ECONOMIC
ANALYSIS
OF
THE
PROPOSED
WATER
QUALITY
STANDARDS
RULE
FOR
THE
STATE
OF
ALABAMA
November
2001
Prepared
for
U.
S.
Environmental
Protection
Agency
Office
of
Water
Office
of
Science
and
Technology
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington,
D.
C.
20460
Prepared
by
Science
Applications
International
Corporation
11251
Roger
Bacon
Drive
Reston,
Virginia
20190
EPA
Contract
No.
68­
C­
99­
252
SAIC
Project
No.
06­
6193­
04­
2805­
xxx
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
iii
Table
of
Contents
1.
Introduction
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1
1.1
Background
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1
1.2
Scope
of
the
Analysis
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2
1.3
Organization
of
Report
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4
2.
Data
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5
2.1
Facility
Data
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5
2.2
Water
Quality
Data
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5
3.
Methods
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7
3.1
Use
Attainability
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7
3.2
Estimating
Revised
Effluent
Limits
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7
3.3
Determining
Necessary
Pollution
Controls
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8
3.4
Estimating
the
Cost
of
Pollution
Controls
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9
3.5
Estimating
Pollutant
Loading
Reductions
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12
4.
Results
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13
4.1
Estimated
Costs
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13
4.1.1
Five
Mile
Creek
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14
4.1.2
Opossum
Creek
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15
4.1.3
Pepperell
Branch
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16
4.1.4
Shirtee
Creek
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16
4.1.5
Valley
Creek
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17
4.1.6
Village
Creek
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18
4.2
Pollutant
Loading
Reductions
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19
4.3
Limitations
of
the
Analysis
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20
5.
References
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21
Appendices
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23
Appendix
A.
Facility
Effluent
Data
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24
Appendix
B.
Instream
Water
Quality
Data
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28
Appendix
C.
Use
Attainability
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36
Appendix
D.
Ammonia
Toxicity
Analysis
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56
Appendix
E.
Dissolved
Oxygen
Analysis
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60
Appendix
F.
Facility
Analyses
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62
Appendix
G.
Nonpoint
Source
Control
Costs
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100
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
iv
List
of
Exhibits
Exhibit
1­
1.
Comparison
of
Criteria
Applicable
to
A&
I,
LWF,
and
F&
W
Standards
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3
Exhibit
2­
1.
Facilities
Potentially
Affected
by
the
Use
Upgrades
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6
Exhibit
3­
1.
Estimated
Treatment
Process
Optimization
Costs
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10
Exhibit
4­
1.
Estimated
Annual
Costs
to
Achieve
Use
Classifications
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13
Exhibit
4­
2.
Estimated
Annual
Nonpoint
Source
Control
Costs
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15
Exhibit
4­
3.
Estimated
Annual
Point
Source
Costs
and
Pollutant
Load
Reductions
for
an
A&
I
Use
Classification
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19
Exhibit
4­
4.
Estimated
Annual
Point
Source
Costs
and
Pollutant
Load
Reductions
for
an
LWF
Use
Classification
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19
Exhibit
4­
5.
Estimated
Annual
Point
Source
Costs
and
Pollutant
Load
Reductions
for
a
F&
W
Use
Classification
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20
Exhibit
4­
6.
Biases
and
Uncertainties
in
the
Analysis
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20
Exhibit
A­
1.
Facility
Effluent
Data
Considered
in
Cost
Analyses
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24
Exhibit
B­
1.
Stream
Data
Considered
in
Cost
Analyses
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28
Exhibit
B­
2.
Five
Mile
Creek
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32
Exhibit
B­
3.
Shirtee
Creek
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33
Exhibit
B­
4.
Valley
Creek
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34
Exhibit
B­
5.
Village
Creek
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35
Exhibit
C­
1.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
FM1
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38
Exhibit
C­
2.
Five
Mile
Creek,
Station
FM1
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.
38
Exhibit
C­
3.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
FM2
.
.
.
.
.
39
Exhibit
C­
4.
Five
Mile
Creek,
Station
FM2
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
39
Exhibit
C­
5.
Pepperell
Branch,
Station
WPP
35
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
41
Exhibit
C­
6.
Pepperell
Branch,
Station
WPP
36
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
41
Exhibit
C­
7.
Pepperell
Branch,
Station
WPP
37
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
42
Exhibit
C­
8.
Pepperell
Branch,
Station
WPP
39
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
42
Exhibit
C­
9.
Pepperell
Branch,
Station
WPP
39A
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
43
Exhibit
C­
10.
Pepperell
Branch,
Station
WPP
40
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
43
Exhibit
C­
11.
Pepperell
Branch,
Station
WPP
41
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
44
Exhibit
C­
12.
Shirtee
Creek,
Station
SHIRTEE03
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
45
Exhibit
C­
13.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VAL­
1
.
.
.
47
Exhibit
C­
14.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VAL­
2
.
.
.
48
Exhibit
C­
15.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VAL­
3
.
.
.
49
Exhibit
C­
16.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VI1
.
.
.
.
.
.
51
Exhibit
C­
17.
Village
Creek,
Station
VILLAGECREEK02
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
Exhibit
C­
18.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
1
.
.
.
.
52
Exhibit
C­
19.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
2
.
.
.
.
53
Exhibit
C­
20.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
3
.
.
.
.
54
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
v
Exhibit
C­
21.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
4
.
.
.
.
55
Exhibit
D­
1.
Summary
of
WLA
Analysis
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
Exhibit
E­
1.
Current
Permit
Limits
and
Discharge
Condition
at
Opossum
Creek
.
.
.
.
.
.
.
.
.
.
60
Exhibit
E­
2.
Summary
of
Key
Model
Parameters
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
61
Exhibit
F­
1.
Compliance
Summary,
ABC
Coke
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
63
Exhibit
F­
2.
Projected
Effluent
Limits,
ABC
Coke
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
64
Exhibit
F­
3.
Required
Effluent
Reductions,
ABC
Coke
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
64
Exhibit
F­
4.
Annual
Cost
of
Required
Effluent
Reductions,
ABC
Coke
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
65
Exhibit
F­
5.
Compliance
Summary,
ACIPCO
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
66
Exhibit
F­
6.
Projected
Effluent
Limits,
ACIPCO
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
67
Exhibit
F­
7.
Required
Effluent
Reductions,
ACIPCO
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
67
Exhibit
F­
8.
Annual
Cost
of
Required
Effluent
Reductions,
ACIPCO
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
68
Exhibit
F­
9.
Compliance
Summary,
Ashland
Chemicals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
Exhibit
F­
10.
Compliance
Summary,
Avondale
Mills
 
Eva
Jane
Plant
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
70
Exhibit
F­
11.
Compliance
Summary,
Earl
Ham
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
72
Exhibit
F­
12.
Annual
Cost
of
Required
Effluent
Reductions,
Earl
Ham
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
73
Exhibit
F­
13.
Compliance
Summary,
Five
Mile
Creek
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
74
Exhibit
F­
14.
Annual
Cost
of
Required
Effluent
Reductions,
Five
Mile
Creek
WWTP
.
.
.
.
.
.
75
Exhibit
F­
15.
Compliance
Summary,
Honeywell
International
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
76
Exhibit
F­
16.
Projected
Effluent
Limits,
Honeywell
International
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
77
Exhibit
F­
17.
Required
Effluent
Reductions,
Honeywell
International
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
77
Exhibit
F­
18.
Annual
Cost
of
Required
Effluent
Reductions,
Honeywell
International
.
.
.
.
.
.
.
78
Exhibit
F­
19.
Compliance
Summary,
Koppers
Ind.
 
Woodward
Coke
Plant
.
.
.
.
.
.
.
.
.
.
.
.
.
.
79
Exhibit
F­
20.
Projected
Effluent
Limits,
Koppers
Ind.
 
Woodward
Coke
Plant
.
.
.
.
.
.
.
.
.
.
.
.
80
Exhibit
F­
21.
Required
Effluent
Reductions,
Koppers
Ind.
 
Woodward
Coke
Plant
.
.
.
.
.
.
.
.
80
Exhibit
F­
22.
Annual
Cost
of
Required
Effluent
Reductions,
Koppers
Ind.
 
Woodward
Coke
Plant
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
80
Exhibit
F­
23.
Compliance
Summary,
Koppers
Ind.
 
Woodward
Tar
Plant
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
81
Exhibit
F­
24.
Projected
Effluent
Limits,
Koppers
Ind.
 
Woodward
Tar
Plant
.
.
.
.
.
.
.
.
.
.
.
.
.
82
Exhibit
F­
25.
Compliance
Summary,
Sloss
Industries
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
85
Exhibit
F­
26.
Projected
Effluent
Limits,
Sloss
Industries
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
85
Exhibit
F­
27.
Required
Effluent
Reductions,
Sloss
Industries
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
86
Exhibit
F­
28.
Annual
Cost
of
Required
Effluent
Reductions,
Sloss
Industries
.
.
.
.
.
.
.
.
.
.
.
.
.
87
Exhibit
F­
29.
Compliance
Summary,
SMI
Steel
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
88
Exhibit
F­
30.
Schematic
Diagram
of
Process
Wastewater
and
Storm
Water
Outfalls,
USX
 
Fairfield
Works
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
89
Exhibit
F­
31.
Compliance
Summary,
USX
 
Fairfield
Works
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
90
Exhibit
F­
32.
Projected
Effluent
Limits,
USX
 
Fairfield
Works
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
90
Exhibit
F­
33.
Required
Effluent
Reductions,
USX
 
Fairfield
Works
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
91
Exhibit
F­
34.
Annual
Cost
of
Required
Effluent
Reductions,
USX
 
Fairfield
Works
.
.
.
.
.
.
.
91
Exhibit
F­
35.
Compliance
Summary,
Valley
Creek
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
92
Exhibit
F­
36.
Projected
Effluent
Limits,
Valley
Creek
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
93
Exhibit
F­
37.
Required
Effluent
Reductions,
Valley
Creek
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
93
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
vi
Exhibit
F­
38.
Annual
Cost
of
Required
Effluent
Reductions,
Valley
Creek
WWTP
.
.
.
.
.
.
.
.
.
94
Exhibit
F­
39.
Compliance
Summary,
Village
Creek
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
95
Exhibit
F­
40.
Projected
Effluent
Limits,
Village
Creek
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
96
Exhibit
F­
41.
Required
Effluent
Reductions,
Village
Creek
WWTP
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
96
Exhibit
F­
42.
Annual
Cost
of
Required
Effluent
Reductions,
Village
Creek
WWTP
.
.
.
.
.
.
.
.
97
Exhibit
F­
43.
Compliance
Summary,
Westwood­
Stevens
 
Opelika
Finishing
Plant
.
.
.
.
.
.
.
.
99
Exhibit
G­
1.
Cost
of
Nonpoint
Source
Controls,
Five
Mile
Creek
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
100
Exhibit
G­
2.
Cost
of
Nonpoint
Source
Controls,
Valley
Creek
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
100
Exhibit
G­
3.
Cost
of
Nonpoint
Source
Controls,
Village
Creek
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
101
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
1
1.
Introduction
The
United
States
Environmental
Protection
Agency
(
EPA,
or
the
Agency)
is
proposing
to
upgrade
Five
Mile
Creek,
Opossum
Creek,
Pepperell
Branch
(
of
Soughahatchee
Creek),
Shirtee
Creek,
Valley
Creek,
and
Village
Creek
in
Alabama
to
a
higher
designated
use.
The
Alabama
Department
of
Environmental
Management
(
ADEM)
currently
designates
these
creeks
for
Agricultural
and
Industrial
(
A&
I)
use.
Potential
future
uses
include
Fish
and
Wildlife
(
F&
W),
Limited
Warmwater
Fishery
(
LWF),
and
variants
on
LWF.

This
report
provides
analysis
of
the
potential
costs
and
pollutant
loading
reductions
associated
with
upgrading
the
designated
uses
of
these
creeks.

1.1
Background
Section
303
(
U.
S.
C.
1313)
of
the
CWA
directs
States,
with
oversight
by
EPA,
to
adopt
water
quality
standards
to
protect
the
public
health
and
welfare,
enhance
the
quality
of
water,
and
serve
the
purposes
of
the
CWA.
Under
Section
303,
States
are
required
to
develop
water
quality
standards
for
waters
of
the
United
States
within
their
boundaries.
Section
303(
c)
provides
that
water
quality
standards
shall
include
the
designated
use
or
uses
for
the
water
and
criteria
necessary
to
protect
those
uses.
States
are
required
to
review
their
water
quality
standards
at
least
once
every
3
years
and,
if
appropriate,
revise
or
adopt
new
standards.
The
results
of
this
triennial
review
must
be
submitted
to
EPA
and
EPA
must
approve
or
disapprove
any
new
or
revised
standards.
Section
303(
c)
also
authorizes
the
EPA
Administrator
to
promulgate
water
quality
standards
to
supersede
State
standards
that
have
been
disapproved
or
when
the
Administrator
determines
that
a
new
or
revised
standard
is
needed
to
meet
the
requirements
of
the
CWA.

On
October
14,
1986,
the
Regional
Administrator
of
EPA
Region
4
disapproved
use
designations
adopted
by
ADEM
for
49
stream
segments
because
the
State
failed
to
justify
lower
use
classifications
in
accordance
with
40
CFR
§
131.10(
j).
Although
the
State
had
previously
submitted
use
attainability
analyses
for
these
stream
segments,
EPA
found
that
the
analyses
did
not
adequately
describe
the
basis
for
the
lower
use
classifications
nor
did
they
provide
adequate
information
to
determine
if
such
classifications
are
appropriate.
Between
1986
and
1991,
ADEM
either
upgraded
the
use
designation
to
fish
and
wildlife
(
F&
W)
or
EPA
approved
an
agricultural
and
industrial
water
supply
(
A&
I)
use
for
20
of
these
streams.
On
July
18,
1991,
the
EPA
Regional
Administrator
for
Region
4
disapproved
30
beneficial
use
designations
adopted
by
ADEM,
29
of
which
were
previously
disapproved
in
1986,
plus
the
beneficial
use
designation
for
one
additional
stream
segment
which
lacked
a
use
attainability
analysis
(
UAA).

ADEM
upgraded
13
of
the
30
segments
which
were
the
subject
of
EPA's
1991
action
to
F&
W.
This
left
17
stream
segments
for
which
EPA
has
disapproved
State
use
designations.
A
State
action
on
April
22,
1997
reduced
the
length
of
7
of
these
remaining
segments
to
reflect
upgrades
of
a
portion
of
these
segments
to
F&
W
use.
However,
the
remaining
portions
of
these
seven
streams
remain
subject
to
EPA's
disapproval.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
2
On
September
18,
1996,
the
Legal
Environmental
Assistance
Foundation
(
LEAF)
filed
suit
in
District
Court
in
Alabama
against
EPA
for
failure
to
propose
water
quality
standards
for
12
stream
segments
in
Alabama
designated
as
A&
I
which
EPA
had
previously
disapproved.
EPA,
the
Department
of
Justice,
and
the
plaintiffs
entered
into
a
consent
decree
covering
9
of
the
12
streams.
Under
the
terms
and
conditions
of
the
consent
decree,
EPA
was
to
propose
Federal
use
designations
in
the
Federal
Register
or
withdraw
the
disapproval
of
the
existing
Alabama
standards
for
these
waters
by
February
28,
1998.
Since
the
signing
of
the
consent
decree,
ADEM
has
upgraded
two
of
these
nine
streams
to
F&
W.
The
proposed
Alabama
Water
Quality
Standards
Rule
published
in
the
Federal
Register
on
March
5,
1998
covered
the
remaining
seven
consent
decree
streams
as
well
as
two
other
streams
still
subject
to
EPA's
outstanding
disapproval.

EPA's
current
proposal
covers
the
following
six
segments:
Five
Mile
Creek,
Opossum
Creek,
Pepperell
Branch
(
of
Soughahatchee
Creek),
Shirtee
Creek,
Valley
Creek,
and
Village
Creek.

1.2
Scope
of
the
Analysis
To
estimate
the
potential
costs
and
pollutant
loading
reductions
associated
with
upgrading
the
designated
uses,
EPA
evaluated
potential
impacts
on
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permitted
facilities
and
nonpoint
sources
of
pollutant
loadings
to
seven
segments
in
the
six
creeks.
In
doing
so,
EPA
used
data
and
information
in
publically
available
sources.
(
The
appendices
to
this
report
describe
the
available
data
in
detail).
Some
modeling
results
were
also
provided
by
ADEM
and
facility
process
information
by
EPA's
Region
4
office.

The
analysis
addresses
the
costs
and
pollutant
loading
reductions
that
would
be
required
to
attain
Alabama
water
quality
criteria
associated
with
A&
I,
LWF,
and
F&
W
uses.
These
criteria
are
shown
in
Exhibit
3­
1.
As
can
be
seen
from
the
exhibit,
there
is
little
difference
in
pH
and
temperature
criteria
across
uses.
The
criteria
for
dissolved
oxygen
(
DO)
and
toxic
pollutants
differ
among
the
three
standards
with
the
A&
I
standard
being
the
least
restrictive.
A&
I
requires
a
3
mg/
L
minimum
concentration
of
DO,
a
level
of
toxic
compounds
that
does
not
interfere
with
water
use
for
agricultural
irrigation
or
impair
fish
survival,
and
a
geometric
mean
of
2,000
fecal
coliform
bacteria
per
100
ml
(
and
a
maximum
of
4,000
per
100
ml).
The
narrative
toxic
criteria
require
that
A&
I
waters
meet
Alabama's
acute
criteria
for
protection
of
aquatic
life
(
ensure
fish
survival)
and
Alabama's
human
health
criteria
for
consumption
of
organisms
only
(
for
agricultural
irrigation
use).

The
LWF
standard
is
more
restrictive
than
the
A&
I
standard
in
that
DO
should
always
be
greater
than
3
mg/
L
between
May
and
November,
and
at
least
5
mg/
L
during
other
months.
Toxic
compounds
should
not
be
present
in
amounts
that
do
not
cause
acute
or
chronic
toxicity,
although
effluent
limits
based
on
chronic
aquatic
life
criteria
will
be
less
stringent
compared
to
F&
W
limits
(
see
below).
The
fecal
coliform
standard
of
1,000
bacteria
per
100
ml
(
geometric
mean)
and
a
maximum
of
2,000
bacteria
per
100
ml
is
about
twice
as
stringent
as
the
A&
I
criterion.

Finally,
the
F&
W
standard
requires
5
mg/
L
DO
at
all
times
unless
natural
conditions
prevent
this,
in
which
case
a
4
mg/
L
criterion
applies.
Toxic
compounds
shall
not
be
present
in
such
amounts
as
to
cause
either
acute
or
chronic
toxicity.
The
difference
in
the
chronic
toxicity
criterion
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
3
between
LWF
and
F&
W
lies
in
the
stream
flows
used
to
determine
compliance.
Under
LWF
criteria,
the
receiving
water
stream
flow
is
specified
as
the
7Q2,
the
lowest
daily
average
stream
flow
over
a
weekly
period
that
is
expected
to
occur
every
2
years;
under
F&
W
criteria,
the
receiving
water
stream
flow
is
specified
as
the
7Q10,
a
lower
flow
than
the
7Q2,
which
results
in
more
restrictive
permit
limits
for
aquatic
life
protection.
The
F&
W
criteria
for
fecal
coliform
require
a
geometric
mean
of
200
organisms
per
100
ml
between
June
and
September
and
a
geometric
mean
of
1,000
organisms
per
100
ml
during
other
months.
At
no
time
shall
the
maximum
number
of
fecal
coliform
bacteria
per
100
ml
exceed
2,000.

Exhibit
1­
1.
Comparison
of
Criteria
Applicable
to
A&
I,
LWF,
and
F&
W
Standards
Parameter
A&
I
LWF
F&
W
pH
6
 
8.5
standard
units
(
SU)
6
 
8.5
SU
6
 
8.5
SU
Temperature
5
°
Fahrenheit
(
F)
above
ambient,
<
90
°
F
5
°
F
above
ambient;
does
not
block
fish
migration
5
°
F
above
ambient;
does
not
block
fish
migration
DO
>
3
m
g/
L
at
mid
depth
>
3
m
g/
L
at
mid
depth
(
May
 
November)
>
5
mg/
L
at
mid
depth
except
under
extreme
conditions;
>
4
mg/
L
when
other
conditions
favorable
Color,
odor,
and
organoleptic
Will
not
render
waters
unsuitable
for
fish
survival
or
downstream
uses
Not
exhibit
acute
or
chronic
toxicity
or
interfere
with
downstream
uses
Not
exhibit
acute
or
chronic
toxicity
or
unreasonably
affect
the
aesthetic
value
of
waters
for
any
use
Toxic
pollutants
Will
not
render
waters
unsuitable
for
irrigation
of
agricultural
crops,
fish
survival,
or
downstream
uses
Will
not
exhibit
acute
or
chronic
toxicity
by
toxicity
testing
or
application
of
numeric
criteria;
use
7Q2
flow
for
calculating
limits
for
chronic
criteria
Will
not
exhibit
acute
or
chronic
toxicity
by
toxicity
testing
or
application
of
numeric
criteria;
use
7Q10
flow
for
calculating
limits
for
chronic
criteria
Fecal
coliform
bacteria
Geometric
mean
<
2,000/
100ml
with
a
maximum
<
4,000/
100ml
in
five
samples
over
a
30­
day
period,
separated
by
24
hours
Geometric
mean
<
1,000/
100ml
with
a
maximum
<
2,000/
100ml
in
five
samples
over
a
30­
day
period,
separated
by
24
hours
Geometric
mean
<
1,000/
100ml
with
a
maximum
<
2,000/
100ml
(
June
 
September,
geometric
mean
of
200/
100ml
when
use
is
water
contact
recreation)
in
five
samples
over
a
30­
day
period,
separated
by
24
hours
Source:
Alabama
State
Regulations
Chapter
335­
6­
10.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
4
1.3
Organization
of
Report
This
report
provides
the
following
sections
documenting
the
cost
and
pollutant
loading
reduction
analyses.
Chapter
2
describes
the
data
used
in
the
analyses.
Chapter
3
provides
a
detailed
description
of
the
methodologies.
Chapter
4
provides
results
and
discusses
uncertainties
in
the
analysis.
Several
appendices
further
document
the
data,
modeling,
and
facility­
level
analyses.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
5
2.
Data
In
analyzing
potential
costs
and
pollutant
loading
reductions
associated
with
the
use
upgrades,
EPA
used
stream
data,
facility
process
and
effluent
data,
and
modeling
results
from
a
number
of
sources.
These
data
are
described
in
the
sections
below.

2.1
Facility
Data
Exhibit
2­
1
lists
the
municipal
and
industrial
facilities
potentially
affected
by
the
use
designation
upgrades
for
Five
Mile
Creek,
Opossum
Creek,
Pepperell
Branch
(
of
Soughahatchee
Creek),
Shirtee
Creek,
Valley
Creek,
and
Village
Creek.
EPA
used
three
sources
of
data
on
these
facilities
in
its
analysis:

C
NPDES
permits,
applications,
fact
sheets,
and
inspection
reports
C
Discharge
monitoring
reports
for
the
most
recent
3
years
available
obtained
from
EPA's
Permit
Compliance
System
(
PCS)
(
or
EPA
Region
4)

C
Facility
wastewater
treatment
process
information
provided
by
EPA
Region
4.

Appendix
A
provides
a
listing
of
the
monitoring
data
available
for
the
analysis.

2.2
Water
Quality
Data
Alabama
water
quality
criteria
associated
with
A&
I,
LWF,
and
F&
W
use
differ
with
respect
to
both
conventional
and
toxic
pollutants.
EPA
evaluated
available
instream
data
for
these
pollutants
from
EPA's
water
quality
storage
and
retrieval
(
STORET
Legacy)
database
(
http://
epa.
gov/
storet)
and
2000
 
2001
data
provided
by
EPA
Region
IV
for
Valley
and
Village
Creeks.
EPA
obtained
flow
data
from
the
USGS
National
Water
Information
System
(
http://
water.
usgs.
gov/
nwis).

