confirm results.

### REFERENCES

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 43**  

## 7. **References** Bureau of Labor Statistics , United States Department of Labor. 2014. May 2014 State Occupational Emplo ym ent and Wage Estimates: Washington. (available at: http://www.bls.gov/oes/current/oes_wa.htm) Department of Ecology , State of Washington (Ecology). 2015a. Phase I Municipal Stormwater Permit. National Pollutant Discharge Elimination System and State Waste Discharge General Permit for Discharges from Large and Medium Municipal Separate Storm Sewer S ys tems. Modification Date: January 16, 2015. Department of Ecology , State of Washington (Ecology). 2015b. Washington’s Water Quality Management Plan to Control Nonpoint Sources of Pollution: Draft. Publication No. 15
- 10
- 015. Department of Ecology , State of Washington (Ecology). 201 5c. Water Quality Program Permit Writer’s Manual. Publication Number 92
- 109. Department of Ecology , State of Washington (Ecology). 2014 a . Draft
-- Washington Human Health Criteria Review Documents. Revised 8/8/2014. Department of Ecology , State of Washington (Ecology). 2014b . Frequently Asked Questions, Water Quality

Program: Municipal Stormwater Permits. Department of Ecology , State of Washington (Ecology). 2014 c . Western Washington Phase II Municipal Stormwater Permit. National Pollutant Discharge Elimination System and State Waste Discharge General Permit for Discharges from Small Municipal Separate Storm Sewers in Western Washington. Modification Date: January 16, 2014. Department of Ecology , State of Washington (Ecology). 2014 d . Industrial Stormwater General Permit. A National Pollutant Discharge Elimination System (NPDES) and State Waste Discharge General Permit for Stormwater Discharges Associated with Industrial Activities. I ssuance Date: December 3, 2014. Department of Ecology , State of Washington (E cology). 2014 e . Water Quality Improvement Project Deschutes River Watershed Area: Multi
- Parameter. Available at: http://www.ecy .wa.gov/programs/wq/tmdl/deschutes/index.html (access ed 4/7/2015). Department of Ecology , State of Washington (Ecology). 2012a. 2012 Stormwater Management Manual for Western Washington. Amended in December 2014. Publication Number 14
- 10
- 055. Department of Ecology , State of Washington (Ecology). 2012b
. Ea stern Washington Phase II Municipal Stormwater Permit. National Pollutant Discharge Elimination System and State Waste Discharge General Permit for Discharges from Small Municipal Separate Storm Sewers in Ea stern Washington. Issuance Date: August 1, 2012.

### REFERENCES

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 44**  

### Department of Ecology , State of Washington (Ecology). 2012c . Water Quality Improvement Project, Yakima Watershed Area: Toxics. Available at: http://www.ecy .wa.gov/programs/wq/tmdl/yakima_wq/YakToxicsTMDL .html (accessed 4/7/2015). Department of Ecology , State of Washington (Ecology). 2012d . Water Quality Program Policy : Assessment of Water Quality for the Clean Water Act Section 303(d) and 305(b) Integrated Report. Chapter 1: WQP Policy 1
- 11. Department of Ecology , State of Washington (Ecology). 2010. Yakima River Pesticides and PCBs Total Maximum Daily L oad. Volume 1: Water Quality Study Findings. Publication No. 10
- 03
- 018. Department of Ecology , State of Washington (Ecology). 200 7 a . Palouse River Chlorinated Pesticides and PCBs Total Maximum Daily L oad: Water Quality

Improvement Report and Implementation Plan. Publication No. 07
- 03
- 018
. Department of Ecology , State of Washington (Ecology). 2007b
. Mission Creek Watershed DDT Total Maximum Daily L oad: Water Quality Improvement Report. Publication No. 07
- 10
- 046. Department of Ecology , State of Washington (Ecology). 2006 a . Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily L oad (Water Cleanup Plan): Submittal Report. Publication No. 05
- 10
- 079
. Department of Ecology , State of Washington (Ecology). 2006b
. Lake Chelan Watershed DDT and PCB Total Maximum Daily L oad: Water Quality Improvement Report. Publication No. 06
- 10
- 022. Department of Ecology , State of Washington (Ecology). 2005
. Lower Okanogan River Basin DDT and PCBs Total Maximum Daily L oad: Submittal Report. Publication No. 04
- 10
- 043
. Department of Ecology , State of Washington (Ecology). 2004 a . Stillaguamish River Watershed Fecal Coliform, Dissolved Oxygen, pH, Mercury , and Arsenic Total Maximum Daily L oad (Water Cleanup Plan): Submittal Report. Publication No. 05
- 10
- 044. Department of Ecology , State of Washington (Ecology). 2004b. Lower Similkameen River Arsenic Total Maximum Daily L oad: Submittal Report for Joint I ssuance. Publication Number 03
- 10
- 074. Department of Ecology , State of Washington (Ecology). 2001. Inner Bellingham Bay Contaminated Sediments Total Maximum Daily Load: Submittal Repo rt. Publication Number 99
- 58
- WQ. Department of Ecology , State of Washington (Ecology). 1999. Spokane River Dissolved Metals Total Maximum Daily L oad: Submittal Report. Publication Number 99
- 49
- WQ. Department of Ecology , State of Washington (Ecology). 1992a . Total Maximum Daily L oad. TMDLNumber: 07
- 001.

### REFERENCES

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 45**  

### Department of Ecology , State of Washington (Ecology). 1992b. Total Maximum Daily L oad. TMDLNumber: 10
- 001. United States Environmental Protection Agency (U.S. EPA). 2014. Toxicity and Bioaccumulation Factors Used in the Draft 2014 Updated Ambient Water Quality Criteria for the Protection of Human Health. (available from: http://water.epa.gov/scitech/swguidance/standards/criteria/current/hhdraft.cfm) United States Environmental Protection Agency (U.S. EPA). 2012. Water: Contaminated Sediments. Basic Information. (available from: http://water.epa.g ov/polwaste/sediments/cs/aboutcs.cfm) United States Environmental Protection Agency (U.S. 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 (U.S. EPA). 2002. National Recommended Water Quality

Criteria: 2002. Human Health Criteria Calculation Matrix. EPA 822
- R
- 02
- 012. November. United States Environmental Protection Agency (U.S. EPA). 2001a. Water Quality Criterion for the Protection of Human Health: Methylmercury
. EPA
- 823
- R
- 01
- 001
. January
. United States Environmental Protection Agency (U.S. EPA). 2001 b
. The National Costs of the Total Maximum Daily Load Program (Draft Report)
. EPA 841
- D
- 01
- 003 . August. United States Environmental Protection Agency (U.S. EPA). 1995. Interim Economic Guidance for Water Quality Standards Workbook. EPA 823
- B
- 95
- 002. March. United States Environmental Protection Agency (U.S. EPA). 1991. Technical Support Document for Water Quality
- Based Toxics Control. EPA/505/2
- 90
- 001. United States Environmental Protection Agency (U.S. EPA). 1980. Guidelines and Methodology

Used in the Preparation of Health Effect Assessment Chapters of the Consent Decree Water Criteri a Documents. Federal Register 45: 79347, Appendix 3.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 46**  

## Ap **pendix A –**  **Facility An**  **al ys**  **es** This appendix provides detailed anal ys es for the sample facilities in alphabetical order by municipal dischargers first followed by industrial dischargers. **A. 1**  **Chambers Creek Regional Wastewater Treatment Facility** The Chambers Creek Regional Wastewater Treatment Facility (WWTF ; NPDES permit WA0039624 ) provides wastewater treatment to 65,000 households and 2,000 businesses in DuPont, Lakewood, Tacoma, University Place, Steilacoom, and other unincorporated areas. The facility

also treats wastewater from five industrial users, including the Boeing Corporation Skin and Spar fabrication facility , the Land Recovery Incorporated Hidden Valley L andfill, James Hardie Building Products, and Fredrickson Power. 22 

### The facility discharges a maximum monthly flow of 14 to 20 mgd (dry weather flow and maximum monthly flow, respectively) to Puget Sound Gordon Point Area. **A. 1.1**  **Treatment Processes** 

### The 2008 permit fact sheet indicates that the current treatment consists of screening equipment and primary

sedimentation; secondary treatment includes bioselectors, secondary clarifiers and ultraviolet disinfection. **A. 1.2**  **Effluent Data** 

### No recent effluent monitoring data for the WWTF were available for any of the pollutants for which human health criteria are being proposed. **A. 1.3**  **Receiving Water** 

### The facility

discharges to Puget Sound Gordon Point Area, whi ch is a Class AA extraordinary

receiving water. According to the 2008 permit fact sheet, Commencement Bay (monitoring station BRW
- COMMENCEBAY) is the nearest monitoring station with available water column data. Exhibit A
- 1 summarizes the available ambient receiving water concentrations for the station based on data from Ecology ’s Environmental Information Management S ys tem between 2008 and 2009. **Exhibit A** **- 1**  **. A mbient Receiving Water Concentrations: Commencement Bay**  **Pollutant Water Column Concentration (μg/L)**  **Ma ximum**  **Av erage**  Copper 1.3 0.837 Zinc 2.91 1.515 Source: W ashington State Department of Ecology Environmental Information Management System, 2008 to 2009 data for station BRW - COMMENCEBAY.

22 The 2008 Fact Sheet does not identify the fifth industrial discharger.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 47**  **A. 1.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. The necessary data to confirm the reasonable potential anal ys is under the baseline scenario were not available. **A. 1.5**  **Policy Scenario** 

### EPA did not have the necessary data to perform the reasonable potential analysis under the policy scenario. Thus, it could not determine reasonable potential or calculate permit limits and costs
. **A. 2**  **King C**  **ounty South**  **W WTP**  **and C SO**  **Sy stem**  The King County

Department of Natural Resources and Parks (Wastewater Treatment Division) operates the King County South WWTP (NPDES permit WA0029581 ), which serves 25 jurisdicti ons and utility districts, including Seattle, across 152 square miles. The majority of flow to the treatment facility is from separated sanitary s ys tems, with approximately

4% coming from a combined s ys tem in Seattle. Average WWTP flow is 76 mgd
. **A. 2.1**  **Treatment Processes**  

### The 2009 permit fact sheet reports that primary treatment consists of screening and settling followed b y primary cl arification. Secondary treatment is an activated sludge process and includes aeration and secondary clarification. After disinfection (using sodium hy pochlorite), effluent is discharged to Puget Sound. **A. 2.2**  **Effluent Data** 

### Exhibit A
- 2 summarizes the last three ye ars of effluent data for the treated wa stewater for the pollutants of concern for which data are available, based on Ecology ’s priority pollutant monitoring data and reasonable potential anal ys is (Appendices C and H in the 2009 permit fact sheet). **Exhibit A** **- 2**  **. Summary of Effluent Data: King County**  **South WWTP 1** 
**Pollutant Observations**  **QL (μg/L)**  **Summary of Detected Values (μg/L) 2** 

**Total Nondetect**  **Me dian**  **Av erage**  **95th Percentile**  **Ma x**  1,1,2,2 - Tetrachloroethane 23 23 1 1,1,2 - Trichloroethane 23 23 1 1,2,4 - Trichlorobenzene 24 24 0.57 - 0.71 1,2 - Trans - d ichloroethylene 23 23 1 2,4 - Dim ethylphenol 24 24 0.94
– 1.2 2,4 - Dinitrophenol 24 24 1.9
– 2.4 2 - Chlorophenol 24 24 1.9
– 2.4 Acenaphthene 24 24 0.57 - 0.71

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 48**  **Exhibit A** **- 2**  **. Summary of Effluent Data: King County**  **South WWTP 1** 
**Pollutant Observations**  **QL (μg/L)**  **Summary of Detected Values (μg/L) 2** 

**Total Nondetect**  **Me dian**  **Av erage**  **95th Percentile**  **Ma x**  Acrolein 23 23 5 Acrylonitrile 23 23 5 Antimony 32 0.5 0.25 <0.51 0.514 0.67 Arsenic 34 0.5 1.26 1.516 1.60 Benzene 23 23 1 Benzidine 24 24 23 - 28 Benzo(a) a nthracene 24 24 0.57 - 0.71 Bromoform 23 23 1 Carbon t etrachloride 23 23 1 Chloroform 23 1.32 1.3 <1.32 2.034 2.18 Copper 32 0.4 16.5 31.34 42.4 Cyanide 33 0.005 .0025 <0.008 0.019 0.028 Dichlorobromomethane 23 23 1 Eth yl benzene 23 23 1 Fluoranthene 24 24 0.57 - 0.71 Fluorene 24 24 0.57 - 0.71 Hexachlorocyclopentadiene 24 24 0.94 - 1.2 Hexachloroethane 24 24 0.94 - 1.2 Indeno(1,2,3 - cd) Pyrene 24 24 0.94 - 1.2 Isophorone 24 24 0.94 - 1.2 Methyl b romide 23 23 5 Methylene c hloride 23 5 2.5 <4.74 2.5 7 Nickel 33 0.3 2.90 2.99 4.004 4.45 Nitrobenzene 24 24 0.94 - 1.2 N - Nitrosodimethylamine 24 24 3.8 - 4.7 N - Nitrosodi - n - p ropy lamine 24 24 0.94 - 1.2 N - Nitrosodiphenylamine 24 24 0.94 - 1.2 Pentachlorophenol (PCP) 24 24 0.94 - 1.2 Phenol 24 24 3.9 Py rene 24 24 0.57 - 0.71 Selenium 33 33 1.5 Tetrachloroethylene 23 23 1 Thallium 33 33 0 .04 - 0.2

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 49**  **Exhibit A** **- 2**  **. Summary of Effluent Data: King County**  **South WWTP 1** 
**Pollutant Observations**  **QL (μg/L)**  **Summary of Detected Values (μg/L) 2** 

**Total Nondetect**  **Me dian**  **Av erage**  **95th Percentile**  **Ma x**  Toluene 23 4 2 <1.45 3.41 3.86 Trichloroethylene 23 23 1 Vin yl Chloride 23 23 1 Zinc 33 0.5 29 49.34 68 Mercury 33 0.05 0.025 <0.05 0.052 0.058 Source: 2009 permit fact sheet (Appendix C and H). QL = quantitation level 1. Blanks indicate unreported data. 2. Metal concentrations are total recoverable form

. **A. 2.3**  **Receiving Water** 

### The facility

discharges to Puget Sound, which Ecology has designated as an extraordinary marine water. Exhibit A
- 3 summarizes the available ambient receiving water concentrations based on 2011 to 2012 data from Ecology ’s Environmental Information Management S ys tem (monitoring station L SNT01, identified in the permit fact sheet as the most appropriate monitoring station for ambient data). **Exhibit A** **- 3**  **. A mbient Receiving Water Concentrations (2011 to 2012): Puget Sound**  **Pollutant Water Column Concentration (μg/L)1** 

**Mi nimum**  **Me dian**  **Geometric Me**  **an 90th** 

**Percentile Ma** **ximum** Antimony 0.143 0.158 0.158 0.172 0.173 Arsenic 1.22 1.4 1.364 1.45 1.46 Copper 0.231 0.287 0.296 0.355 0.387 Cyanide nd nd nd nd nd Mercury nd nd nd nd nd Nickel 0.39 0.4115 0.410904577 0.4275 0.43 Zinc 0.27 0.395 0.428224144 0.605 0.707 Source: based on data from Ecology’s Environmental Information Management System, monitoring station LSNT01. nd=nondetect 1. Metal concentrations are dissolved.
**A. 2.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 50**  

### WQBEL w ould have been included in the NPDES permit. 23 

### Incases of reasonable potential, EPA cal culated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 4 summarizes the reasonable potential analysis under the policy scenario. Based on effluent concentrations in Exhibit A
- 2 and available ambient data in Exhibit A
- 3 , there is reasonable potential to exceed the baseline human health criteria for arsenic. **Exhibit A** **- 4**  **. Human Health Reasonable Potential A naly** **sis for King County**  **South WWTP**  **– Baseline Scenario**  **1 Parameter**  **Effluent Conc.**

**( total;**  **μg/L) Am**  **bient Conc.**

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 1.26 1.364 1.364 0.14 1. See effluent concentrations in Exhibit A- 2 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observa tions is less than 10, and otherwise uses the geom etric mean) and available ambient concentrations in Exhibit A- 3

. 2. Based on W ashington Department o f Ecology’s Permit writer spreadsheet tool using a dilution factor of 428. 3. C onsumption of organisms only

. Exhibit A
- 5 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 5**  **. Human Health Based Effluent Limitations for Kin g County**  **South WWTP –**  **Baseline Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.14 0.16 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an average monthly effluent limit (AML) of 0.14 μg/L and a maximum daily effluent limitation (MDL) of 0.16 μg/L. Since the average effluent concentration is 1.26 μg/L and the maximum effluent concentration is 1.6 μg/L, which are greater than the projected baseline permit limitations, the discharger will need to reduce arsenic in its effluent to ensure that permit limitations are consistently

met. Arsenic and arsenic
- containing chemicals are not used in wastewater treatment. However, the facility has a large industrial base and regulates 65 industrial users of which 27 are significant industrial users and 19 are categorical industrial users (i.e., users subject to EPA’s

23 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitatio ns must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 51**  

### national pretreatment standards), including 32 in the electroplating and metal finishing categories. Thus, a source control program that targets or imposes more stringent limits on the most likely

indirect industrial dischargers of arsenic to the plant could reduce arsenic concentrations to the necessary levels. Costs for such a program would depend on the number of arsenic sources and the measures that could be implemented at those sources to reduce arsenic. However, without more detailed information on these industrial users and King County’s pretreatment program (e.g., flows and arsenic concentrations for each industrial user, local limits for arsenic, ordinances, etc.), it is not possible to estimate pretreatment or P2 costs to indirect dischargers. Other potential sources of arsenic to the treatment plant are water and groundwater infiltration. Details on the drinking water sources for the municipalities served by King County South, including whether these sources are surface water or groundwater and levels of arsenic in these sources , were not evaluated . The drinking water maximum contaminant level is 10 μg/L, which is higher than current wastewater effluent concentrations and human health criteria. EPA did not attempt to determine with any certainty whether drinking water is contributing to high arsenic levels in the wastewater effluent. However, if the facility determines that drinking water is the source of high arsenic values in the wastewater, it is likely that the facility

would pursue a variance. The fact sheet for the facility ’s 2009 permit indicates that King County created a Regional In filtration and Inflow (I & I) Control Program in 1999 as part of the Regional Wastewater Services Plan (RWSP) to explore the feasibility of a regional I& I control program to reduce the amount of peak wet weather flow entering the County's wastewater conveyance. In response to the RWSP I&I Control Program policies, County staff, working in a consensus
based approach with the local sewer agencies, conducted a comprehensive 6
- ye ar, $41 million, I&I control study. The study began in 2000 and culminated with the County Executive’s recommendation for a regional I& I control program. The study included: defining levels of I&I for each local agency tributary to the regional system through an extensive flow monitoring and modeling program; constructing 10 pilot projects in 12 local agency jurisdictions to demonstrate the effectiveness of collection system rehabilitation projects and to test various technol ogies and gain cost information; developing model standards, procedures, policies, and guidelines for use b y local agencies to reduce I&I in their systems; performing a cost
-benefit anal ys is to determine the cost
- effectiveness of I&I reduction; developing a long
- term regional I&I control plan; working with the local sewer agencies to conduct an I&I reduction feasibility analysis; and performing several I&I reduction projects. As the focus of these studies and anal ys es were on reduction of peak flows to minimize combined sewer overflows, it is uncertain whether this I&I reduction program and these modifications to the collection system would address arsenic levels (there are a number of modifications that can correct I&I issues that would not necessaril y red uce arsenic concentrations). If groundwater infiltration is causing the high arsenic effluent levels, the

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 52**  

### facility may have to implement modifications to the existing I&I reduction program for compliance with the baseline scenario criteria. Due to the fact that ambient receiving water concentrations exceed the baseline human health criteria, the discharger may pursue obtaining a water quality standards variance. The one
time cost associated with pursuing a variance is estimated to be $426,000, with minimal costs associated with renewal. If the arsenic effluent levels are the result of infiltration of arsenic
contaminated groundwater, total costs could be $10,600,000 for a comprehensive I&I reduction program that includes source identification and pipe rehabi litation for a s ys tem with 145 miles 24 

### of sewer pipes (approximately $1,000,000 per year annualized at 7% over 20 years). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for compliance and the discharger would not likely undertake such a program for compliance with toxic criteria alone. **A. 2.5**  **Policy Scenario** 

### Exhibit A
- 6 summari zes the reasonable potential analysis under the policy scenario. Based on effluent concentrations in Exhibit A
- 2 and available ambient data in Exhibit A
- 3 , there is reasonable potential to exceed the proposed human health criteria for arsenic. **Exhibit A** **- 6**  **. Human Health Reasonable Potential A**  **naly sis for King County**  **South WWTP**  **– Policy Scenario**  **1**
**Parameter Baseline** 

**A verage Monthly**  **Effluent Limit (**  **total; μg/L)**  **Am bient Conc.** 

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0.14 1.364 1.364 0.0059 1. See effluent concentrations in Exhibit A- 2 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 3

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 428. 3. C onsumption of organisms only

. Exhibit A
- 7 summarizes the calculated permit limits for arsenic under the policy scenario.

24 Estimated based on information from the King County L ong Term Control Plan , which indicated “over 350 miles” of service lines in the basin, pro
- rated for each plants sub
-basin based on the plant’s share of the total flow capacity (41% for King County South).

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 53**  **Exhibit A** **- 7**  **. Human Health Based Effluent Limitations for King County**  **South WWTP –**  **Policy Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; ug/L)**  **1 Ma** **ximum Daily Effluent Limit (total; ug/L)**  **1** Arsenic 0.0059 0.0069 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the policy

scenario, the discharger would have to meet an AML of 0.0059 μg/L and a MDL of 0.0069 μg/L. Under the baseline scenario, the projected effluent limitations are below the anal ytical quantitation level (QL) and EPA estimated that the discharger would incur costs for I&I control as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL. Since the projected effluent limitations under the policy scenario are also below th e QL, no additional compliance strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **A. 3**  **King C**  **ounty W**  **est P**  **oint WWTP**  **and C SO**  **Sys tem**  King County provides wholesale wastewater treatment services to 17 cities, 16 local sewer utilities, and one Indian tribe. The King County West Point WWTP and Combined Sewer Overflow (CSO) System (NPDES permit WA002 9181) provides coverage for King County ’s West Point WWTP, four CSO treatment facilities (Alki, Carkeek, Ell iott West, and Henderson/MLK), and 38 CSO outfalls. The WWTP discharges to the Puget Sound, and the CSO treatment plants discharge to the Puget Sound, Elliot Bay , and Duwamish Waterway
. Average annual WWTP flow is 95 mgd. **A. 3.1**  **Treatment Processes** 

### The 2014 permit fact sheet for the facility indicates that the West Point WWTP treats domestic, commercial, and industrial wastewater and CSO stormwater from the greater Seattle area using a high rate oxygenated activated sludge biological treatment process with chlorin e disinfection before discharging the treated effluent to central Puget Sound. The Alki, Carkeek, Denny/Elliott West, and Henderson/MLK CSO treatment p lants have primary treatment with disinfection
. **A. 3.2**  **Effluent Data** 

### Exhibit A
- 8 summarizes effluent monitoring data for the WWTP from the permit fact sheet, which reports detected concentrations onl y for the pollutants of concern. **Exhibit A** **- 8**  **. Summary of Effluent Data (2009**  **- 2013): King County West Point WWTP**  **Pollutant Number of** 

**Observations Effluent Concentration**  **(μg/L) 1** 

**Mi nimum**  **Me dian**  **95 th**  **Percentile Ma** **ximum** 1,4 - Dichlorobenzene 9 1.0 10.2 10.2 2,4 - Dichlorophenol 9 0.12 0.96 0.96 2,4 - Dim ethylphenol 9 0.24 0.48 0.48

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 54**  **Exhibit A** **- 8**  **. Summary of Effluent Data (2009**  **- 2013): King County West Point WWTP**  **Pollutant Number of** 

**Observations Effluent Concentration**  **(μg/L) 1** 

**Mi nimum**  **Me dian**  **95 th**  **Percentile Ma** **ximum** Antimony 15 0.30 0.44 0.63 Arsenic 15 0.27 2.196 2.28 Bis(2 - ethy lhex yl) p hthalate 9 0.41 7.332 10.20 Chloroform 9 1.00 5.68 5.68 Copper 15 0.40 16.3 16.3 Cyanide 15 5.0 6.0 Diethyl p hthalate 9 0.120 0.85 0.85 Mercury 21 0.002 0.005 0.0155 0.016 Methylene c hloride 9 5.0 5.3 5.3 Nickel 23 0.1 2.81 5.999 6.5 Phenol 9 40 0.95 90 Py rene 9 0.071 0.29 0.290 Selenium 15 0.50 0.5 0.74 1.30 Thallium 15 0.040 0.050 0.130 Toluene 9 1.0 1.1 1.1 Zinc 23 10.7 50.78 54.2 Source: Summarized data from 2014 Fact Sheet, Table 15 and Appendix F. 1. Metal concentrations are total recoverable form

. **A. 3.3**  **Receiving Water** 

### Exhibit A
- 9 summarizes the available ambient receiving water concentrations based on data from the 2014 Fact Sheet for the permit and King County Department of Natural Resources (2013). **Exhibit A** **- 9**  **. A mbient Receiving Water Concentrations: Puget Sound**  **Pollutant Water Column Concentration (μg/L)**  **1**

**Mi nimum**  **Me dian**  **Me an**  **90 th**  **Percentile Ma** **ximum** Arsenic 1.15 1.33 1.29 1.36 1.43 Copper 0.234 0.308 0.322 0.41 0.617 Mercury nd nd nd nd nd Nickel 0.387 0.407 0.408 0.437 0.443 Zinc 0.170 0.417 0.438 0.685 0.694

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 55**  **Exhibit A** **- 9**  **. A mbient Receiving Water Concentrations: Puget Sound**  **Pollutant Water Column Concentration (μg/L)**  **1**

**Mi nimum**  **Me dian**  **Me an**  **90 th**  **Percentile Ma** **ximum** nd = nondetect Source: King County Department of Natural Resources (2013; Table 3 - 2) and 2014 Fact Sheet (for 90 th percentile values only); based on 12 samples (9 with detectable concentrations of total mercury ). 1. Metal concentrations are dissolved.
**A. 3.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 25 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 10 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 8 and available ambient data in Exhibit A
- 9 , there is reasonable potential to exceed the baseline human health arsenic criterion. **Exhibit A** **- 10**  **. Human Health Reasonable Potential A nalysis for King County**  **West Point WWTP**  **– Baseline Scenario**  **1 Parameter**  **Effluent Conc.**

**( total;**  **μg/L) Am**  **bient Conc.**

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0.27 1.33 1.33 0.14 1. See effluent concentrations in Exhibit A- 8 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 9

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 324. 3. C onsumption of organisms only

. 

### Exhibit A
- 11 summarizes the calculated permit limits for arsenic under the baseline scenario.

25 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 56**  **Exhibit A** **- 11**  **. Human Health Based Effluent Limitations for King County**  **West Point WWTP**  **– Baseline Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; ug/L)**  **1 Ma** **ximum Daily Effluent Limit (total; ug/L)**  **1** Arsenic 0.14 0.28 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AM ) of 0.14 μg/L and a MDL of 0.28 μg/L. Since the average effluent concentration is not listed in the fact sheet and the maximum effluent concentration is 2.28 μg/L, whi ch is greater than the projected baseline permit limitations, the discharger will need to reduce arsenic in its effluent to ensure that permit limitations are consistently met. Arsenic and arsenic
- containing chemicals are not used in wastewater treatment. However, the facility

has a large industrial base and regulates 48 industrial users of which 27 are significant industrial users and 39 are categorical industrial users (i.e., users subject to EPA’s national pretreatment standards), including 16 in the el ectroplating and metal finishing categories. West Point receives an estimated daily flow of 9.6 MGD from these industrial users. Thus, a source control program that targets or imposes more stringent limits on the most likely

indirect industrial dischargers of arsenic to the plant could reduce arsenic concentrations to the necessary levels. Costs for such a program would depend on the number of arsenic sources and the measures that could be implemented at those sources to reduce arsenic. However, without more detailed information on these industrial users and King County’s pretreatment program (e.g., flows and arsenic concentrations for each industrial user, local limits for arsenic, ordinances), it is not possible to estimate pretreatment or P2 costs to indirect dischargers. Other potential sources of arsenic to the treatment plant are drinking water and groundwater infiltration. Details on the drinking water sources for the municipalities served by West Point, including whether these sources are surface water or groundwater a nd levels of arsenic in these sources, were not evaluated . The drinking water maximum contaminant level is 10 μg/L, which is higher than current wastewater effluent concentrations and human health criteria. EPA did not attempt to determine with any certainty whether drinking water is contributing to high arsenic levels in the wastewater effluent. However, if the facility determines that drinking water is the source of high arsenic values in the wastewater, it is likely that the facility

would pursue a variance. The fact sheet for the facility ’s 2014 permit indicates that King County created a Regional I& I Control Program in 1999 as part of the Regional Wastewater Services Plan (RWSP) to explore the feasibility

of a regional I& I control program to reduce the amount of peak wet weather flow entering the County's wastewater conveyance. In response to the RWSP I&I Control Program policies, County staff, working in a consensus
-based approach with the local sewer agencies, conducted a comprehensive 6
- ye ar, $41 mill ion, I& I control study . The

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 57**  

### study began in 2000 and culminated with the County Executive’s recommendation for a regional I& I control program. The study included: defining levels of I&I for each local agency tributary to the regional system through an extensive flow monitoring and modeling program; constructing 10 pilot projects in 12 local agency jurisdictions to demonstrate the effectiveness of collection system rehabilitation projects and to test various technologies and gain cost information; developing model standards, procedures, policies, and guidelines for use b y local agencies to reduce I&I in their systems; performing a cost
-benefit anal ys is to determine the cost
- effectiveness of I&I reduction; developing a long
- term regional I&I control plan; working with the local sewer agencies to conduct an I&I reduction feasibility analysis; and performing several I&I reduction projects. As the focus of these studies and anal ys es were on reduction of peak flows to minimize combined sewer overflows, it is uncer tain whether this I&I reduction program and these modifications to the collection system would address arsenic levels (there are a number of modifications that can correct I&I issues that would not necessaril y reduce arsenic concentrations). If groundwater infiltration is causing the high arsenic effluent levels, the facility may have to implement modifications to the existing I&I reduction program for compliance with the baseline scenario criteria. Due to the fact that ambient receiving water concentration s exceed the baseline human health criteria, the discharger may pursue obtaining a water quality standards variance. The one
time cost associated with pursuing a variance is estimated to be $426,000, with minimal costs associated with renewal. If the arsenic effluent levels are the result of infiltration of arsenic
contaminated groundwater, total costs could be $11,650,000 for a comprehensive I&I reduction program that includes source identification and pipe rehabilitation for a s ys tem with 165 miles 26 

### of sewer pipes (approximately $1,100,000 per year annualized at 7% over 20 years). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for compliance and the discharger would not likely undertake such a program for compliance with toxic criteria alone. **A. 3.5**  **Policy Scenario** 

### Exhibit A
- 12 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 8 and available ambient data in Exhibit A
- 9 , there is reasonable potential to exceed the proposed human health criteria for arsenic.

26 Estimated based on information from the King County LTCP, which indicated “over 350 miles” of service lines in the basin, pro
- rated for each plants ’ sub
-basin based on the plant’s share of the total flow capacity (47% for King County West Point).

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 58**  **Exhibit A** **- 12**  **. Human Health Reasonable Potential A nalysis for King County**  **West Point WWTP**  **– Policy Scenario**  **1**
**Parameter Baseline** 

**A verage**  **M onthly**  **Effluent Limit (**  **total; μg/L)**  **Am bient Conc.** 

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0. 14 1.33 1.33 0.0059 1. See effluent concentrations in Exhibit A- 8 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 9

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 324. 3. C onsumption of organisms only

. 

### Exhibit A
- 13 summarizes the calculated permit limits for arsenic under the policy scenario. **Exhibit A** **- 13**  **. Human Health Based Effluent Limitations for King County**  **West Point WWTP**  **– Policy Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; ug/L)**  **1 Ma** **ximum Daily Effluent Limit (total; ug/L)**  **1** Arsenic 0.0059 0.012 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the policy

scenario, the discharger would have to meet an AML of 0.0059 μg/L and a MDL of 0.012 μg/L. Under the baseline scenario, where the projected effluent limitations are below the anal ytical QL, EPA estimated that the discharger would incur costs for I&I control as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL . Since the projected effluent limitations under the policy scenario are also below the QL , no additional compliance strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **A. 4**  **Pasco Wastewater Treatment Works** The Pasco Wastewater Treatment Works (NPDES permit WA0044962 ) provides wastewater treatment to 43,500 people in the City of Pasco and two permitted industrial users (Easterday Farms Produce Company and A1 Quality Services, a truck washing facility). The Wastewater Treatment Works discharges an annual average flow of 4.5 mgd to the Lake Wallula reach of the Columbia River. **A. 4.1**  **Tr eatment Processes**  

### The 2014 permit limits evaluation indicates that treatment processes include headworks with traveling screens, grit removal, primary clarifiers, a trickling filter, an intermediate clarifier, aeration basins, and secondary clarifiers foll owed by

disinfection.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 59**  **A. 4.2**  **Effluent Data** 

### Exhibit A
- 14 summarizes available effluent monitoring data for the Wastewater Treatment Works from 2012 through 2014. **Exhibit A** **- 14**  **. Summary of Effluent Data (2012 -** **2014): Pasco Waste water Treatment**  **Works Pollutant**  **Number of**

**Observations Effluent Concentration (μg/L)**  **1**

**Me dian**  **Av erage**  **95 th**  **Percentile Ma** **ximum** Arsenic 3 1.0 1.5 2.35 2.5 Chloroform 6 1.65 1.94 Copper 15 40.7 42.013 53.57 54.9 Cyanide 15 10 10 10 10 Mercury 27 0.0004 0.012 Methylene c hloride 2 0.72 0.76 Phenol 2 0.77 0.87 Selenium 3 3 5.3 9.21 9.9 Zinc 3 42.1 54.167 74.68 78.3 Source: Discharge mo nitoring reports for 2012 through 2014 (for arsenic, copper, cyanide, selenium, and zinc), a 2014 permit application (for chloroform and mercury ), and a 2014 permit limit evaluation (for methylene chloride and phenol). 1. Metal concentrations are in tota l recoverable form

. **A. 4.3**  **Receiving Water** 

### Exhibit A
- 15 summarizes the available ambient receiving water concentrations based on data from Ecology ’s Environmental Information Management System between 2004 and 2014. **Exhibit A** **- 15**  **. A mbient Receiving Water Concentrations: Columbia River**  **Pollutant Water Column Concentration (μg/L)**  **90 th**  **Percentile Av**  **erage** Arsenic 0.77 0.6175 Copper 1.1 0.677 Mercury 0.002 0.002 Nickel 0.71 0.6183 Zinc 6.2 3.77 Source: W ashington State Department of Ecology Environmental Information Management System, 2004 to 2014 data for station 36A070.
**A. 4.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of c oncern. In this case, EPA performed a reasonable potential analysis for each

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 60**  

### pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 27 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 16 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 14 and available ambient data in Exhibit A
- 15 , there is reasonable potential to exceed the baseline human health arsenic criterion. **Exhibit A** **- 16**  **. Human Health Reasonable Potential A nalysis for Pasco Wastewater**  **Treatment Works –**  **Baseline Scenario 1**  **Parameter Effluent** 

**Conc. (μg/L) Am**  **bient Conc.**

**(μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 2.35 0.6175 0.6178 0.018 1. See effluent concentrations in Exhibit A- 14 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the me dian) and available ambient concentrations in Exhibit A- 15

. 2. Base d on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 8477 for carcinogens and 3077 for non - carcinogens. 3. C onsumption of water and organisms

. 