Appendix
B
provides
a
detailed
list
of
the
STORET
data
available
at
each
sampling
station
and
maps
locating
STORET
and
USGS
stations
on
Five
Mile,
Shirtee,
Valley,
and
Village
Creeks.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
6
Exhibit
2­
1.
Facilities
Potentially
Affected
by
the
Use
Upgrades
Facility
(
Capacity)
NPDES
Number
Major
Five
Mile
Creek
ABC
Coke
(
0.12
mgd)
AL0003417
Yes
Five
Mile
Creek
WWTP
(
20
mgd)
AL0026913
Yes
Sloss
Industries
(
3.2
mgd)
AL0003247
Yes
Opossum
Creek
Koppers
 
Coke
(
0.236
mgd)
AL0000680
No
Koppers
 
Tar
(
0.036
mgd)
AL0003221
No
USX
Fairfield
Works
(
11
mgd)
AL0003646
Yes
Pepperell
Branch
(
of
Soughahatchee
Creek)

Westpoint­
Stevens
Opelika
Finishing
Plant
(
1.85
mgd)
AL0002968
Yes
Shirtee
Creek
Avondale
Mills
(
2.0
mgd)
AL0001627
Yes
Earl
Ham
WWTP
(
2.4
mgd)
AL0020001
Yes
Valley
Creek
Valley
Creek
WWTP
(
85
mgd)
AL0023655
Yes
Village
Creek
American
Cast
Iron
Pipe
Company
(
0.55
mgd)
AL0029378
No
Ashland
Chemical
(
0.025
mgd)
AL0021695
Yes
Honeywell
International
(
0.06
mgd)
AL0021695
Yes
Miller
Steam
(
storm
water
only)
AL0027146
Yes
SMI
Steel
(
7.3
mgd)
AL0001554
Yes
Village
Creek
WWTP
(
60
mgd)
AL0023647
Yes
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
7
3.
Methods
This
chapter
describes
the
methods
EPA
used
to
estimate
the
potential
costs
and
pollutant
loading
reductions
associated
with
meeting
the
various
designated
uses.
As
a
first
step,
EPA
conducted
screening­
level
analyses
of
use
attainability
for
each
creek.
UAAs
can
indicate
circumstances
that
might
prevent
the
use
from
being
attained
and
help
identify
sources
(
e.
g.,
urban
runoff)
that
need
to
be
controlled.
Next,
EPA
estimated
the
required
effluent
limits
(
for
point
sources),
control
technologies,
and
costs
that
would
be
required
under
each
use
designation.
These
analyses
are
described
below.

3.1
Use
Attainability
As
described
above,
EPA
evaluated
use
attainability
using
available
data
as
a
means
determining
the
types
of
controls
that
would
be
required
to
meet
a
higher
designated
use.
This
analysis
is
described
in
detail
in
Appendix
F.

3.2
Estimating
Revised
Effluent
Limits
With
the
designation
of
LWF
or
F&
W
use,
more
stringent
criteria
apply
for
fecal
coliform
bacteria,
DO,
and
toxic
pollutants.
The
greater
stringency
of
receiving
water
criteria
often
requires
more
stringent
effluent
limits
to
be
placed
on
facilities
discharging
to
upgraded
waters.

Conventional
Pollutants
EPA
estimated
revised
effluent
limits
for
conventional
pollutants
at
permitted
facilities
when
a
segment
was
not
currently
attaining
the
receiving
water
criterion
for
the
higher
use
designation
and
a
facility
had
an
existing
effluent
limit
for
the
pollutant.
However,
EPA
did
not
estimate
new
fecal
coliform
limits
for
POTWs.
Instead,
it
assumed
that
disinfection
process
optimization
would
be
necessary
to
attain
the
fecal
coliform
criterion
for
F&
W
in
all
stream
segments
where
a
geometric
mean
of
200
per100
ml
is
not
now
being
attained
during
summer
months.
No
additional
controls
appeared
necessary
to
meet
a
LWF
classification.

EPA
ran
a
steady­
state
Streeter­
Phelps
model
to
predict
oxygen
concentrations
based
on
stream
and
effluent
characteristics
for
segments
that
might
have
difficulty
meeting
a
F&
W
use.
EPA
used
stream
parameters
in
the
model
from
similar
analyses
run
by
ADEM,
using
the
7Q10
stream
flow,
summer
temperatures,
and
discharges
of
BOD,
ammonia,
and
Kjeldahl
nitrogen.
If,
based
on
these
runs,
the
resulting
DO
levels
would
not
comply
with
the
use
requirements,
EPA
reduced
point
source
loads
of
BOD
and
ammonia
at
the
facilities
proportionately
until
the
higher
use
criterion
was
attained
in
the
receiving
water.
The
effluent
concentrations
used
in
the
simulation
that
obtained
the
higher
use
DO
criterion
became
the
revised
effluent
limits
for
each
facility.

Toxic
Pollutants
Some
facilities
that
now
discharge
toxic
pollutants
have
only
best
available
technology
(
BAT)
effluent
limits
for
a
range
of
toxic
pollutants.
Therefore,
for
each
pollutant
limited
at
each
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
8
facility,
EPA
calculated
water
quality­
based
limits
based
on
the
A&
I
acute
aquatic
life
and
human
health
criteria.
These
effluent
limits
apply,
but
often
have
not
been
implemented,
in
facility
permits.
EPA
then
estimated
effluent
limits
for
all
toxic
pollutants
based
on
the
acute
and
chronic
aquatic
life
criteria
and
the
human
health
criterion
(
for
organisms
only)
that
would
apply
under
a
F&
W
classification.

EPA
estimated
revised
effluent
limits
only
for
those
pollutants
that
had
a
reasonable
potential
to
cause
or
contribute
to
an
instream
criterion
exceedance.
EPA
determined
reasonable
potential
by
comparing
the
receiving
water
concentration
that
would
result
from
discharge
of
the
maximum
effluent
concentration
at
different
receiving
water
flows
with
appropriate
criteria
(
Note
that
the
receiving
water
concentration
is
a
function
of
the
mean
background
receiving
water
concentration,
the
effluent
concentration,
and
relative
effluent
design
flow
and
receiving
water
flows).
For
a
F&
W
classification,
EPA
compared
the
receiving
water
concentration
using
a
1Q10
receiving
water
flow
to
the
acute
criterion,
the
receiving
water
concentration
using
a
7Q10
receiving
water
flow
to
the
chronic
criterion,
and
the
receiving
water
concentration
using
average
flow
to
the
human
health
criterion.
For
LWF
use,
EPA
substituted
the
2Q10
for
the
7Q10
for
chronic
criteria
used
in
the
F&
W
analysis.
EPA
determined
that
pollutants
for
which
the
maximum
concentration
would
cause
an
exceedance
of
any
one
criterion
had
reasonable
potential.

EPA
calculated
the
revised
effluent
limits
according
to
the
two­
value
steady­
state
wasteload
allocation
procedure
specified
in
the
Technical
Support
Document
for
Water
Quality­
based
Toxics
Control
(
EPA
1991).
As
in
determining
reasonable
potential,
EPA
determined
wasteload
allocations
(
WLA)
for
a
facility
based
on
acute,
chronic,
and
human
health
criteria
using
the
facility
design
flow
and
the
1Q10,
7Q10
(
or
7Q2),
and
average
receiving
water
flows,
respectively,
and
the
mean
receiving
water
concentration.

EPA
assumed
coefficients
of
variation
(
CVs)
of
0.6
for
the
facilities
and
pollutants
because
available
data
did
not
contain
individual
effluent
concentrations,
but
averages
or
maxima
of
concentrations
observed
over
specified
months.
Using
the
assumed
CVs,
EPA
determined
the
minimum
long­
term
average
(
LTA)
effluent
concentration
that
would
allow
compliance
with
each
criterion.
The
effluent
limit
then
becomes
the
limit
calculated
from
the
most
stringent
LTA.
If
the
human
health
criterion
had
the
limiting
LTA,
EPA
set
the
average
monthly
limit
(
AML)
to
the
human
health
WLA.
Similarly,
if
the
acute
criterion
had
the
limiting
LTA,
EPA
set
the
AML
to
the
acute
LTA
times
3.11.
Finally,
if
the
chronic
criterion
had
the
limiting
LTA,
EPA
set
the
AML
to
the
chronic
LTA
times
1.55.
The
multipliers
are
based
on
the
assumed
CV
of
0.6.
For
limits
based
on
the
chronic
criterion,
EPA
chose
a
95th
percentile
probability
basis
and
4
samples
per
month
to
determine
the
multipliers.
For
limits
based
on
the
acute
criterion,
EPA
chose
a
99th
percentile
probability
basis
and
one
sample
per
month.

3.3
Determining
Necessary
Pollution
Controls
EPA
determined
the
necessary
controls
on
point
sources
to
reduce
effluent
concentrations
to
the
required
level
by
first
evaluating
whether
low
cost
control
option
would
be
feasible
and
then
considering
more
costly
controls
if
necessary.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
9
EPA
considered
the
lowest
cost
option
 
adjustment
of
existing
treatment
(
process
optimization)
 
to
be
feasible
if
literature
indicated
that
the
existing
treatment
process
could
achieve
the
revised
effluent
limit
or
when
the
additional
pollutant
reduction
was
relatively
small
(
e.
g.,
10%
to
25%
of
current
discharge
levels).

Where
it
was
not
technically
feasible
to
simply
adjust
existing
operations,
EPA
selected
the
next
most
attractive
control
strategy:
waste
minimization/
pollution
prevention
controls.
However,
EPA
developed
costs
for
these
controls
only
when
the
reviewing
engineer
considered
them
feasible
for
the
treatment
processes
at
a
given
facility.
Decision
considerations
included
the
level
of
pollutant
reduction
achievable
through
waste
minimization/
pollution
prevention
techniques,
appropriateness
of
waste
minimization/
pollution
prevention
for
specific
pollutants,
and
knowledge
of
the
manufacturing
processes
generating
the
pollutant
of
concern.
In
general,
NPDES
permit
files
did
not
contain
detailed
information
on
treatment
and
manufacturing
processes.
EPA
Region
4
provided
some
process
information.
EPA
also
used
best
professional
judgment
based
on
general
knowledge
of
industrial
and
municipal
operations.

If
waste
minimization/
pollution
prevention
alone
would
not
be
feasible
to
reduce
pollutant
levels
to
those
needed
to
comply
with
projected
effluent
limits,
EPA
considered
a
combination
of
waste
minimization/
pollution
prevention,
simple
treatment,
and/
or
process
optimization.
If
these
relatively
low­
cost
controls
could
not
achieve
the
projected
effluent
limits,
EPA
considered
additional
treatment.

Development
of
treatment
cost
estimates
began
with
a
review
of
the
existing
treatment
systems
at
each
facility.
For
determining
the
need
for
additional
or
supplemental
treatment,
sources
of
performance
information
included
the
EPA
Office
of
Research
and
Development
Risk
Reduction
Engineering
Laboratory's
RREL
Treatability
Database
(
Version
4.0).
EPA
evaluated
the
pollutant
removal
capabilities
of
the
existing
treatment
systems
and/
or
any
proposed
additional
or
supplemental
systems
using
the
following
criteria:
(
1)
the
current
effluent
levels
achieved
by
the
facility
and
(
2)
the
levels
that
are
documented
in
the
RREL
Treatability
Database.
If
this
analysis
showed
that
additional
treatment
was
needed,
EPA
identified
unit
processes
that
would
achieve
compliance
with
the
projected
effluent
limits
using
the
same
documentation.

EPA
determined
that
controls
on
nonpoint
sources
would
be
required
for
all
streams
that
do
not
currently
meet
instream
criteria
for
A&
I,
LWF,
or
F&
W
uses.
Evaluation
of
landuse
data
indicated
that
the
source
of
pollutants
of
concern
is
likely
the
urban
areas
in
the
vicinity
of
the
creeks.
In
the
absence
of
detailed
knowledge
of
the
existing
storm
water
management
systems,
EPA
assumed
that
storm
water
detention
systems
would
be
retrofit
in
urban
areas
that
drain
to
affected
streams.
Detention
systems
generally
reduce
metals,
BOD,
and
fecal
coliforms,
the
three
pollutants
that
cause
instream
exceedances
in
the
affected
stream
segments.
Removal
efficiencies
can
be
as
high
as
80%
for
these
pollutants,
depending
on
the
design
of
the
system
(
Rouge
River
National
Wet
Weather
Demonstration
Project
Cost
Estimating
Guidelines,
2001).
Land
use
data
for
the
creeks
requiring
nonpoint
source
controls
is
provided
in
Appendix
G.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
10
3.4
Estimating
the
Cost
of
Pollution
Controls
EPA
estimated
the
cost
of
pollution
controls
for
point
and
nonpoint
sources
using
available
estimates
from
the
literature.

Treatment
Process
Optimization
Costs
Treatment
process
optimization
refers
to
measures
facilities
can
implement
to
modify
or
adjust
the
operating
efficiency
of
their
wastewater
treatment
process.
Such
measures
usually
involve
engineering
analysis
of
existing
treatment
processes
to
identify
minor
adjustments
to
enhance
pollutant
removal
or
reduce
chemical
additions
(
e.
g.,
chlorine)
that
can
result
in
toxic
byproducts,
followed
by
implementation
of
such
adjustments.
The
costs
for
treatment
process
optimization
vary
according
to
the
specific
type
of
treatment
process
used
at
a
site.
EPA
estimated
the
costs
of
treatment
process
optimization
for
chlorination/
dechlorination
as
10%
of
the
total
treatment
process
costs.
For
organic
pollutant
removal,
optimization
costs
are
based
on
Truax
(
1992).

Exhibit
3­
1.
Estimated
Treatment
Process
Optimization
Costs
Treatment
Process
Facility
Effluent
Flow
(
in
MGD)

<
1
1
 
<
10
>
10
Chlorination/
Dechlorination1
not
estimated
$
7,400
$
24,000
Biological
Treatment2
$
125,000
$
170,000
$
233,000
Organic
pollutant
removal2
$
60,000
$
88,000
$
135,000
1Estimated
as
10%
of
total
treatment
process
cost.
2Based
on
Truax
(
1992).

Process
analysis
is
a
key
factor
in
achieving
optimum
treatment
efficiency.
Process
analysis
is
a
time­
consuming
investigation
to
determine
performance­
limiting
factors.
Performance­
limiting
factors
include
operator
training,
response
to
changes
in
wastewater
quality,
individual
treatment
unit
design
limits,
maintenance
activities,
automation,
process
control
testing,
and
administrative
factors
such
as
the
number
of
trained
staff
to
run
a
facility
at
all
times.
The
cost
of
process
analysis
includes
the
cost
of
site
visits,
additional
monitoring
at
selected
sites,
data
collection,
data
analysis,
and
report
preparation.
Process
analysis
also
includes
post
process
modification
treatment
performance
evaluation.

Process
modifications
include
activities
short
of
adding
a
new
treatment
technology
units
(
conventional
or
unconventional)
to
the
treatment
train.
Process
modifications
may
include
one
or
more
of
the
following:
hydraulic
regime
modification,
treatment
train
modification,
chemical
adjustment,
operator
training,
installation
of
process
control
testing
equipment,
installation
of
automation
equipment
including
necessary
hardware
and
software.
Several
months
of
control
system
adjustment
may
be
needed
to
achieve
a
desired
level
of
process
optimization
due
to
anticipated
problems
(
e.
g.,
pump
rate
synchronization
with
varied
levels
of
treatment
parameters
such
pH,
temperature,
etc.).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
11
Waste
Minimization/
Pollution
Prevention
Costs
When
EPA
lacked
information
for
developing
alternative
treatment
or
where
existing
effluent
concentrations
were
close
to
projected
effluent
limits,
it
assumed
that
it
would
be
more
appropriate
and
technically
efficient
for
a
facility
to
use
waste
minimization
or
pollution
prevention
activities
rather
than
provide
additional
or
supplemental
treatment
units.
EPA
also
assumed
that
a
facility
would
incur
costs
to
implement
a
waste
minimization
or
pollution
prevention
practice
that
would
be
adequate
to
comply
with
the
projected
effluent
limit.
Waste
minimization
or
pollution
prevention
practices
could
include
the
installation
of
equipment,
best
management
practices,
and
production/
process
changes
at
industrial
facilities,
and
modifications
to
pretreatment
requirements
for
POTWs.

The
costs
for
implementing
waste
minimization/
pollution
prevention
controls
are
taken
from
EPA's
cost
analysis
for
the
proposed
Great
Lakes
Water
Quality
Guidance
(
U.
S.
EPA,
1993).
The
unit
waste
minimization/
pollution
prevention
costs
used
for
this
analysis
are
for
POTWs.
The
estimated
total
cost
is
$
488,000,
updated
to
year
2001
dollars
using
the
Consumer
Price
Index.

The
feasibility
of
waste
minimization
cannot
be
determined
without
process­
specific
information.
In
general,
however,
relatively
simple,
inexpensive
source
controls,
best
management
practices,
and
process
changes
have
been
shown
to
result
in
significant
pollution
reductions
as
well
as
savings
in
raw
materials.

New/
Additional
Treatment
Systems
EPA
estimated
capital
costs
for
those
facilities
for
which
new/
additional
treatment
was
needed.
After
EPA
selected
an
appropriate
treatment
system,
EPA
extracted
the
costs
from
cost
curves
available
in
Treatability
Manual,
Volume
IV:
Cost
Estimating
(
U.
S.
EPA,
1980).
Capital
costs
are
total
capital
costs
and
include
the
cost
of
the
equipment,
design,
and
installation.
EPA
escalated
costs
to
2001
dollars
using
the
Engineering
News
Record
(
ENR)
Construction
Cost
Index.

O&
M
costs
are
annual
costs
associated
with
operating
and
maintaining
the
equipment,
treatment
chemicals,
and
energy.
EPA
also
derived
these
expenses
from
cost
curves
taken
from
U.
S.
EPA
(
1980).
EPA
escalated
costs
to
2001
dollars
using
the
ENR
Construction
Cost
Index.
EPA
assumed
that
residuals
management
and
any
required
additional
monitoring
are
included
in
the
O&
M
costs.
Generally,
these
costs
are
1%
or
less
of
annualized
costs.

Storm
Water
Runoff
Controls
EPA
estimated
the
cost
of
storm
water
controls
for
facilities
that
had
permit
limits
or
reporting
requirements
for
a
pollutant
in
storm
water
on
streams
that
exceeded
instream
aquatic
life
or
human
health
criteria.
EPA
estimated
costs
based
on
a
300,000
ft3
storm
water
detention
system
that
would
remove
a
large
percentage
of
the
metal
constituents
that
were
exceeded
in
the
receiving
water.
The
cost
of
$
227,300
was
taken
from
the
Rouge
River
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
12
National
Wet
Weather
Demonstration
Project
Cost
Estimating
Guidelines
(
http://
www.
wcdoe.
org/
rougeriver/
pdfs/
stormwater/
sr10.
pdf)
and
updated
to
2001
dollars.

Nonpoint
Sources
Controls
EPA
estimated
the
cost
of
urban
nonpoint
source
controls
by
acreage.
For
high­
density
residential,
commercial,
industrial,
and
transportation
land,
EPA
used
a
cost
of
$
10,600
an
acre
(
or
$
1000/
acre
annualized
at
7%
over
20
years).
For
low
density
residential
land,
EPA
used
a
cost
of
$
4,000
per
acre
(
or
$
377/
acre
annualized
at
7%
over
20
years).
The
costs
are
averages
(
updated
to
2001
dollars
using
the
Engineering
News
Record
Construction
Cost
Index)
of
urban
storm
water
retrofitting
projects
in
Florida
(
See
Appendix
G).
EPA
assumed
that
agriculture,
forestry,
and
other
undeveloped
land
uses
contribute
little
to
the
metals
impairments
that
occur
in
the
creeks
and
did
not
estimate
costs
for
these
sources.

3.5
Estimating
Pollutant
Loading
Reductions
EPA
calculated
loading
reductions
by
subtracting
the
estimated
effluent
loading
(
the
AML
times
the
design
flow
and
appropriate
conversion
factor)
under
the
higher
designated
use
from
the
estimated
loading
under
the
lower
use.
To
calculate
a
current
pollutant
loading,
EPA
multiplied
the
maximum
effluent
concentration
times
the
design
flow
and
an
appropriate
conversion
factor.

For
toxic
pollutants,
EPA
also
calculated
toxic­
weighted
loading
reductions
by
multiplying
by
toxicity
weighting
factors
that
standardize
toxicity
to
the
toxicity
of
copper
(
U.
S.
EPA,
1988).
Toxicity
factors
are
derived
primarily
from
EPA
chronic
freshwater
aquatic
criteria
and
toxicity
values.
However,
EPA
human
health
criteria
also
are
used
in
cases
in
which
EPA
established
a
human
health
criterion
for
fish
consumption.
To
calculate
toxic
pound­
equivalents
for
each
pollutant,
EPA
multiplied
the
pollutant
loading
reduction
for
each
facility
by
the
appropriate
toxic
weight
for
that
pollutant.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
13
4.
Results
This
chapter
provides
a
summary
of
the
costs
and
pollutant
loading
reductions
required
for
the
six
creeks
to
meet
the
different
uses.
More
detailed
stream
and
facility
level
results
are
provided
in
Appendix
F.

4.1
Estimated
Costs
Exhibit
4­
1
provides
a
summary
of
the
estimated
costs
for
each
creek.
As
shown
in
the
exhibit,
the
largest
cost
is
associated
with
meeting
the
baseline
use
designation
(
A&
I).
Costs
to
meet
the
baseline
use
reflect
controls
needed
for
point
and
nonpoint
sources.
Nonpoint
source
costs
reflect
municipal
runoff
controls
(
see
Appendix
G).
However,
Jefferson
County,
in
which
Five
Mile,
Valley,
and
Village
Creeks
are
located,
is
under
a
1995
Consent
Agreement
with
U.
S.
EPA
to
eliminate
sanitary
sewer
overflows
and
frequent
bypasses
of
the
treatment
facilities.
Eliminating
overflows
and
treatment
bypasses
may
reduce
or
eliminate
the
need
for
the
nonpoint
source
control
costs
shown.
Incremental
costs
to
meet
a
LWF
use
reflect
controls
needed
for
point
sources
to
reduce
loadings
of
toxic
pollutants.
Incremental
costs
to
meet
a
F&
W
reflect
controls
needed
for
point
sources
to
reduce
conventional
pollutants.

Exhibit
4­
1.
Estimated
Annual
Costs
to
Achieve
Use
Classifications1
(
Millions
of
Year
2001
Dollars)

Creek
A&
I2
LWF5
F&
W6
Point
Sources3
Nonpoint
Sources4
Total
Five
Mile
Creek
3.82
5.96
9.8
0
0.07
Opossum
Creek
2.46
0
2.46
0.26
0.13
Pepperell
Branch7
0
0
0
0
0.00
Shirtee
Creek
0
0
0
0
0.07
Valley
Creek
0.05
10.8
10.8
0
0.10
Village
Creek
0.68
12.9
13.6
0
0.05
Total
7.01
29.6
36.7
0.26
0.42
1Reflects
capital
costs
annualized
at
7%
over
20
years
plus
annual
O&
M
costs.
2The
creeks
are
currently
designated
for
A&
I
use
and
thus
this
is
the
baseline
for
the
rule.
Costs
attributable
to
meeting
A&
I
use
result
from
facilities
not
meeting
their
current
permit
limits
or
having
permit
limits
that
do
not
reflect
A&
I
criteria.
3Costs
reflect
controls
for
industrial
and
municipal
point
sources
to
reduce
toxic
pollutants.
4Costs
reflect
municipal
runoff
controls
(
see
Appendix
G).
However,
Jefferson
County,
in
which
Five
Mile,
Valley,
and
Village
Creeks
are
located,
is
under
a
1995
Consent
Agreement
with
U.
S.
EPA
to
eliminate
sanitary
sewer
overflows
and
frequent
bypasses
of
the
treatment
facilities.
Eliminating
overflows
and
treatment
bypasses
may
reduce
or
eliminate
the
need
for
the
nonpoint
source
control
costs
shown.
5Costs
reflect
controls
for
industrial
and
municipal
point
sources
to
reduce
toxic
pollutants.
6Costs
reflect
controls
for
industrial
and
municipal
point
sources
to
reduce
conventional
pollutants.
7Controls
(
and
hence
costs)
may
be
required
at
the
Westpoint­
Stevens
facility
on
Pepperell
Branch
(
see
Appendix
F).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
14
4.1.1
Five
Mile
Creek
Analysis
of
available
data
indicate
that
both
point
and
nonpoint
sources
would
be
necessary
to
meet
designated
uses
along
Five
Mile
Creek.
However,
most
of
the
costs
reflect
a
need
for
further
controls
to
meet
the
baseline
(
A&
I)
use.

Conventional
Pollutants
Fecal
coliform
numbers
in
Five
Mile
Creek
exceed
the
geometric
mean
criterion
of
200
per100
ml
for
a
F&
W
use.
The
likely
source
of
fecal
coliforms
is
the
Five
Mile
Creek
WWTP.
This
facility
does
not
have
a
limit
for
fecal
coliforms
and
there
are
no
effluent
data
for
this
pollutant.
However,
optimization
of
the
existing
chlorination
process
at
the
facility
would
likely
reduce
fecal
coliform
in
the
effluent
to
levels
that
would
meet
the
F&
W
criterion.

Analysis
of
instream
data
on
DO
and
facility
discharges
on
Five
Mile
Creek
indicates
that
no
additional
controls
would
be
needed
to
meet
a
F&
W
criterion.