### Exhibit A
- 17 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 17**  **. Human Health Based Effluent Limitations for Pa sco Wastewater**  **Treatment Works –**  **Baseline Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.018 0.036 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 0.018 μg/L and a MDL of 0.036 μg/L. Since the average effluent concentration is 1.5 μg/L and the maximum effluent concentration is 2.5 μg/L, which are greater than the projected baseline permit limitations, the discharger will need to reduce arsenic in its effluent to ensure that permit limitations are consistently met. Arsenic and arsenic
- containing chemicals are not used in wastewater treatment and the facility ha s only

two permitted industrial users, one of which is a produce company . If the produce is treated with arsenic
- containing pesticides, then any wash water from the

27 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d) (1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 61**  

### packaging operations could contribute to the high effluent arsenic levels. Thus, a source c ontrol program that targets the most likely indirect industrial dischargers of arsenic to the plant could reduce arsenic concentrations to the necessary levels. Costs for such a program would depend on the number of arsenic sources and the measures that could be implemented at those sources to reduce arsenic. Without specific information on the types of industrial dischargers that may

need controls, it is not possible to estimate pretreatment or P2 costs to indirect dischargers. Other potential sources of arsenic to the treatment plant include drinking water and groundwater infiltration. Details on the drinking water source(s) for the City of Pasco, including whether these sources are surface water or groundwater and levels of ars enic in these sources, were not evaluated . The drinking water maximum contaminant level is 10 μg/L, which is higher than current wastewater effluent concentrations and human health criteria. EPA did not attempt to determine with any certainty whether drinking water is contributing to high arsenic levels in the wastewater effluent. However, if the facility determines that drinking water is the source of high arsenic values in the wastewater, it is likely that the facility

would pursue a variance. The wastewater treatment plant exceeded 85% of the design maximum month in October, November and December 2008, likely due to infiltration. The City has been working on relining old sewer lines to prevent I&I. Itis uncertain whether this I&I reduction program would address arsenic levels (there are a number of modifications that can correct I&I issues that would not necessarily reduce arsenic concentrations). If groundwater infiltration is causing the high arsenic effluent levels, the facility may have to implement m odifications to the existing I&I reduction program for compliance with the baseline scenario criteria. Due to the fact that ambient receiving water concentrations exceed the baseline human health criteria, the discharger may pursue obtaining a water quality standards variance. The one
time cost associated with pursuing a variance is estimated to be $180,000, with minimal costs associated with renewal. If the arsenic effluent levels are the result of infiltration of arsenic
contaminated groundwater, total co sts could be $16,200,000 for a comprehensive I&I reduction program that includes source identification and pipe rehabilitation for a s ys tem with 307 miles of sewer pipes (approximately $1,530,000 per year annualized at 7% over 20 ye ars). Note that if groun dwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for compliance and the discharger would not likely undertake such a program for compliance with toxic criteria alone. **A. 4.5**  **Policy Scenario**  

### Exhibit A
- 18 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 14 and available ambient data in Exhibit A
- 15 , there is reasonable potential to exceed the proposed hum an health criteria for arsenic.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 62**  **Exhibit A** **- 18**  **. Human Health Reasonable Potential A nalysis for Pasco Wastewater**  **Treatment Works –**  **Policy Scenario 1** 

**Parameter Baseline** 

**A verage**  **Monthly Effluent**  **Limit (μg/L)**  **Am bient Conc.** 

**(μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0.018 0.6175 0.6178 0.0045 1. See effluent concentrations in Exhibit A- 14 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the me dian) and available ambient concentrat ions in Exhibit A- 15

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 8477 for carcinogens and 3077 for non - carcinogens. 3. C onsumption of water and organisms

. 

### Exhibit A
- 19 summarizes the calculated permit limits for arsenic under the policy scenario. **Exhibit A** **- 19**  **. Human Health Based Effluent Limitations for Pasc o Wastewater**  **Treatment Works –**  **Policy Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.0045 0.0091 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the policy

scenario, the discharger would have to meet an AML of 0.0045 μg/L and a MDL of 0.0091 μg/L. Under the baseline scenario, where the projected effluent limitations are below the anal ytical QL , EPA estimated that the disch arger would incur costs for I&I control as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL. Since the projected effluent limitations under the policy scenario are also below the QL, no additional complianc e strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **A. 5**  **Puy allup**  **WWTP** The City of Puyallup owns and operates a municipal WWTP (NPDES permit WA0037168 ) that provides primary

and secondary

treatment. The WWTP discharges an annual average flow of 4.07 mgd to the Puyallup River within the Puyallup Reservation. The EPA has authority to issue permits for the facility based on the Puyallup Tribe’s WQS , pursuant to a memorandum of understanding among the EPA, the Puyallup Tribe, and Ecology
. **A. 5.1**  **Treatment Processes** 

### The 2014 fact sheet for the permit states that the facility uses preliminary

treatment consisting of fine screening for solids removal, and primary treatment includes clarification, sludge/grit centrifugal separation, and grit disposal. Secondary treatment consists of activated sludge, secondary

clarification, and ultraviolet light disinfection.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 63**  **A. 5.2**  **Effluent Data** 

### Exhibit A
- 20 summarizes available effluent monitoring data for the WWTP from 2012 through 2014. **Exhibit A** **- 20**  **. Summary of Effluent Data (2012 -** **2014): Puy allup WWTP**  **Pollutant Number of** 

**Observations Effluent Concentration (μg/L)**  **1**

**Me dian**  **Av erage**  **95 th**  **Percentile Ma** **ximum** Copper 15 5.60 5.39 6.34 6.90 Mercury 15 0.00180 0.00183 0.00279 0.00300 Zinc 15 33.90 33.83 43.93 44.70 Source: Discharge monitoring reports for 2012 through 2014. 1. Metal concentrations are in total recoverable form

. **A. 5.3**  **Receiving Water** 

### Exhibit A
- 21 summarizes the available ambient receiving water concentrations based on data from Ecology ’s Environmental Information Management System from 2009. **Exhibit A** **- 21**  **. Am**  **bient Receiving Water Concentrations: Puy allup River**  **Pollutant Water Column Concentration (μg/L)**  **90 th**  **Percentile Av**  **erage** Arsenic 0.90 0.62 Di(2 - ethy lhex yl) phthalate 0.07 0.07 Copper 11.60 3.36 Zinc 12.66 5.28 Source: W ashington State Department of Ecology Environmental Information Management System, 2009 data for station PSTLA- RIV05.
**A. 5.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 28 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL.

28 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 64**  

### Based on effluent concentrations in Exhibit A
- 20 and available ambient data in Exhibit A
- 21 , there is no reasonable potential to exceed the proposed human health criteria for pollutants for which effluent data are available (copper, mercury , and zinc). Thus, there are no permit limits or costs associated with the baseline scenario. 29 **A. 5.5**  **Policy Scenario** 

### Based on effluent concentrations in Exhibit A
- 20 and available ambient data in Exhibit A
- 21 , there is no reasonable potential to exceed the proposed human health criteria for pollutants for which effluent data are available (copper, mercury , and zinc). Thus, there are no permit limits or costs associated with the policy scenario. **A. 6**  **Redondo WWTP**  The Lakehaven Utility

District owns and operates the Redondo WWTP (NPDES permit WA0023451 ) which serves residential and commercial customers. The WWTP discharges an annual average flow of 2.8 mgd 30 

### to Puget Sound

– Poverty Bay
. **A. 6.1**  **Treatment Processes** 

### The 2013 fact sheet for the permit (Washington Department of Ecology , 2 013a) indicates that the facility

employs primary

and secondary

treatment consisting of screening, grit removal and comminution, primary clarification, biological treatment using plastic media trickling filters, secondary

clarification, and ultraviolet dis infection (p. 8). **A. 6.2**  **Effluent Data** 

### Exhibit A
- 22 summarizes available effluent monitoring data for the WWTP from 2009 through 2012. **Exhibit A** **- 22**  **. Summary of Effluent Data (2009 -** **2012): Redondo WWTP**

**Pollutant Number of Observations**  **Detected Value (μg/L) 1**  **Total Nondetect**  **QL (μg/L) Ma** **ximum Av**  **erage** 1,1,2,2 - Tetrachloroethane 3 3 1 1,1,2 - Trichloroethane 3 3 1 1,1 - Dichloroethylene 3 3 1 1,2,4 - Trichlorobenzene 3 3 0.29 1,2 - Dichloropropane 3 3 1 1,2 - Diphenylhydrazine 3 3 0.95 1,2 - Trans - d ichloroethylene 3 3 1

29 For all pollutants except arsenic, the aquatic life criteria are more stringe nt than human health criteria (as noted in the 2014 fact sheet, p. 31). The facility has water quality
-based limits for copper; the average mo nthly limit is 8.5 μg/L and the maximum daily limit is 13.7 μg/L. 30 Based on average flow between 2008 and 2012, from the 2013 fact sheet for the permit, Appendix D.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 65**  **Exhibit A** **- 22**  **. Summary of Effluent Data (2009 -** **2012): Redondo WWTP**

**Pollutant Number of Observations**  **Detected Value (μg/L) 1**  **Total Nondetect**  **QL (μg/L) Ma** **ximum Av**  **erage** 1,3 - Dichlorobenzene 3 3 1 1,4 - Dichlorobenzene 3 3 1 2,4,6 - Trichlorophenol 3 3 1.9 2,4 - Dichlorophenol 3 3 0.4 2,4 - Dinitrotoluene 3 3 0.16 2 - Chloronaphthalene 3 3 0.24 2 - Chlorophenol 3 3 1 3,3' - Dichlorobenzidine 3 3 0.48 4,4' - DDD 3 3 0.024 4,4' - DDE 3 3 0.024 4,4' - DDT 3 3 0.024 Acenaphthene 3 3 0.029 Acrolein 3 3 5 Acrylonitrile 3 3 5 Aldrin 3 3 0.024 alpha - BHC 3 3 0.024 alpha - e ndosulfan 3 3 0.024 Anthracene 3 3 0.29 Antimony 3 3 0.3 Arsenic 5 2.39 1.61 Benzene 3 3 1 Benzidine 3 3 11 Benzo(a) a nthracene 3 3 0.29 Benz o(a) p yrene 3 3 0.48 beta - BHC 3 3 0.024 beta - e ndosulfan 3 3 0.024 Bis(2 - chloroethyl) e ther 3 3 0.29 Bis(2 - C c loroisopropyl) e ther 3 3 0.29 Bis(2 - e thy lhex yl) p hthalate 3 3.69 2.88 Bromoform 3 3 1 But yl benzyl Phthalate 3 2 0.29 0.76 0.39 Carbon Tetrachloride 3 3 1 Chlorobenzene 3 3 1 Chlorodibromomethane 3 3 1

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 66**  **Exhibit A** **- 22**  **. Summary of Effluent Data (2009 -** **2012): Redondo WWTP**

**Pollutant Number of Observations**  **Detected Value (μg/L) 1**  **Total Nondetect**  **QL (μg/L) Ma** **ximum Av**  **erage** Chloroform 3 3 1 Chrysene 3 3 0.29 Copper 5 68.7 42.1 Cyanide 3 3 5 Dichlorobromomethane 3 3 1 Dieldrin 3 3 0.024 Diethyl Phthalate 3 3 0.48 Dim ethyl Phthalate 3 3 0.19 Di - n - Butyl Phthalate 3 3 0.48 Endosulfan Sulfate 3 3 0.024 Endrin 3 3 0.024 Endrin Aldehyde 3 3 0.024 Eth yl benzene 3 3 1 Fluoranthene 3 3 0.29 Fluorene 3 3 0.29 Heptachlor 3 3 0.024 Heptachlor e poxide 3 3 0.024 Hexachlorobenzene 3 3 0.29 Hexachlorobutadiene 3 3 0.48 Hexachlorocyclopentadiene 3 3 0.48 Hexachloroethane 3 3 0.48 Indeno(1,2,3 - cd) p yr ene 3 3 0.48 Isophorone 3 3 0.48 Mercury 5 0.0851 0.0341 Methyl Bromide 3 3 5 Nickel 5 2.05 1.60 Nitrobenzene 3 3 0.48 N - Nitrosodi - n - p ropy lamine 3 3 0.48 N - Nitrosodiphenylamine 3 3 0.48 Pentachlorophenol (PCP) 3 3 0.48 Phenol 3 3 1.9 Py rene 3 3 0.29 Selenium 5 0.51 0.50 Tetrachloroethylene 3 3 1

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 67**  **Exhibit A** **- 22**  **. Summary of Effluent Data (2009 -** **2012): Redondo WWTP**

**Pollutant Number of Observations**  **Detected Value (μg/L) 1**  **Total Nondetect**  **QL (μg/L) Ma** **ximum Av**  **erage** Toluene 3 3 0.38 Thallium 3 3 0.04 Toxaphene 3 3 1 Trichloroethylene 3 3 1 Vin yl c hloride 3 3 1 Zinc 3 57.4 51.0 Source: 2013 Fact Sheet, Appendix D. QL = quantitation level 1. Metal concentrations are in total recoverable form

. **A. 6.3**  **Receiving Water** 

### Exhibit A
- 23 summarizes the available ambient receiving water concentrations in Puget Sound based on data from Ecology ’s Environmental Information Management System f rom 2011 to 2013. **Exhibit A** **- 23**  **. A mbient Receiving Water Concentrations (2011 to 2013): Puget Sound**  **Pollutant Water Column Concentration (μg/L)1**  **90th Percentile Av**  **erage** Antimony 0.172 0.158625 Arsenic 1.45 1.36625 Copper 0.3545 0.299 Cyanide nd nd Mercury nd nd Nickel 0.4275 0.411125 Zinc 0.662 0.604167 nd=nondetect Source: Environmental Information Management System data (NPDES receiving water characterization study ). 1. Metal concentrations are dissolved form

. **A. 6.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e. , existing) human health criteria to confirm whether a

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 68**  

### WQBEL w ould have been included in the NPDES permit. 31 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 24 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 22 and available ambient data in Exhibit A
- 23 , there is reasonable potential to exceed the baseline human health criterion for arsenic. **Exhibit A** **- 24**  **. Human Health Reasonable Potential A nalysis for Redondo WWTP**  **– Baseline Scenario**  **1 Parameter**  **Effluent Conc.**

**( total;**  **μg/L) Am**  **bient Conc.**

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 2.39 1.3663 1.371 0.14 1. See effluent concentrations in Exhibit A- 22 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 23

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 182. 3. C onsumption of organis ms only

. 

### Exhibit A
- 25 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 25**  **. Human Health Based Effluent Limitations for Re dondo WWTP**  **– Baseline**  **Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.14 0.28 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 0.14 μg/L and a MDL of 0.28 μg/L. Since the average effluent concentration is 1.61 μg/L and the maximum effluent concentration is 2.39 μg/L, which are greater than the projected basel ine permit limitations, the discharger will need to reduce arsenic in its effluent to ensure that permit limitations are consistently met. Arsenic and arsenic
- containing chemicals are not used in wastewater treatment and the facility does not have any

significant or categorical industrial users. However, drinking water and groundwater infiltration are two potential sources of arsenic to the treatment plant.

31 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharg ed “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 69**  

### Details on the drinking water sources for the communities served by the Redondo WWTP, including whether these sources are surface water or groundwater and levels of arsenic in these sources, were not evaluated . The drinking water maximum contaminant level is 10 μg/L, which is higher than current wastewater effluent concentrations and human health criteria. EPA did not attempt to determine with any certainty whether drinking water is contributing to high arsenic levels in the wastewater effluent. However, if the facility determines that drinking water is the source of high arsenic values in the wastewater, it is likely that the facility

would pursue a variance. The fact sheet for the facility ’s 2013 permit indicates that the District completed a comprehensive wastewater s ys tem plan in 1999. A collection system analysis found that I&I is a significant problem at this plant, and it recommended various I&I and flow reduction programs. The District incorporated an I&I rehab program focusing on the Redondo basin areas. Itis uncertain whether this I&I reduction program and these modifications to the collection system would address arsenic levels (there are a number of modifications that can correct I&I issues that would not necessaril y reduce arsenic concentrations) . If groundwater infiltration is causing the high arsenic effluent levels, the facility may have to modify

or expand the existing I&I reduction program for compliance with the baseline scenario criteria. Due to the fact that ambient receiving water concentrations exceed the baseline human health criteria, the discharger may pursue obtaining a water quality standards variance. The one
time cost associated with pursuing a variance is estimated to be $180,000, with minimal costs associated with renewal. If the arsenic effluent levels are the result of infiltration of arsenic
contaminated groundwater, total costs could be $6,020,000 for a comprehensive I&I reduction program that includes source identification and pipe rehabilitation for a s ys tem with 114 miles o f sewer pipes (approximately $568,000 per year annualized at 7% over 20 ye ars). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for compliance and the discharger would not likely undertake such a program for compliance with toxic criteria alone. **A. 6.5**  **Policy Scenario** 

### Exhibit A
- 26 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 22 and available ambient data in Exhibit A
- 23 , there is reasonable potential to exceed the proposed human health criterion for arsenic. **Exhibit A** **- 26**  **. Human Health Reasonable Potential A nalysis for Redondo WWTP**  **– Policy**  **Scenario 1** 
**Parameter Baseline** 

**A verage Monthly**  **Effluent Limit (**  **total; μg/L)**  **Am bient Conc.** 

**( dissolved;**  **μg/L) Conc. at Edge**  **of**

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0.14 1.3663 1.371 0.0059

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 70**  **Exhibit A** **- 26**  **. Human Health Reasonable Potential A nalysis for Redondo WWTP**  **– Policy**  **Scenario 1** 
**Parameter Baseline** 

**A verage Monthly**  **Effluent Limit (**  **total; μg/L)**  **Am bient Conc.** 

**( dissolved;**  **μg/L) Conc. at Edge**  **of**

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** 1. See effluent concentrations in Exhibit A- 22 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 23

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 182. 3. C onsumption of organis ms only

. 

### Exhibit A
- 27 summarizes the calculated permit limits for arsenic under the policy scenario. **Exhibit A** **- 27**  **. Human Health Based Effluent Limitations for Redondo WWTP**  **– Policy**  **Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.0059 0.012 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the policy

scenario, the discharger would have to meet an AML of 0.0059 μg/L and a MDL of 0.012 μg/L. Under the baseline scenario, where the projected effluent limitations are below the anal ytical QL , EPA estimated that the discharger would incur cos ts for I&I control as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL . Since the projected effluent limitations under the policy scenario are also below the QL , no additional compliance strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **A. 7**  **Salmon Creek WWTP**  The Salmon Creek WWTP (NPDES permit WA0022772 ) , operated b y the Southwest Suburban Sewer District (District), serves households and some commercial customers in King County. The facility does not serve any industrial customers. It has an average wet weather flow of 3.6 mgd. **A. 7.1**  **Treatment Processes** 

### According to a 2009 inspection report, treatment at the facility includes screening, grit removal, primary

clarification, biological treatment, secondary clarification, and chlorine disinfection. **A. 7.2**  **Effluent Data** 

### Exhibit A
- 28 summarizes available effluent monitoring data for the WWTP from 2010 through 2012.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 71**  **Exhibit A** **- 28**  **. Summary of Effluent Data (2010 -** **2012): Salmon Creek WWTP**

**Pollutant Number of**  **Observations Effluent Concentra**  **tion (μg/L)1 Ma** **ximum Av**  **erage** Antimony 3 0.55 0.45 Arsenic 3 2.37 1.76 Bis(2 - e thy lhex yl) p hthalate 3 1.5 Copper 3 11.6 8.62 Nickel 3 2.3 1.87 Selenium 3 1.4 1.14 Thallium 3 0.017 0.017 Toluene 3 1.1 1.1 Zinc 3 44.2 37.7 Mercury 3 0.0074 0.0064 Source: 2012 priority pollutant monitoring report; bis(2 - ethylhex yl) phthalate data are from 2013 fact sheet addendum. 1. Metal concentrations are in total recoverable form

. **A. 7.3**  **Receiving Water** 

### The facility

discharges to Puget Sound, which is designated as a Class AA receiving water in the vicinity

of the outfall. Exhibit A
- 29 summarizes the available ambient receiving water concentrations in Puget Sound based on data from Ecology ’s Environmental Information Management S ys tem from 2011 to 2013. **Exhibit A** **- 29**  **. A mbient Receiving Water Concentrations (2011 to**  **2013): Puget Sound Pollutant**  **Water Column Concentration (μg/L) 1**  **90th Percentile Av**  **erage** Antimony 0.172 0.158625 Arsenic 1.45 1.36625 Copper 0.3545 0.299 Cyanide nd nd Mercury nd nd Nickel 0.4275 0.411125 Zinc 0.662 0.604167 nd=nondetect Source: Environmental Information Management System data (NPDES receiving water characterization study ). 1. Metal concentrations are dissolved form

.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 72**  **A. 7.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pol lutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 32 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 30 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 28 and available ambient data in Exhibit A
- 29 , there is reasonable potential to exceed the baseline human health arsenic criterion. **Exhibit A** **- 30**  **. Human Health Reasonable Potential A nalysis**  **for Salmon Creek WWTP –**  **Baseline Scenario 1**  **Parameter Effluent Conc.** 

**( total;**  **μg/L) Am**  **bient Conc.**

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 2.37 1.3663 1.368 0.14 1. See effluent concentrations in Exhibit A- 28 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient concentrations in Exhibit A- 29

. 2. Based on W ashington Department of Ecology’s Permit writer sp readsheet tool using a dilution factor of 1025. 3. C onsumption of organisms only

. 

### Exhibit A
- 31 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 31**  **. Human Health Based Effluent Limitations for Salmon Creek WWTP**  **– Baseline Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; ug/L)**  **1 Ma** **ximum Daily Effluent Limit (total; ug/L)**  **1** Arsenic 0.14 0.28 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 0.14 μg/L and a MDL of 0.28 μg/L. Since the average effluent concentration is 1.76 μg/L and the maximum effluent concentration is 2.37 μg/L, which are greater than the projected base line permit limitations, the discharger will need to reduce arsenic in its effluent to ensure that permit limitations are consistently met.

32 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 73**  

### Arsenic and arsenic
- containing chemicals are not used in wastewater treatment and the facility does not have any

significant or categorical industrial users. However, drinking water and groundwater infiltration are two potential sources of arsenic to the treatment plant. Details on the drinking water sources for the communities served by the Salmon Creek WWTP, including whether these sources are surface water or groundwater and levels of arsenic in these sources, were not evaluated . The drinking water maximum contaminant l evel is 10 μg/L , which is higher than current wastewater effluent concentrations and human health criteria. EPA did not attempt to determine with any certainty whether drinking water is contributing to high arsenic levels in the wastewater effluent. However, if the facility determines that drinking water is the source of high arsenic values in the wastewater, it is likely that the facility

would pursue a variance. The fact sheet for the facility ’s 2003 permit indicates that the District had performed an evaluation of I&I attributed to direct storm runoff and that I&I flow for the Salmon Creek basin was 48%. The District obtained funds for a major rehabilitation program for the Salmon Creek basin and identified a list of collection system rehabilitation proje cts in its Comprehensive Sewer Plan to address I&I. It is uncertain whether this I&I reduction program and these modifications to the collection system would address arsenic levels (there are a number of modifications that can correct I&I issues that would not necessaril y reduce arsenic concentrations). If groundwater infiltration is causing the high arsenic effluent levels, the facility

may have to modify

or expand its existing I&I reduction program for compliance with the baseline scenario limitations. Due to the fact that ambient receiving water concentrations exceed the baseline human health criteria, the discharger may also pursue obtaining a water quality standards variance. The one - time cost associated with pursuing a variance is estimated to be $180, 000, with minimal costs associated with renewal. If the arsenic effluent levels are the result of infiltration of arsenic
- contaminated groundwater, total costs could be $6,810,000 for a comprehensive I&I reduction program that includes source identificatio n and pipe rehabilitation for a s ys tem with 129 miles of sewer pipes (approximately $643,000 per year annualized at 7% over 20 ye ars). Note that if groundwater infiltration is not the only source of arsenic to the treatment plant, an I&I reduction program alone may not be sufficient for compliance and the discharger would not likely undertake such a program for compliance with toxic criteria alone. **A. 7.5**  **Policy Scenario** 

### Exhibit A
- 32 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 30 and available ambient data in Exhibit A
- 31 , there is reasonable potential to exceed the proposed human health arsenic criterion.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 74**  **Exhibit A** **- 32**  **. Human Health Reasonable Potential A nalysis for Salmon Creek WWTP**  **– Policy**  **Scenario 1** 
**Parameter Baseline** 

**A verage Monthly**  **Effluent Limit (**  **total; μg/L)**  **Am bient Conc.** 

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0.14 1.3663 1.368 0.0059 1. See effluent concentrations in Exhibit A- 28 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 29

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 1025. 3. C onsumption of organi sms only

. 

### Exhibit A
- 33 summarizes the calculated permit limits for arsenic under the policy scenario. **Exhibit A** **- 33**  **. Human Health Based Effluent Limitations for Salmon Creek WWTP**  **– Policy**  **Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.0059 0.012 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the policy

scenario, the discharger would have to meet an AML of 0.0059 μg/L and a MDL of 0.012 μg/L. Under the baseline scenario, where the projected effluent limitations are below the anal ytical QL, EPA estimated that the discharger would incur c osts for I&I control as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL . Since the projected effluent limitations under the policy scenario are also below the QL , no additional compliance strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **A. 8**  **BP Cherry**

**Point Refinery** The BP Cherry

Point Refinery

(NPDES permit number WA0022900 ) encompasses 740 acres in a rural area of Whatcom County
. The facility ’s wastewater treatment plant treats process water, ballast water from tankers, tank water draws, and stormwater that falls in process areas of the site. The permit also authorizes treatment of wastewater from the Praxair, Inc. Ferndale facility and a proposed cogeneration facility . The facility discharges treated effluent into the Strait of Georgia. The facility ’s average flow is 3.87 million gallons per day (mgd). **A. 8.1**  **Treatment Processes** 

### The 2012 NPDES permit for the facility lists current treatment processes as f our parallel oil/water separators, two induced gas floatation units, an equalization tank, a complete mix activated sludge unit, a secondary clarifier, and two clarification ponds.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 75**  **A. 8.2**  **Effluent Data** 

### Exhibit A
- 34 summarizes the last three ye ars of effluent data for the treated wastewater for the pollutants of concern for which data are available. **Exhibit A** **- 34**  **. Summary of Effluent Data (2012 -** **2014): BP Cherry Point Refinery**  **, Outfall Parameter**  **Number of Observations Summary of**  **Detected Values (μg/L)**  **Total Nondetect**  **QL (μg/L)**  **Ma ximum**  **Geometric Me**  **an Mi**  **nimum** 1,1,2,2 - Tetrachloroethane 1 1 0.4 1,1,2 - Trichloroethane 1 1 0.4 1,1 - Dichloroethylene 1 1 0.4 1,2,4 - Trichlorobenzene 1 1 0.4 1,2 - Dichlorobenzene 1 1 0.4 1,2 - Dichloroethane 1 1 0.4 1,2 - Dichloropropane 1 1 0.4 1,2 - Diphenylhydrazine 1 1 0.4 1,2 - Trans - Dichloroethylene 1 1 0.4 1,3 - Dichlorobenzene 1 1 0.4 1,3 - Dichloropropene 1 1 0.4 1,4 - Dichlorobenzene 1 1 0.4 2,3,7,8 - TCDD (Dioxin) 1 1 0.0005 2,4,6 - Trichlorophenol 1 1 1 2,4 - Dichlorophenol 1 1 1 2,4 - Dim ethylphenol 1 1 1 2,4 - Dinitrophenol 1 1 1 2,4 - Dinitrotoluene 1 1 0.4 2 - Chloronaphthalene 1 1 0.4 2 - Chlorophenol 1 1 1 Acenaphthene 1 1 0.1 Acrolein 1 1 2 Acrylonitrile 1 1 2 Anthracene 1 1 0.1 Antimony 1 1 1 Arsenic (total) 1 46 46 46 Benzene 1 1 0.4 Benzidine 1 1 10 Benzo(a) Anthracene 1 1 0.1 Benzo(a) Py rene 1 1 0.1

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 76**  **Exhibit A** **- 34**  **. Summary of Effluent Data (2012 -** **2014): BP Cherry Point Refinery**  **, Outfall Parameter**  **Number of Observations Summary of**  **Detected Values (μg/L)**  **Total Nondetect**  **QL (μg/L)**  **Ma ximum**  **Geometric Me**  **an Mi**  **nimum** Benzo(b) Fluoranthene 1 1 0.1 Benzo(k) Fluoranthene 1 1 0.1 Bis(2 - Chloroethyl) Ether 1 1 0.4 Bis(2 - Chloroisopropyl) Ether 1 1 0.4 Bis(2 - Ethylhexyl) Phthalate 1 1 0.4 Bromoform 1 1 0.4 But yl benzyl Phthalate 1 1 0.4 Carbon Tetrachloride 1 1 0.4 Chlorobenzene 1 1 0.4 Chloroform 1 1 0.4 Chrysene 1 1 0.1 Copper (total) 1 10 10 10 Cyanide 1 5 Dibenzo(a,h) Anthracene 1 1 Dichlorobromomethane 1 0.4 Diethyl Phthalate 1 0.4 Dim ethyl Phthalate 1 0.4 Di - n - Butyl Phthalate 1 0.4 Eth yl benzene 1 0.4 Fluoranthene 1 0.1 Fluorene 1 0.1 Hexachlorobenzene 1 1 0.4 Hexachlorobutadiene 1 1 0.4 Hexachlorocyclopentadiene 1 1 0.4 Hexachloroethane 1 1 0.4 Indeno(1,2,3 - cd) Pyrene 1 1 0.1 Isophorone 1 1 0.4 Methyl Bromide 1 1 0.4 Methylene Chloride 1 1 0.4 Nickel (total) 1 42 42 42 Nitrobenzene 1 1 0.4 N - Nitrosodimethylamine 1 1 0.4

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 77**  **Exhibit A** **- 34**  **. Summary of Effluent Data (2012 -** **2014): BP Cherry Point Refinery**  **, Outfall Parameter**  **Number of Observations Summary of**  **Detected Values (μg/L)**  **Total Nondetect**  **QL (μg/L)**  **Ma ximum**  **Geometric Me**  **an Mi**  **nimum** N - Nitrosodi - n - Propylamine 1 1 0.4 N - Nitrosodiphenylamine 1 1 0.4 Pentachlorophenol (PCP) 1 1 1 Phenol 1 1 1 Py rene 1 1 0.1 Selenium (total) 1 83 83 83 Tetrachloroethylene 1 1 0.4 Thallium (total) 1 0.5 0.5 0.5 Toluene 1 1 0.4 Trichloroethylene 1 1 0.4 Vin yl Chloride 1 1 0.4 Zinc (total) 1 55 55 55 Mercury (total) 1 0.0114 0.0114 0.0114 Source: Based on discharge monitoring reports submitted to Wa shington Department of Ecology, 2012 to 2014. QL = Quantification limit
**A. 8.3**  **Receiving Water** 

### The Strait of Georgia has been categorized b y Ecology as extraordinary marine receiving water with characteristic uses including fish, shellfish, clam, oyster, and mussel rearing, spawning, migration, and harvesting; wildlife habitat, primary contact recre ation, sport fishing, commerce and navigation, boating, and aesthetic enjoy ment. The Strait is also part of the Cherry

Point Aquatic Reserve. The BP Cherry Point facility ’s NPDES permit contains requirements pursuant to the Cherry Point Reserve Plan. Furth er, the Strait of Georgia is on the 303(d) list for benzo[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene, and chrysene concentrations in tissue (mussels) approximately 15 miles from the facility. Exhibit A
- 35 summarizes the available ambient receiving water concentrations based on data from 1999 and 2005. **Exhibit A** **- 35**  **. A mbient Receiving Water Concentrations: Strait**  **of Georgia**

**Parameter Geometric Mean Concentration (dissolved; μg/L)**  Copper 0.673 Mercury 0.001 Zinc 3.9 Source: reported in 2012 Fact Sheet for BP Cherry Point NPDES permit (Appendix I) from Ecology’s reasonable potential analysis.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 78**  **A. 8.4**  **Baseline Scenario**  

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 33 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 36 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 34 and available ambient data in Exhibit A
- 35 , there is reasonable potential to exceed human health criteria for arsenic **Exhibit A** **- 36**  **. Human Health Reasonable Potential A nalysis for BP Cherry**  **Point 1** 
**– Baseline Scenario**  **Parameter Effluent Conc.** 

**(total; μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc.**  **at Edge of**

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 46 NR 0.842 0.14 NR = not reported 1. See effluent concentrations in Exhibit A- 34 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 35

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 136. 3. Consumption of organisms only. 

### Exhibit A
- 37 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 37**  **. Human Health Based Effluent Li mitations for BP Cherry**  **Point –**  **Baseline Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total;**  **μ g/L)**  **1 Ma** **ximum Daily Effluent Limit (total;**  **μ g/L)**  **1** Arsenic 19 38 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 19 μg/L and a MDL of 38 μg/L. Arsenic was observed in the effluent at of 46 μg/L. Since the effluent monitoring data exceeds the applicable effluent limitations under the base line scenario, the discharger will need to control arsenic in its effluent to ensure that permit limits are

33 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 79**  

### consistently

met. It is possible that more recent or future monitoring data could provide evidence that the facility

is in compliance with the proje cted effluent limits and no costs would be incurred for compliance. However, additional data could provide further evidence of non
- compliance. Based on the available information, EPA assumes the discharger will need to reduce discharge concentrations for c ompliance with the baseline scenario. End
- of
-pipe treatment technologies capable of controlling arsenic include options such as chemical precipitation, microfiltration, and reverse osmosis. Given the limited nature of the information available regarding th e internal process operations at the facility, EPA has assumed the use of reverse osmosis for arsenic control. Reverse osmosis is capable of reliably controlling arsenic at levels below the limit of quantitation. Further, EPA has assumed that treatment of the entire plant flow will be necessary . This is a conservative assumption as it is possible that a detailed study of the facility’s internal process operations would result in a more targeted treatment strategy

—for instance, if onl y a single internal proc ess flow was the source of the contamination, then only the contaminated stream would require treatment. EPA estimated a reverse osmosis treatment cost for a 3.87 mgd flow at $7,054,000 per ye ar assuming an interest rate of 7 percent over 20 ye ars. **A. 8.5**  **Policy Scenario**  

### Exhibit A
- 38 summarizes the RP analysis under the policy scenario. Based on effluent concentrations in Exhibit A
- 34 and available ambient data in Exhibit A
- 35 , there is reasonable potential to exceed human health criteria for arsenic and mercury . However, ambient concentrations for mercury exceed the criteria. **Exhibit A** **- 38**  **. Human Health Reasonable Potential A nalysis for BP Cherry**  **Point 1** 
**– Policy**  **Scenario**

**Parameter Baseline** 

**A verage Monthly**  **Effluent Limit or**  **Conc. (tota l;**  **μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 19 NR 0.842 0.0059 Mercury 0.0114 0.001 0.0012 0.00088 NR = not reported 1. See effluent concentrations in Exhibit A- 34 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and avai lable ambient concentrations in Exhibit A- 35

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 136. 3. C onsumption of organisms only

. Exhibit A
- 39 summarizes the calculated permit limits for arsenic under the policy scenario.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 80**  **Exhibit A** **- 39**  **. Human Health Based Effluent Limitations for BP Cherry Point**  **– Policy**  **Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; μg/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; μg/L) 1**  Arsenic 0.81 1.6 Mercury 0.00088 0.0018 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool.
**Arsenic** 

### Under the policy

scenario, the discharger would have to meet an AML of 0.81 μg/L and a MDL of 1.6 μg/L. Under the baseline scenario, EPA estimated that the discharger would incur costs for end
- of

-pipe treatment using reverse osmosis which would likely result in an effluent quality performance at or near the limit of quantitation. However, if the facility has not yet achieved a level of performance which would result in immediate compliance with effluent limitations under the policy scenario, EPA has included costs associated with a P2 program which is likel y to result in compliance. **Me rcury**  