Toxic
Pollutants
Analysis
of
effluent
monitoring
data
indicates
that
two
industries
on
Five
Mile
Creek
(
ABC
Coke
and
Sloss
Industries)
that
require
additional
controls
to
meet
A&
I
acute
aquatic
life
or
human
health
criteria
for
PAHs,
cyanide,
ammonia,
and
metals
(
See
Appendix
D
for
details
of
the
ammonia
analysis).
Both
facilities
would
comply
with
projected
effluent
limits
with
the
addition
of
chemical
oxidation.
Sloss
Industries
would
also
require
additional
chemical
precipitation
to
control
discharges
of
metals
and
a
detention
basin
to
treat
storm
water
for
zinc.
The
addition
of
these
controls
to
meet
an
A&
I
use
would
also
allow
both
facilities
to
meet
effluent
limits
based
on
either
a
LWF
or
F&
W
standard.

Instream
data
indicate
that
Five
Mile
Creek
exceeds
the
human
health
criterion
for
mercury
and
mercury
is
commonly
found
in
WWTP
effluents.
The
Five
Mile
Creek
WWTP
would
achieve
the
highest
quality
effluent
for
mercury
with
a
waste
minimization
program
that
would
reduce
inputs
to
the
plant
at
the
source.
This
program
is
necessary
to
meet
the
A&
I
human
health
criterion
for
mercury.
Development
of
a
program
would
also
ensure
compliance
with
criteria
required
by
LWF
and
F&
W
classifications.

Nonpoint
Sources
As
shown
in
Exhibit
4­
2,
the
instream
concentrations
of
copper,
mercury,
lead,
and
zinc
in
Five
Mile
Creek
exceed
relevant
acute,
chronic,
or
human
health
criteria.
Potential
sources
of
these
metals
include
combined
sewer
overflows
and
urban
runoff.
Jefferson
County
is
under
a
1995
Consent
Agreement
to
reduce
combined
sewer
overflows,
but
unsewered
areas
could
also
be
contributing
to
instream
exceedances
of
these
pollutants.
There
is
no
basis
for
estimating
resulting
concentrations
once
combined
sewer
overflows
are
eliminated.
To
ensure
that
the
different
uses
are
met
instream,
the
existing
storm
water
management
system
in
the
area
might
need
to
be
retrofit
with
storm
water
controls.
Nonpoint
source
controls
for
Five
Mile
Creek
may
or
may
not
be
part
of
Phase
I
storm
water
program
activities
for
the
City
of
Birmingham.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
15
Exhibit
4­
2.
Estimated
Annual
Nonpoint
Source
Control
Costs1
(
Millions
of
Year
2001
Dollars)

Creek
Pollutants
Requiring
Controls
A&
I
Cost
LWF/
F&
W
Cost
Five
Mile
Creek
A&
I2:
copper,
zinc,
mercury
LWF/
F&
W3:
lead
5.96
0
Opossum
Creek
None
0
0
Pepperell
Branch
No
data
0
0
Shirtee
Creek
No
data
0
0
Valley
Creek
A&
I2:
zinc,
mercury
F&
W3:
lead
10.8
0
Village
Creek
A&
I2:
zinc,
mercury
F&
W3:
lead
12.9
0
TOTAL
29.6
0
1Reflects
capital
costs
annualized
at
7%
over
20
years.
2Pollutants
which
exceed
the
acute
water
quality
criterion
for
more
than
10%
of
all
observations.
3Pollutants
which
exceed
the
chronic
water
quality
criterion
for
more
than
10%
of
all
observations
but
do
not
exceed
the
acute
criterion
for
more
than
10%
of
all
observations.

4.1.2
Opossum
Creek
Similar
to
Five
Mile
Creek,
most
of
the
costs
for
Opossum
Creek
reflect
a
need
for
further
controls
to
meet
the
baseline
(
A&
I)
use.

Conventional
Pollutants
There
are
no
facilities
that
discharge
fecal
coliforms
in
Opossum
Creek.

The
current
discharges
of
BOD,
ammonia,
and
total
Kjeldahl
nitrogen
from
USX
and
the
Koppers
facilities
will
allow
a
3
mg/
L
A&
I
criterion
as
well
as
the
3/
5
mg/
L
LWF
criterion
to
be
met
(
an
ammonia
discharge
from
Koppers
Coke
would
be
reduced
to
acceptable
levels
by
controls
for
cyanide).
USX
would
need
to
add
activated
sludge
treatment
to
meet
a
year­
round
5
mg/
L
F&
W
criterion.
Appendix
E
provides
details
of
the
DO
analysis
for
Opossum
Creek.

Toxic
Pollutants
Analysis
of
discharge
data
indicate
that
Koppers
Coke
requires
additional
treatment
to
meet
A&
I
cyanide
criteria.
With
chemical
oxidation
at
this
facility,
A&
I
criteria
will
be
met
instream.
No
additional
controls
would
be
necessary
to
meet
either
LWF
or
F&
W
criteria
because
the
small
additional
reductions
required
(
less
than
5%
of
the
reductions
required
to
meet
A&
I
criteria)
would
be
obtained
with
the
treatment
to
achieve
A&
I
criteria.

USX
would
need
to
reduce
lead
discharges
to
comply
with
criteria
for
both
LWF
and
F&
W
uses.
The
addition
of
a
chemical
precipitation
unit
should
allow
discharges
to
be
sufficiently
reduced
to
meet
projected
effluent
limits
for
lead.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
16
Nonpoint
Sources
Available
data
indicated
that
the
revised
effluent
limits
for
point
sources
would
allow
the
higher
uses
to
be
attained
in
Opossum
Creek.

4.1.3
Pepperell
Branch
Analysis
of
available
data
indicate
that
there
are
no
costs
for
this
creek.
However,
as
described
below,
data
for
the
Westpoint­
Stevens
facility
are
limited
and
prevent
full
analysis
of
this
segment.

Conventional
Pollutants
No
controls
for
fecal
coliforms
would
be
required
on
Pepperell
Branch
to
achieve
a
F&
W
criterion.

Instream
DO
data
indicate
that
oxygen
levels
are
reduced
near
the
Westpoint­
Stevens
Opelika
facility.
Although
there
is
insufficient
information
for
a
full
assessment,
the
Westpoint­
Stevens
Opelika
facility
may
need
additional
controls
to
meet
DO
criteria
for
A&
I,
LWF,
or
F&
W.
Additional
data
are
required
to
quantify
the
reductions
needed
and
estimate
controls
and
costs.

Toxic
Pollutants
There
are
no
data
that
indicate
that
toxics
would
exceed
appropriate
criteria
in
Pepperell
Branch.
The
Westpoint
Stevens
facility
currently
discharges
at
levels
that
comply
with
projected
effluent
limits
for
A&
I,
LWF,
and
F&
W
uses.

Nonpoint
Sources
There
are
no
data
on
which
to
assess
the
need
for
nonpoint
source
controls
for
Pepperell
Branch.

4.1.4
Shirtee
Creek
There
are
no
costs
associated
with
attaining
A&
I
or
LWF
uses
and
only
minimal
costs
to
meet
a
F&
W
use
on
Shirtee
Creek.

Conventional
Pollutants
Fecal
coliform
data
indicate
that
the
maximum
allowable
numbers
of
fecal
coliform
bacteria
for
a
F&
W
use
designation
may
be
exceeded
in
Shirtee
Creek.
Process
optimization
of
the
chlorination/
dechlorination
process
at
the
Earl
Ham
WWTP
should
ensure
that
a
F&
W
criterion
will
be
met.
A&
I
and
LWF
criteria
for
fecal
coliforms
are
currently
being
attained.

Both
Avondale
Mills
and
the
Earl
Ham
WWTP
comply
with
a
wasteload
allocation
that
was
developed
in
1993
to
determine
loadings
required
to
meet
5
mg/
L
at
all
times.
No
additional
controls
are
required.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
17
Toxic
Pollutants
Both
Avondale
Mills
and
Earl
Ham
WWTP
appear
to
comply
with
projected
effluent
limits
under
a
F&
W
use
designation.

Nonpoint
Sources
There
are
no
data
with
which
to
assess
the
need
for
nonpoint
source
controls
for
Shirtee
Creek.

4.1.5
Valley
Creek
Costs
for
Valley
Creek
are
primarily
associated
with
meeting
the
baseline
(
A&
I)
use.
No
additional
costs
are
required
to
meet
LWF
and
only
minimal
costs
are
associated
with
meeting
F&
W
use.

Conventional
Pollutants
Analysis
of
discharges
from
the
Valley
Creek
WWTP
indicate
that
it
marginally
complies
with
a
F&
W
criterion
for
fecal
coliforms.
Process
optimization
of
chlorination
should
allow
the
criterion
to
be
met
instream.

Toxics
Pollutants
Valley
Creek
WWTP
would
not
comply
with
projected
effluent
limits
for
hexavalent
chromium
and
cyanide.
The
sources
of
these
pollutants
is
likely
indirect
discharges
from
industrial
facilities.
Therefore,
waste
minimization
programs
for
hexavalent
chromium
and
cyanide
at
the
Valley
Creek
WWTP
should
allow
instream
A&
I
criteria
to
be
met.
The
reductions
of
these
pollutants
required
to
meet
A&
I
use
are
large
compared
to
the
small
additional
reductions
to
meet
projected
effluents
limits
for
LWF
and
F&
W.
The
additional
reductions
will
likely
be
met
with
the
programs
implemented
to
achieve
A&
I
use.

Valley
Creek
exceeds
the
human
health
criterion
for
mercury.
Although
the
Valley
Creek
WWTP
is
not
know
to
discharge
mercury,
mercury
is
a
common
pollutant
in
POTW
effluents.
A
waste
minimization
program
for
mercury
would
allow
instream
mercury
criteria
to
be
met.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
18
Nonpoint
Sources
Valley
Creek
exceeds
A&
I
criteria
for
zinc
and
the
lead
and
mercury
LWF
and
F&
W
criteria
(
Exhibit
4­
2).
Potential
sources
of
these
metals
include
combined
sewer
overflows
and
urban
runoff.
Jefferson
County
is
under
a
1995
Consent
Agreement
with
U.
S.
EPA
to
reduce
combined
sewer
overflows,
but
unsewered
areas
could
also
be
contributing
to
instream
exceedances
of
these
pollutants.
There
is
no
basis
for
estimating
resulting
concentrations
once
combined
sewer
overflows
are
eliminated.
To
ensure
that
the
different
uses
are
met
instream,
the
existing
storm
water
management
system
in
the
area
might
need
to
be
retrofit
with
storm
water
controls.
Nonpoint
source
controls
for
Valley
Creek
may
or
may
not
be
part
of
Phase
I
storm
water
activity
for
the
City
of
Birmingham.

4.1.6
Village
Creek
Costs
for
Village
Creek
reflect
controls
on
point
and
nonpoint
sources
to
meet
the
baseline
(
A&
I)
use.

Conventional
Pollutants
Instream
data
on
fecal
coliforms
and
DO
below
the
discharges
to
Village
Creek
indicate
that
no
additional
controls
would
be
needed
to
meet
criteria
for
A&
I,
LWF,
or
F&
W
uses.

Toxic
Pollutants
American
Cast
Iron
Pipe
Company
requires
additional
controls
for
copper
and
zinc
to
meet
projected
effluent
limits
based
on
A&
I
criteria
and
controls
for
lead
to
meet
projected
effluent
limits
based
on
LWF
and
F&
W
criteria.
The
addition
of
chemical
precipitation
should
be
adequate
to
control
copper
and
zinc,
and
this
treatment
would
incidentally
remove
lead
to
required
levels
to
meet
projected
effluent
limits
for
lead.

Village
Creek
WWTP
requires
controls
to
meet
projected
effluent
limits
based
on
A&
I
criteria
for
cyanide
and
hexavalent
chromium.
Since
both
are
industrial
pollutants,
waste
minimization
programs
would
identify
and
reduce
effluent
concentrations
to
levels
that
would
comply
with
projected
limits.
Because
Village
Creek
exceeds
the
human
health
criterion
for
mercury
and
POTWs
are
a
common
source
of
mercury,
a
pollutant
minimization
program
for
mercury
is
also
needed.

Nonpoint
Sources
Village
Creek
exceeds
the
A&
I
criteria
for
zinc
and
the
LWF
and
F&
W
criteria
for
lead
and
mercury
(
Exhibit
4­
2).
Potential
sources
of
these
metals
include
combined
sewer
overflows
and
urban
runoff.
Jefferson
County
is
under
a
1995
Consent
Agreement
with
U.
S.
EPA
to
reduce
combined
sewer
overflows,
but
unsewered
areas
could
also
be
contributing
to
instream
exceedances
of
these
pollutants.
There
is
no
basis
for
estimating
resulting
concentrations
once
combined
sewer
overflows
are
eliminated.
To
ensure
that
the
different
uses
are
met
instream,
the
existing
storm
water
management
system
in
the
area
might
need
to
be
retrofit
with
storm
water
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
19
controls.
Nonpoint
source
controls
for
Village
Creek
may
or
may
not
be
part
of
Phase
I
storm
water
activity
for
the
City
of
Birmingham.

4.2
Pollutant
Loading
Reductions
Exhibits
4­
3
through
4­
5
present
the
estimated
incremental
pollutant
loading
reductions
and
annual
costs
associated
with
point
source
controls
to
meet
the
baseline
use
(
A&
I),
LWF,
and
F&
W
uses
(
loading
reductions
and
costs
associated
with
nonpoint
source
controls
are
not
included).

Exhibit
4­
3.
Estimated
Annual
Point
Source
Costs
and
Pollutant
Load
Reductions
for
an
A&
I
Use
Classification
Segment
Pollutant
Reduction
Cost
Pounds
Toxic
Poundequivalents
Total
(
millions)
Per
Toxic
Poundequivalent
Five
Mile
Creek1
5,054
5,488
$
3.79
$
690.60
Opossum
Creek
58,495
60,235
$
2.46
$
40.84
Pepperell
Branch
0
0
$
0
$
0
Shirtee
Creek
0
0
$
0
$
0
Valley
Creek
4,330
153,715
$
0.04
$
0.26
Village
Creek
1,574,159
1,768,574
$
0.33
$
0.19
Total
1,642,038
1,988,012
$
6.62
$
3.332
1Does
not
include
reductions
in
ammonia
at
ABC
Coke
and
Sloss
because
their
current
permit
limit
is
more
stringent
than
the
projected
A&
I,
LWF,
and
F&
W
limits
(
costs
reflect
controls
for
other
pollutants
necessary
to
meet
A&
I
and
so
are
included).
2Represents
sum
of
total
costs
divided
by
sum
of
toxic
pound­
equivalents.

Exhibit
4­
4.
Estimated
Annual
Point
Source
Costs
and
Pollutant
Load
Reductions
for
an
LWF
Use
Classification1
Segment
Pollutant
Reduction
Cost
Pounds
Toxic
Poundequivalents
Total
(
millions)
Per
Toxic
Poundequivalent
Five
Mile
Creek
0
0
$
0
$
0
Opossum
Creek
1,013
1,823
$
0.26
$
142.59
Pepperell
Branch
0
0
$
0
$
0
Shirtee
Creek
0
0
$
0
$
0
Valley
Creek
0
0
$
0
$
0
Village
Creek
0
0
$
0
$
0
Total
1,013
1,823
$
0.26
$
142.59
1
Reductions
and
costs
are
additional
to
those
to
meet
an
A&
I
classification.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
20
Exhibit
4­
5.
Estimated
Annual
Point
Source
Costs
and
Pollutant
Load
Reductions
for
a
F&
W
Use
Classification1
Segment
Pollutant
Reduction
Cost
Pounds
Toxic
Poundequivalents
Total
(
millions)
Per
Toxic
Poundequivalent
Five
Mile
Creek
0
0
$
0
$
0
Opossum
Creek
54,750
54,750
$
0.13
$
2.37
Pepperell
Branch
0
0
$
0
$
0
Shirtee
Creek
0
0
$
0
$
0
Valley
Creek
0
0
$
0
$
0
Village
Creek
0
0
$
0
$
0
Total
54,750
54,750
$
0.13
$
2.37
1
Reductions
and
costs
are
additional
to
those
required
to
meet
A&
I
and
LWF
classifications.

4.3
Limitations
of
the
Analysis
Exhibit
4­
6
provides
a
summary
of
the
limitations
of
the
analysis.
Data
limitations
are
among
the
largest
sources
of
uncertainty
and
may
result
in
understating
costs.
However,
EPA's
method
for
calculating
potential
pollutant
loading
reductions
required
at
permitted
facilities
(
i.
e.,
comparing
an
average
monthly
effluent
limit
to
a
maximum
effluent
concentration)
potentially
overstates
costs.

Exhibit
4­
6.
Biases
and
Uncertainties
in
the
Analysis
Assumption
Potential
Impact
on
Costs
Comments
Receiving
water
and
effluent
concentrations
are
limited
and
assumed
to
be
zero
if
no
data
indicate
otherwise.
There
are
no
data
for
organic
pollutants
in
any
of
the
streams
and
no
data
for
metals
in
Pepperell
Branch,
Shirtee,
and
Opossum
Creeks.
 
Receiving
waters
and
effluents
may
contain
low
levels
of
pollutants
that
require
facilities
to
install
treatm
ent
to
ensure
instream
criteria
are
met.

Required
pollutant
loading
reductions
are
calculated
by
comparing
the
maximum
effluent
concentration
to
the
average
monthly
limit.
"+
Comparing
maximum
concentrations
with
average
monthly
limits
overstates
the
required
pollutant
loading
reductions.

POTWs
will
use
waste
minimization
to
reduce
effluent
concentrations
rather
than
install
treatm
ent.
 
Additional
treatment
would
cost
considerably
more
than
waste
minimization
programs
at
POTWs.

Treatment
costs
based
on
U.
S.
EPA
(
1980;
1993)
and
Truax
(
1992).

?
Facilities
may
experience
higher
or
lower
actual
treatment
costs.
In
particular,
use
of
U.
S.
EPA
(
1980)
may
result
in
overstated
costs
because
of
technological
advances
over
the
last
25
years.
Use
of
engineering
cost
indices
to
update
to
current
dollars
can
further
magnify
differences.

Capital
costs
annualized
over
20
years.
"+
The
useful
life
of
capital
equipment
is
often
more
than
20
years
so
annual
costs
may
be
overstated.

Key:
+
=
Costs
are
potentially
overstated
 
=
Costs
are
potentially
understated
?
=
Affect
on
costs
is
unknown.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
21
5.
References
Alabama
Department
of
Environmental
Management
(
ADEM).
1996.
Waste
Load
Allocation
for
the
USX
WWTP
Discharge
to
Opposum
Creek
near
Fairfield.
Montgomery,
Alabama.
August.

Alabama
Department
of
Environmental
Management
(
ADEM).
2001.
Waste
Load
Allocation
for
Valley
Creek
WWTP
Assuming
Fish
and
Wildlife
Use
Classification
for
Valley
Creek.
Montgomery,
Alabama.
February.

Alabama
State
Regulations.
2000.
Chapter
335­
6­
10.

Applied
Technology
and
Engineering,
P.
C.
1992.
Shirtee
Creek
Wasteload
Allocation
Study.
Prepared
for
Mr.
Albert
Chieves.
Avondale
Mills,
Inc.
Sylacauga,
Alabama.
January.

Livingston,
Eric.
1999.
A
Review
of
Urban
Stormwater
Retrofitting
in
Florida.
From:
Comprehensive
Stormwater
&
Aquatic
Ecosystem
Management,
Proceedings
of
a
Conference
held
in
Auckland,
New
Zealand.
February
22
 
26,
2999.

Rouge
River
National
Wet
Weather
Demonstration
Project
Cost
Estimating
Guidelines.
2001.
http://
www.
wcdoe.
org/
rougeriver/
pdfs/
stormwater/
sr10.
pdf.

STORET
Legacy.
2001.
http://
epa.
gov/
storet
Truax,
Dennis
D.
1992.
Optimization
of
Wastewater
Treatment
Plant
Systems.
Water
Environment
Research.
64(
4):
400
 
02.

U.
S.
EPA.
2001.
Permit
Compliance
System.

U.
S.
EPA.
1999.
1999
Update
of
Ambient
Water
Quality
Criteria
for
Ammonia.
EPA­
822­
R­
99­
014.
Washington,
D.
C.
December.

U.
S.
EPA.
1993.
Assessment
of
Compliance
Costs
Resulting
from
the
Implementation
of
the
Proposed
Great
Lakes
Water
Quality
Guidance.
Prepared
by
Science
Applications
International
Corporation
for
U.
S.
EPA
Office
of
Water,
Office
of
Science
and
Technology.

U.
S.
EPA.
1991.
Technical
Support
Document
for
Water
Quality­
based
Toxics
Control.
EPA/
505/
2­
90­
001.
Washington,
DC.

U.
S.
EPA.
1990.
A
Calibrated
QUAL2E
Model
of
Pepperell
Branch
and
Sougahathee
Creek,
Volume
II.
Opelika,
Alabama.
September.

U.
S.
EPA.
1980.
Treatability
Manual
Volume
IV
 
Cost
Estimating.
EPA/
600/
8­
80­
042d.
Washington,
DC.
July.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
22
U.
S.
EPA
Office
of
Research
and
Development
Risk
Reduction
Engineering
Laboratory.
RREL
Treatability
Database.
Cincinnati,
OH.

U.
S.
Geological
Survey
(
USGS).
USGS
National
Water
Information
System.
2001.
http://
water.
usgs.
gov.
nwis.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
23
Appendices
Appendix
A.
Facility
Effluent
Data
Appendix
B.
Instream
Water
Quality
Data
Appendix
C.
Use
Attainability
Appendix
D.
Ammonia
Toxicity
Analysis
Appendix
E.
Dissolved
Oxygen
Analysis
Appendix
F.
Facility
Analyses
Appendix
G.
Nonpoint
Source
Control
Costs
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
24
Appendix
A.
Facility
Effluent
Data
Exhibit
A­
1.
Facility
Effluent
Data
Considered
in
Cost
Analyses
Facility
Toxic
Pollutants
Evaluated
Existing
Perm
it
Limit?
Conventional
Pollutants
Evaluated
Existing
Perm
it
Limit?

ABC
Coke
Benzene
Benzo(
a)
pyrene
Phenols
Cyanide
Yes
Yes
Yes
No
BOD
DO
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
Yes
Yes
American
Cast
Iron
Pipe
Company
Copper
Lead
Zinc
Phenols
Yes
Yes
Yes
Yes
None
N/
A
Ashland
Chemical
BETX
1,1,2­
Trichloroethane
Dichloromethane
Yes
Yes
Yes
None
N/
A
Avondale
Mills
Copper
Lead
Phenols
Zinc
Yes
Yes
Yes
Yes
BOD
DO
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
Yes
Yes
Birmingham
Steel
None
N/
A
None
N/
A
Earl
Ham
WWTP
Arsenic
Cadmium
Chromium
Hexavalent
Copper
Lead
Nickel
Silver
Cyanide
Zinc
No
No
No
No
No
No
No
No
No
BOD
DO
Ammonia
Yes
Yes
Yes
Five
Mile
Creek
WWTP
None
N/
A
BOD
DO
Fecal
Coliform
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
No
Yes
Yes
Koppers
Industries
­
Woodward
Tar
Plant
1,1,1­
Trichloroethane
1,1,2­
Trichloroethane
1,1­
Dichloroethane
1,1­
Dichloroethylene
1,2,4­
Trichlorobenzene
1,2­
Dichlorobenzene
1,2­
Dichloroethane
1,2­
Dichloropropane
1,2­
Trans­
Dichloroethylene
1,3­
Dichloropropene
1,3­
Dichlorobenzene
1,4­
Dichlorobenzene
2,4­
Dichlorophenol
2,4­
Dimethlyphenol
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
BOD
DO
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
Yes
Yes
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
Facility
Toxic
Pollutants
Evaluated
Existing
Perm
it
Limit?
Conventional
Pollutants
Evaluated
Existing
Perm
it
Limit?

25
2,4­
Dinitrophenol
2,4­
Dinitrotuluene
2,6­
Dinitrotoluene
2­
Chlorophenol
2­
Nitrophenol
3,4­
Benzofluoranthene
4,6­
Dinitro­
O­
Cresol
4­
Nitrophenol
Acnepahthene
Acenaphthylene
Acrylonitirle
Anthracene
Benzene
Benzo(
a)
anthracene
Benzo(
a)
pyrene
Benzo(
k)
fluoranthene
Bis(
2­
Ethlyhexyl)
Phthalate
Carbon
Tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Chromium
(
as
Cr)
Chrysene
Copper
(
as
Cu)
Cyanide
(
as
Cn)
Di­
n­
Butyl
Phthalate
Diethyl
Phthalate
Dimethyl
Phthalate
Ethylbenzene
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
(
as
Pb)
Methyl
Chloride
Methylene
Chloride
Naphthalene
Nickel,
(
as
Ni)
Nitrobenzene
Phenanthrene
Phenol,
Single
Compound
Pyrene
Tetrachloroethylene
Toluene
Trichloroethyleen
Vinyl
Chloride
Zinc
(
as
Zn)
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
Facility
Toxic
Pollutants
Evaluated
Existing
Perm
it
Limit?
Conventional
Pollutants
Evaluated
Existing
Perm
it
Limit?