### Under the p olicy

scenario, the discharger would have to meet an AML of 0.00088 μg/L and a MDL of 0.0018 μg/L. The maximum effluent concentration is 0.0029 μg/L and the average effluent concentration is 0.0019 μg/L. Based on the available data, the discharger will likely need to reduce mercury

in its effluent to ensure that permit limits are consistently met. Because there are no proven end
- of
-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consistent basis, the facility would lik ely

implement a P2 program for compliance with the projected effluent limits. Annual P2 program costs for this industrial facility

are estimated to be approximately $28,000. To ensure compliance in case a P2 program would not be sufficient to meet the proj ected effluent limitations, EPA assumed that the facility

would incur costs for a variance. **A. 9**  **Cosmo Specialty Fibers**  Cosmo Specialty

Fibers (NPDES permit WA0000809) operates a paper mill that produces dissolving pulp of the acetate, viscose, and ether grades with a permitted capacity of 550 tons per day . Average flow is approximately 24 mgd, 34 

### and the facility discharges to Grays Harbor and Chehalis River.

34 Based on discharge mo nitoring reports between 2012 and 2014; average monthly flow for Outfall 1 (discharging to Grays Harbor) is 18 mgd and average monthly flow for Outfall 2 (discharging to Chehalis River) is 6 mgd.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 81**  **A. 9.1**  **Treatment Processes** 

### Primary treatment consists of an ash clarifier, a disco strainer, a Brinkley screen, and a sweet sewer settling basin. Secondary treatment consists of four aeration lagoons, two clarifiers, and disinfection. Wastewater is routed to a s ys tem of storage ponds and then discharged through Outfall 1. Stormwater, truck wash overflow, and filter plant backwash are discharged through Outfall 2. **A. 9.2**  **Effluent Data** 

### Exhibit A
- 40 summarizes 2012 to 2014 effluent monitoring data for the facility discharge monitoring reports for Outfall 1. Data are not available for Outfall 2. **Exhibit A** **- 40**  **. Summary of Effluent Data (2012**  **- 2014):**  **Cosmo Specialty Fibers ,**  **Outfall 1**  **Pollutant Number of Observations**  **Detected Values ( μg/L)**  **Total Nondetects**  **95 th**  **Percentile Me**  **dian** 2,3,7,8 - TCDD (dioxin) 14 13 0.000002 nd 1 2,4,6 - Tricholorophenol 32 32 Chloroform 32 1 28.85 19.1 Pentachlorophenol (PCP) 32 32 Source: Discharge monitoring reports, 2012 to 2014 nd = nondetect 1. Discharge monitoring report data notes various detection limits for dioxin, between 1 μ g/L and 9.3 μ g/L.
**A. 9.3**  **Receiving Water** 

### The facility

discharges to Grays Harbor (via Outfall 1), a Class B marine water, and Chehalis River (via Outfall 2), a Class A fresh water. Ambient data for these waters are not available. **A. 9.4**  **Baseline Scenario**  

### The NPDES permit for facility does not have WQBELs based on human health criteria for the pollutants of concern. Inthis case, EPA performed a reasonable potential anal ys is for e ach pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit
. 35 

### Based on the effluent concentrations in Exhibit A
- 40 , there is no reasonable potential to exceed criteria for the pollutants of concern. Therefore, there are no costs associated with achieving compliance with the baseline scenario.

35 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 82**  **A. 9.5**  **Policy Scenario** 

### Based on the effluent conc entrations in Exhibit A
- 40 , there is no reasonable potential to exceed criteria for the pollutants of concern. Therefore, there are no costs associated with achieving compliance with the policy scenario. **A. 10**  **Intalco A luminum Corporation**  Intalco Aluminum Corporation operates multiple wastewater treatment plants that combine and discharge to the Strait of Georgia. The facility produces primary aluminum metal from alumina ore using the Hall
- Heroult reduction process. Wastewater associated with the industrial process includes contact and non
- contact cooling water for metal casting and anode production, and wastewater generated from wet air pollution control systems. Additionall y, the facility

generates domestic wastewater, wastewater from steam cleaning operating systems, and some stormwater. Average flow is 3 mgd. **A. 10.1**  **Treatment Processes** 

### The 2014 permit fact sheet for the facility (p. 10) states that the facility treats wastewater from the casting process and from the wet scrubbers using primary treatment consisting of an 800 gallon receiving tank, a polymer addition system, two clarifiers, two filter feed pumps, a mud recycle tank, a vacuum pump, a vacuum filter drum, a recycle tank, a caustic addition system, and three recycle pumps 

### . Secondary treatment includes an equalization tank and two treatment trains consisting of reaction tanks and flocculation tanks that feed into a clarifier. Anode cooling water, which is contaminated with coke and pitch containing benzo(a)p yrene, is treated using a baffled settling chamber (fact sheet, p. 11). Domestic sanitary

wastewater treatment consists of inlet vault, lagoon s ys tem, outlet weir box, and ultraviolet disinfection (fact sheet, p. 11)
. **A. 10.2**  **Effluent Data** 

### Exhibit A
- 41 summarizes 2010 to 2013 effluent monitoring data for the facility from the permit fact sheet. **Exhibit A** **- 41**  **. Summary of Effluent Data (2010 to 2013): Intalco A luminum Facility** 

**Pollutant Number of**  **Observations Ma** **ximum (μg/L)**  **Av erage**  **(μg/L)** Acenaphthene 5 0.6 0.25 Anthracene 5 0.5 0.04 Antimony 9 17 3.6 Arsenic 5 50 27.4 Benzo(a) Anthracene 5 1.6 0.53 Benzo(a) Py rene 5 1.9 0.75 Benzo(k) Fluoranthene 5 0.9 0.32 Copper 6 5.2 4.0

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 83**  **Exhibit A** **- 41**  **. Summary of Effluent Data (2010 to 2013): Intalco A luminum Facility** 

**Pollutant Number of**  **Observations Ma** **ximum (μg/L)**  **Av erage**  **(μg/L)** Cyanide 2 0.7 Fluoranthene 5 3.3 1.09 Fluorene 5 0.2 0.07 Indeno(1,2,3 - cd) Pyrene 5 1.6 0.37 Mercury 6 0.0035 4 0.0025 Methylene Chloride 2 0.59 0.3 Nickel 9 90 37 Phenol 2 25 Polychlorinated Biphenyls (PCBs) 1 36 nd nd Py rene 5 2.8 0.92 Selenium 5 12 3 Thallium 5 1 0.17 Zinc 5 62 53 nd = nondetect Source: 2014 Fact Sheet, Appendix E and Table 3. 1. Data for PCBs from Ecology’s discharge mo nitoring reports; 36 observations below detection limits.
**A. 10.3**  **Receiving Water** 

### Exhibit A
- 42 summarizes the available ambient receiving water concentrations based on data from the 2014 fact sheet for the permit. **Exhibit A** **- 42**  **. A mbient Receiving Water Concentrations: Strait of Georgia**  **Pollutant Water Column Concentration (μg/L)**  **90 th**  **Percentile Av**  **erage** Chrysene 0.47 NR Copper (dissolved) NR 0.47 Indeno(1,2,3 - cd) Py rene 0.012 NR Mercury (dissolved) NR 0.00065 Selenium 0.57 NR Zinc (dissolved) NR 0.57 Source: 2014 fact sheet for the permit; 90 th percentile values are from Appendix E (reasonable potential analysis); average values based on Table 2 (from 10 samples collected upstream from Intalco discharges in July and September 1999). NR = not reported

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 84**  **A. 10.4**  **Baseline Scenario**  

### The facility

does not have WQBELs based on human health criteria for the pollutants of concern. 36 

### In this case, EPA performed a reasonable potential anal ys is for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 37 

### In cases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 43 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 41 and available ambient data in Exhibit A
- 42 , there is reasonable potential to exceed the baseline human health criteria for arsenic. **Exhibit A** **- 43**  **. Human Health Reasonable Potential A nalysis for Intalco A**  **luminum 1** 
**– Baseline Scenario**  **Parameter Effluent** 

**Conc. (μg/L) Am**  **bient Conc.**

**(μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 50.0 NR 0.6063 0.14 1. See effluent concentrations in Exhibit A- 41 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 42

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 77 for carcino gens and 105 for non - carcinogens. 3. Consumption of organisms only. 

### Exhibit A
- 44 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 44**  **. Human Health Based Effluent Limitations for Intalco A**  **luminum –**  **Baseline Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; μg/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; μg/L) 1**  

### Arsenic 11 22 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. **Arsenic** 

### Under the baseline scenario, the discharger would have to meet an AML of 1 1 μg/L and a MDL of 22 μg/L. Arsenic was observed in the effluent at a concentration of 50 μg/L. Since the effluent monitoring data exceed the applicable effluent limitations under the baseline scenario, the discharger will need to control arsenic in its effluent to ensure that permit limits

36 There are technology
-based limits for benzo(a)pyrene, antimony, and nickel. 37 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable po tential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 85**  

### are consistentl y met. It is possible that more recent or future monitoring data could provide evidence that the facility

is in compliance with the projected effluent limits and no costs would be incurred for compliance. However, additional data could provide further evidence of noncompliance. Based on the available information, EPA assumes the discharger will need to reduce discharge concentrations for compliance with the baseline scenario. End
- of
-pipe treatment technologies capable of controlling arsenic include options such as chemical precipitation, microfiltration, and reverse osmosis. Given the limited nature of the information available regarding the internal process operations at the f acility , EPA has assumed the use of reverse osmosis for arsenic control. Reverse osmosis is capable of reliably controlling arsenic at levels below the limit of quantitation. Further, EPA has assumed that treatment of the entire plant flow will be necessary. This is a conservative assumption as it is possible that a detailed study of the facility’s internal process operations would result in a more targeted treatment strategy

—for instance, if onl y a single internal process flow was the source of the contamination, then only the contaminated stream would require treatment. EPA estimated a reverse osmosis treatment cost for a 3.0 mgd flow at $ 5 , 907 ,000 per ye ar assuming an interest rate of 7 percent over 20 ye ars. **A. 10.5**  **Policy Scenario** 

### Based on effluent concentratio ns in Exhibit A
- 41 and available ambient data in Exhibit A
- 42 , there is reasonable potential to exceed human health criteria for the pollutants shown in Exhibit A
- 45
. **Exhibit A** **- 45**  **. Human Health Reasonable Potential A nalysis for Intalco A**  **luminum 1** 
**– Policy**  **Scenario**
**Parameter Baseline** 

**A verage**  **Monthly Effluent Limit**  **(μg/L) Am**  **bient Conc.**

**(μg/L) Conc. at Ed**  **ge of**

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 11.0 NR 0.6063 0.0059 1. See effluent concentrations in Exhibit A- 41 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 42

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 77 for carcinogens and 105 for non - carcinogens. 3. C onsumption of organisms only

. 

### Exhibit A
- 46 summarizes the calculated permit limits for arsenic under the policy scenario. **Exhibit A** **- 46**  **. Human Health Based Effluent Limitations for Intalco A**  **luminum –**  **Policy Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; μg/L)**  **1 Ma** **ximum Daily Effluent Limit (total; μg/L)**  **1** Arsenic 0.46 0.92 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 86**  

### Under the policy

scenario, the discharger would have to meet an AML of 0 .46 μg/L and a MDL of 0. 92 μg/L. Under the baseline scenario, EPA assumed that end
- of
- pipe treatment (i.e., reverse osmosis) would be necessary to meet effluent limitations. Since reve rse osmosis is capable of treating the effluent to levels below the QL on a regular basis and further treatment below the QL is infeasible, EPA estimated that the discharger would incur costs for a P2 program to assist in ensuring compliance
. **A. 11**  **Quincy**

**Indust rial Wastewater Treatment Facility**  The City of Quincy

owns an industrial wastewater treatment facility (NPDES permit number WA0021067) that treats process wastewater from a potato and vegetable processor (ConAgra Foods and Quincy

Foods, respectivel y). The facility discharges to a U.S. Bureau of Reclamation wasteway
. 38



### . Eco logy has developed a proposed NPDES permit which contains requirements to develop a special study and reapplication to direct the discharge to a new location. The average flow is 1.5 mgd. **A. 11.1**  **Tr eatment Processes**  

### The fact sheet for the 2012 NPDES permit for the facility lists primary

and secondary treatment processes consisting of primary settling, anaerobic digestion, sequencing batch reactors, disinfection, summer season cooling, and re
- aeration
. **A. 11.2**  **Effluent Data** 

### Effluent monitoring data for the pollutants of interest are not available for this facility
. Ecology has determined that the discharge is not likely to contain any

pollutants addressed b y the proposed human health criteria. **A. 11.3**  **Receiving Wate r**  

### Quincy Industrial discharges treated process wastewater to the U.S. Bureau of Reclamation wasteway DW237. The wasteway

joins with other wasteways and eventually discharges to Potholes Reservoir. The entire water s ys tem is part of the federal Columbia Bas in Irrigation Project. According to the 2012 fact sheet for the NPDES permit (p. 25), Potholes Reservoir, downstream of the discharge point, is impaired for dieldrin, 2,3,7,8
- TCDD, 4
- 4
- DDE, and PCB. Another downstream waterbody, Frenchman Hills Waterway, i s impaired for temperature and pH. Ecology finds that the travel distance from the facility’s discharge to these impairments is large and the influence of the discharge is negligible.

38 A wa steway drain is a manmade part of an irrigation project that receives excess water from irrigated lands and field underdrain systems. This wasteway system is part of the Columbia Basin Irrigation Project that brings water from the Columbia River to 500,000 acres in central Washington (2012 fact sheet, page 12).

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 87**  **A. 11.4**  **Baseline Scenario** 

### The NPDES permit for the facility does not have WQBEL s based on human health criteria for the pollutants of concern. Due to the lack of available monitoring data, EPA could not evaluate reasonable potential and compliance costs for the facility under the baseline scenario. **A. 11.5**  **Policy Scenario** 

### Due to the lack of available monitoring data, EPA could not determine reasonable potential and estimate compliance costs under the policy scenario. **A. 12**  **Steelscape Inc.** Steelscape, Inc., located in Kalama, Washington, is an industrial facility (NPDES permit WA0040851 ) for the cold rolling and coating of steel strip. The facility is composed of four primary production lines: Pickle Line, Cold Rolling Mill, Metallic (zinc) Coating Line, and Coil Paint Line. **A. 12.1**  **Treatment Processes** 

### The facility

has two distinct wastewater treatment systems: one for treating “oily waste” from all process waters that are potentially contaminated with oil or grease, and the other for treating “metal waste.” Domestic waste is treated by the Port of Kalama Municipal Wastewater Treatment System. The oil waste s ys tem treats wastewater from the Cold Roll Mill, Metallic Coating, and Coil Paint lines, using collection and blending, oil water separation, holding s ys tems, and feeding systems for hydrochloric acid, de
- emulsifier, coagulant, and poly mer. The metal waste system treats waste streams from the Pickle line, Metallic Coating line, Coil Paint line, and other auxiliary waste water from the facility (e.g., demineralizer regenerant waste, cooling tower blowdowns, and clear effluent from the oily waste s ystem). The metal wastewater is chemically reduced, neutralized, oxidized, coagulated, precipitated, clarified, filtered, and dewatered (2010 fact sheet for the permit, p. 7). **A. 12.2**  **Effluent Data** 

### Exhibit A
- 47 summarizes available effluent monitoring data for the facility for 2012 through 2014. Concentration
-based effluent monitoring data were not available for the reasonable potential anal ys is. **Exhibit A** **- 47**  **. Summary of Effluent Data (2012 to 2014): Steelscape Inc. Pollutant**  **Number of**

**Observations Quantified Values** 

**Ma ximum**  **Av erage**  **Units** Arsenic (total) 32 7 1.34 kg/day Copper (total) 32 0.004 0.0011 kg/day Cyanide 32 0.004 0.00032 kg/day Nickel (total) 32 0.005 0.0016 kg/day

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 88**  **Exhibit A** **- 47**  **. Summary of Effluent Data (2012 to 2014): Steelscape Inc. Pollutant**  **Number of**

**Observations Quantified Values**  Zinc (total) 32 0.024 0.0019 kg/day Source: B ased on discharge monitoring reports submitted to Ecology.
**A. 12.3**  **Receiving Water** 

### The facility

discharges to the Columbia River through a submerged outfall that is shared with the Port of Kalama Municipal Wastewater Treatment Plant. Exhibit A
- 48 summarizes the available ambient receiving water concentrations. **Exhibit A** **- 48**  **. Am**  **bient Receiving Water Concentrations: Columbia River**

**Pollut ant**  **Water Column Concentration (μg/L) 90**  **th Percentile**  **Geometric Mean** Arsenic (dissolved) 1.53 0.879 Copper (dissolved) 1.29 0.741 Nickel (dissolved) 0.842 0.4839 Zinc (dissolved) 2.76 1.5862 Source: 2010 Fact Sheet (Table 23).
**A. 12.4**  **Baseline Scenario** 

### The NPDES permit for the facility does not have WQBEL s based on human health criteria for the pollutants of concern. Due to the lack of available concentration
-based effluent monitoring data, EPA could not evaluate reasonable potential and compliance costs for the facility under the baseline scenario
. **A. 12.5**  **Policy Scenario** 

### Due to the lack of available concentration
-based effluent monitoring data, EPA could not determine reasonable potential and estimate compliance costs under the policy scenario. **A. 13**  **Sonoco Products** Sonoco Products (NPDES permit WA0000884) is a recycled paperboard manufacturing facility in Sumner Washington, producing an average of 138 tons of paperboard per day from recycled materials (based on data between 2007 and 2012). The facility discharges to the White River. Average flow is 0.14 mgd. **A. 13.1**  **Treatment Processes** 

### The 2013 permit fact sheet indicates that the current treatment consists of primary clarification, activated sludge aeration, and secondary clarification.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 89**  **A. 13.2**  **Effluent Data** 