26
Koppers
Industries
­
Woodward
Coke
Plant
Benzene
Benzo(
a)
pyrene
Phenols
Cyanide
Yes
Yes
Yes
Yes
BOD
DO
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
Yes
Yes
Sloss
Industries
2,4­
Dimethylphenol
Benzo(
a)
anthracene
Benzo(
a)
pyrene
Benzo(
b)
fluoranthene
Benzo(
k)
fluoranthene
Chlorobenzene
Chrysene
Fluoranthene
Flourene
Pyrene
Phenols
Toluene
Copper
Cyanide
Lead
Nickel
Zinc
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
BOD
DO
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
Yes
Yes
USX
­
Fairfield
Works
Benzene
Benzo(
a)
pyrene
Chromium
Hexavalent
Phenols
Tetrachloroethylene
Lead
Zinc
Cyanide
No
No
Yes
Yes
Yes
Yes
Yes
Yes
BOD
DO
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
Yes
Yes
Valley
Creek
WWTP
Chromium
Hexavalent
Cyanide
No
No
BOD
DO
Fecal
Coliform
Ammonia
Kjeldahl
Nitrogen
Yes
Yes
Yes
Yes
Yes
Westpoint­
Stevens
Opelika
Finishing
Plant
Phenols
Chromium
Yes
Yes
BOD
DO
Ammonia
Yes
Yes
Yes
Honeywell
International
1,1,2­
Trichloroethane
1,1­
Dichloroethane
1,1­
Dichloroethylene
1,2­
Dichlorobenzene
1,2­
Dichloroethane
1,2­
Dichloropropane
1,2­
Trans­
Dichloroethylene
1,3­
Dichloropropene
1,3­
Dichlorobenzene
1,4­
Dichlorobenzene
2,4­
Dichlorophenol
2,4­
Dimethlyphenol
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
BOD
Ammonia
Yes
Yes
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
Facility
Toxic
Pollutants
Evaluated
Existing
Perm
it
Limit?
Conventional
Pollutants
Evaluated
Existing
Perm
it
Limit?

27
2,4­
Dinitrophenol
2,4­
Dinitrotoluene
2­
Chlorophenol
Acenaphthene
Acenaphthylene
Acrylonitrile
Anthracene
Benzene
Benzo(
a)
anthracene
Benzo(
a)
pyrene
Benzo(
k)
fluoranthene
Bis(
2­
Ethylhexyl)
phthalate
Carbon
Tetrachloride
Chlorobenzene
Chloroform
Chrysene
Di­
N­
Butylphthalate
Diethylphthalate
Demethylphthalate
Ethylbenzene
Fluoranthene
Fluorene
Hexachloroethane
Methylene
Chloride
Nitrobenzene
Phenols
Pyrene
Tetrachloroethylene
Toluene
Copper
Cyanide
Lead
Nickel
Zinc
Trichloroethylene
Vinyl
Chloride
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
No
Yes
Yes
SMI
Steel
Lead
Zinc
Yes
Yes
None
N/
A
Village
Creek
WWTP
Hexavalent
Chromium
Cyanide
No
No
BOD
DO
Fecal
Coliform
Ammonia
Yes
Yes
Yes
Yes
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
28
Appendix
B.
Instream
Water
Quality
Data
Exhibit
B­
1
summarizes
the
data
available
for
assessing
water
quality
and
developing
water
quality­
based
effluent
limits.
Some
stations,
however,
contain
only
very
old
data
(
earlier
than
1980)
and/
or
have
so
few
observations
that
the
data
are
inconclusive.
Exhibits
B­
2
through
B­
5
provide
maps
and
station
locations
for
four
of
the
creeks.

Exhibit
B­
1.
Stream
Data
Considered
in
Cost
Analyses
Station
Conventional
Pollutants
Toxic
Pollutants
Five
Mile
Creek2
FIVEMILECREEK01
Ammonia,
Water
Temperature,
BOD,
Kjeldahl
Nitrogen,
DO
Ammonia
FIVEMILECREEK02
Ammonia
Nitrogen,
Water
Temperature,
BOD,
DO,
Kjeldahl
Nitrogen
Ammonia
FMC­
01
Ammonia,
Kjeldahl
Nitrogen,
Water
Temperature,
Hardness,
DO,
BOD
Ammonia
FMC­
02
Water
Temperature,
Ammonia,
DO,
Hardness,
BOD,
Kjeldahl
Nitrogen
Cyanide,
Chromium,
Recoverable
Phenolics,
Lead,
Cadmium,
Copper,
Nickel,
Zinc
FMC­
03
BOD,
Kjeldahl
Nitrogen,
DO,
Hardness,
pH,
Ammonia,
Water
Temperature
Recoverable
Phenolics
010359C
Hardness
(
calculated),
Kjeldahl
Nitrogen,
DO,
Water
Temperature,
Ammonia
Nitrogen
Zinc,
Lead,
Thallium,
Cobalt,
Manganese,
Aluminum,
Cadmium,
Cyanide,
Copper,
Silver,
Iron,
Chromium,
Nickel,
Antimony,
Mercury,
Selenium,
Arsenic
FM1
BOD,
Kjeldahl
Nitrogen,
DO,
pH,
Ammonia,
Fecal
Coliform,
Water
Temperature,
Water
Temperature,
Hardness
Phenols,
Cyanide,
Aluminum,
Arsenic,
Copper,
Zinc,
Mercury,
Manganese,
Lead,
Cadmium,
Chromium,
Iron
FMC­
04
Ammonia,
DO,
Water
Temperature,
DO,
Kjeldahl
Nitrogen,
Hardness,
pH
Copper,
Cadmium,
Chromium,
Lead,
Zinc,
Cyanide,
Nickel,
Recoverable
Phenolics
010359B
Ammonia,
Water
Temperature,
Kjeldahl
Nitrogen,
Hardness
(
calculated),
pH,
DO
Nickel,
Beryllium,
Chromium,
Manganese,
Lead,
Mercury,
Iron,
Zinc,
Copper,
Thallium,
Cyanide,
Silver,
Antimony,
Selenium,
Arsenic,
Aluminum,
Cadmium
FMC­
05
Kjeldahl
Nitrogen,
DO,
Water
Temperature,
Hardness,
BOD,
pH,
Ammonia
FMC­
06
Kjeldahl
Nitrogen,
Ammonia,
Water
Temperature,
DO,
BOD,
pH
Cadmium,
Cyanide,
Lead,
Zinc,
Nickel,
Chromium,
Copper,
Recoverable
Phenolics
FMC­
07
Ammonia,
pH,
Water
Temperature,
DO,
BOD,
Kjeldahl
Nitrogen,
DO,
Hardness
FM2
Water
Temperature,
DO,
Kjeldahl
Nitrogen,
pH,
Fecal
Coliform,
Ammonia,
Hardness,
BOD
Lead,
Zinc,
Copper,
Cadmium,
Mercury,
Cyanide,
Phenols,
Chromium,
Arsenic
010359A
Copper,
Lead,
Lindane,
Nickel,
Heptachlor,
Chromium,
Heptachlor
Epoxide,
Toxaphene,
Cadmium,
4,4
DDD,
PCB
1260,
PCB
1254,
Aldrin,
PCB
1242,
Dieldrin,
Endrin,
4,4
DDE
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
Station
Conventional
Pollutants
Toxic
Pollutants
29
FMC­
12
Ammonia,
Water
Temperature,
Kjeldahl
Nitrogen,
pH,
BOD,
DO
FMC­
13
Ammonia,
Kjeldahl
Nitrogen,
Water
Temperature,
DO,
pH,
Hardness
Lead,
Chromium,
Cyanide,
Cadmium,
Nickel,
Copper,
Recoverable
Phenolics
FMC­
14
(
Unnamed
Tributary)
Ammonia,
Kjeldahl
Nitrogen,
Water
Temperature,
Hardness,
pH,
BOD,
DO
Lead,
Cadmium,
Chromium,
Copper,
Zinc,
Nickel
FMC­
15
DO,
Hardness,
Ammonia,
Kjeldahl
Nitrogen,
BOD,
pH,
Water
Temperature
Lead,
Cadmium,
Nickel,
Copper,
Chromium,
Zinc
FMC­
16
Ammonia,
Kjeldahl
Nitrogen,
Water
Temperature,
DO,
Hardness,
BOD
Lead,
Copper,
Cyanide,
Zinc,
Chromium,
Cadmium,
Recoverable
Phenolics,
Nickel
Opossum
Creek
010359O
Hardness,
DO,
pH,
Water
Tem
perature
Chromium,
Copper,
Cyanide,
Lead,
Nickel,
Zinc
010359P
Hardness,
DO,
pH,
Water
Tem
perature
Chromium,
Copper,
Cyanide,
Lead,
Nickel,
Zinc
010359Q
Hardness,
DO,
pH,
Water
Tem
perature
Chromium,
Copper,
Cyanide,
Lead,
Nickel,
Zinc
OC­
1
DO,
pH,
Water
Tem
perature
OC­
3
DO,
pH,
Water
Tem
perature
OC­
4
DO,
pH,
Water
Tem
perature
OPOSSUMCREEK01
Fecal
Coliform,
DO,
pH,
Water
Temperature
Pepperell
Branch
WPP35
DO,
pH,
Water
Tem
perature
WPP36
DO,
pH,
Water
Tem
perature
WPP37
DO,
pH,
Water
Tem
perature
WPP39
DO,
pH,
Water
Tem
perature
WPP40
DO,
pH,
Water
Tem
perature
WPP41
DO,
pH,
Water
Tem
perature
WPP39A
DO,
pH,
Water
Tem
perature
PEPPERELLBR01
DO,
pH,
Water
Temperature,
Ammonia,
Kjeldahl
Nitrogen
PEPPERELLBR02
DO,
pH,
Water
Temperature,
Fecal
Coliform,
Ammonia,
Kjeldahl
Nitrogen
PEPPERELLBR03
DO,
pH,
Water
Temperature,
Ammonia,
Kjeldahl
Nitrogen
PEPPERELLBR04
DO,
pH,
Water
Temperature,
Ammonia,
Kjeldahl
Nitrogen
PEPPERELLBR05
DO,
pH,
Water
Temperature,
Ammonia,
Kjeldahl
Nitrogen
PEPPERELLBR06
DO,
pH,
Water
Temperature,
Ammonia,
Kjeldahl
Nitrogen
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
Station
Conventional
Pollutants
Toxic
Pollutants
30
Shirtee
Creek
SHIRT11
Water
Temperature,
pH,
DO,
Kjeldahl
Nitrogen,
BOD
SHIRT12
Water
Temperature,
pH,
DO,
Kjeldahl
Nitrogen,
BOD
SHIRTEE01
Water
Temperature,
pH,
DO,
Kjeldahl
Nitrogen,
Ammonia
,
BOD
SHIRTEE02
Water
Temperature,
pH,
DO,
Kjeldahl
Nitrogen,
Ammonia,
BOD
SHIRTEE03
Water
Temperature,
pH,
DO,
Kjeldahl
Nitrogen,
Ammonia,
Fecal
Coliform,
BOD
SHIRTEECREEK012
Water
Temperature,
pH,
DO,
Kjeldahl
Nitrogen,
Ammonia
SHIRTEECREEK02
Water
Temperature,
pH,
DO,
Kjeldahl
Nitrogen,
Ammonia,
BOD
SHIRTEECREEK03
Water
Temperature,
pH,
DO
Kjeldahl
Nitrogen,
BOD
Valley
Creek
010359J
DO,
Water
Temperature
010359K
DO,
Water
Temperature
010359L
DO,
Water
Temperature
010359M
DO,
Water
Temperature
010359N
DO,
Water
Temperature
02462000
DO,
Water
Temperature
VA1
Fecal
Coliform,
DO,
Water
Tem
perature
VALLEYCREEK02
DO,
Water
Temperature
VC­
10
DO,
Water
Temperature
VC­
11
DO,
Water
Temperature
VC­
5
Fecal
Coliform,
DO,
Water
Tem
perature
VC­
6
DO,
Water
Temperature
VC­
7
DO,
Water
Temperature
VC­
8
DO,
Water
Temperature
VC­
9
DO,
Water
Temperature
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
Station
Conventional
Pollutants
Toxic
Pollutants
31
Village
Creek3
2460500
Ammonia,
DO,
Fecal
Coliform,
Hardness,
pH,
Water
Temperature
Arsenic,
Cadm
ium,
Chrom
ium,
Copper,
Cyanide,
Lead,
Mercury,
Nickel,
Selenium,
Silver,
Zinc
VI1
Ammonia,
DO,
Fecal
Coliform,
Hardness,
pH,
Water
Temperature
Chromium,
Copper,
Cyanide,
Lead,
Mercury,
Phenols,
Zinc
010359E
Ammonia,
Water
Temperature,
pH,
DO,
hardness
Antimony,
Chloroform,
Chrom
ium,
Copper,
Cyanide,
Lead,
Mercury,
Nickel,
Selenium,
Silver,
Zinc
010359F
Ammonia,
DO,
hardness,
pH,
Water
Temperature
Antimony,
Chromium,
Copper,
Cyanide,
Lead,
Mercury,
Nickel,
Selenium,
Silver,
Zinc
010359G
Ammonia,
DO,
hardness,
pH,
Water
Temperature
Antimony,
Chromium,
Copper,
Cyanide,
Lead,
Mercury,
Nickel,
Selenium,
Silver,
Zinc
010359H
Ammonia,
DO,
hardness,
pH,
Water
Temperature
Antimony,
Chromium,
Copper,
Cyanide,
Lead,
Mercury,
Nickel,
Selenium,
Silver,
Zinc
010359I
Ammonia,
DO,
hardness,
pH,
Water
Temperature
Antimony,
Chromium,
Copper,
Cyanide,
Lead,
Mercury,
Nickel,
Selenium,
Silver,
Zinc
VILLAGECREEK01
Ammonia,
DO,
pH,
Water
Tem
perature
VILLAGECREEK02
Ammonia,
DO,
Fecal
Coliform,
pH,
Water
Temperature
VILLAGECREEK03
Ammonia,
DO,
Fecal
Coliform,
pH,
Water
Temperature
1No
data
exist
for
stations
2457595,
245700,
010359D
shown
in
Exhibit
B­
2
2The
exact
location
of
station
SHIRTEECREEK01
is
unknown
and
so
it
is
not
shown
in
Exhibit
B­
3.
3Stations
2458203,
2458300,
and
2458375
shown
in
Exhibit
B­
5
only
contain
flow
data.
Note:
Blank
cells
indicate
that
no
data
are
available.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
32
Exhibit
B­
2.
Five
Mile
Creek
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
33
Exhibit
B­
3.
Shirtee
Creek
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
34
Exhibit
B­
4.
Valley
Creek
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
35
Exhibit
B­
5.
Village
Creek
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
36
Appendix
C.
Use
Attainability
This
appendix
describes
the
methods
EPA
used
to
evaluate
the
attainability
of
different
use
classifications
among
the
stream
segments
and
the
results
of
the
evaluation.

C.
1
Methods
C.
1.1
Conventional
Pollutants
EPA
evaluated
four
conventional
pollutants:
fecal
coliforms
and
those
pollutants
affecting
DO
levels
in
receiving
waters
[
DO,
biochemical
oxygen
demand
(
BOD),
and
ammonia].

Fecal
Coliforms
EPA
downloaded
all
data
on
fecal
coliform
bacteria
for
the
affected
stream
segments
from
the
STORET
Legacy
system.
In
general,
samples
are
too
infrequent
(
e.
g.,
less
than
five
per
month)
to
evaluate
compliance
with
Alabama
water
quality
criteria.
Therefore,
EPA
compared
individual
observations
and
geometric
means
with
the
criteria
to
evaluate
current
attainment
of
A&
I,
LWF,
and
F&
W
criteria.
If
a
geometric
mean
between
June
and
September
exceeds
200
per100
ml,
or
a
geometric
mean
in
other
months
exceeded
1,000
per100
ml,
F&
W
is
not
currently
being
attained.
These
data
also
provide
some
indication
of
whether
point
source
and
upstream
nonpoint
source
controls
could
be
used
to
achieve
attainment.

Dissolved
Oxygen
EPA
downloaded
DO,
BOD,
and
ammonia
data
from
the
STORET
Legacy
system.
EPA
assumed
that
only
the
most
recent
data
(
since
1980)
reflect
current
stream
conditions,
although
the
data
series
covered
the
period
since
the
early
1970s
for
some
stations
on
some
segments.
This
assumption
is
justified
because
early
data
represent
stream
conditions
prior
to
substantial
improvements
in
pollution
control
technology
and
the
closing
of
several
facilities
that
had
a
negative
impact
on
water
quality
in
several
segments.
EPA
compared
DO
concentrations
to
the
5
mg/
L
minimum
DO
criterion
for
F&
W.
If
the
criterion
is
not
currently
being
attained,
then
EPA
determined
if
the
criterion
would
be
attained
with
control
of
point
sources
through
modeling
of
instream
concentrations
with
a
steady­
state
Streeter­
Phelps
model.
If,
even
with
the
control
of
point
sources,
an
instream
DO
criterion
would
not
be
met,
EPA
concluded
nonpoint
source
controls
for
BOD
would
be
required.

C.
1.2
Toxic
Pollutants
EPA
evaluated
toxic
pollutants
by
comparing
instream
concentrations
of
priority
pollutants
and
ammonia
with
the
most
stringent
of
the
acute
aquatic
life,
chronic
aquatic
life,
and
human
health
criteria
(
organisms
only).
If
the
instream
data
indicated
compliance
with
the
instream
criteria
(
based
on
the
mean
of
the
detected
samples),
EPA
calculated
revised
effluent
limits
for
point
sources
and
assumed
that
nonpoint
source
controls
would
not
be
needed.
However,
if
the
instream
data
indicated
consistent
noncompliance
with
instream
criteria
(
based
on
mean
of
the
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
37
detected
samples),
and
EPA
could
not
attribute
these
exceedences
to
point
source
discharges,
it
assumed
that
nonpoint
source
controls
would
also
be
required.

C.
2
Results
C.
2.1
Five
Mile
Creek
Data
are
available
for
stations
FM1
and
FM2
for
Five
Mile
Creek
covering
more
than
the
last
20
years.
EPA
used
only
data
since
1980
because
earlier
data
do
not
represent
current
stream
conditions.
Station
FM1,
which
is
located
above
all
point
source
discharges,
has
a
mean
DO
of
8.7
(
191
observations),
and
2.6%
of
these
observations
are
less
than
5
mg/
L
(
Exhibit
C­
1
and
Exhibit
C­
2).
Station
FM2,
which
is
located
among
several
point
source
discharges,
has
a
mean
DO
of
8.48
mg/
L
and
1.4%
of
observations
are
less
than
5
mg/
L(
Exhibit
C­
3
and
Exhibit
C­
4).
Therefore,
Five
Mile
Creek
is
attaining
a
5
mg/
L
F&
W
standard
for
DO.

Fecal
coliform
data
are
available
for
stations
FM1
and
FM2
for
Five
Mile
Creek.
At
station
FM1,
which
is
upstream
of
all
dischargers
on
this
segment,
3.4%
of
the
88
observations
from
May
1989
to
October
1998
exceed
the
F&
W
maximum
criterion
of
2,000
per
100
ml.
The
geometric
mean
for
this
station
is
145
per
100
ml
for
all
observations,
well
below
the
minimum
200
per
100
ml
F&
W
criterion.
At
station
FM2,
which
is
below
many
dischargers,
including
the
Jefferson
County
Five
Mile
Creek
WWTP,
5.7%
of
the
87
observations
from
June
1989
to
October
1998
exceed
the
F&
W
maximum
criterion
of
2,000
per
100
ml.
The
geometric
mean
for
this
station
is
232
per
100
ml
for
all
observations,
but
is
well
below
the
year­
round
F&
W
geometric
mean
requirement
of
1,000
per
100
ml.
The
geometric
mean
between
June
and
September
of
363
per
100
ml
exceeds
the
F&
W
requirement
for
this
period
of
200
per
100
ml.
Therefore,
the
stream
segment
is
currently
meeting
the
LWF
standard,
and
a
F&
W
standard
could
be
attained
with
additional
control
of
the
wastewater
treatment
plant
effluent.

Two
stations
on
File
Mile
Creek
have
data
for
toxic
pollutants:
FM1
and
FM2.
As
indicated
in
Exhibits
C­
1
and
C­
3,
Five
Mile
Creek
waters
exceed
criteria
for
several
toxic
pollutants:
arsenic,
cadmium,
copper,
cyanide,
lead,
mercury,
and
zinc.
Cyanide,
mercury,
and
zinc
exceed
criteria
in
more
than
10%
of
samples
at
both
stations
and
copper
exceeds
criteria
in
more
than
10%
of
samples
at
station
FM1
(
the
upstream
station).
The
downstream
station
(
FM2)
is
near
several
facilities
that
discharge
some
of
the
pollutants
with
concentrations
exceeding
the
criteria.
However,
even
with
control
of
these
discharges,
some
pollutants
(
such
as
mercury)
may
continue
to
exceed
criteria
because
the
facilities
do
not
have
limits
for
these
pollutants.
Additional
controls
on
urban
runoff
will
be
necessary
for
Five
Mile
Creek
to
attain
either
LWF
or
F&
W
standards.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
38
Exhibit
C­
2.
Five
Mile
Creek,
Station
FM1
Exhibit
C­
1.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
FM1
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia,
Unionized
(
calculated)
mg/
L
4
100.0
0.0019
0
0
a
Ammonia,
Unionzed
mg/
L
4
100.0
0.0016
0
0
a
Arsenic,
Total
µ
g/
L
51
7.8
10
4
7.8
0.3
Cadmium,
Total
µ
g/
L
56
1.8
5.0
1
1.8
2.04
Chromium,
Total
µ
g/
L
65
10.8
25
0
0
382.5
Copper,
Total
µ
g/
L
68
22.1
167
13
19.1
22.4
Cyanide,
Total
mg/
L
54
48.1
0.028
23
42.6
0.0052
Lead,
Total
µ
g/
L
54
3.7
17
2
3.7
8.26
Mercury,
Total
µ
g/
L
45
15.6
2.0
7
15.6
0.012
Phenols
mg/
L
60
15.0
4.6
0
0
106
Zinc,
Total
µ
g/
L
11
81.8
249
5
45.5
200
a
 
Criteria
based
on
pH
and
temperature.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
39
Exhibit
C­
4.
Five
Mile
Creek,
Station
FM2
Exhibit
C­
3.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
FM2
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia,
Unionized
(
calculated)
mg/
L
4
100.0
0.0012
0
0
a
Ammonia,
Unionzed
mg/
L
4
100.0
0.00099
0
0
a
Arsenic,
Total
µ
g/
L
56
5.4
203
3
5.4
0.3
Cadmium,
Total
µ
g/
L
60
0
0
2.04
Chromium,
Total
µ
g/
L
64
4.7
9.7
0
0
382.5
Copper,
Total
µ
g/
L
64
9.4
61
3
4.7
22.4
Cyanide,
Total
mg/
L
58
41.4
0.037
23
39.7
0.0052
Lead,
Total
µ
g/
L
59
7.8
10
2
3.4
8.26
Mercury,
Total
µ
g/
L
51
17.6
5.3
9
17.6
0.012
Phenols
mg/
L
56
3.6
0.075
0
0
106
Zinc,
Total
µ
g/
L
4
25.0
280
1
25.0
200
a
 
Criteria
based
on
pH
and
tem
perature
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
1The
single
point
source
may
have
already
reduced
discharges
sufficiently
to
attain
the
standard.

40
C.
2.2
Opossum
Creek
Opossum
Creek
has
six
stations
with
DO
data,
but
the
number
of
observations
is
limited
at
each
(
the
station
with
the
most
observations
has
seven).
With
one
exception,
all
of
the
data
were
taken
between
1985
and
1989.
The
maximum
average
concentration
for
these
stations
is
7.3
mg/
L
and
the
minimum
average
concentration
is
1.3
mg/
L.
At
all
stations,
between
43%
and
100%
of
observations
are
below
5
mg/
L.
The
most
recent
and
only
data
point
in
the
1990s
(
in
1998),
is
compliant
with
a
5
mg/
L
criterion.
A
wasteload
allocation
study
for
Valley
Creek
conducted
by
ADEM
(
1996)
indicates
that
although
a
5
mg/
L
criterion
would
be
met
in
Valley
Creek,
it
would
not
be
met
in
Opossum
Creek
without
substantial
load
reductions
from
the
USX
Fairfield
Plant.
To
calculate
the
load
reductions
required
at
USX
Fairfield
to
meet
the
F&
W
standards,
EPA
ran
a
steady­
state
Streeter­
Phelps
DO
model
based
on
the
results
from
the
ADEM
Valley
Creek
model.
Appendix
E
summarizes
the
methods
and
results
of
the
analysis.

A
single
data
point
is
available
for
Opossum
Creek
for
fecal
coliforms:
1,200
per
100
ml
in
August
1998.
There
are
not
sufficient
data
to
determine
compliance
with
any
fecal
coliform
standard.

A
single
sample
was
taken
at
each
of
three
stations
on
Opossum
Creek
for
chromium,
copper,
cyanide,
lead,
nickel,
and
zinc.
Chromium,
copper,
lead,
and
nickel
were
not
detected
at
any
station.
Cyanide
was
detected
at
two
of
the
three
stations,
and
one
value
exceeds
the
acute
criterion.
Zinc
samples
all
meet
the
criterion.

C.
2.3
Pepperell
Branch
There
are
several
thousand
DO
observations
of
Pepperell
Branch
since
1980.
Most
of
the
observations
(
5,920
out
of
6,944)
and
most
of
the
stations
(
7
out
of
10)
indicate
less
than
5%
of
samples
are
less
than
5
mg/
L.
The
remaining
observations
and
remaining
stations
have
17.5,
33,
and
40%
of
observations
under
5
mg/
L,
but
the
latter
two
values
are
for
stations
with
6
observations.
Exhibits
C­
4
through
C­
11
summarize
DO
observations
at
the
stations.
Although
the
exact
location
of
the
stations
on
Pepperell
Branch
is
uncertain,
data
indicate
that
sampling
occurred
three
times
a
week
at
a
number
of
stations
downstream
of
the
Westpoint
Stevens
facility.
Only
one
of
these
stations
indicates
a
relatively
high
number
of
values
less
than
5
mg/
L.
Thus,
with
control
of
the
single
point
source,
1
a
5
mg/
L
standard
is
attainable
in
Pepperell
Branch.

Fecal
Coliform
data
are
available
for
station
PEPPERELLBR02.
Of
the
six
observations
taken
between
June
1997
and
October
1998,
all
were
less
than
2,000
per
100
ml.
The
geometric
mean
of
all
observations
is
177
per
100
ml,
and
the
geometric
mean
of
all
observations
between
June
and
September
is
208
per
100
ml.
Pepperell
Branch
essentially
complies
with
a
F&
W
standard
at
present.

No
toxic
data
have
been
taken
in
Pepperell
Branch.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
41
Exhibit
C­
5.
Pepperell
Branch,
Station
WPP
35
Exhibit
C­
6.
Pepperell
Branch,
Station
WPP
36
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
42
Exhibit
C­
7.
Pepperell
Branch,
Station
WPP
37
Exhibit
C­
8.
Pepperell
Branch,
Station
WPP
39
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
43
Exhibit
C­
9.
Pepperell
Branch,
Station
WPP
39A
Exhibit
C­
10.
Pepperell
Branch,
Station
WPP
40
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
44
Exhibit
C­
11.
Pepperell
Branch,
Station
WPP
41
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
45
Exhibit
C­
12.
Shirtee
Creek,
Station
SHIRTEE03
C.
2.4
Shirtee
Creek
There
are
7
stations
on
Shirtee
Creek
with
limited
data
(
maximum
11
observations).
Most
of
the
samples
were
taken
in
the
mid
to
late
1980s
and
were
frequently
less
than
5
mg/
L.
Data
taken
from
1997
and
1998,
however,
all
were
greater
than
5
mg/
L,
as
shown
in
Exhibit
C­
12.
In
addition,
a
wasteload
allocation
study
performed
for
Avondale
Mills
in
1993
indicated
that
a
5
mg/
L
DO
standard
is
attainable
with
control
of
point
sources.

Fecal
coliform
data
are
available
for
station
SHIRTEE03.
Out
of
six
observations
taken
between
June
1997
and
October
1998,
1
exceeded
the
F&
W
maximum
criterion
of
2,000
per
100
ml.
The
geometric
mean
of
all
observations
is
205
per
100
ml
and
the
geometric
mean
of
observations
between
June
and
September
is
393
per
100
ml.
Except
for
the
single
exceedance
of
2,000
per
100
ml,
a
LWF
standard
is
currently
being
attained
in
Shirtee
Creek.
A
F&
W
standard
could
be
attained
with
further
controls
at
the
Earl
Ham
WWTP.

No
toxic
pollutant
data
have
been
taken
in
Shirtee
Creek.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
46
C.
2.5
Valley
Creek
There
are
15
stations
on
Valley
Creek
with
DO
data.
The
two
stations
with
the
largest
number
of
observations,
VA1
and
2462000,
are
several
miles
downstream
of
all
discharges.
Both
of
these
stations
indicate
that
F&
W
DO
standards
are
currently
being
met
for
this
part
of
this
creek.
In
the
area
of
the
Valley
Creek
WWTP,
there
are
several
stations,
but
all
but
one
of
the
stations
has
limited
(
less
than
10)
observations,
most
of
which
are
from
the
mid
to
late
1980s.
DO
observations
for
the
station
for
which
data
exists
is
summarized
in
Exhibit
C­
13.
All
of
these
stations
indicate
that
F&
W
DO
criteria
were
not
being
met
at
that
time.
ADEM,
however,
has
developed
a
Streeter­
Phelps
model
for
Valley
Creek
(
ADEM,
2001)
and
the
model
output
indicates
that
a
5
mg/
L
DO
level
is
attainable.
Data
from
EPA
Region
IV,
covering
2000
and
part
of
2001,
indicate
an
LWF
standard
is
achievable
at
all
but
the
uppermost
station
(
above
the
Valley
Creek
WWTP).

Ninety
fecal
coliform
samples
were
taken
at
station
VA1
between
February
1986
and
October
1998.
Six
of
these
samples
(
6.7%)
exceeds
2,000
per
100
ml.
The
overall
geometric
mean
is
191
per
100
ml,
with
a
geometric
mean
of
224
per
100
ml
during
the
months
between
June
and
September.
Four
samples
were
taken
at
station
VC5
between
June
1997
and
October
1998.
The
geometric
mean
of
these
samples
is
586
per
100
ml.
Eight
fecal
coliform
samples
were
taken
at
each
of
three
stations
in
2000
and
2001.
All
of
the
samples
at
the
upstream
station
(
above
Valley
Creek
WWTP)
exceed
1000
per
100
mL
by
a
large
margin.
The
geometric
mean
of
the
upstream
station
exceeds
10,000
per
100
mL.
The
two
downstream
stations
exceed
1000
per
100
mL
two
or
more
times
(
three
times
at
the
station
below
Valley
WWTP),
but
have
geometric
means
of
472
per
100
mL
(
above
Valley
Creek
WWTP)
and
252
per
100
mL
(
below
Valley
Creek
WWTP).
Therefore,
the
fecal
coliforms
are
most
likely
attributable
to
nonpoint
sources.

A
limited
number
of
samples
have
been
taken
for
toxic
pollutants
in
2000
and
2001
at
3
stations
(
Exhibits
C­
14
 
C­
17).
The
chronic
criteria
for
a
variety
of
PAHs
are
exceeded
on
at
least
one
occasion
at
the
uppermost
station
(
above
the
Valley
Creek
WWTP).
At
the
intermediate
station,
there
is
one
exceedance
each
for
copper,
mercury,
lead,
and
zinc.
At
the
lowermost
station,
two
PAHs
have
one
exceedance
in
three
samples
and
lead
exceeds
the
chronic
criterion
in
two
out
of
six
samples.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
47
Exhibit
C­
13.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VAL­
1
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia­
dissolved
mg/
L
10
100.0
0.218
0
0.0
1.23
Arsenic
µ
g/
L
6
50.0
2.45
0
0.0
190
Cadmium
µ
g/
L
6
66.7
0.140
0
0.0
1.58
Chromium
µ
g/
L
6
66.7
2.62
0
0.0
292
Copper
µ
g/
L
6
100.0
7.61
0
0.0
16.9
Lead
µ
g/
L
6
100.0
6.21
2
33.3
5.43
Mercury
µ
g/
L
6
0.0
N/
A
0
0.0
0.012
Nickel
µ
g/
L
6
50.0
2.02
0
0.0
225
Selenium
µ
g/
L
6
0.0
N/
A
0
0.0
5.0
Silver
µ
g/
L
6
50.0
1.14
0
0.0
8.36
Zinc
µ
g/
L
6
66.7
63.6
0
0.0
151
Acenaphthene
µ
g/
L
5
20.0
0.0218
0
0.0
579
Anthracene
µ
g/
L
5
60.0
0.0460
0
0.0
23,333
Benz(
a)
anthracene
µ
g/
L
5
20.0
0.189
1
20.0
0.067
Benzo(
a)
pyrene
µ
g/
L
5
40.0
0.124
1
20.0
0.067
Benzo(
b)
fluoranthene
µ
g/
L
5
40.0
0.283
1
20.0
0.067
Benzo(
k)
fluoranthe77ne
µ
g/
L
5
40.0
0.209
1
20.0
0.067
Chrysene
µ
g/
L
5
60.0
0.165
1
20.0
0.067
Dibenzanthracene
µ
g/
L
5
0.0
N/
A
0
0.0
0.067
Fluoranthene
µ
g/
L
5
80.0
0.233
0
0.0
81
Fluorene
µ
g/
L
5
40.0
0.0439
0
0.0
3,111
Indeno(
1,2,3­
cd)
pyrene
µ
g/
L
5
40.0
0.1388
1
20.0
0.067
Pyrene
µ
g/
L
5
80.0
0.197
0
0.0
2,333
Dieldrin
µ
g/
L
4
0.0
N/
A
0
0.0
0.0019
Lindane
µ
g/
L
4
0.0
N/
A
0
0.0
0.08
p,
p'
DDE
µ
g/
L
4
0.0
N/
A
0
0.0
0.00128
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
48
Exhibit
C­
14.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VAL­
2
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia­
dissolved
mg/
L
11
81.8
0.0740
0
0.0
0.401
Arsenic
µ
g/
L
6
83.3
3.10
0
0.0
190
Cadmium
µ
g/
L
6
16.7
0.233
0
0.0
1.85
Chromium
µ
g/
L
6
83.3
3.78
0
0.0
345
Copper
µ
g/
L
6
100.0
13.2
1
16.7
20.2
Lead
µ
g/
L
6
50.0
25.9
1
16.7
7.05
Mercury
µ
g/
L
6
16.7
N/
A
1
16.7
0.012
Nickel
µ
g/
L
6
16.7
1.70
0
0.0
268
Selenium
µ
g/
L
6
0.0
N/
A
0
0.0
5.0
Silver
µ
g/
L
6
16.7
0.210
0
0.0
11.9
Zinc
µ
g/
L
6
33.3
79.1
1
16.7
180
Acenaphthene
µ
g/
L
4
75.0
0.0202
0
0.0
579
Anthracene
µ
g/
L
4
50.0
0.0271
0
0.0
23,333
Benz(
a)
anthracene
µ
g/
L
4
0.0
N/
A
0
0.0
0.067
Benzo(
a)
pyrene
µ
g/
L
4
0.0
N/
A
0
0.0
0.067
Benzo(
b)
fluoranthene
µ
g/
L
4
0.0
N/
A
0
0.0
0.067
Benzo(
k)
fluoranthene
µ
g/
L
4
0.0
N/
A
0
0.0
0.067
Chrysene
µ
g/
L
4
25.0
0.0265
0
0.0
0.067
Dibenzanthracene
µ
g/
L
4
0.0
N/
A
0
0.0
0.067
Fluoranthene
µ
g/
L
4
100.0
0.0398
0
0.0
81
Fluorene
µ
g/
L
4
75.0
0.0178
0
0.0
3,111
Indeno(
1,2,3­
cd)
pyrene
µ
g/
L
4
0.0
N/
A
0
0.0
0.067
Pyrene
µ
g/
L
4
100.0
0.0389
0
0.0
2,333
Dieldrin
µ
g/
L
3
0.0
N/
A
0
0.0
0.0019
Lindane
µ
g/
L
3
0.0
N/
A
0
0.0
0.08
p,
p'
DDE
µ
g/
L
3
0.0
N/
A
0
0.0
0.00128
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
49
Exhibit
C­
15.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VAL­
3
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia­
dissolved
mg/
L
10
60.0
0.0392
0
0.0
0.544
Arsenic
µ
g/
L
6
66.7
2.47
0
0.0
190
Cadmium
µ
g/
L
6
33.3
0.147
0
0.0
1.64
Chromium
µ
g/
L
6
50.0
2.01
0
0.0
304
Copper
µ
g/
L
6
100.0
4.68
0
0.0
17.7
Lead
µ
g/
L
6
83.3
7.05
2
33.3
5.79
Mercury
µ
g/
L
6
0.0
N/
A
0
0.0
0.012
Nickel
µ
g/
L
6
16.7
1.70
0
0.0
235
Selenium
µ
g/
L
6
0.0
N/
A
0
0.0
5.0
Silver
µ
g/
L
6
16.7
0.210
0
0.0
9.12
Zinc
µ
g/
L
6
50.0
39.6
0
0.0
158
Acenaphthene
µ
g/
L
3
33.3
0.0260
0
0.0
579
Anthracene
µ
g/
L
3
33.3
0.0498
0
0.0
23,333
Benz(
a)
anthracene
µ
g/
L
3
33.3
0.0662
0
0.0
0.067
Benzo(
a)
pyrene
µ
g/
L
3
33.3
0.0600
0
0.0
0.067
Benzo(
b)
fluoranthene
µ
g/
L
3
33.3
0.105
1
33.3
0.067
Benzo(
k)
fluoranthene
µ
g/
L
3
33.3
0.0444
0
0.0
0.067
Chrysene
µ
g/
L
3
66.7
0.0433
1
33.3
0.067
Dibenzanthracene
µ
g/
L
3
0.0
N/
A
0
0.0
0.067
Fluoranthene
µ
g/
L
3
66.7
0.0915
0
0.0
81
Fluorene
µ
g/
L
3
33.3
0.0224
0
0.0
3,111
Indeno(
1,2,3­
cd)
pyrene
µ
g/
L
3
33.3
0.0512
0
0.0
0.067
Pyrene
µ
g/
L
3
66.7
0.0761
0
0.0
2,333
Dieldrin
µ
g/
L
3
0.0
N/
A
0
0.0
0.0019
Lindane
µ
g/
L
3
0.0
N/
A
0
0.0
0.08
p,
p'
DDE
µ
g/
L
3
0.0
N/
A
0
0.0
0.00128
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
50
C.
2.6
Village
Creek
There
is
one
station
that
has
a
long
data
series
for
DO
on
Village
Creek
 
station
VI1.
While
data
from
this
station
indicate
that
a
F&
W
standard
is
now
being
met
(
only
one
value
below
5
mg/
L
has
occurred
in
the
last
10
years),
this
station
is
probably
not
representative
of
the
creek
as
a
whole
because
it
is
downstream
of
the
lake.
There
are
limited
data
upstream
of
the
discharges,
and
data
from
VILLAGECREEK02
(
Exhibit
C­
15)
indicate
that
2
of
4
samples
in
1988
were
below
5
mg/
L
(
4.4
and
4.1
mg/
L).
Both
of
the
1998
samples
at
this
station
exceed
5
mg/
L.
In
general,
it
appears
that
Village
Creek
could
currently
attain
a
F&
W
standard
for
DO,
but
the
data
are
too
limited
for
an
accurate
assessment
in
the
area
of
the
discharges.
Data
from
EPA
Region
IV
for
2000
and
2001
indicate
a
F&
W
standard
is
currently
being
met.

Fecal
coliform
data
are
available
for
station
VI1
for
the
period
from
June
to
October
1998.
Of
the
96
samples
taken,
2
(
2.1%)
exceed
2,000
per
100
ml.
The
geometric
mean
of
all
observations
is
45
per
100
ml
and
the
geometric
mean
of
all
observations
between
June
and
September
is
39
per
100
ml.
Village
Creek
now
complies
with
a
F&
W
fecal
coliform
standard
at
station
VI1.
Very
limited
data,
one
observation
at
station
VILLAGECREEK02
and
two
observations
at
VILLAGECREEK03,
however,
indicate
there
may
be
relatively
higher
levels
upstream
of
the
dischargers
(
680
per
100
ml
at
VILLAGECREEK02
and
1,340
and
36
per
100
ml
at
VILLAGECREEK03).
Data
taken
in
2000
and
2001
indicate
high
geometric
means
for
fecal
coliform
at
2
stations
near
the
headwaters
(
1585
and
1973
per
100
mL).
However,
fecal
coliform
numbers
decrease
downstream.
Two
miles
upstream
of
the
Village
Creek
WWTP
the
geometric
mean
is
321
per
100
mL
and
the
only
sample
below
the
treatment
plant
has
a
value
of
180
per
100
mL.
These
higher
levels
indicate
that
nonpoint
source
controls
may
be
needed
before
a
F&
W
use
can
be
attained.

The
longest
series
of
toxic
data
for
Village
Creek
is
for
station
VI1
which
is
downstream
of
all
dischargers,
but
also
downstream
of
a
lake
that
likely
allows
the
settling
of
many
of
the
toxic
compounds
evaluated.
Data
for
most
pollutants
(
except
zinc)
cover
the
period
from
at
least
1981
to
1996
or
1997.
The
zinc
samples
were
taken
in
the
1970s
and
probably
do
not
reflect
current
conditions.
Exhibit
C­
17
indicates
the
mean
toxic
pollutant
concentrations
and
criteria
exceedances
for
this
station.
Arsenic,
copper,
cyanide,
mercury,
and
zinc
all
exceed
criteria
for
more
than
10%
of
samples.
Data
from
2000
and
2001,
shown
in
Exhibits
C­
19
through
C­
22,
show
similar
patterns
to
the
1981
 
1997
data
except
that
arsenic
does
not
exceed
the
criterion
and
lead
exceeds
the
criterion
at
least
once
at
3
of
the
4
stations.
At
the
uppermost
station,
PAH
values
exceed
applicable
criteria
in
two
of
the
three
observations.
Similar
exceedances
are
not
observed
at
the
three
downstream
stations.
Even
with
control
of
point
sources,
nonpoint
sources
would
also
need
to
be
controlled
before
LWF
or
F&
W
standards
for
toxic
pollutants
could
be
attained.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
51
Exhibit
C­
17.
Village
Creek,
Station
VILLAGECREEK02
Exhibit
C­
16.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VI1
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia,
Unionized
(
Calculated)
mg/
L
4
100.0
0.072
0
0
a
Ammonia,
Unionized
mg/
L
4
100.0
0.060
0
0
a
Arsenic,
Total
µ
g/
L
54
3.7
12
2
3.7
0.3
Cadmium,
Total
µ
g/
L
59
0.0
0
0
1.46
Chromium,
Total
µ
g/
L
67
6.0
29
0
0
269
Copper,
Total
µ
g/
L
69
14.5
143
8
11.6
15.6
Cyanide,
Total
mg/
L
39
25.6
0.011
9
23.1
5.2
Lead,
Total
µ
g/
L
59
3.4
11
2
3.4
4.79
Mercury,
Total
µ
g/
L
49
14.3
5.0
7
14.3
0.012
Phenols
mg/
L
58
1.7
0.010
0
0
106
Zinc,
Total1
µ
g/
L
11
81.8
264
5
45.5
139
1
Zinc
data
are
for
the
1970s
only.
a
­
Criteria
based
on
pH
and
temperature.

Exhibit
C­
18.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
1
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
52
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia­
dissolved
mg/
L
11
18.2
0.198
0
0.0
1.14
Arsenic
µ
g/
L
6
50.0
1.86
0
0.0
190
Cadmium
µ
g/
L
6
33.3
0.17
0
0.0
1.68
Chromium
µ
g/
L
6
50.0
2.16
0
0.0
312
Copper
µ
g/
L
6
33.3
6.02
0
0.0
18.2
Lead
µ
g/
L
6
33.3
15.0
2
33.3
6.03
Mercury
µ
g/
L
6
0.0
N/
A
0
0.0
0.012
Nickel
µ
g/
L
6
33.3
1.19
0
0.0
241
Selenium
µ
g/
L
6
0.0
N/
A
0
0.0
5.0
Silver
µ
g/
L
6
0.0
N/
A
0
0.0
9.63
Zinc
µ
g/
L
6
33.3
60.2
0
0.0
162
Acenaphthene
µ
g/
L
3
100.0
0.0177
0
0.0
579
Anthracene
µ
g/
L
3
66.7
0.0770
0
0.0
23,333
Benz(
a)
anthracene
µ
g/
L
3
66.7
0.468
2
66.7
0.067
Benzo(
a)
pyrene
µ
g/
L
3
66.7
0.671
2
66.7
0.067
Benzo(
b)
fluoranthene
µ
g/
L
3
66.7
0.931
2
66.7
0.067
Benzo(
k)
fluoranthene
µ
g/
L
3
66.7
0.501
2
66.7
0.067
Chrysene
µ
g/
L
3
66.7
0.796
2
66.7
0.067
Dibenzanthracene
µ
g/
L
3
66.7
0.251
2
66.7
0.067
Fluoranthene
µ
g/
L
3
100.0
0.897
0
0.0
81
Fluorene
µ
g/
L
3
100.0
0.0357
0
0.0
3,111
Indeno(
1,2,3­
cd)
pyrene
µ
g/
L
3
66.7
0.967
2
66.7
0.067
Pyrene
µ
g/
L
3
100.0
0.658
0
0.0
2,333
Dieldrin
µ
g/
L
4
25.0
0.005
1
25.0
0.0019
Lindane
µ
g/
L
4
0.0
N/
A
0
0.0
0.08
p,
p'
DDE
µ
g/
L
4
0.0
N/
A
0
0.0
0.00128
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
53
Exhibit
C­
19.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
2
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia­
dissolved
mg/
L
7
71.4
0.106
0
0.0
0.988
Arsenic
µ
g/
L
4
75.0
4.03
0
0.0
190
Cadmium
µ
g/
L
4
100.0
2.53
3
75.0
1.73
Chromium
µ
g/
L
4
100.0
3.07
0
0.0
322
Copper
µ
g/
L
4
100.0
10.1
1
25.0
18.7
Lead
µ
g/
L
4
100.0
16.1
1
25.0
6.31
Mercury
µ
g/
L
4
0.0
N/
A
0
0.0
0.012
Nickel
µ
g/
L
4
100.0
1.77
0
0.0
249
Selenium
µ
g/
L
4
25.0
2.85
0
0.0
5
Silver
µ
g/
L
4
50.0
0.537
0
0.0
10.2
Zinc
µ
g/
L
4
100.0
272
2
50.0
167
Acenaphthene
µ
g/
L
2
50.0
0.140
0
0.0
579
Anthracene
µ
g/
L
2
0.0
N/
A
0
0.0
23,333
Benz(
a)
anthracene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Benzo(
a)
pyrene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Benzo(
b)
fluoranthene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Benzo(
k)
fluoranthene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Chrysene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Dibenzanthracene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Fluoranthene
µ
g/
L
2
100.0
0.145
0
0.0
81
Fluorene
µ
g/
L
2
50.0
0.131
0
0.0
3,111
Indeno(
1,2,3­
cd)
pyrene
µ
g/
L
2
50.0
0.0355
0
0.0
0.067
Pyrene
µ
g/
L
2
100.0
0.170
0
0.0
2,333
Dieldrin
µ
g/
L
2
0.0
N/
A
0
0.0
0.0019
Lindane
µ
g/
L
2
0.0
N/
A
0
0.0
0.08
p,
p'
DDE
µ
g/
L
2
0.0
N/
A
0
0.0
0.00128
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
54
Exhibit
C­
20.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
3
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia­
dissolved
mg/
L
10
100.0
0.136
0
0.0
0.423
Arsenic
µ
g/
L
5
60.0
1.88
0
0.0
190
Cadmium
µ
g/
L
5
100.0
0.321
0
0.0
1.69
Chromium
µ
g/
L
5
40.0
0.988
0
0.0
314
Copper
µ
g/
L
5
100.0
8.02
0
0.0
18.3
Lead
µ
g/
L
5
100.0
2.07
0
0.0
6.09
Mercury
µ
g/
L
5
0.0
N/
A
0
0.0
0.012
Nickel
µ
g/
L
5
80.0
1.89
0
0.0
243
Selenium
µ
g/
L
5
0.0
N/
A
0
0.0
5.0
Silver
µ
g/
L
5
0.0
N/
A
0
0.0
9.77
Zinc
µ
g/
L
5
100.0
95.9
1
20.0
163
Acenaphthene
µ
g/
L
2
0.0
N/
A
0
0.0
579
Anthracene
µ
g/
L
2
0.0
N/
A
0
0.0
23,333
Benz(
a)
anthracene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Benzo(
a)
pyrene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Benzo(
b)
fluoranthene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Benzo(
k)
fluoranthene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Chrysene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Dibenzanthracene
µ
g/
L
2
0.0
N/
A
0
0.0
0.067
Fluoranthene
µ
g/
L
2
0.5
0.0537
0
0.0
81
Fluorene
µ
g/
L
2
0.5
0.0373
0
0.0
3,111
Indeno(
1,2,3­
cd)
pyrene
µ
g/
L
2
0.5
0.103
1
50.0
0.067
Pyrene
µ
g/
L
2
0.5
0.0446
0
0.0
2,333
Dieldrin
µ
g/
L
3
0.0
N/
A
0
0.0
0.0019
Lindane
µ
g/
L
3
0.0
N/
A
0
0.0
0.08
p,
p'
DDE
µ
g/
L
3
0.0
N/
A
0
0.0
0.00128
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
55
Exhibit
C­
21.
Toxic
Pollutant
Concentrations
and
Criteria
Exceedances
at
Station
VIL­
4
Pollutant
Units
Number
of
Samples
Percent
of
Samples
Detected
Mean
of
Detected
Values
Number
of
Samples
Exceeding
Criteria
Percent
of
Samples
Exceeding
Criteria
Criteria
Ammonia­
dissolved
mg/
L
3
100.0
0.112
0
0.0
2.29
Arsenic
ug/
L
2
100.0
2.35
0
0.0
190
Cadmium
ug/
L
2
100.0
0.277
0
0.0
1.37
Chromium
ug/
L
2
50.0
1.20
0
0.0
252
Copper
ug/
L
2
100.0
6.61
0
0.0
14.5
Lead
ug/
L
2
100.0
4.89
1
50.0
4.31
Mercury
ug/
L
2
0.0
N/
A
0
0.0
0.012
Nickel
ug/
L
2
100.0
2.20
0
0.0
193
Selenium
ug/
L
2
0.0
N/
A
0
0.0
5.0
Silver
ug/
L
2
0.0
N/
A
0
0.0
6.12
Zinc
ug/
L
2
100.0
155
2
100.0
130
Acenaphthene
ug/
L
1
100.0
0.0461
0
0.0
579
Anthracene
ug/
L
1
0.0
N/
A
0
0.0
23,333
Benz(
a)
anthracene
ug/
L
1
0.0
N/
A
0
0.0
0.067
Benzo(
a)
pyrene
ug/
L
1
0.0
N/
A
0
0.0
0.067
Benzo(
b)
fluoranthene
ug/
L
1
100.0
0.0404
0
0.0
0.067
Benzo(
k)
fluoranthene
ug/
L
1
0.0
N/
A
0
0.0
0.067
Chrysene
ug/
L
1
100.0
0.0284
0
0.0
0.067
Dibenzanthracene
ug/
L
1
0.0
N/
A
0
0.0
0.067
Fluoranthene
ug/
L
1
100.0
0.0731
0
0.0
81
Fluorene
ug/
L
1
100.0
0.0262
0
0.0
3,111
Indeno(
1,2,3­
cd)
pyrene
ug/
L
1
0.0
N/
A
0
0.0
0.067
Pyrene
ug/
L
1
100.0
0.0442
0
0.0
2,333
Dieldrin
ug/
L
16
0.0
N/
A
0
0.0
0.0019
Lindane
ug/
L
0
0.0
N/
A
0
0.0
0.08
p,
p'
DDE
ug/
L
0
0.0
N/
A
0
0.0
0.00128
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
56
Equation
(
2)
Equation
(
1)
Appendix
D.
Ammonia
Toxicity
Analysis
This
appendix
describes
the
approach
used
to
assess
the
ammonia
toxicity
compliance
for
all
the
facilities
with
an
existing
effluent
limit
for
ammonia
(
NH3­
N).
EPA
evaluated
the
criteria
for
ammonia
using
the
procedures
described
in
the
Guidelines
for
Deriving
Numerical
National
Water
Quality
Criteria
for
the
Protection
of
Aquatic
Organisms
and
Their
Uses
(
U.
S.
EPA,
1999).
The
guidelines
indicate
that,
except
where
an
unusually
sensitive
species
is
important
at
a
site,
freshwater
aquatic
life
should
be
protected
if
both
of
the
following
conditions
are
satisfied
for
the
temperature
and
pH
of
the
waterbody:

The
1­
hour
average
concentration
of
total
ammonia
nitrogen
(
in
mg
N/
L)
does
not
exceed,
more
than
once
every
3
years
on
the
average,
the
CMC
(
acute
criterion)
calculated
using
the
following
equation
when
salmonid
fish
are
absent:

The
30­
day
average
concentration
of
total
ammonia
nitrogen
(
in
mg
N/
L)
does
not
exceed,
more
than
once
every
3
years
on
the
average,
the
CCC
(
chronic
criterion)
calculated
using
the
following
equations
when
fish
early
life
stages
are
present:

D.
1
Description
of
Approach
EPA
evaluated
data
for
all
the
facilities
with
an
existing
ammonia
permit
limit.
First,
EPA
evaluated
historic
ambient
data
to
identify
any
potential
exceedances
of
the
in­
stream
ammonia
criteria.
Then,
it
developed
waste
load
allocations
(
WLAs)
for
the
facilities.
The
two
steps
are
described
below.

D.
1.1
Analysis
of
Ambient
Data
 
In­
Stream
Criteria
Exceedance
EPA
analyzed
temperature,
pH,
and
NH3­
N
ambient
observations
with
the
objective
of
identifying
historic
violations
of
the
NH3­
N
criterion:

C
Identify
ambient
monitoring
stations
with
pH,
temperature,
and
NH3­
N
observations
C
Use
Equations
1
and
2
to
compute
the
corresponding
acute
and
chronic
criteria
using
pH
and
temperature
observations
C
Compare
the
corresponding
criteria
with
the
corresponding
observed
NH3­
N
to
identify
any
historic
ammonia
violations.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
57
D.
1.2
Ammonia
WLAs
Following
the
in­
stream
data
analysis,
EPA
developed
WLAs
for
the
facilities.
Because
the
ammonia
criterion
is
a
function
of
pH
and
temperature,
EPA
used
critical
temperature
(
28
°
C)
and
pH
(
8
SU)
values
based
on
in­
stream
data
in
developing
the
NH3
limits
(
Equation
3).
The
steps
in
the
analysis
are:

C
Calculate
the
acute
and
chronic
criteria
using
Equations
1
and
2
C
Estimate
the
biologically­
based
design
flow;
following
U.
S.
EPA
(
1999),
the
1Q10
flow
is
used
for
the
acute
criteria
and
the
30Q10
is
used
for
the
chronic
criteria
C
Estimate
the
ambient
NH3­
N
concentration
for
each
segment
C
Calculate
the
NH3­
N
waste
allocation
based
on
the
biologically
based
flow,
the
ammonia
criterion,
the
discharge
flows,
and
the
ambient
NH3
concentration:

WLA
=
[(
Qdischarge
+
Design_
Flow)*
criteria
­
Design_
Flow*
Cambient]/
Qdischarge
Equation
(
3)

where,

Qdischarge
=
facility
discharge
flow
Criteria
=
acute
or
chronic
criterion
Design_
Flow
=
stream
flow
(
1Q10
for
acute
and
30Q5
for
chronic)
Cambient
=
NH3­
N
in­
stream
concentration
in
mg/
l
C
Use
the
more
stringent
of
the
two
load
allocations
and
compare
it
with
the
existing
discharge
observations
to
estimate
level
of
reduction
(
if
any)
needed
to
meet
the
ammonia
stream
criteria.

D.
2
Application
to
Alabama
Facilities
As
shown
in
Exhibit
D­
1
and
in
the
sections
below,
the
ammonia
WLA
analyses
indicates
that
three
facilities
need
to
control
ammonia
discharge:
ABC
Coke,
Sloss
Industries,
and
Koppers
Coke.

D.
2.1
ABC
Coke
Ammonia
WLA
Discharge
Flow
=
0.12
MGD
Effluent
Limit
Acute
=
255
mg/
l
NH3­
N
Effluent
Limit
Chronic
=
28.4
mg/
l
A
total
of
36
observations,
consisting
of
average
monthly
concentrations,
were
reported
between
January
1998
and
December
2000.
The
existing
monthly
average
permit
limit
for
ABC
Coke
is
25
lbs
per
day
and
is
more
stringent
than
the
projected
limit.
Based
on
these
recent
data,
covering
a
period
of
3
years,
the
projected
chronic
effluent
limit
as
well
as
the
existing
limit
are
exceeded
9
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
58
times
(
17%).
Based
on
these
observations,
EPA
estimated
the
necessary
load
reduction
using
the
mean
of
all
exceedances.
EPA
estimated
the
required
reduction
to
be
27%
and
be
attributable
to
the
existing
limit.
No
additional
reduction
is
required
to
meet
a
F&
W
standard.

D.
2.2
Sloss
Industries
Ammonia
WLA
Discharge
Flow
=
3.22
MGD
WLA
Acute
=
17.6
mg/
l
NH3­
N
WLA
Chronic
=
1.89
mg/
l
NH3­
N
A
total
of
28
observations
were
reported
between
January
1998
and
December
2000.
The
observations
consist
of
maximum
monthly
discharge
concentrations.
Based
on
these
data,
covering
a
period
of
3
years,
the
projected
chronic
ammonia
limit
is
exceeded
eight
times
(
29%).
All
of
the
8
violations
also
exceed
the
existing
permit
limit
of
1.86
mg/
L.
Based
on
these
observations,
EPA
estimated
the
load
reduction
to
be
47%.
This
reduction
is
required
to
comply
with
existing
effluent
limits.
No
additional
reduction
would
be
required
to
meet
F&
W
standards.

D.
2.3
Koppers
Coke
Ammonia
Waste
Load
Allocation
Discharge
Flow
=
0.22
MGD
WLA
Acute
=
376
mg/
l
NH3­
N
WLA
Chronic
=
34.8
mg/
l
NH3­
N
A
total
of
20
observations
were
reported
between
January
1998
and
December
2000.
The
observations
consist
of
average
monthly
discharge
concentrations.
Based
on
these
data,
covering
a
period
of
3
years,
the
projected
ammonia
limit
is
exceeded
5
times
(
25%).
All
of
the
5
violations
also
exceed
the
existing
permit
limit
of
35
mg/
L.
Based
on
these
excursions
from
the
existing
limit,
EPA
estimated
the
load
reduction
to
be
46%.
This
reduction
is
required
to
comply
with
existing
effluent
limits
as
well
as
limits
based
on
LWF
and
F&
W
criteria.
Exhibit
D­
1.
Analysis
of
WLA
Analysis
Facility
Discharge
cfs
1Q10
cfs
30Q10
cfs
NH3
Ambient
mg/
l
WLA
Acute
mg/
l
WLA
Chronic
mg/
l
Final
WLA
mg/
l
Compliance?
Discharge
data
ABC
Coke
0.188
5.8
8.3
0.4
255.45
28.41
28.41
No
17%
of
observations
above
limit
Sloss
Industries
5.05
5.85
8.4
0.5
17.57
1.89
1.89
No
29%
of
observations
above
limit
Koppers
Tar
0.07
15
21.5
0.3
1,745.75
222.29
222.29
Yes
no
observations
above
limit
Koppers
Coke
0.339
15.75
22
0.5
375.80
34.79
34.79
No
25%
of
observations
above
limit
Valley
Creek
WWTP
133.45
15.3
27
0.044
9.37
1.22
1.22
Yes
no
observations
above
limit
Village
Creek
94.2
9.75
12.8
0.053
9.27
1.15
1.15
Yes
no
observations
above
limit
Five
Mile
Creek
WWTP
31.4
10.9
13.45
0.1
11.29
1.41
1.41
Yes
no
observations
above
limit
Honeywell
0.054
1.1
1.5
0.053
178.59
27.89
27.89
Yes
no
observations
above
limit
Earl
Ham
3.8
5.6
8.1
0.015
20.78
3.16
3.16
Yes
no
observations
above
limit
Avondale
Mills
3.18
5.6
8.1
0.015
23.19
3.58
3.58
Yes
no
observations
above
limit
USX
17.5
0.33
0.49
0.05
8.57
1.05
1.05
Yes
3%
of
observations
above
limit
Westpoint
Stevens
4.3
0.46
0.68
0.09
9.30
1.17
1.17
Yes
5%
of
observations
above
limit
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
59
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
60
Appendix
E.
Dissolved
Oxygen
Analysis
This
appendix
summarizes
the
results
for
the
waste
load
allocation
modeling
runs
EPA
performed
for
Opossum
Creek.
EPA
used
the
results
from
a
previous
waste
load
allocation
study
performed
by
ADEM
(
1996).
ADEM
used
a
calibrated
and
verified
dissolved
oxygen
(
DO)/
BOD
model
to
develop
load
allocations
for
the
three
dischargers
to
Opossum
Creek
(
Koppers
Coke,
Koppers
Tar,
and
USX).
Using
the
ADEM
model
parametrization,
EPA
reproduced
the
results
with
a
Streeter
Phelps
DO
model
and
then
assessed:

C
The
attainment
of
a
minimum
DO
standard
of
3
mg/
l
all
year
long
(
A&
I
use)

C
The
attainment
of
a
minimum
DO
standard
of
3
mg/
l
in
summer
and
5
mg/
l
in
winter
(
LWF
use)

C
The
attainment
of
a
minimum
DO
standard
of
5
mg/
l
all
year
long
(
F&
W
use).

E.
1
Facility
Limits
and
Discharges
Exhibit
E­
1
contains
the
current
permit
limits
for
the
three
dischargers
and
the
reported
concentrations
and
loading
for
BOD
and
ammonia
taken
from
the
EPA's
PCS
database.
The
limits
presented
in
Exhibit
E­
1
are
based
on
the
results
of
ADEM's
WLA
to
meet
A&
I
use.
Exhibit
E­
1
also
presents
the
current
concentrations,
loading,
and
percent
of
total
loading
for
each
facility
of
the
three
dischargers.
For
example,
Koppers
Coke
contributes
5.85%
of
the
current
total
BOD
loading
to
the
creek.
Similarly,
they
are
responsible
for
63.6
%
of
the
current
total
ammonia
nitrogen
loading.

All
facilities
are
currently
discharging
well
below
their
permit
limits
(
except
for
Koppers
Coke
with
respect
to
ammonia).
EPA
used
current
discharges
to
assess
reductions
needed
to
attain
the
three
DO
standards.
The
loads
presented
are
derived
from
discharge
data
reported
in
EPA's
PCS.

Exhibit
E­
1.
Current
Permit
Limits
and
Discharge
Condition
at
Opossum
Creek1
Facility
(
flow)
BOD
Concentration
BOD
Loading
(%
of
Total)
NH3­
N
Concentration
NH3­
N
Loading
(%
of
total)
Limit
Discharge
Limit
Discharge
Limit
Discharge
Limit
Discharge
USX
(
11
mgd)
8
4.0
734
(
88.7%)
367
(
94.1%)
1
0.4
92.0
(
55.1%)
37
(
36.1%)

Koppers
Tar
(
0.036
mgd)
15
1.1
4.5
(
0.6%)
0.33
(
0.085%)
20
1.4
6.0
(
3.6%)
0.42
(
0.41%)

Koppers
Coke
(
0.236
mgd)
45
11.6
88.5
(
10.7%)
22.8
(
5.85%)
35
33.1
69.0
(
41.3%)
65.2
(
63.6%)
1Concentrations
in
mg/
L;
Loadings
in
lbs/
day.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
61
E.
2
Modeling
Results
Exhibit
E­
2
contains
the
key
model
parameters
used
for
the
four
model
segments
with
the
three
dischargers.
The
model
parameters
are
the
same
as
those
used
in
the
ADEM
(
1996)
model.

Exhibit
E­
2.
Summary
of
Key
Model
Parameters
Segment
Length
(
miles)
Discharger
Kd
CBOD
Decay
Rate
(
1/
day)
KNH3
(
NBOD
Decay
rate
(
1/
day)
Ka
Reaeration
rate
(
1/
day)
7Q10
Stream
Flow
(
cfs)
Average
Stream
Velocity
(
ft/
sec)

1
0.47
USX
2.06
3.08
6.73
0.36
0.304
2
0.47
Koppers
Tar
2.06
2.82
7.42
17.44
0.304
3
0.51
None
2.06
2.82
4.92
17.46
0.305
4
1.19
Koppers
Coke
2.06
2.60
8.53
17.82
0.308
Source:
ADEM
(
1996).

EPA's
model
predictions
for
the
three
potential
use
designations
are
as
follows:

C
Based
on
the
existing
discharge
conditions,
Opossum
Creek
meets
the
DO
standard
for
A&
I
(
3
mg/
l
all
year
long)

C
Based
on
the
existing
discharge
conditions,
Opossum
Creek
meets
the
LWF
DO
standard
(
DO
=
3
mg/
l
from
May
through
November
and
5
mg/
l
from
December
through
April)

C
LWF
DO
standards
will
be
attained
with
the
incidental
removal
of
NH3­
N
loads
from
Koppers
Coke
associated
with
removal
of
cyanide
C
BOD
discharge
reduction
of
40%
to
50%
of
current
loads
is
needed
from
USX
to
meet
the
F&
W
standard
(
the
addition
of
activated
sludge
treatment
at
USX
should
reduce
BOD
sufficiently
to
attain
5
mg/
l
at
all
times
of
the
year).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
62
Appendix
F.
Facility
Analyses
This
appendix
provides
the
detailed
engineering
and
cost
analyses
for
each
facility
organized
alphabetically
by
name.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
63
ABC
Coke
Description
Alabama
ByProducts
Corporation
(
ABC)
is
a
producer
of
foundry
coke,
used
in
the
production
of
metals.
ABC
Coke
Division/
Drummond
Company
(
NPDES
permit
number
AL0003417),
located
in
Trussville,
Alabama,
is
a
0.12
mgd
facility
that
discharges
to
Five
Mile
Creek.
The
facility
has
two
permitted
outfalls,
DSN001
and
DSN002.
In
the
facility's
2000
permit,
limits
for
outfall
DSN001
(
treated
process
wastewater
and
storm
water
runoff)
are
based
either
on
the
more
stringent
of
Federal
effluent
guidelines
[
40
CFR
420.13(
b)
BAT
/
40
CFR
420.12(
b)
BPT]
or
water
quality
requirements.
Limits
for
outfall
DSN002
(
storm
water
runoff
from
coal
yard)
are
based
on
best
professional
judgment.
Flows
(
in
cfs)
in
Five
Mile
Creek
are
as
follows:
average:
43.0,
harmonic
mean:
19.2,
1Q10:
5.76,
7Q10:
6.40,
7Q2:
6.53.

Existing
Treatment
Processes
Information
from
U.
S.
EPA
Region
4
indicates
that
the
facility
has
a
very
advanced
biological
treatment
operation
that
can
achieve
NH3
concentrations
in
the
range
of
1
to
2
mg/
l.
ABC
Coke
is
also
installing
a
new
biological
treatment
system
and
advanced
secondary
activated
sludge
with
recycle
soon.
The
Region
also
indicated
that
cyanide
is
a
concern
at
the
facility
(
that
it
may
need
a
hydrogen
peroxide
unit)
and
that
facility
has
been
planning
for
the
use
classification
upgrade.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
1
summarizes
the
last
3
years
(
approximately)
of
effluent
monitoring
for
outfall
DSN001
for
pollutants
with
existing
limits.

Exhibit
F­
1.
Compliance
Summary,
ABC
Coke
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Ammonia
nitrogen
(
mg/
l)
36
36
55.3
15.3
25
No2
Benzene
24
0
 
 
150
Yes
Benzo(
a)
pyrene
14
6
120
39.9
150
Yes
Cyanide
3
3
6,095
3,131
400
No3
Phenols
60
59
220
83.3
170
Yes
1Detected
values
only
(`
 
`
indicates
not
applicable).
2About
25%
of
the
average
reported
concentrations
exceed
the
existing
average
monthly
limit
for
ammonia.
3One
of
three
reported
values
complies
with
the
effluent
limit.

Naphthalene
is
also
limited
at
outfall
DSN001,
but
because
there
are
no
Alabama
criteria
for
napthalene,
there
would
be
no
change
associated
with
a
change
in
use.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
64
Exhibit
F­
2
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
criteria
are
not
reflected
in
the
facility's
permit.
Only
pollutants
with
reasonable
potential
and
for
which
data
indicates
that
a
reduction
in
effluent
concentrations
is
needed
are
shown.

Exhibit
F­
2.
Projected
Effluent
Limits,
ABC
Coke
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Ammonia­
N
(
mg/
l)
55.3
25
278
56
56
Benzo(
a)
pyrene
120
150
16
16
16
Cyanide
6,095
400
42
4.2
4.2
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
permit.

Exhibit
F­
3.
Required
Effluent
Reductions,
ABC
Coke
(
pounds
per
year)

Pollutant
Projected
Pollutant
Loading
Reductions
Current
Permit1
A&
I2
LWF
F&
W
Ammonia­
N
11,0703
0
0
0
Benzo(
a)
pyrene
0
38
0
0
Cyanide
2,080
131
145
0
1Reductions
needed
to
meed
current
limit
indicate
noncompliance.
2Reductions
needed
to
m
eet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.
3For
Ammonia­
N,
the
current
permit
is
more
stringent
than
projected
A&
I,
LWF,
and
F&
W
limits
Controls
Needed
Ammonia
Nitrogen:
ABC
Coke
does
not
meet
its
existing
limit
for
ammonia.
A
27%
reduction
would
be
required
to
meet
the
existing
limit
and
will
be
met
with
the
addition
of
chemical
oxidation
(
see
below
for
benzo(
a)
pyrene).

Benzo(
a)
pyrene:
ABC
Coke
is
in
compliance
with
its
existing
limit
but
not
in
compliance
with
the
projected
A&
I
limit.
Consequently,
pollution
controls
need
to
be
installed
to
meet
the
A&
I
limit.
Chemical
oxidation
will
reduce
benzo(
a)
pyrene
to
the
projected
A&
I
limit;
the
reduction
will
also
be
sufficient
to
meet
projected
LWF
and
F&
W
limits.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
65
Cyanide:
ABC
Coke
is
not
in
compliance
with
its
existing
limit
or
the
projected
A&
I
limit.
Consequently,
pollution
controls
need
to
be
installed
to
meet
the
existing
and
A&
I
limit.
Chemical
oxidation
that
will
be
installed
to
remove
ammonia
and
benzo(
a)
pyrene
will
incidentally
reduce
cyanide
to
levels
required
to
meet
a
F&
W
standard
as
well.

Exhibit
F­
4.
Annual
Cost
of
Required
Effluent
Reductions,
ABC
Coke
(
Millions
of
Year
2001dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Chemical
Oxidation
2.4
0.23
1.0
1.23
TOTAL
2.4
0.23
1.0
1.23
1Annualized
at
7%
over
20
years.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
66
American
Cast
Iron
Pipe
Company
Description
American
Cast
Iron
Pipe
Co.(
ACIPCO)
(
NPDES
permit
number
AL0029378)
manufactures
ductile
iron
pipe
and
fittings,
fire
hydrants,
valves
and
pumps
for
fire
trucks,
centrifugally
cast
steel
tubes,
static
castings
and
fabricated
assemblies,
electric
resistance
welded
steel
pipe,
and
spiral
welded
steel
pipe.
ACIPCO,
a
0.55
MGD
facility
located
in
Birmingham,
Alabama,
discharges
to
Village
Creek.
The
facility
has
eight
permitted
outfalls.
In
the
facility's
1993
permit,
limits
for
outfall
DSN001
(
treated
process
wastewater
and
storm
water)
are
based
on
Federal
effluent
guidelines
[
40
CFR
464].
Limits
for
outfalls
DSN002
 
DSN008
(
storm
water
runoff
from
industrial
activity)
are
based
on
Federal
guidelines
[
40
CFR
464].
Flows
(
in
cfs)
in
Village
Creek
are
as
follows:
average:
47.04,
harmonic
mean:
21,
1Q10:
6.3,
7Q10:
7,
7Q2:
7.14.

Existing
Treatment
Processes
Information
from
U.
S.
EPA
Region
4
indicates
that
the
facility's
wastewater
is
treated
in
lime
settling
ponds
followed
by
a
final
pH
adjustment.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
5
summarizes
effluent
monitoring
from
January
1,
2000
through
February
28,
2001
for
outfall
DSN001
for
pollutants
with
existing
limits.

Exhibit
F­
5.
Compliance
Summary,
ACIPCO
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Limit?
Total
Detect
Maximum
Mean
Total
Copper
14
14
654
327
1,330
Yes
Total
Lead
7
7
218
218
6,388
Yes
Total
Zinc
27
27
11,990
3,117
4,556
No2
Total
Phenols
14
14
872
358
556
No
1Detected
values
only.
2The
five
m
ost
recent
observations
exceed
the
current
limit.

Exhibit
F­
6
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
criteria
are
not
reflected
in
the
facility's
permit.
Only
pollutants
with
reasonable
potential
and
for
which
data
indicate
that
a
reduction
in
effluent
concentrations
is
needed
are
shown.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
67
Exhibit
F­
6.
Projected
Effluent
Limits,
ACIPCO
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Total
Copper3
654
1,330
8.8
8.8
8.8
Total
Lead4
218
6,388
41
2.6
2.6
Total
Zinc3
11,990
4,556
489
489
489
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
permit.
3The
A&
I,
LWF,
and
F&
W
effluent
limits
are
the
same
because
they
are
all
based
on
the
acute
criterion
which
has
the
limiting
LTA.
4The
A&
I
effluent
limit
is
based
on
the
acute
criterion
end­
of­
pipe
because
the
receiving
water
concentration
exceeds
the
acute
criterion.
The
LWF
and
F&
W
effluent
limits
are
based
on
the
chronic
criterion
end­
of­
pipe
because
the
receiving
water
concentration
exceeds
the
chronic
criterion.
There
is
no
human
health
criterion
for
lead.