### The fact sheet for the 2013 NPDES permit states that the effluent contains some heavy metals. Exhibit A
- 49 summarizes available effluent monitoring data for the facility from the 2013 permit fact sheet and a 2014 inspection report from Ecology
. **Exhibit A** **- 49**  **. Summary of Effluent Data (2012 -** **2014): Sonoco Products Pollutant**  **Number of Observations Concentration (total recoverable; μg/L)**  Antimony 1 1.18 Arsenic 1 2.16 Copper1 12 5.56 - 28.6 Mercury 1 0.007 Nickel 1 3.04 Selenium 2 2 0.82 - 10 Thallium 1 nondetect Zinc 3 2 28.6 - 40 Source: 2013 fact sheet for the permit and 2014 inspection report. 1. The 2013 fact sheet reports a maximum copper concentration of 28.6 out of 12 samples; the 2014 inspection report has 5.56 ug/L. 2. The 2013 fact sheet reports a concentration of 10 ug/L for selenium; the 2014 insp ection report has 0.82 ug/L. 3. The 2013 fact sheet reports a concentration of 40 ug/L for zinc; the 2014 inspection report has 28.6 ug/L.
**A. 13.3**  **Receiving Water** 

### The facility

discharges to the White River, which has designated uses of salmonid spawning, rearin g and migration, habitat, and primary contact recreation. Exhibit A
- 50 summarizes the available ambient receiving water concentrations based on data reported in the 2 013 permit fact sheet. **Exhibit A** **- 50**  **. A mbient Receiving Water Concentrations: White River** 

**Pollutant Water Column Concentration (total recoverable; μg/L)**  Copper 1.94 Zinc 1.91 Source: 2013 fact sheet for the permit (Table 2); average of 8 samples.
**A. 13.4**  **Baseline Scenario**  

### The NPDES permit for facility does not have WQBELs based on human health criteria for the pollutants of concern. 39 

### Inthis case, EPA performed a reasonable potential anal ys is for

39 The facility has discharge limitations for sel enium and copper; however, these limitations are based on aquatic life rather than human health. All organic toxics have technology
- based limitations of nondetect.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 90**  

### each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 40 

### In cases of reasonable potential, EPA cal culated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 51 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 49 and available ambient data in Exhibit A
- 50 , there is reasonable potential to exceed the human health arsenic criterion. **Exhibit A** **- 51**  **. Human Health Reasonable Potential A nalysis for Sonoco Products**  **1**
**– Baselin**  **e Scenario Parameter**  **Effluent Conc.**

**(total; μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 2.16 NR 0.0414 0.0045 NR = not reported 1. See effluent concentrations in Exhibit A- 49 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the ge om etric mean) and available ambient concentrations in Exhibit A- 50

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution fa ctor of 130. 3. Consumption of water and organisms. Exhibit A
- 52 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 52**  **. Human Health Based Effluent Limitations for Son oco Products**  **– Baseline Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; μg/L)**  **1 Ma** **ximum Daily Effluent Limit (total; μg/L)**  **1** Arsenic 2.3 4.7 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 2.3 μg/L and a MDL of 4.7 μg/L. Effluent arsenic was observed at an average concentration of 2.16 μg/L. Since the effluent monitoring data are less than the effluent limitations under the baseline scenario, EPA anticipates that immediate compliance with effluent limitations under the baseline scenario will be feasible, and that no compliance activities are necessary
.

40 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by E cology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 91**  **A. 13.5**  **Policy Scenario** 

### Exhibit A
- 53 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 49 and available ambient data in Exhibit A
- 50 , there is reasonable potential to exceed the human health arsenic criterion. **Exhibit A** **- 53**  **. Human Health Reasonable Potential A nalysis for Sonoco Products**  **1**
**– Policy**  **Scenario Parameter**  **Effluent Conc.**

**(total; μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **C riterion**  **3 (μg/L)**  Arsenic 2.16 NR 0.0414 0.0045 NR = not reported 1. See effluent concentrations in Exhibit A- 49 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 50

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 130. 3. Consumption of water a nd organisms. Exhibit A
- 54 summarizes the calculated permit limits for arsenic under the policy scenario. **Exhibit A** **- 54**  **. Human Health Based Effluent Limitations for Sonoco Products**  **– Policy**  **Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; μg/L) 1**  **Ma ximum Daily Effluent Limit (total;**  **μg/L) 1**  Arsenic 0.59 1.2 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the policy

scenario, the discharger would have to meet an AML of 0.59 μg/L and a MDL of 1.2 μg/L. Effluent arsenic was observed at an average concentration of 2.16 μg/L. Since this value exceeds the applicable effluent limitations under the policy sc enario, the discharger will need to control arsenic in its effluent to ensure that permit limits are consistently

met. It is possible that more recent or future monitoring data could provide evidence that the facility

is in compliance with the projected ef fluent limits and no costs would be incurred for compliance. However, additional data could provide further evidence of non
- compliance. Based on the available information, EPA assumes the discharger will need to reduce discharge concentrations for compliance with the policy scenario. End
- of
-pipe treatment technologies capable of controlling arsenic include options such as chemical precipitation, microfiltration, and reverse osmosis. Given the limited nature of the information available regarding the internal process operations at the facility , EPA has assumed the use of reverse osmosis for arsenic control. Reverse osmosis is capable of reliably controlling arsenic at levels below the limit of quantitation. Further, EPA has assumed that treatment of the entire plant flow will be necessary . This is a conservative assumption as it is possible that a detailed study of the facility’s internal process operations

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 92**  

### would result in a more targeted treatment strategy

—for instance, if onl y a single internal process flow was the source of the contamination, then only the contaminated stream would require treatment. EPA estimated a reverse osmosis treatment cost for a 0.14 mgd flow at $2,136,000 per ye ar assuming an interest rate of 7 percent over 20 ye ars. **A. 14**  **Tesoro Refining and Marketing LLC**  **- An**  **acortes** Tesoro Refining and Marketing LLC operates a wastewater treatment plant (NPDES permit WA0000761) that discharges to Fidalgo Bay in northwestern Washington. The refinery processes crude oil from Alaska’s Northern Slope, Canada, and the Bakken Shale Reserves of Montana and North Dakota. The wastewater treatment plant treats process water, sanitary wastewater, stormwater, and ballast water. The permit also authorizes the treatment of wastewater from an onsite crude railcar offloading facility . Average flow is 2.8 mgd. During extremely

heavy rainfall events, Tesoro may also discharge water from a retention pond that would consist almost entirely of stormwater, but may

contain small amounts of oily wastewater. Tesoro has increased th e volume of the retention pond and no discharges have occurred since December 1996. **A. 14.1**  **Treatment Processes** 

### The 2013 draft fact sheet for the permit states that the facility uses primary

and secondary treatment for process wastewater and contaminated stormwater. This s ys tem consists of API oil/water separators, primary clarifiers, activated sludge units, secondary clarifiers, and holding ponds. Sanitary

wastewater is treated with a septic tank and a neutralization pit. **A. 14.2**  **Effluent Data** 

### Exhibit A
- 55 summarizes the effluent data for the treated wastewater for the pollutants of concern for which data are available, based on Ecology ’s reasonable potential anal ys is (Appendix H in the 2013 draft permit fact sheet). **Exhibit A** **- 55**  **. Summary of Effluent Data: Tesoro Refinery**  **, Outfall 1**

**Pollutant Number of**  **Observations Quantification**  **Limit (μg/L) Summary of Detected**  **Values (μg/L) 1**  **Total Nondetect**  **Ma ximum**  **Av erage**  1,1 - Dichloroethylene 4 4 0.2 1,2 - Dichlorobenzene 1 1 2 1,2 - Dichloroethane 4 4 0.1 1,2 - Dichloropropane 4 4 0.4 1,2 - Diphenylhydrazine 4 4 0.5 1,3 - Dichlorobenzene 1 1 2 1,4 - Dichlorobenzene 1 1 2 2,4 - Dichlorophenol 4 4 1 2,4 - Dim ethylphenol 1 1 2

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 93**  **Exhibit A** **- 55**  **. Summary of Effluent Data: Tesoro Refinery**  **, Outfall 1**

**Pollutant Number of**  **Observations Quantification**  **Limit (μg/L) Summary of Detected**  **Values (μg/L) 1**  **Total Nondetect**  **Ma ximum**  **Av erage**  2,4 - Dinitrophenol 4 4 1 2,4 - Dinitrotoluene 4 4 0.1 2 - Chloronaphthalene 1 1 2 3,3' - Dichlorobenzidine 1 1 2 Anthracene 1 1 2 Antimony 2 1.4 Arsenic 1 5.33 5.33 Benzene 4 44.9 Benzidine 1 1 2 Benzo(a) anthracene 1 1 2 Benzo(a) pyrene 1 1 2 Benzo(b) Ffuoranthene 1 1 2 Benzo(k) fluoranthene 1 1 2 Bis(2 - chloroethyl) ether 1 1 2 Bis(2 - ethy lhex yl) phthalate 1 1 1 Bromoform 4 0.6 But yl benzyl phthalate 1 1 2 Carbon tetrachloride 4 4 0.4 Chlordane 4 4 0.1 Chlorobenzene 4 4 0.4 Chlorodibromomethane 4 1.9 Chloroform 4 13.7 Chrysene 4 4 2 Copper 4 7 5.01 Cyanide 4 15 7.0 Dibenzo(a,h) anthracene 1 1 2 Dichlorobromomethane 1 2.4 Diethyl phthalate 4 4 Dim ethyl phthalate 1 1 2 Di - n - but yl phthalate 4 4 0.5 Endosulfan sulfate 4 4 0.1 Endrin 4 4 0.1 Endrin aldehyde 4 4 0.1

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 94**  **Exhibit A** **- 55**  **. Summary of Effluent Data: Tesoro Refinery**  **, Outfall 1**

**Pollutant Number of**  **Observations Quantification**  **Limit (μg/L) Summary of Detected**  **Values (μg/L) 1**  **Total Nondetect**  **Ma ximum**  **Av erage**  Eth yl benzene 4 4 0.4 Fluoranthene 4 4 0.5 Fluorene 4 4 0.5 Hexachlorobutadiene 4 4 0.5 Hexachlorocyclopentadiene 4 4 0.5 Hexachloroethane 4 4 0.5 Indeno(1,2,3 - cd) py rene 1 1 0.1 Isophorone 4 4 0.5 Mercury2 35 0.44 0.069 Methyl bromide 4 4 0.4 Methylene chloride 4 0.6 Nickel 4 7 5.33 Nitrobenzene 4 4 0.5 N - Nitrosodimethylamine 1 1 0.2 N - Nitrosodi - n - propylamine 1 1 0.2 N - Nitrosodiphenylamine 1 1 0.2 Pentachlorophenol (PCP) 4 4 0.5 Phenol 52 2 0.009 Py rene 4 0.8 Selenium 4 21 Tetrachloroethylene 4 4 0.6 Thallium 4 4 1 Toluene 4 8.2 Toxaphene 4 4 0.5 Trichloroethylene 4 4 0.4 Vin yl chloride 4 4 0.4 Zinc 4 66 66 Source: 2013 draft permit fact sheet (Appendix H and Table 2); based on the 2010 permit application and annual priority pollutant scans (years not specified). 1. Metal concentrations are total recoverable. 2. Data for mercury

is from 2012 to 2014 discharge monitoring reports.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 95**  **A. 14.3**  **Receiving Water** 

### Tesoro discharges to Fidalgo Bay , which Ecology has designated as an extraordinary marine receiving water. Exhibit A
- 56 summarizes the available ambient receiving water concentrations based on data in the permit fact sheet for 1998 through 2005. **Exhibit A** **- 56**  **. A mbient Receiving Water Concentrations: Fidalgo Bay**  **1 Pollutant**  **Geometric Mean Concentration (μg/L) Concentration at 90**  **th Percentile**  **Temperature (μg/L)** Arsenic 1.15 NR Copper 0.512 0.673 Nickel 0.522 NR Selenium 0.0713 NR Zinc 1.26 3.9 Mercury 0.0007 0.001 Source: 2013 Draft Fact Sheet Table 3 and Appendix H (reasonable potential analysis). NR = not reported 1. Metal concentrations are dissolved.
**A. 14.4**  **Baseline Scenario** 

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould h ave been included in the NPDES permit. 41 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 57 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 55 and available ambient data in Exhibit A
- 56 , there is reasonable potential to exceed the baseline human health arsenic criterion. **Exhibit A** **- 57**  **. Human Health Reasonable Potential A nalysis for Tesoro Facility**  **1**
**– Baseline Scenario**  **Parameter Effluent Conc.** 

**(total; μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 5.33 1.15 13.3 0.14

41 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 96**  **Exhibit A** **- 57**  **. Human Health Reasonable Potential A nalysis for Tesoro Facility**  **1**
**– Baseline Scenario**  **Parameter Effluent Conc.** 

**(total; μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** 1. See effluent concentrations in Exhibit A- 55 (reasonable potential analysis uses the maximum or 95th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 56

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using end - of- pipe lim itations

. 3. Consumption of organism s only. 

### Exhibit A
- 5 8 summarizes the calculated permit limits for arsenic and mercury under the baseline scenario. **Exhibit A** **- 5**  **8 . Human Health Based Effluent**  **Limitations for Tesoro Facility –**  **Baseline Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total;**  **μ g/L)**  **1 Ma** **ximum Daily Effluent Limit (total;**  **μ g/L)**  **1** Arsenic 0.14 0.28 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 0.14 μg/L and a MDL of 0.28 μg/L. According to the draft 2013 Fact Sheet for the facility , arsenic was observed in the effluent with a long
- term average concentration of 5.3 μg/L. Since this value exceeds the applicable effluent limitations under the baseline scenario, the discharger will need to control arsenic in its effluent to ensure that permit limits are consistently met. It is possible that more recent or fut ure monitoring data could provide evidence that the facility is in compliance with the projected effluent limits and no costs would be incurred for compliance. However, additional data could provide further evidence of non
- compliance. Based on the availabl e information, EPA assumes the discharger will need to reduce discharge concentrations for compliance with the baseline scenario. Crude petroleum is an important source of metals at petroleum refining and processing facilities, including arsenic. Metals found in crude petroleum, and their concentrations, depend on the origin of the crude oil. Other sources include arsenic contaminated process equipment and other manufacturing inputs (i.e., spent catal ys t). A P2 program that identifies likely sources of arsenic in the facility ’s waste stream can provide adequate levels of control through updated source control and P2 best management practices. Costs for designing and implementing a P2 program for arsenic is estimated to be $28,000 per ye ar. However, if the facility determines that source water derived from ground water, surface waters, or drinking water is the source of high arsenic values in the wastewater, or if it is determined that control of arsenic in the discharge is infeasible (e.g., due to the economi c impacts of controlling the pollutant) it is likely

that the facility

would pursue a variance.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 97**  

### Due to the fact that ambient receiving water concentrations exceed the proposed human health criteria, the discharger may pursue obtaining a water quality standards variance. The one - time cost associated with pursuing a variance is estimated to be $180,000 , with minimal costs associated with renewal. **A. 14.5**  **Policy Scenario** 

### Exhibit A
- 59 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent c oncentrations in Exhibit A
- 55 and available ambient data in Exhibit A
- 56 , there is reasonable potential to exceed the human health a rsenic and mercury

criteria. **Exhibit A** **- 59**  **. Human Health Reasonable Potential A nalysis for Tesoro Facility**  **1**
**– Policy**  **Scenario**
**Parameter Baseline A**  **verage Monthly Effluent**  **Limit or**  **Conc. (total ;**  **μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0.14 1.15 13.3 0.0059 Mercury 0. 44 0.0007 0.069 0.017 1. See effluent concentrations in Exhibit A- 55 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 56

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 93 for arsenic and 91 for merc ury . 3. Consumption of organisms only. Exhibit A
- 60 summarizes the calculated permit limits for arsenic and mercury under the policy scenario. **Exhibit A** **- 60**  **. Human Health Based Effluent Limitatio ns for Tesoro Facility**  **– Policy**  **Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.0059 0.012 Mercury 0.017 0.042 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. **Arsenic** 

### Under the policy

scenario, the discharger would have to meet an AML of 0.0059 μg/L and a MDL of 0.12 μg/L. Under the policy scenario, where the projected effluent limitations are below the anal ytical QL, EPA estimated that the discharger would incur costs for P2 as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL. Since the proj ected effluent limitations under the policy scenario are also below the QL, no additional compliance strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance).

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 98**  **Me rcury**  

### Under the policy

scenario, the discharger would have to meet an AML of 0.017 μg/L and a MDL of 0.042 μg/L. The average effluent concentration is 0.069 μg/L and the maximum effluent concentration is 0.44 μg/L. The average ambient mercury concentration is 0.0007 μg/L. Based on the available data, the discharger will likely need to reduce mercury

in its effluent to ensure that permit limits are consistently met. Fidalgo Bay is not listed on the State’s 303(d) list for mercury
. Because there are no proven end
- of
-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consistent basis, the facility would likely

implement a P2 program for compliance with the projected effluent limits. Annual P2 program costs for this industrial facility

are estimated to be approximately $28,000. **A. 15**  **TransA lta Centralia Generating Station**  The TransAlta Centralia Generating Station (NPDES permit WA0001546) is a coal
- fired power plant with two 702.5 Megawatt turbine units as well as a 250 Megawatt natural gas power plant on the same site. The facility generates process wastewater, stormwater runoff, and sanitary

effluent, as well as sanitary effluent from the adjacent TransAlta Centralia Mining facility . Average flow for the facility is 3.57 mgd. **A. 15.1**  **Treatment Processes** 

### The fact sheet for the facil ity ’s 2010 NPDES permit lists current treatment processes as an oil skimmer pond and two effluent detention ponds. Sanitary effluent from the facility , TransAlta Centralia Mining, and the Big Hanaford Project is treated using an activated sludge process. **A. 15.2**  **E ffluent Data**  

### Exhibit A
- 61 summarizes the results of a 2008 priority pollutant scan, from the 2010 fact sheet for the permit (Appendix C). **Exhibit A** **- 61**  **. Summary of Effluent Data (2008): Transalta Centralia Generation, Outfall 1** 

**Pollutant Number of Observations**  **Quantitation Level**  **(μg/L) Detected Value** 

**(μg/L) 1**  **Total Nondetect**  1,1,2,2 - Tetrachloroethane 1 1 1 1,1,2 - Trichloroethane 1 1 1 1,1 - Dichloroethylene 1 1 1 1,2,4 - Trichlorobenzene 1 1 2.5 1,2 - Dichlorobenzene 1 1 2.5 1,2 - Dichloroethane 1 1 1 1,2 - Dichloropropane 1 1 1 1,3 - Dichlorobenzene 1 1 2.5 1,4 - Dichlorobenzene 1 1 2.5

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 99**  **Exhibit A** **- 61**  **. Summary of Effluent Data (2008): Transalta Centralia Generation, Outfall 1** 

**Pollutant Number of Observations**  **Quantitation Level**  **(μg/L) Detected Value** 

**(μg/L) 1**  **Total Nondetect**  2,4,6 - Trichlorophenol 1 1 2.5 2,4 - Dichlorophenol 1 1 2.5 2,4 - Dinitrophenol 1 1 10 2,4 - Dinitrotoluene 1 1 2.5 2 - Chloronaphthalene 1 1 2.5 2 - Chlorophenol 1 1 2.5 3,3' - Dichlorobenzidine 1 1 20 4,4' - DDD 1 1 0.01 4,4' - DDE 1 1 0.01 4,4' - DDT 1 1 0.01 Acenaphthene 1 1 1 Acrolein 1 1 10 Acrylonitrile 1 1 10 Aldrin 1 1 0.01 alpha - BHC 1 1 0.01 Anthracene 1 1 1 Antimony 1 0.21 2 Arsenic 1 0.24 5 Benzene 1 1 1 Benzidine 1 1 20 Benzo(a) anthracene 1 1 1 Benzo(a) pyrene 1 1 1 Benzo(k) fluoranthene 1 1 1 beta - BHC 1 1 0.01 Bis(2 - chloroethyl) ether 1 1 2.5 Bis(2 - chloroisopropyl) ether 1 1 2.5 Bis(2 - ethy lhex yl) phthalate 1 1 2.5 Bromoform 1 1 1 But yl benzyl phthalate 1 1 2.5 Carbon tetrachloride 1 1 1 Chlorobenzene 1 1 1 Chlorodibromomethane 1 1 1 Chloroform 1 1 1 Chrysene 1 1 1

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 100**  **Exhibit A** **- 61**  **. Summary of Effluent Data (2008): Transalta Centralia Generation, Outfall 1** 

**Pollutant Number of Observations**  **Quantitation Level**  **(μg/L) Detected Value** 

**(μg/L) 1**  **Total Nondetect**  Copper 1 0.18 2 Dibenzo(a,h) anthracene 1 1 1 Dichlorobromomethane 1 1 1 Dieldrin 1 1 0.01 Diethyl phthalate 1 1 2.5 Dim ethyl phthalate 1 1 2.5 Di - n - but yl phthalate 1 1 2.5 Endosulfan sulfate 1 1 0.01 Endrin 1 1 0.01 Endrin aldehyde 1 1 0.01 Eth yl benzene 1 1 1 Fluoranthene 1 1 1 Fluorene 1 1 1 Heptachlor 1 1 0.01 Heptachlor epoxide 1 1 0.01 Hexachlorobenzene 1 1 2.5 Hexachlorobutadiene 1 1 2.5 Hexachlorocyclohexane (gamma - BHC; lindane) 1 1 0.01 Hexachlorocyclopentadiene 1 1 2.5 Hexachloroethane 1 1 2.5 Indeno(1,2,3 - cd) py rene 1 1 1 Isophorone 1 1 2.5 Methyl bromide 1 1 1 Methylene chloride 1 1 1 Nickel 1 0.14 1 Nitrobenzene 1 1 2.5 N - Nitrosodi - n - propylamine 1 1 2.5 Pentachlorophenol (PCP) 1 1 10 Phenol 1 1 2.5 Polychlorinated biphenyls (PCBs) 1 1 0.1 Py rene 1 1 1 Selenium 2 1 0.39 3

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 101**  **Exhibit A** **- 61**  **. Summary of Effluent Data (2008): Transalta Centralia Generation, Outfall 1** 

**Pollutant Number of Observations**  **Quantitation Level**  **(μg/L) Detected Value** 

**(μg/L) 1**  **Total Nondetect**  Tetrachloroethylene 1 1 1 Thallium 1 1 0.28 Toluene 1 1 1 Toxaphene 1 1 1 Trichloroethylene 1 1 1 Vin yl chloride 1 1 1 Zinc 1 0.33 1 Source: 2010 Fact Sheet, Appendix C. 1. Metal concentrations are total recoverable. 2. Appendix C, Table 2 lists the selenium detected value as 3 ug/L; however Ecology used a maximum value of 80 ug/L in the reasonable potential analysis (Appendix C Table 3).
**A. 15.3**  **Receiving Water** 

### The facility

discharges to Hanaford Creek. Ambient water quality data are not available for this receiving water. **A. 15.4**  **Baseline Scenario** 

### The NPDES permit for facility does not have WQBELs based on human health criteria for the pollutants of concern. 42 

### Inthis case, EPA performed a reasonable potential anal ys is for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 43 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 62 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 61 , there is reasonable potential to exceed human health criteria for arsenic.

42 The facility has discharge limitations for selenium and copper; however, these limitations are based on aquatic life rather than human health criteria. All organic toxics have technology
-based limitations of nondetect. 43 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 102**  **Exhibit A** **- 62**  **. Human Health Reasonable Potential A nalysis for Transalta Centralia**  **Generation 1** 
**– Baseline Scenario**  **Parameter Effluent Conc.** 

**(total; μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 5.0 NR 12.448 0.018 NR = not reported 1. See effluent concentrations in Exhibit A- 61 (reasonable potential analysis uses the maximum or 95th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean). 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 1. 3. Consumption of water and organisms. 

### Exhibit A
- 63 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 63**  **. Human Health Based Effluent Limitations for Transalta Centralia**  **Generation –**  **Baseline Scenario Parameter**  **Av erage Monthly Effluent Limit (total;**  **μ g/L)**  **1 Ma** **ximum Daily Effluent Limit (total; μ**  **g/L) 1**  Arsenic 0.018 0.036 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario , the discharger would have to meet an AML of 0.0 18 μg/L and a MDL of 0.0 36 μg/L. Arsenic was observed in the effluent at of 5 μg/L. No ambient data are available and Hanaford Creek near the discharge is not listed on the State’s 303(d) list as impaired for arsenic. Since the effluent monitoring data exceeds the applicable effluent limitations under the baseline scenario, the discharger will need to control arsenic in its effluent to ensure that permit limits are consistently met. It is possible that more recent or future monitoring data could provide evidence that the facility is in compliance with the projected effluent limits and no costs would be incur red for compliance. However, additional data could provide further evidence of non
- compliance. Based on the available information, EPA assumes the discharger will need to reduce discharge concentrations for compliance with the baseline scenario. A P2 program is a possible pathway to achieve compliance with effluent limitations for arsenic. A P2 program that identifies likely sources of arsenic in the facility’s waste stream can provide adequate levels of control through updated source control and P2 best management practices. Costs for designing and implementing a P2 program for arsenic is estimated to be $28,000 per year. However, if the facility determines that source water derived from ground water, surface waters, or drinking water is the source of high arsenic values in the wastewater, or if it is determined that control of arsenic in the discharge is infeasible (e.g., due to the economic impacts of controlling the pollutant) it is likely that the facility would pursue a variance.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 103**  

### Due to the fact that ambient receiving water concentrations exceed the proposed human health criteria, the discharger may pursue obtaining a water quality standards variance. The one - time cost associated with pursuing a variance is estimated to be $180,000, with minimal costs associated with renewal. **A. 15.5**  **Policy Scenario** 

### Exhibit A
- 64 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 61 , there is reasonable potential to exceed human health criteria for antimony , arsenic, and selenium. **Exhibit A** **- 64**  **. Human Health Reasonable Potential A nalysis for Transalta Centralia**  **Generation 1** 
**– Policy Scenario**  **Parameter Baseline A**  **verage M**  **onthly Effluent Limit or**  **Conc. (total; μg/L) Am**  **bient Conc. (dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg /L)**  **Human Health**

**Criterion 3**  **(μg/L)** Antimony 2.0 NR 4.98 2.49 Arsenic 0.018 NR 12.448 0.0045 Selenium 80.0 NR 199.16 24.69 NR = not reported 1. See effluent concentrations in Exhibit A- 61 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean). 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 1. 3. Consumption of water and organisms. 

### Exhibit A
- 65 summarizes the calculated permit limits for antimony and arsenic under the policy scenario. For this anal ys is, EPA did not consider limitations for selenium further since under the policy

scenario the discharger would face more stringent limitations established on the basis of aquatic life criteria. **Exhibit A** **- 65**  **. Human Health Based Effluent Limitations for Transalta Centralia Generation**  **– Policy Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; ug/L)**  **1 Ma** **ximum Daily Effluent Limit (total; ug/L)**  **1** Antimony 2.5 5.0 Arsenic 0.0045 0.0091 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. **An timony**  

### Under the policy

scenario, the discharger would have to meet an AML of 2.5 μg/L and a MDL of 5.0 μg/L. Based on the available effluent data , the facility will be capable of immediate compliance with antimony effluent limitations under the policy scenario.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 104**  

### Therefore, EPA estimates there will be no compliance cost associated with effluent limitations. **Arsenic** 

### Under the policy

scenario, the disch arger would have to meet an AML of 0.00 45 μg/L and a MDL of 0.00 91 μg/L. Under the baseline scenario, where the projected effluent limitations are below the anal ytical QL , EPA estimated that the discharger would incur costs for P2 as well as pursuit of a v ariance in order to ensure compliance with effluent limitations below the QL . Since the projected effluent limitations under the policy scenario are also below the QL, no additional compliance strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **A. 16**  **TransA lta Centralia Mining**  TransAlta Centralia Mining (NPDES permit number WA0 037338) mines and processes approximately

6 million tons of coal annually for use at the adjacent TransAlta Centralia Generating Station. The mine discharges stormwater overflow to Big Hanaford Creek and its tributaries. Average monthly flow is approximately

8 cubic feet per second (or 5 mgd). 44 **A. 16.1**  **Treatment Processes** 

### The 2011 NPDES permit fact sheet for the facility lists current treatment processes as sedimentation ponds, which are built as excavation progresses and abandoned as reclamation progresses. Discharges from the facility consist of stormwater overflows. Sanitary effluent from the facility

is treated by

the TransAlta Centralia Generating Station. **A. 16.2**  **Effluent Data** 

### Exhibit A
- 66 summarizes 2014 and 2015 effluent monitoring data for the mine. **Exhibit A** **- 66**  **. Summary of Effluent Data (2014 to 2015): Transalta Centralia Mining, Outfall**  **1 Pollutant**  **Number of**

**Observations Water Column Concentrations (total recoverable; μg/L)** 

**Me dian**  **Av erage**  **95 th**  **Percentile Ma** **ximum** Arsenic 12 2.8 3.567 22.275 12.1 Mercury 3 0.00195 0.001907 0 0.00294 Source: discharge monitoring data submitted to Ecology.
**A. 16.3**  **Receiving Water** 

### The facility

discharges to Big Hanaford Creek and several tributaries, which are designated as “Class A” receiving waters. Ambient water quality data are not available for this receiving water.

44 Based on 2012 to 2014 discharge monitoring reports submitted to Ecology.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 105**  **A. 16.4**  **Baseline Scenario**  

### The permit does not include any water quality-based effluent limitations (WQBEL s ) based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to confirm whether a WQBEL w ould have been included in the NPDES permit. 45 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL
. Exhibit A
- 67 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 66 , there is reasonable potential to exceed the baseline human health arsenic criterion. **Exhibit A** **- 67**  **. Human Health Reasonable Potential A nalysis**  **for Transalta Centralia Mining**  **1**
**– Baseline Scenario**  **Parameter Effluent** 

**Conc. (total; μg/L)**  **Am bient Conc.** 

**(dissolved; μg/L) Conc. at Edge of Mixing**  **Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 2.8 NR 2.8 0.018 NR = not reported 1. See effluent concentrations in Exhibit A- 66 (reasonable potential analysis uses the maximum or 95th percentile concentration if the number of observations is less than 10, and otherwise uses the me dian). 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 1. 3. Consumption of water and organisms. 

### Exhibit A
- 68 summarizes the calculated permit limits for arsenic under the baseline scenario. **Exhibit A** **- 68**  **. Human Health Based Effluent Limitations for Tr ansalta Centralia Mining** 

**– Baseline Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; ug/L)**  **1 Ma** **ximum Daily Effluent Limit (total; ug/L)**  **1** Arsenic 0.018 0.060 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 0.018 μg/L and a MDL of 0.060 μg/L. Arsenic was observed in the effluent at of 2.8 μg/L. No ambient data are available and Hanaford Creek near the discharge is not listed on the State’s 303(d) list as impaired for arsenic. Since the effluent monitoring data exceeds the applicable effluent

45 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteri a for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 106**  

### limitations under the baseline scenario, the discharger will need to control arsenic in its effluent to ensure that permit limits are consis tently met. It is possible that more recent or future monitoring data could provide evidence that the facility is in compliance with the projected effluent limits and no costs would be incurred for compliance. However, additional data could provide further evidence of non
- compliance. Based on the available information, EPA assumes the discharger will need to reduce discharge concentrations for compliance with the baseline scenario. A P2 program is a possible pathway to achieve compliance with effluent limitations for arsenic. A P2 program that identifies likely sources of arsenic in the facility’s waste stream can provide adequate levels of control through updated source control and P2 best management practices. Costs for designing and implementing a P2 program for arsenic is estimated to be $28,000 per year. However, if the facility determines that source water derived from ground water, surface waters, or drinking water is the source of high arsenic values in the wastewater, or if it is determined that control of arsenic in the discharge is infeasible (e.g., due to the economic impacts of controlling the pollutant) it is likely that the facility would pursue a variance. Due to the fact that ambient receiving water concentrations exceed the proposed human health criteria, the discharger may pursue obtaining a water quality standards variance. The one - time cost associated with pursuing a variance is estimated to be $180,000, with minimal costs associated with renewal. **A. 16.5**  **Policy Scenario** 

### Exhibit A
- 69 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 66 , there is reasonable potential to exceed human health criteria for arsenic and mercury
. **Exhibit A** **- 69**  **. Human Health Reasonable Potential A nalys**  **is for Transalta Centralia Mining**  **1**
**– Policy Scenario**  **Parameter Baseline A**  **verage Monthly Effluent Limit**  **or Conc. (total; μg/L)**  **Am bient Conc.**  **(dissolved; μg/L) Conc. at Edge of**  **Mixing Zone 2**  **(μg/L) Human Health** 

**Criterion 3**  **(μg/L)** Arsenic 0.018 NR 2.8 0.0045 Mercury 0.0029 NR 0.0035 0.00088 NR = not reported 1. See effluent concentrations in Exhibit A- 66 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the me dian). 2. Based on W ashington Departme nt of Ecology’s Permit writer spreadsheet tool using a dilution factor of 1. 3. Consumption of water and organisms. Exhibit A
- 70 summarizes the calculated permit limits for arsenic and mercury under the policy scenario
.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 107**  **Exhibit A** **- 70**  **. Human Health Based Effluent Limitatio ns for Transalta Centralia Mining** 

**– Policy**  **Scenario Parameter**  **Av erage Monthly Effluent Limit (total;**  **μg/L) 1**  **Ma ximum Daily Effluent Limit (total;**  **μg/L) 1**  Arsenic 0.00 45 0.015 Mercury 0.00088 0.0018 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. **Arsenic** 

### Under the policy

scenario, the discharger would have to meet an AML of 0.0045 μg/L and a MDL of 0.015 μg/L. Under the baseline scenario, where the projected effluent limitations are below the anal ytical Q L , EPA estimated that the discharger would incur costs for P2 as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL. Since the projected effluent limitations under the policy scenario are also below the QL, no additional compliance strategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **Me rcury**  

### Under the policy

scenario, the discharger would have to meet an AML of 0.00088 μg/L and a MDL of 0.0018 μg/L. The maximum effluent concentration is 0.0029 μg/L and the average effluent concentration is 0.0019 μg/L. Based on the available data, the discharger will likely need to reduce mercury

in its effluent to ensure that permit limits are consis tently met. Because there are no proven end
- of
-pipe treatment technologies that can achieve low mercury levels (e.g., <10 ng/L) on a consistent basis, the facility would likely

implement a P2 program for compliance with the projected effluent limits. Annual P2 program costs for this industrial facility

are estimated to be approximately $28,000. To ensure compliance in case a P2 program would not be sufficient to meet the projected effluent limitations, it is assumed that the facility would incur costs for a variance
. **A. 17**  **U.S. Oil & Refining Corporation** U.S. Oil and Refining Corporation (NPDES permit WA0001783 ) in Tacoma consists of an oil refinery , tank farm, and marine terminal. The facility encompasses 122 acres and has a daily throughput of 36,000 barrels per day (based on output between 2002 and 2006). The refinery separates crude oil into component parts and blends them into petroleum products including gasoline, jet fuel, diesel fuel, marine fuel, gas oils, and asphalts. The average wastewater flow for the maximum month is 0.62 mgd. **A. 17.1**  **Treatment Processes** 

### The 2008 permit fact sheet for the facility indicates that the facility employs primary

and secondary treatment for process wastewater and contaminated stormwater before discharging to a City of Tacoma storm drain. Primary treatment includes an oil/water separator and an induced air flotation unit, and secondary treatment is an activated sludge biological unit and a

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 108**  

### clarifier. Sanitary

waste from the facility is collected separatel y and treated by the City of Tacoma’s municipal wastewater treatment plant. **A. 17.2**  **Effluent Data** 

### Exhibit A
- 71 summarizes effluent monitoring data for the facility from a 2014 monitoring report, which reports detected concentrations only for the pollutants of concern. 46 

### According to the 2008 NPDES permit fact sheet, monitoring data for organic toxics are not reported because all samples were below detection limits. **Exhibit A** **- 71**  **. Summary of Effluent Data (2013 -** **2014): US Oil & Refining Facility 1** 

**Pollutant Number of**  **Observations Av**  **erage (μg/L) Ma** **ximum (μg/L)** Antimony 2 0.47 0.54 Arsenic 2 6.5 8.6 Copper 2 0.58 0.6 Mercury 2 0.00245 0.0028 Nickel 2 1.295 1.4 Phenols 2 nd nd Selenium 2 3.08 3.56 Thallium 2 nd 0.02 Zinc 2 3.7 5.7 nd = nondetect Source: 2014 Inspection Report (Table 1 and Table 2); includes one sample taken by Wa shington Department of Ecology (2014) and one sample submitted by the facility (2013). 1. Metal concentrations are in total recoverable.
**A. 17.3**  **Receiving Water** 

### USOR discharges to the Lincoln Avenue Ditch, where it flows to the Blair Waterway which is a tidal inlet to Commencement Bay . The Blair Waterway is a Class B marine waterbody, with uses including industrial uses; fish migration; shellfish spawning, rearing and harvesting; wildlife habitat; secondary contact recreation; sport fishing; boating and aesthetic enjoy ment; commerce; and navigation. Exhibit A
- 72 summarizes the available ambient receiving water concentrations from the 2008 permit fact sheet.