Exhibit
F­
7.
Required
Effluent
Reductions,
ACIPCO
(
pounds
per
year)

Pollutant
Projected
Pollutant
Loading
Reductions
Current
Permit1
A&
I2
LWF
F&
W
Total
Copper
0
1,080
0
0
Total
Lead
0
297
63.7
0
Total
Zinc
12,450
6,810
0
0
1Reductions
needed
to
meet
current
limit
indicate
noncompliance.
2Reductions
needed
to
m
eet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.

Controls
Needed
Copper:
Existing
copper
discharges
are
in
compliance
with
the
current
permit
limit
but
are
not
in
compliance
with
the
projected
A&
I,
LWF,
or
F&
W
limits.
Chemical
precipitation
is
needed
to
reduce
copper
to
meet
A&
I
limits.
Removal
efficiencies
of
up
to
95%
to
97%
are
reported
for
facilities
using
chemical
precipitation
to
control
copper
(
RREL
Treatability
Database).
Consequently,
copper
will
be
removed
at
levels
that
comply
with
the
LWF
and
F&
W
limits.

Lead:
Existing
lead
discharges
are
in
compliance
with
the
current
permit
limit
but
are
not
in
compliance
with
the
projected
A&
I,
LWF,
and
F&
W
limits.
Consequently,
pollution
controls
need
to
be
added
to
meet
the
projected
limits.
Chemical
precipitation
installed
to
remove
copper
will
incidentally
reduce
lead
to
the
required
A&
I,
LWF,
and
F&
W
levels.

Zinc:
The
existing
discharge
is
not
in
compliance
with
either
current
permit
limits
or
projected
A&
I
limits.
Chemical
precipitation
is
needed
to
reduce
zinc
to
the
A&
I
limits.
Removal
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
68
efficiencies
of
up
to
90%
were
reported
for
facilities
using
chemical
precipitation
to
control
zinc
(
RREL
Treatability
Database).
Consequently,
zinc
will
be
also
removed
at
levels
that
comply
with
the
LWF
and
F&
W
limits.

Stormwater:
Village
Creek
exceeds
the
acute
criterion
for
zinc.
ACIPCO
also
has
a
reporting
requirement
for
zinc
in
its
stormwater
discharge.
Therefore,
a
stormwater
BMP
(
detention
basin)
is
needed
at
this
facility
to
meet
the
A&
I
criterion.

Exhibit
F­
8.
Annual
Cost
of
Required
Effluent
Reductions,
ACIPCO
(
Millions
of
Year
2001
dollars)

Control
(
pollutant
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Chemical
Precipitation
1.1
0.104
0.14
0.24
Stormwater
BMP
0.31
0.29
 
0.29
TOTAL
1.1
0.104
0.14
0.24
1Annualized
at
7%
over
20
years.
"­"
indicates
not
applicable.
One
time
capital
cost
annualized.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
69
Ashland
Chemicals
Description
Ashland
Chemical
Company
(
NPDES
permit
number
AL0021695)
is
a
wholesale
distributor
of
chemicals
and
petrochemicals.
Located
in
Birmingham,
Alabama,
Ashland
Chemicals
has
three
permitted
outfalls
to
Village
Creek.
In
the
facility's
1999
permit,
limits
for
outfall
DSN002
(
facility
storm
water
runoff),
DSN002a
(
storm
water
runoff
from
secondary
containment
area
drainage),
and
DSN003
(
treated
groundwater
from
groundwater
remediation
activities)
are
based
on
either
the
more
stringent
of
human
health
or
water
quality
criteria
and
on
best
professional
judgment.
Flows
(
in
cfs)
in
Village
Creek
are
as
follows:
average:
47.07,
harmonic
mean:
21,
1Q10:
6.3,
7Q10:
7,
7Q2:
7.14.

Existing
Treatment
Processes
Information
from
U.
S.
EPA
Region
4
indicates
that
the
facility
has
stormwater
controls.
Water
is
stored
in
dyked
areas
and
then
released.
There
is
no
end­
of­
pipe
treatment.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
9
summarizes
effluent
monitoring
data
from
January
2000
through
April
2001
for
outfall
DSN002a
for
pollutants
with
existing
limits
(
outfall
DSN002
does
not
have
numeric
limits
for
toxics).

Exhibit
F­
9.
Compliance
Summary,
Ashland
Chemicals
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
BETX
11
0
 
 
200
Yes
1,1,2­
Trichloroethane
22
0
 
 
420
Yes
1,1,1­
Trichloroethane
0
0
 
 
5,280
 
Dichloromethane
11
0
 
 
13
Yes
1Detected
values
only
(
`
 
`
indicates
not
applicable).

There
are
no
data
indicating
that
a
reduction
in
effluent
concentrations
is
needed
for
this
facility.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
70
Avondale
Mills
 
Eva
Jane
Plant
Description
Avondale
Mills,
Inc.
operates
textile
mills
which
produce
cotton
and
synthetic
yarns
and
fabrics
throughout
the
southern
United
States.
Avondale
Mills
Eva
Jane
Plant
(
NPDES
permit
number
AL0001627),
located
in
Sylacauga,
Alabama,
is
a
2.0
mgd
yarn
preparation,
dyeing,
and
weaving
facility
that
discharges
to
Shirtee
Creek.
The
facility
has
13
permitted
outfalls.
In
the
facility's
1991
permit,
limits
for
outfalls
DSN001
(
process
wastewater
and
cooling
tower
blowdown)
and
DSN002
are
based
on
limits
from
the
facility's
previous
permit.
The
limits
have
been
modified
for
some
pollutants
as
requested
by
the
permittee
or
where
otherwise
deemed
appropriate.
Limits
for
outfalls
DSN009
and
DSN011
(
intermittent
discharges
from
steam
traps)
are
based
on
water
quality
requirements
and
ADEM
Administrative
Code
Division
6,
Volume
1.
Limits
for
outfalls
DSN013
 
DSN021
(
storm
water
associated
with
the
manufacture
of
textile
products
and
storm
water
from
the
landfill)
"
have
been
demonstrated
through
experience
by
the
Department
to
be
best
conventional
technology."
Flows
(
in
cfs)
in
Shirtee
Creek
are
as
follows:
average:
42.3,
harmonic
mean:
18.9,
1Q10:
5.66,
7Q10:
6.29,
7Q2:
6.41.

Existing
Treatment
Processes
There
is
no
information
on
existing
treatment
processes
at
this
plant.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
10
summarizes
of
effluent
monitoring
data
collected
from
January
1998
through
May
2001
for
outfall
DSN001
for
pollutants
with
existing
limits.

Exhibit
F­
10.
Compliance
Summary,
Avondale
Mills
 
Eva
Jane
Plant
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Ammonia
nitrogen
(
mg/
l)
40
37
2.5
0.92
 
 
Phenols
3
3
240
155
444
Yes
Total
Recoverable
Copper
 
 
 
 
87
 
Total
Recoverable
Lead
 
 
 
 
420
 
Total
Recoverable
Zinc
 
 
 
 
635
 
1Detected
values
only
(
`
 
`
indicates
no
data
or
limit).

The
pollutants
for
which
effluent
data
exists
comply
with
existing
limits.
The
facility
does
not
have
an
existing
limit
for
ammonia
but
its
discharge
levels
comply
with
the
projected
WLA
(
see
Appendix
D).
The
facility's
data
do
not
contain
effluent
monitoring
data
for
copper,
lead
or
zinc
discharges
to
Shirtee
Creek.
Based
on
this
information,
EPA
estimate
that
no
additional
controls
would
be
needed
at
this
facility.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
71
Birmingham
Steel
Corporation
Description
Birmingham
Steel
(
NPDES
permit
number
AL0003735)
is
the
steel
division
of
Birmingham
Steel
Corporation
in
Alabama.
The
facility
manufactures
reinforcing
bars
(
used
in
concrete
construction),
rounds
(
used
in
bolt
manufacturing
and
equipment
production)
and
squares
(
used
in
stair
railings
and
railroad
spikes).
Birmingham
Steel
is
a
0.72
mgd
facility
located
in
Birmingham,
Alabama.
The
facility's
1997
permit
names
Village
Creek
as
the
receiving
waters
for
the
facility's
two
permitted
outfalls.
However,
more
recent
information
from
U.
S.
EPA
Region
4
indicates
that
Birmingham
Steel
has
no
discharge.
Based
on
this
information
and
the
unavailability
of
discharge
data,
EPA
did
not
conduct
additional
analysis
for
this
facility.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
72
Earl
Ham
WWTP
Description
The
J.
Earl
Ham
Wastewater
Treatment
Plant
(
NPDES
permit
number
AL0020001),
located
in
Sylacauga,
Alabama,
is
a
2.4
mgd
facility
that
discharges
to
Shirtee
Creek.
A
July
20,
2001
ADEM
State
Affirmation
of
Environmental
Findings
indicates
that
the
City
of
Sylacauga
plans
to
increase
the
capacity
of
the
Earl
Ham
facility.
The
facility
currently
has
one
permitted
outfall.
In
the
fact
sheet
for
the
facility's
1998
permit,
limits
for
outfall
001
are
based
on
the
previous
permit,
Federal
effluent
guidelines
[
40
CFR
133.102(
b)(
1)
/
40
CFR
133.102(
c)],
and
ADEM's
Disinfection
Toxicity
Strategy.
Flows
(
in
cfs)
in
Shirtee
Creek
are
as
follows:
average:
42.26,
harmonic
mean:
18.87,
1Q10:
5.66,
7Q10:
6.29,
7Q2:
6.42.

Existing
Treatment
Processes
Information
from
the
fact
sheet
for
the
facility's
1998
permit
indicates
that
Earl
Ham
WWTP's
existing
treatment
processes
include
mechanical
bar
screen,
aerated
grit
chamber,
extended
aeration
basins,
final
clarifications,
effluent
disinfection
(
chlorination)
and
dechlorination,
post
aeration,
waste
sludge
thickening,
sludge
drying
beds,
sludge
belt
press,
and
land
application
of
dewatered
sludge.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
11
summarizes
effluent
monitoring
from
June
1998
through
June
2000
for
outfall
001
for
toxic
pollutants
which
have
reasonable
potential.
The
facility's
permit
does
not
contain
numeric
limits
or
monitoring
requirements
for
toxics
other
than
ammonia.
However,
12
toxic
pollutants
are
reported
in
DMR
reports
provided
by
U.
S.
EPA
Region
4.

Exhibit
F­
11.
Compliance
Summary,
Earl
Ham
WWTP
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
mg/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Fecal
Coliform
 
 
 
 
 
 
Ammonia
7
7
0.50
0.21
10.0
Yes
1Detected
values
only
(
`
 
`
indicates
no
data
or
limit).

Controls
Needed
Fecal
Coliform:
There
is
no
existing
limit
or
effluent
data
available
for
fecal
coliform
at
Lower
and
Upper
Earl
Hamm
WWTP.
However
Shirtee
Creek
exceeds
the
F&
W
criterion
for
fecal
coliform.
Since
the
wastewater
treatment
plant
is
the
only
potential
fecal
coliform
source,
optimization
of
the
plant's
existing
chlorination
process
will
reduce
the
fecal
coliform
levels.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
73
Exhibit
F­
12.
Annual
Cost
of
Required
Effluent
Reductions,
Earl
Ham
WWTP
(
Millions
of
Year
2001dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Chlorination
Optimization
0.78
0.074
 
0.074
TOTAL
0.78
0.074
 
0.074
1Annualized
at
7%
over
20
years.
`
 
`
indicates
not
applicable
(
only
a
one
time
capital
cost
applies).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
74
Five
Mile
Creek
WWTP
Description
Jefferson
County
Five
Mile
Creek
WWTP
(
NPDES
permit
number
AL0026913),
located
in
Fultondale,
Alabama,
is
a
20
mgd
facility
that
discharges
to
Five
Mile
Creek.
The
facility
has
5
permitted
outfalls;
DSN001
is
the
treated
wastewater
outfall
and
DSN002­
005
are
storm
water
outfalls
with
no
effluent
limits.
In
the
fact
sheet
for
the
facility's
1999
draft
permit,
limits
for
outfall
DSN001
are
based
on
Federal
effluent
guidelines
[
40
CFR
133.102],
a
waste
load
allocation
model,
and
ADEM's
Disinfection
Strategy
Toxicity
Strategy.
Limits
for
outfalls
DSN002­
005
are
based
on
best
professional
judgment.
Flows
(
in
cfs)
in
Five
Mile
Creek
are
as
follows:
average:
31.9,
harmonic
mean:
14.25,
1Q10:
3.56,
7Q10:
4.75,
7Q2:
4.85.

Existing
Treatment
Processes
Information
from
the
Fact
Sheet
for
the
facility's
1999
draft
permit
indicates
that
the
facility's
treatment
processes
comprise
bar
screen,
grit
removal,
grease
removal,
primary
sedimentation,
activated
sludge,
final
clarification,
chlorination,
and
dechlorination.
Sludge
is
treated
by
an
aerobic
digester
then
pumped
to
a
sludge
lagoon
or
drying
beds.
Dried
biosolids
are
land
applied
for
reclamation
purposes.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
13
summarizes
the
last
3
years
(
approximately)
of
effluent
monitoring
for
outfall
DSN001
for
pollutants
with
existing
limits.

Exhibit
F­
13.
Compliance
Summary,
Five
Mile
Creek
WWTP
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
mg/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Fecal
Coliform
 
 
 
 
 
 
Ammonia
nitrogen
(
mg/
l)
39
39
.2
.1
2
Yes
1Detected
values
only
(
`
 
`
indicates
no
dat
or
no
limit).

Controls
Needed
Fecal
Coliform:
There
is
no
existing
limit
or
effluent
data
available
for
fecal
coliform
at
Five
Mile
Creek
WWTP.
However
Five
Mile
Creek
exceeds
the
F&
W
criterion
for
fecal
coliform.
Since
the
wastewater
treatment
plant
is
the
only
potential
fecal
coliform
source,
optimization
of
the
plant's
existing
chlorination
process
will
reduce
the
fecal
coliform
levels.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
75
Mercury:
The
human
health
criterion
for
mercury
is
exceeded
in
Five
Mile
Creek.
Although
there
are
no
discharge
data
indicating
that
this
facility
discharges
mercury,
mercury
is
a
common
pollutant
in
POTW
effluents.
Therefore,
a
waste
minimization
program
for
mercury
should
be
implemented
to
meet
the
F&
W
criterion.

Exhibit
F­
14.
Annual
Cost
of
Required
Effluent
Reductions,
Five
Mile
Creek
WWTP
(
Millions
of
Year
2001dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Chlorination
Optimization
0.25
0.02
 
0.02
Waste
Minimization
0.49
0.05
 
0.05
TOTAL
0.74
0.07
 
0.07
1Annualized
at
7%
over
20
years.
`
 
`
indicates
not
applicable
(
only
a
one
time
capital
cost
applies).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
76
Honeywell
International
Description
Honeywell
International,
Inc.,
manufactures
coal
tar
distillates.
Honeywell
(
NPDES
permit
number
AL0002097),
located
in
Birmingham,
Alabama,
is
a
0.034
mgd
facility
that
discharges
to
Village
Creek.
The
facility
has
one
permitted
outfall.
In
the
facility's
2000
permit,
limits
for
outfall
DSN001
(
treated
process
wastewater,
steam
condensate,
boiler
blowdown,
treated
storm
water,
contaminated
remediation
groundwater,
and
off
site
coal
tar
wastewaters)
are
based
on
the
more
stringent
of
Federal
effluent
guidelines
[
40
CFR
414.71
BPT
/
40
CFR
414.73(
b)
/
40
CFR
414.91],
human
health
criteria,
or
water
quality
criteria.
Flows
(
in
cfs)
in
Five
Mile
Creek
are
as
follows:
average:
9.61,
harmonic
mean:
4.29,
1Q10:
2.29,
7Q10:
1.43,
7Q2:
1.46.

Existing
Treatment
Processes
Information
from
U.
S.
EPA
Region
4
indicates
that
the
facility's
treatment
processes
consist
of
activated
sludge
in
a
converted
above­
ground
tank
with
clarification
and
filter
press
for
sludge
and
an
activated
carbon
unit
after
clarification.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
15
summarizes
effluent
monitoring
data
from
December
1996
through
December
2000
for
outfall
DSN001.
The
facility's
2000
permit
includes
numeric
limits
and
monitoring
requirements
for
63
pollutants
at
this
discharge
point.
Only
those
with
reasonable
potential
are
shown
in
the
following
tables.

Exhibit
F­
15.
Compliance
Summary,
Honeywell
International
Pollutant
Number
of
Observations
Effluent
Concentrations
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Ammonia
­
mg/
L
36
36
21.3
4.5
46.9
Yes
1,1,2­
Trichloroethane
4
3
35,000
11,700
21
No
1,2­
Dichloropropane
3
2
4.6
4.0
150
Yes
Acrylonitrile
3
2
32
22
96
Yes
Benzo(
a)
anthracene
4
3
62
28
22
No
Benzo(
a)
pyrene
3
2
13
10
23
Yes
Benzo(
k)
fluoranthene
4
3
62
28
22
No
Chrysene
4
3
57
26
22
No
Copper,
Total
4
3
60
49
Monitor
 
Cyanide,
Total
3
2
36
34
420
Yes
Lead,
Total
3
2
5.3
4.4
None
­

Zinc,
Total
4
3
179
133
None
­
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
77
Naphthalene
is
also
limited
at
outfall
DSN001,
but
because
there
are
no
Alabama
criteria
for
napthalene,
there
would
be
no
change
associated
with
a
change
in
use.

Exhibit
F­
16
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
criteria
are
not
reflected
in
the
facility's
permit.
Only
pollutants
for
which
a
reduction
in
effluent
concentrations
is
needed
(
Exhibit
F­
17)
are
shown.

Exhibit
F­
16.
Projected
Effluent
Limits,
Honeywell
International
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Benzo(
a)
anthracene
62
22
0.067
0.067
0.067
Benzo(
a)
pyrene
13
23
0.067
0.067
0.067
Benzo(
k)
fluoranthene
62
22
0.067
0.067
0.067
Chrysene
57
22
0.067
0.067
0.067
Copper,
Total
60
None
243
205
205
Cyanide,
Total
36
420
205
4.2
4.2
Lead,
Total
5.3
None
1844
5.15
5.15
Zinc,
Total
179
None
92
92
92
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
permit.

Exhibit
F­
17.
Required
Effluent
Reductions,
Honeywell
International
(
pounds
per
year)

Pollutant
Projected
Pollutant
Loading
Reductions
Current
Permit1
A&
I2
LWF
F&
W
Benzo(
a)
anthracene
4.2
2.27
0
0
Benzo(
a)
pyrene
0
1.33
0
0
Benzo(
k)
fluoranthene
4.2
2.27
0
0
Chrysene
3.61
2.27
0
0
Copper,
Total
 
0
0
0
Cyanide,
Total
0
0
3.32
0
Lead,
Total
 
0
0.016
0
Zinc,
Total
­
9.0
0
0
1Reductions
needed
to
meed
current
limit
indicate
noncompliance.
2Reductions
needed
to
m
eet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.
If
no
reduction
is
needed
to
meet
current
limit,
reduction
to
meet
estimated
limit
is
from
MEC.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
78
Exhibit
F­
17
shows
that
pollution
controls
need
to
be
installed
to
control
PAHs,
copper,
cyanide
and
lead.
The
existing
data
are
limited
in
that
no
more
than
four
observations
exist
for
any
pollutant.
Information
on
the
facility
indicates
that
the
existing
treatment
train,
consisting
of
activated
sludge,
clarification
and
a
GAC
unit,
should
be
able
to
remove
the
pollutants
to
A&
I
levels.
Therefore,
process
optimization
of
the
existing
GAC
unit
is
needed
(
Exhibit
F­
18).

Cyanide
concentrations
meet
the
existing
limit
and
the
estimated
A&
I
limit
but
would
not
comply
with
LWF
and
F&
W
limits.
The
optimization
of
the
GAC
unit
will
incidentally
remove
cyanide
to
required
LWF
and
F&
W
levels.
Consequently,
the
cost
of
compliance
is
associated
with
meeting
projected
A&
I
limits.

Zinc
does
not
comply
with
the
projected
A&
I,
LWF,
and
F&
W
limits.
The
existing
treatment
train
consists
of
activated
sludge.
EPA's
RREL
Treatability
database
indicates
that
activated
sludge
can
achieve
remove
up
to
90%
of
influent
zinc.
Therefore
optimization
of
the
activated
sludge
process
is
needed
to
comply
with
the
A&
I
limits.
The
LWF
and
F&
W
limits
will
also
be
met
since
they
are
the
same
as
the
A&
I
limits.

Exhibit
F­
18.
Annual
Cost
of
Required
Effluent
Reductions,
Honeywell
International
(
Millions
of
Year
2001dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
GAC
Process
Optimization2
0.06
0.0057
 
0.0057
Activated
Sludge
Process
Optimization
0.13
0.012
­
0.012
TOTAL
0.19
0.018
 
0.018
1Annualized
at
7%
over
20
years.
2Costs
attributed
to
compliance
with
current
permit
limit
and
not
proposed
rule.
`
 
`
indicates
not
applicable
(
only
a
one
time
capital
cost
applies).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
79
Koppers
Industries
 
Woodward
Coke
Plant
Description
Koppers
Industries
Woodward
Coke
Plant
(
NPDES
permit
number
AL0000680),
a
division
of
Koppers
Industries,
is
involved
in
the
carbonization
of
coal
to
produce
coke
and
coal
by­
products.
Average
daily
production
is
2,000
tons/
day.
The
facility
has
two
permitted
outfalls
to
Opossum
Creek
in
Woodward,
Alabama:
outfall
DSN001
(
0.2
mgd)
for
treated
process
wastewater,
cooling
tower
blowdown,
and
storm
water,
and
outfall
DSN002
(
0.16
mgd)
for
noncontact
cooling
water,
cooling
tower
blowdown,
boiler
blowdown,
and
storm
water
runoff.
Receiving
water
flows
are
as
follows:
average:
118
cfs;
harmonic
mean:
52.5;
7Q2:
17.9;
7Q10:
17.5;
1Q10:
15.8.

Existing
Treatment
Processes
The
facility's
1994
permit
application
indicates
that,
for
process
wastewater
discharged
at
outfall
DSN001,
it
uses
ammonia
stripping,
sand
filtration,
neutralization,
activated
sludge,
and
reuses
and
recycles
as
appropriate.
Coal
and
coke
are
stored
on
the
ground
in
piles,
and
all
runoff
is
directed
to
a
collection
pond.
The
application
indicates
that
the
facility
uses
evaporation,
sedimentation,
neutralization,
and
reuse
and
recycle
as
appropriate
for
outfall
DSN002.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
19
summarizes
effluent
monitoring
data
from
1996
through
1998
for
outfall
DSN001
for
pollutants
with
existing
limits.

Exhibit
F­
19.
Compliance
Summary,
Koppers
Ind.
 
Woodward
Coke
Plant
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
l
unless
noted)
Existing
Limit
Comply
with
Existing
Limit?
Total
Detect
Maximum
Mean
Ammonia
 
mg/
l
20
20
86
23.5
35
No
Benzene
10
10
57
7.2
80
Yes
Benzo(
a)
pyrene
10
10
83
18
23
No1
Cyanide
27
27
34,000
8,100
9,100
No
Phenols
27
27
62,000
3,600
80
No
1Three
observations
were
above
limit
 
no
reasonable
potential.

Naphthalene
is
also
limited
at
outfall
001,
but
because
there
are
no
Alabama
criteria
for
napthalene,
there
would
be
no
change
associated
with
a
change
in
use.

Exhibit
F­
20
summarizes
the
projected
effluent
limits
for
the
facility.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
80
criteria
are
not
reflected
in
the
facility's
permit.
Only
pollutants
with
reasonable
potential
and
for
which
data
indicate
that
a
reduction
in
effluent
concentrations
is
needed
are
shown.

Exhibit
F­
20.
Projected
Effluent
Limits,
Koppers
Ind.
 
Woodward
Coke
Plant
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Ammonia
­
mg/
L
86
35
376
34.8
34.8
Total
Cyanide
34,000
9,100
445
58
57
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
permit.

Exhibit
F­
21.
Required
Effluent
Reductions,
Koppers
Ind.
 
Woodward
Coke
Plant
(
pounds
per)

Pollutant
Projected
Pollutant
Loading
Reductions
Current
Permit1
A&
I
LWF
F&
W
Ammonia
36,600
0
144
0
Total
Cyanide
16,000
5,500
250
0.6
1Reductions
needed
to
meet
current
limit
indicate
noncompliance.
2Reductions
needed
to
meet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.