46 The NPDES permit requires an annual priority pollutant scan; however, these data are not available in Ecology’s discharge monitoring report (DMR) online tool nor EPA’s ICIS
-NPDES database.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 109**  **Exhibit A** **- 72**  **. A mbient Receiving Water Concen**  **trations: Blair Waterway**

**Pollutant Water Column Concentration (μg/L)**  Arsenic (unfiltered) 1.3 Copper (dissolved) 0.81 Mercury (total recoverable) 0.0023 Zinc (dissolved) 3.7 Source: 2008 permit fact sheet (p. 21).
**A. 17.4**  **Baseline Scenario** 

### The permit does not include any WQBELs based on the existing human health criteria for the pollutants of concern. In this case, EPA performed a reasonable potential analysis for each pollutant based on the baseline (i.e., existing) human health criteria to co nfirm whether a WQBEL w ould have been included in the NPDES permit. 47 

### Incases of reasonable potential, EPA calculated a WQBEL using the existing human health criteria and evaluated compliance with this baseline WQBEL. Exhibit A
- 73 summarizes the reasonable potential anal ys is under the baseline scenario. Based on effluent concentrations in Exhibit A
- 71 and available ambient data in Exhibit A
- 72 , there is reasonable potential to exceed the baseline human health arsenic criterion. **Exhibit A** **- 73**  **. Human Health Reasonable Potential A nalysis for U.S. Oil & Refining**  **Facility 1** 
**– Baseline Scenario**  **Parameter Effluent Conc.** 

**( total;**  **μg/L) Am**  **bient Conc .** 

**( dissolved;**  **μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 8.6 1.3 1.466 0.14 1. See effluent concentrations in Exhibit A- 71 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 72

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 1025. 3. C onsumption of organi sms only

. 

### Exhibit A
- 74 summarizes the calculated permit limits for arsenic under the baseline scenario.

47 Based on 40 CFR 122.44(d)(1), were it not for the approaches and other policies used by Ecology. 40 CFR 122.44(d)(1) requires that effluent limitations must be established when a pollutant is discharged “...at a level which will cause, have the reasonable potential to cause, or contribute to an e xcursion above any State water quality standard, including State narrative criteria for water quality.”

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 110**  **Exhibit A** **- 74**  **. Human Health Based Effluent Limitations for U. S. Oil & Refining Facility** 

**– Baseline Scenario**  **Parameter Av**  **erage Monthly Effluent Limit (total; μg/L)**  **1 Ma** **ximum Daily Effluent Limit (total; μg/L)**  **1** Arsenic 0.14 0.28 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the baseline scenario, the discharger would have to meet an AML of 0.14 μg/L and a MDL of 0.28 μg/L. Arsenic was observed in the effluent at a concentration of 8.6 μg/L and in the ambient receiving water at a concentration of 1.3 μg/L. Blair Waterway near the discharge is not listed on the State’s 303(d) list as impaired for arsenic, though ambient data used in the reasonable potential analysis does exceed criteria. Since the effluent monitoring data exceeds the applicable effluent limitations under the baseline scenario, the discharger will need to control arsenic in its effluent to ensure that permit limits are consistently met. It is possible that more recent or future monitoring data could provide evidence that the facility is in compliance with the projected effluent limits and no costs would be incurred for compliance. However, additional data could provide further evidence of non
- compliance. Based on the available information, EPA assumes the discharger will need to reduce dis charge concentrations for compliance with the baseline scenario. A P2 program is a possible pathway to achieve compliance with effluent limitations for arsenic. A P2 program that identifies likely sources of arsenic in the facility’s waste stream can provi de adequate levels of control through updated source control and P2 best management practices. Costs for designing and implementing a P2 program for arsenic is estimated to be $28,000 per year. However, if the facility determines that source water derived from ground water, surface waters, or drinking water is the source of high arsenic values in the wastewater, or if it is determined that control of arsenic in the discharge is infeasible (e.g., due to the economic impacts of controlling the pollutant) it i s likely that the facility would pursue a variance. Due to the fact that ambient receiving water concentrations exceed the proposed human health criteria, the discharger may pursue obtaining a water quality standards variance. The one - time cost associated with pursuing a variance is estimated to be $180,000, with minimal costs associated with renewal. **A. 17.5**  **Policy Scenario** 

### Exhibit A
- 75 summarizes the reasonable potential anal ys is under the policy scenario. Based on effluent concentrations in Exhibit A
- 71 and available ambient data in Exhibit A
- 72 , there is reasonable potential to exceed human health criteria for arsenic.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 111**  **Exhibit A** **- 75**  **. Human Health Reasonable Potent ial A** **nalysis for US Oil & Refining Facility**  **1**
**– Policy** 

**Scenario Parameter**  **Baseline A verage**  **Monthly Effluent Limit**  **(total; μg/L) Am**  **bient Conc.**

**(dissolved; μg/L) Conc. at Edge of** 

**Mixing Zone 2**  **(μg/L) Human Health**  **Criterion 3**  **(μg/L)** Arsenic 0.14 1.3 1.466 0.0059 NA = not available 1. See effluent concentrations in Exhibit A- 71 (reasonable potential analysis uses the maximum or 95 th percentile concentration if the number of observations is less than 10, and otherwise uses the geom etric mean) and available ambient co ncentrations in Exhibit A- 72

. 2. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool using a dilution factor of 71. 3. Consump tion of organisms only. Exhibit A
- 76 summarizes effluent limitations for arsenic applicable to the facility under the policy scenario. **Exhibit A** **- 76**  **. Human Health Based Effluent L imitations for US Oil & Refining Facility**  **– Policy**  **Scenario Parameter**  **Av erage Monthly Effluent Limit**  **(total; ug/L) 1**  **Ma ximum Daily Effluent Limit**  **(total; ug/L) 1**  Arsenic 0.0059 0.012 1. Based on W ashington Department of Ecology’s Permit writer spreadsheet tool. 

### Under the policy

scenario, the discharger would have to meet an AML of 0.00 59 μg/L and a MDL of 0.0 12 μg/L. Under the baseline scenario, where the projected effluent limitations are below the anal ytical QL, EPA estimated that the discharger would incur costs for P2 as well as pursuit of a variance in order to ensure compliance with effluent limitations below the QL. Since the projected effluent limitations under the policy scenario are also below the QL, no additional compliance s trategy would be required under the policy scenario (i.e., the discharger would not pursue a second variance). **A. 18**  **References and Sources**  City of Pasco. 2014. NPDES Permit Application Form 2A. Fairfield
- Suisun Sewer District (SD). 2003. 2003 NPDES Permit Renewal Infeasibility Analyses. June 17. Online at http://www.swrcb.ca.gov/rwqcb2/Agenda/08
- 20
- 03/08
- 20
- 03
- 5ainfeasibility

rev.doc
. King County Department of Natural Resources. 2013. Receiving Water Characterization Study : King County NP DES Monitoring Program. Final Report prepared for the King County Department of Natural Resources and Parks and the Washington State Department of Ecology
.

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 112**  

### King County Department of Natural Resources and Parks. 2012. 2012 King County L ong term Combined Sewer Overflow Control Plan Amendment. Washington Department of Ecology . 2014. Fact Sheet for NPDES Permit WA0029181: West Point Wastewater Treatment Plant (WWTP) and Combined Sewer Overflow (CSO) System. Washington Department of Ecology . 2013. Fact Sheet for NPDES Permit No.WA0023451 , Lakehaven Utility

District Redondo Wastewater Treatment Plant
. Washington Department of Ecology . 2013. Addendum to the Fact Sheet for National Pollutant Discharge Elimination System (NPDES) Permit No. WA0022772, March 1, 2013. Washington Department of Ecology . 2009. Fact Sheet for NPDES Permit WA0029581: King County South Wastewater Treatment Plant (WWTP). Washington Department of Ecology . 2008. Fact Sheet for NPDES Permit No. WA0044962 City of Pasco Wastewater Treatment Works. Washington Department of Ecology . 2003. Fact Sheet for NPDES Permit WA0022772, Southwest Suburban Sewer District Salmon Creek Wastewater Treatment Plant. U.S. Environmental Protection Agency (EPA) . 2014. Fact Sheet: The U.S. Environmental Protection Agency

(EPA) Proposes to Reissue a National Pollutant Discharge Elimination System (NPDES) Permit to Discharge Pollutants Pursuant to the Provisions of the Clean Water Act (CWA) to: City of Puyallup Wastewater Treatment Plant, 1602 18th St NW, Puyallup, WA 98371. U.S. Environmental Protection Agency (EPA). 2014. Response to Comments: City of Puyallup Wastewater Treatment Plant, NPDES Permit WA0037168, September 23, 2014. U.S. Environmental Protection Agency (EPA). 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan for the Petroleum Refining Category . EPA
- 821
- R
04
- 014

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 113**  

## Ap **pendix B –**  **Sample Facility Results and St**  **atewide Extrapolation** This appendix provides a summary of the sample facility

results (facility- specific details are provided in Appendix A), and shows the extrapo lation of statewide costs for the baseline scenario and the policy

scenario
. EPA annualized capital costs, including study (e.g., dilution, variance) and program (e.g., pollution prevention) costs over 20 years using a 7% discount rate to obtain total annual costs per facility , then calculated a minimum and maximum annual cost for each facility in the sample. **B.1 Baseline Scenario Extrapolation**  Exhibit B
- 1 summarizes the estimated annual compliance costs for the sample facilities under the baseline scenario
. **Exhibit B**  **- 1**  **. Potential Total A nnual Compliance Costs for Sample Facilities**  **, Baseline Scenario**  **Facility Name Permit**  **Number Category**  **Total Costs (2014$)**  **1 Low**  **High Certainty Sample**  King County W est Point WW TP WA0029181 POTW $1,100,000 $1,140,211 King County South WWTP WA0029581 POTW $1,000,000 $1,040,211 BP Cherry Point Refinery WA0022900 Chemicals, p etroleum, and related i ndustries $7,053,698 $7,053,698 **Random Sample** Chambers Creek STP WA0039624 POTW $0 $0 Pu yallup STP WA0037168 POTW $0 $0 Salm on Creek WWTP WA0022772 POTW $643,000 $659,991 Redondo WW TP WA0023451 POTW $568,000 $584,991 Pasco WWTP WA0044962 POTW $1,530,000 $1,546,991 Tesoro Refining & Marketing Company LLC WA0000761 Chemicals, p etroleum, and related i ndustries $28,000 $44,991 U.S. Oil & Refining Facility WA0001783 Chemicals, p etroleum, and related i ndustries $28,000 $44,991 Quincy Industrial WA0021067 Food and k indred p roducts $0 $0

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 114**  **Exhibit B**  **- 1**  **. Potential Total A nnual Compliance Costs for Sample Facilities**  **, Baseline Scenario**  **Facility Name Permit**  **Number Category**  **Total Costs (2014$)**  **1 Low**  **High** Transalta Centralia Mining WA0037338 Mining $28,000 $44,991 Cosmo Specialty Fibers, Inc. WA0000809 Paper and allied p roducts $0 $0 Sonoco Products Company WA0000884 Paper and allied p roducts $0 $0 Intalco Aluminum Corp Ferndale WA0002950 Prim ary m etal i ndustries $5,906,642 $5,906,642 Steelscape, Inc. WA0040851 Prim ary m etal i ndustries $0 $0 Transalta Centralia Generation WA0001546 Transportation & p ublic u tilities (except POTW s) $28,000 $44,991 1. Annual costs plus one - time costs annualized over 20 years using a 7% discount rate. 

### Exhibit B
- 2 shows the extrapolation of the sample results to estimate statewide costs for major dischargers under the baseline scenario . For each category of facilities, EPA calculated a per- facility cos t based on the sample, and applied that cost to all other facilities in that category statewide. **Exhibit B**  **- 2**  **. Sample and Total**  **An nual Compliance**  **Costs (millions**  **; 2014$ )**  **by Discharger Category**  **, Baseline Scenario**  **Category Ma**  **jor Dischargers Sample Costs**  **Total Costs Sample**  **Statewide Low**  **High Low**  **High**

**Certainty** Municipal 2 2 $2.10 $2.18 $2.10 $2.18 Chemicals, Petroleum, and Related Industries 1 1 $7.05 $7.05 $7.05 $7.05 **Random** Municipal 5 46 $2.74 $2.79 $25.22 $25.69 Mining 1 1 $0.03 $0.04 $0.03 $0.04 Food and Kindred Products 1 1 $0.00 $0.00 $0.00 $0.00 Paper and Allied Products 2 12 $0.00 $0.00 $0.00 $0.00 Chemicals, Petroleum, and Related Industries 2 5 $0.06 $0.09 $0.14 $0.22 Prim ary Metal Industries 2 4 $5.91 $5.91 $11.81 $11.81

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 115**  **Exhibit B**  **- 2**  **. Sample and Total**  **An nual Compliance**  **Costs (millions**  **; 2014$ )**  **by Discharger Category**  **, Baseline Scenario**  **Category Ma**  **jor Dischargers Sample Costs**  **Total Costs Sample**  **Statewide Low**  **High Low**  **High** Transportation & Public Utilities (except POTW s) 1 1 $0.03 $0.04 $0.03 $0.04 **Total** All Dischargers 17 73 $17.91 $18.11 $46.38 $47.05 1. Annual costs plus one - time costs annualized over 20 years using a 7% discount rate. 

### B.2 **Policy**

**Scenario Extrapolation** Exhibit B
- 3 summarizes the annual compliance costs for the sample facilities under the policy scenario. **Exhibit B**  **- 3**  **. Potential Total A nnual Compliance**  **Costs for Sample Facilities, Policy Scenario**  **Facility Name Permit**  **Number Category**  **Total Costs (2014$)**  **1 Low**  **High Certainty Sample**  King County W est Point WWTP WA0029181 POTW $0 $0 King County South WWTP WA0029581 POTW $0 $0 BP Cherry Point Refinery WA0022900 Chemicals, p etroleum, and related i ndustries $56,000 $72,991 **Random Sample** Chambers Creek STP WA0039624 POTW $0 $0 Pu yallup STP WA0037168 POTW $0 $0 Salm on Creek WWTP WA0022772 POTW $0 $0 Redondo WW TP WA0023451 POTW $0 $0 Pasco WWTP WA0044962 POTW $0 $0 Tesoro Refining & Marketing Company LLC WA0000761 Chemicals, p etroleum, and related i ndustries $28,000 $28,000 U.S. Oil & Refining Facility WA0001783 Chemicals, p etroleum, and related i ndustries $0 $0 Quincy Industrial WA0021067 Food and k indred p roducts $0 $0 Transalta Centralia Mining WA0037338 Mining $28,000 $44,991 Cosmo Specialty Fibers, Inc. WA0000809 Paper and allied p roducts $0 $0

### AP **PENDIX**

**Abt Associ ates**  **Cost of Compliance with WQS for Washington ▌**  **pg. 116**  **Exhibit B**  **- 3**  **. Potential Total A nnual Compliance**  **Costs for Sample Facilities, Policy Scenario**  **Facility Name Permit**  **Number Category**  **Total Costs (2014$)**  **1 Low**  **High** Sonoco Products Company WA0000884 Paper and allied p roducts $2,135,858 $2,135,858 Intalco Aluminum Corp Ferndale WA0002950 Prim ary m etal i ndustries $28,000 $28,000 Steelscape, Inc. WA0040851 Prim ary m etal i ndustries $0 $0 Transalta Centralia Generation WA0001546 Transportation & p ublic u tilities (except POTW s) $0 $0 1. Annual costs plus one - time costs annualized over 20 years using a 7% discount rate. 

### Exhibit B
- 4 shows the extrapolation of the sample results to estimate statewide costs for major dis chargers. For each category of facilities, EPA calculated a per
- facility cost based on the sample, then applied that cost to all other facilities in that category statewide. **Exhibit B**  **- 4**  **. Sample and Total**  **An n**  **ual Compliance Costs**  **(millions; 2014$) by**  **Discharger Category , Policy**  **Scenario Category**  **Ma jor Dischargers**  **Sample Costs Total Costs**  **Sample Statewide**  **Low High**  **Low High** 

**Certainty** Municipal 2 2 $0.00 $0.00 $0.00 $0.00 Chemicals, Petroleum, and Related Industries 1 1 $0.06 $0.07 $0.06 $0.07 **Random** Municipal 5 46 $0.00 $0.00 $0.00 $0.00 Mining 1 1 $0.03 $0.04 $0.03 $0.04 Food and Kindred Products 1 1 $0.00 $0.00 $0.00 $0.00 Paper and Allied Products 2 12 $2.14 $2.14 $12.82 $12.82 Chemicals, Petroleum, and Related Industries 2 5 $0.03 $0.03 $0.07 $0.07 Prim ary Metal Industries 2 4 $0.03 $0.03 $0.06 $0.06 Transportation & Public Utilities (except POTW s) 1 1 $0.00 $0.00 $0.00 $0.00 **Total** All Dischargers 17 73 $2.28 $2.31 $13.03 $13.06 1. Annual costs plus one - time costs annualized over 20 years using a 7% discount rate.