Controls
Needed
Ammonia
Nitrogen:
Koppers
Coke
does
not
meet
its
existing
limit
and
its
LWF
limit
for
ammonia.
The
required
reduction
is
30%.
No
additional
reduction
is
required
to
meet
an
F&
W
standard.
The
addition
of
a
chemical
oxidation
unit
is
sufficient
to
meet
the
existing
limits
and
projected
water
quality­
based
limits
(
see
Appendix
C).

Cyanide:
There
are
27
cyanide
observations
for
the
discharge.
Nine
of
these
27
observations
do
not
comply
with
the
existing
limit
and
range
from
9,900
µ
g/
l
to
34,000
µ
g/
l.
The
facility
is
not
in
compliance
with
limits
based
on
A&
I.
A
chemical
oxidation
unit
would
allow
the
facility
to
comply
with
A&
I
limits
(
as
well
as
LWF
and
F&
W
limits).
Consequently,
the
cost
associated
with
the
chemical
oxidation
unit
is
attributable
to
complying
with
projected
A&
I
limits.

Exhibit
F­
22.
Annual
Cost
of
Required
Effluent
Reductions,
Koppers
Ind.
 
Woodward
Coke
Plant
(
Millions
of
Year
2001
Dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Chemical
Oxidation2
2.9
0.26
2.2
2.46
TOTAL
2.9
0.26
2.2
2.46
1Annualized
at
7%
over
20
years.
2Costs
are
attributed
to
compliance
with
current
permit
and
not
to
proposed
rule.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
81
Koppers
Industries,
Woodward
Tar
Plant
Description
The
Woodward
Tar
Plant,
part
of
Koppers
Industries
Carbon
Materials
and
Chemicals
Division,
specializes
in
carbon
pitch,
coal
tar
distillates,
industrial
wood
preservatives,
and
refined
tars.
Woodward
Tar
Plant
(
NPDES
permit
number
AL0003221),
located
in
Dolomite,
Alabama,
is
a
0.044
mgd
facility
that
discharges
to
Opossum
Creek.
The
facility
has
two
permitted
outfalls.
In
the
facility's
1996
permit,
limits
for
outfall
DSN001
(
uncontaminated
storm
water
and
DSN001A)
are
based
on
a
1992
ADEM
Waste
Load
Allocation
Study.
Limits
for
outfall
DSN001A
(
treated
process
and
sanitary
wastewater
and
storm
water)
are
based
on
OCPSF
guidelines
[
40
CFR
414.71/
40
CFR
414.91].
Flows
(
in
cfs)
in
Opossum
Creek
are
as
follows:
average:
117.02,
harmonic
mean:
52.2,
1Q10:
15.66,
7Q10:
17.4,
7Q2:
17.8.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
23
summarizes
effluent
monitoring
data
from
January
1996
through
February
2001.
The
limits
and
effluent
concentrations
shown
reflect
end­
of­
pipe
limits
and
calculated
effluent
concentrations
for
the
external
outfall
based
on
limits
and
data
from
both
the
internal
and
external
outfalls.
The
facility's
1996
permit
includes
numeric
limits
for
63
pollutants.
Only
pollutants
with
reasonable
potential
are
shown
in
the
following
tables.

Exhibit
F­
23.
Compliance
Summary,
Koppers
Ind.
 
Woodward
Tar
Plant
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Ammonia
­
mg/
L
27
23
12.6
1.9
20
Yes
Benzo(
k)
fluoranthene
5
4
152
4.9
4.6
Yes
Total
Lead
3
2
8.2
5.3
None
 
Total
Cyanide
62
60
1503
49
172
Yes
1Detected
values
only
(
`
 
`
indicates
not
applicable).
2Outlier;
rest
of
observations
below
limt.
3One
outlier
removed
Exhibit
F­
24
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
criteria
are
not
reflected
in
the
facility's
permit.

The
facility
complies
with
existing
limits
and
projected
limits
are
all
less
stringent
than
existing
limits.
Consequently,
there
are
no
additional
pollution
controls
needed.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
82
Exhibit
F­
24.
Projected
Effluent
Limits,
Koppers
Ind.
 
Woodward
Tar
Plant
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Limit
Projected
Effluent
Limit
A&
I
LWF
F&
W
Benzo(
k)
fluoranthene
15
4.6
116
116
116
Total
Lead
2.5
None
4808
2.6
2.6
Total
Cyanide
150
172
2072
260
255
1Maximum
effluent
concentration.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
83
Miller
Steam
Description
The
James
H.
Miller,
Jr.
Electric
Generating
plant
is
a
coal­
fueled
power
plant
owned
by
Alabama
Power,
a
subsidiary
of
Southern
Company.
Miller
Steam
has
four
generating
units
that
provide
a
total
generating
capacity
of
2,640,000
KW.
Miller
Steam
(
NPDES
permit
number
AL0027146),
located
in
Quinton,
Alabama,
is
a
11.42
mgd
facility
that
discharges
to
Village
Creek
and
the
Locust
Fork
of
the
Black
Warrior
River.
The
two
permitted
discharges
to
Village
Creek,
outfalls
DSN008
and
DSN009
are
discharges
from
stormwater
retention
ponds.
There
are
no
numeric
limits
or
monitoring
requirements
associated
with
these
discharges.
The
facility's
DMR
data
do
not
contain
effluent
monitoring
data
for
either
of
the
discharges
to
Village
Creek.
Based
on
this
information,
EPA
did
not
conduct
additional
analysis
for
this
facility.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
84
Sloss
Industries
Description
Information
from
an
EPA/
ADEM
joint
Performance
Audit
Inspection
indicates
that
Sloss
Industries
Coke
Division
(
NPDES
permit
number
AL0003247,
2000
Draft
Permit)
produces
coke
for
both
blast
furnaces
and
foundries,
sulphonic
acid,
and
slag
wool.
The
3.22
mgd
facility
is
located
in
Birmingham,
Alabama,
and
discharges
process
wastewater
and
storm
water
to
Five
Mile
Creek.
The
facility
has
two
additional
storm
water
outfalls
(
one
to
Five
Mile
Creek
and
one
to
Village
Creek).

Information
in
the
facility's
permit
fact
sheet
indicates
that
limits
for
outfall
DSN001
(
treated
process
wastewater
and
sanitary
wastewaters,
non­
contact
cooling
water,
boiler
blowdown
and
storm
water
runoff)
are
based
on
effluent
guidelines
and
water
quality.
This
outfall
includes
effluent
from
internal
outfalls
DSN001A
(
treated
wastewater
from
metal
molding
and
casting
operations)
and
DSN001B
(
treated
wastewater
from
coke
plant,
chemical
plant
and
pilot
plant,
and
Arachem
wastewater).
The
fact
sheet
indicates
that
limits
for
outfall
DSN001A
are
based
on
effluent
guidelines
for
the
metal
molding
casting
industry
[
40
CFR
464].
Limits
for
outfall
DSN001B
are
based
on
the
more
stringent
of
Federal
effluent
guidelines
[
40
CFR
420.13(
b)
/
40
CFR
440.414]
or
water
quality
requirements.
Flows
(
in
cfs)
in
Five
Mile
Creek
at
the
location
of
these
outfalls
are
as
follows:
average:
43.71,
harmonic
mean:
19.5,
1Q10:
5.85,
7Q10:
6.5,
7Q2:
6.63.

Existing
Treatment
Processes
According
to
the
Performance
Audit
Inspection,
which
was
performed
on
August
29,
2000,
Sloss
Industries'
process
wastewater
is
treated
in
a
1.1
mgd
activated
sludge
treatment
plant
consisting
of
two
equalization
tanks,
three
neutralization
tanks,
one
primary
clarifier,
two
aeration
basins,
one
secondary
clarifier,
and
one
settling
lagoon.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
25
summarizes
of
effluent
monitoring
from
June
1998
through
June
2001
for
toxics
at
outfall
DSN001.
The
facility's
2000
draft
permit
includes
numeric
limits
for
76
pollutants
for
outfall
DSN001
and
its
associated
internal
outfalls.
Only
those
pollutants
with
reasonable
potential
are
shown
in
Exhibit
F­
25.
The
limits
reported
for
outfall
DSN001
include
actual
permit
limits
where
they
exist
for
DSN001
and
calculated
limits
based
on
permit
limits
for
internal
outfalls
DSN001A
and
DSN001B.

Exhibit
F­
26
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
criteria
are
not
reflected
in
the
facility's
permit.
Only
pollutants
for
which
data
indicate
that
a
reduction
in
effluent
concentrations
is
needed
are
shown
in
Exhibit
F­
27.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
85
Exhibit
F­
25.
Compliance
Summary,
Sloss
Industries
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Ammonia
­
mg/
L
28
28
10.9
1.54
1.86
No
Benzo(
A)
Anthracene
1
1
9.5
 
1.2*
No
Benzo(
A)
Pyrene
1
1
13
 
1.3*
No
Benzo(
B)
Fluoranthene
1
1
13
 
1.3*
No
Benzo(
K)
Fluoranthene
1
1
5.3
 
1.2*
No
Chrysene
1
1
10
 
1.2*
No
Total
Copper
10
10
24
10
82*
Yes
Total
Cyanide
4
4
191
152
454*
Yes
Total
Lead
34
34
25
6.2
23*
No
Total
Zinc
35
35
421
66
65*
No
1Detected
values
only
("
 
"
indicates
not
applicable).
2About
15%
of
the
maximum
reported
concentrations
exceed
the
maximum
daily
limit
for
ammonia.
*
Calculated
based
on
internal
BAT
limits.

Exhibit
F­
26.
Projected
Effluent
Limits,
Sloss
Industries
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Ammonia
­
mg/
L
10.9
1.86
17.6
1.89
1.89
Benzo(
a)
Anthracene
9.5
1.2
0.7
0.7
0.7
Benzo(
a)
Pyrene
13
1.3
0.7
0.7
0.7
Benzo(
b)
Fluoranthene
13
1.3
0.7
0.7
0.7
Benzo(
k)
Fluoranthene
5.3
1.2
0.7
0.7
0.7
Chrysene
10
1.2
0.7
0.7
0.7
Total
Copper
24
82
8.84
8.84
8.84
Total
Cyanide
191
454
12
4.2
4.2
Total
Lead
25
23
23
2.6
2.3
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criterion
are
not
reflected
in
current
permit.
3These
pollutants
are
polyaromatic
hydrocarbons
(
PAHs)
and
are
grouped
together
for
compliance
and
cost
analysis.
4The
copper
limit
for
Sloss
is
based
on
the
Acute
criteria,
so
it
is
the
same
for
all
cases.
Although
the
chronic
criterion
is
lower
than
the
acute
criterion,
once
you
calculate
a
WLA
and
a
LTA,
the
acute
LTA
is
the
lowest.
There
is
no
HH
criteria
for
copper.
The
7Q2
vs
7Q
10
flow
does
not
affect
the
limit
since
the
chronic
criterion
is
not
the
basis
of
the
limit.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
86
Exhibit
F­
27.
Required
Effluent
Reductions,
Sloss
Industries
(
pounds
per
year)

Pollutant
Reduction
to
Meet
Current
Permit1
Projected
Pollutant
Loading
Reductions
A&
I2
LWF
F&
W
Ammonia
88,6003
0
0
0
Benzo(
a)
Anthracene
81.3
5.28
0
0
Benzo(
a)
Pyrene
111
5.80
0
0
Benzo(
b)
Fluoranthene
111
5.80
0
0
Benzo(
k)
Fluoranthene
40.4
5.28
0
0
Chrysene
89.4
5.28
0
0
Total
Copper
0
147
0
0
Total
Cyanide
0
1,753
77.1
0
Total
Lead
25.1
0
197.3
0
1Reductions
needed
to
meet
current
limit
indicate
noncompliance.
2Reductions
needed
to
m
eet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.
3The
current
permit
limit
is
more
stringent
than
the
projected
A&
I,
LWF,
and
F&
W
limits.

Controls
Needed
Ammonia
Nitrogen:
Sloss
does
not
meet
its
existing
limit
for
ammonia.
However,
the
MEC
is
in
compliance
with
the
projected
A&
I
limit.
A
reduction
of
47%
is
to
meet
LWF
or
F&
W
use.
The
addition
of
a
chemical
oxidation
unit
is
sufficient
to
meet
the
projected
LWF
and
F&
W
limits
(
see
below
for
PAHs).
Chemical
oxidation
will
also
enable
the
facility
to
achieve
their
existing
permit
limit.

PAHs:
All
observed
values
for
PAHs
exceed
the
existing
limit
of
0.8
µ
g/
l.
The
A&
I,
LWF,
and
F&
W
limits
are
the
same
and
estimated
at
0.5
µ
g/
l.
Consequently,
a
chemical
oxidation
unit
for
the
reduction
of
PAHs
is
needed.
The
required
removal
varies
from
80%
to
99%
depending
on
the
limit.
The
cost
associated
with
removal
of
PAHs
is
attributable
to
the
A&
I
standard.
Since
the
A&
I,
LWF,
and
F&
W
limits
are
the
same,
there
are
no
costs
associated
with
LWF
and
F&
W
uses.

Cyanide:
The
facility
is
not
in
compliance
with
estimated
A&
I
limits.
A
reduction
of
90%
is
required
to
meet
the
A&
I
limit
of
11.7
µ
g/
l.
The
LWF
and
F&
W
limits
are
the
same
and
estimated
at
4.2
µ
g/
l.
Consequently,
compliance
with
the
A&
I
limit
will
allow
compliance
with
the
LWF
and
F&
W
limits.
Chemical
oxidation
is
needed
to
treat
the
internal
discharge
001a
and
001b
with
a
flow
of
0.46
MGD.

Copper:
Sloss
Industries
is
in
compliance
with
the
current
limit.
However,
it
is
not
in
compliance
with
the
A&
I
limit.
The
estimated
reduction
for
copper
is
about
60%.
Chemical
precipitation
will
reduce
copper
to
A&
I
levels
as
well
as
the
LWF
and
F&
W
limits.
The
chemical
precipitation
will
treat
the
internal
discharge
001a
and
001b
with
a
flow
of
0.46
MGD.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
87
Lead:
Based
on
the
observed
discharge
data,
the
facility
is
in
compliance
with
existing
limits
(
1
out
of
the
34
observations
exceed
the
existing
limit)
and
with
the
A&
I
limit.
However,
it
is
not
in
compliance
with
the
LWF
and
F&
W
limits
for
lead.
Chemical
precipitation
is
required
to
remove
copper
to
meet
A&
I
limits;
it
will
also
remove
the
excess
lead.
Consequently,
the
cost
of
removing
lead
to
the
LWF
and
F&
W
limits
is
associated
with
the
A&
I
limits.

Stormwater:
Village
Creek
exceeds
the
acute
criterion
for
zinc.
ACIPCO
also
has
a
reporting
requirement
for
zinc
in
its
stormwater
discharge.
Therefore,
a
stormwater
BMP
(
detention
basin)
is
needed
at
this
facility
to
meet
the
A&
I
criterion.

Exhibit
F­
28.
Annual
Cost
of
Required
Effluent
Reductions,
Sloss
Industries
(
Millions
of
Year
2001
Dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Chemical
Oxidation
6.0
0.54
1.8
2.34
Chemical
Precipitation
0.7
0.063
0.16
0.223
Stormwater
BMP
(
zinc)
0.31
0.029
 
0.029
TOTAL
7.01
0.63
2.96
2.59
1
Annualized
at
7%
over
20
years.
`
 
`
indicates
not
applicable
(
only
a
one­
time
capital
cost
applies).

Note
that
the
permit
writer
based
his/
her
BAT
limit
calculations
on
internal
flows
that
do
not
agree
with
reported
flow
in
PCS.
The
PCS
flows
are
on
the
average
between
two
and
three
times
higher.
EPA
based
its
analysis
on
the
average
flow
from
PCS
that
agrees
with
the
process
flow
diagram
presented
in
the
application
(
1998
permit
renewal
Fact
Sheet).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
88
SMI
Steel
Description
SMI
Steel
is
a
division
of
CMC
Steel
Group,
which
manufactures
angles,
flats,
channels,
and
beams.
SMI
Steel,
Inc.
(
NPDES
permit
number
AL0001554),
located
in
Birmingham,
Alabama
is
a
7.3
MGD,
Iron
and
Steel
category
facility
with
continuous
casting
and
hot
forming
operations.
The
facility
discharges
to
Village
Creek
and
has
two
permitted
outfalls.
According
to
the
ADEM
Permit
Rationale
for
the
facility's
1993
permit,
limits
for
outfall
DSN001
(
treated
process
wastewater)
and
DSN002
(
non­
contact
cooling
water)
are
based
on
Federal
effluent
guidelines
[
40
CFR
420.62/
420.63/
420.72].
Additional
mass
discharge
allowances
were
determined
based
on
the
development
document
for
the
Hot
Forming
subcategory
(
P.
B.
82­
240458,
Table
X­
1).
Flows
(
in
cfs)
in
Village
Creek
are
as
follows:
average:
47.04,
harmonic
mean:
21,
1Q10:
6.3,
7Q10:
7,
7Q2:
7.14.

Existing
Treatment
Processes
Information
from
U.
S.
EPA
Region
4
indicates
that
the
facility
has
an
oil
and
water
separator
and
final
settling
tanks.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
29
summarizes
effluent
monitoring
data
from
May
2000
through
March
2001
for
outfall
DSN001
for
pollutants
with
existing
limits.

Exhibit
F­
29.
Compliance
Summary,
SMI
Steel
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Total
Lead2
23
7
2.13
1.9
5.1
Yes
Total
Zinc
23
12
18
5
19
Yes
1Detected
values
only.
2Only
one
of
eight
detected
values
(
out
of
30
observations)
exceeded
the
limit.
3One
outlier
removed.

SMI
Steel
is
in
compliance
for
lead
and
zinc
for
all
current
and
projected
limits.
Of
23
lead
observations,
16
are
below
the
detection
level.
The
MEC,
7.97
µ
g/
l,
can
be
considered
an
outlier
since
all
other
detected
values
range
from
0.28
to
2.07
µ
g/
l.
Consequently,
there
are
no
additional
pollution
controls
needed
at
this
facility.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
89
Exhibit
F­
30.
Schematic
Diagram
of
Process
Wastewater
and
Storm
Water
Outfalls,
USX
 
Fairfield
Works
U.
S.
Steel
 
Fairfield
Works
Description
A
subsidiary
of
U.
S.
Steel
(
USX),
Fairfield
Works
manufactures
high
quality
hot
roll,
cold
roll,
GALVALUME
®
and
galvanized
coils.
USX
 
Fairfield
Works
(
NPDES
permit
number
AL0003646)
is
located
in
Fairfield,
Alabama
and
discharges
process
wastewater
to
Opossum
Creek.
Some
storm
water
is
discharged
to
Little
Creek,
a
tributary
of
Opossum
Creek,
but
the
permit
does
not
specify
which
storm
water
outfalls
discharge
to
which
stream.
The
facility's
design
flow,
as
reported
in
the
1996
fact
sheet,
is
11
MGD.
Actual
measured
flow
at
the
external
outfall
for
process
wastewater,
as
reported
in
the
facility's
DMRs,
is
19.62
MGD.
Calculated
endof
pipe
limits
and
pollutant
concentrations
are
based
on
observed
flows
from
the
facility's
DMRs.

The
facility
has
13
permitted
outfalls
(
Exhibit
E­
30).
Outfalls
DSN017,
DSN018,
DSN022,
DSN024,
and
DSN025
are
storm
water
and
noncontact
cooling
water
outfalls
to
Opossum
Creek
and
Little
Creek.
Outfall
DSN026
(
process
wastewater
and
storm
water)
is
an
external
process
wastewater
and
storm
water
outfall
to
Opossum
Creek.
Outfall
DSN026
includes
internal
outfalls
DSN013
(
Dolomite
System
outfall)
and
DSN023.
Outfall
DSN013
includes
four
internal
outfalls:
DSN011A,
DSN012A,
DSN014A,
and
DSN016A.
Outfall
DSN023
includes
storm
water
and
outfall
DSN010A.
In
the
1996
ADEM
Permit
Rationale
for
the
facility's
1996
permit
modification,
limits
for
outfall
DSN026
are
based
on
the
1996
Seasonal
Waste
Load
Allocation
for
the
USX
WWTP
Discharge
to
Opossum
Creek
Near
Fairfield.
Flows
(
in
cfs)
in
Opossum
Creek
are
as
follows:
average:
2.42,
harmonic
mean:
1.08,
1Q10:
0.32,
7Q10:
0.36,
7Q2:
0.37.

Existing
Treatment
Processes
Information
from
U.
S.
EPA
Region
4
indicates
that
USX
 
Fairfield
Works
is
currently
operating
a
biological
treatment
process.
Most
process
wastewater
is
treated
by
several
internal
plant
processes
using
oil/
water
separators
with
alkaline
precipitation
for
metals
followed
by
acid
pH
adjustment.
Water
is
recycled
from
the
Dolomite
pond,
which
receives
treated
wastewater
from
various
plant
processes.
This
results
in
a
significant
reduction
of
water
consumption.
In
anticipation
of
the
change
in
use
classification
for
Opossum
Creek,
the
facility
is
preparing
to
upgrade
its
treatment
processes.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
90
Summary
of
Effluent
Data
and
Limits
Exhibit
F­
31
summarizes
effluent
monitoring
for
outfall
DSN026
from
January
1996
through
March
2001
for
pollutants
with
calculated
limits.

Exhibit
F­
31.
Compliance
Summary,
USX
 
Fairfield
Works
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
BOD
 
mg/
l
18
18
6.5
3.75
8.0
Yes
Ammonia
 
mg/
l
39
39
1.4
0.24
1.0
Yes
Chromium
(
Hexavalent)
63
63
1.7
0.17
0.55
No
Total
Cyanide
55
55
2.512
0.68
72
Yes
Total
Lead
63
63
20
3.4
35
Yes
Phenols
58
58
4.1
0.61
2.4
No
Tetrachloroethylene
62
62
20
0.91
2.8
No
Total
Zinc
63
63
408
30
49
No
1Detected
values
only.
2One
outlier
removed.

Naphthalene
is
also
limited
at
outfall
DSN026,
but
because
there
are
no
Alabama
criteria
for
napthalene,
there
would
be
no
change
associated
with
a
change
in
use.

Exhibit
F­
32
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
criteria
are
not
reflected
in
the
facility's
permit.
Only
pollutants
with
reasonable
potential
for
which
data
indicate
that
a
reduction
in
effluent
concentrations
is
needed
(
Exhibit
F­
33)
are
shown.

Exhibit
F­
32.
Projected
Effluent
Limits,
USX
 
Fairfield
Works
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Total
Lead
20
35
41
2.6
2.6
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
permit.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
91
Exhibit
F­
33.
Required
Effluent
Reductions,
USX
 
Fairfield
Works
(
pounds
per
year)

Pollutant
Projected
Pollutant
Loading
Reductions
Current
Permit1
A&
I2
LWF
F&
W
Total
Lead
0
0
1,013
0
1Reductions
needed
to
meet
current
limit
indicate
noncompliance.
2Reductions
needed
to
m
eet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.

Controls
Needed
Lead:
USX
is
in
compliance
with
the
current
permit
limit
for
lead
and
the
projected
A&
I
limit.
They
are
not
in
compliance
with
the
LWF
limit.
Consequently,
pollution
controls
need
to
be
installed
to
meet
the
LWF
limit.
Since
the
LWF
and
F&
W
limits
are
the
same,
the
cost
for
removing
lead
is
attributable
to
the
LWF
use.
Chemical
precipitation
is
needed
to
reduce
lead
to
meet
LWF
limits.
Removal
efficiencies
of
up
to
95%
to
97%
are
reported
for
facilities
using
chemical
precipitation
to
control
lead.

BOD:
A
reduction
in
BOD
discharge
of
40%
to
50%
from
USX
is
needed
to
meet
the
F&
W
standard
in
Opossum
Creek.
The
addition
of
activated
sludge
treatment
should
reduce
BOD
sufficiently
to
attain
5
mg/
l
DO
at
all
times
of
the
year.

Exhibit
F­
34.
Annual
Cost
of
Required
Effluent
Reductions,
USX
 
Fairfield
Works
(
Millions
of
Year
2001
dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Chemical
Precipitation
0.8
0.076
0.18
0.26
Activated
Sludge
0.39
0.037
0.09
0.13
TOTAL
1.2
0.11
0.27
0.39
1Annualized
at
7%
over
20
years.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
92
Valley
Creek
WWTP
Description
Valley
Creek
Waste
Water
Treatment
Plant
(
NPDES
permit
number
AL0023655)
is
located
in
Bessemer,
Alabama.
The
fact
sheet
for
the
facility's
2001
permit
indicates
that,
as
of
January
2001,
the
facility's
design
capacity
was
65
MGD
with
a
planned
addition
of
a
two­
stage
biological
treatment
plant
that
would
increase
the
design
capacity
to
85
MGD.
In
addition,
a
new
peak
flow
wastewater
treatment
facility
with
a
design
capacity
of
350
MGD
is
proposed
for
completion
by
2005.
All
of
the
limits
and
load
reductions
shown
in
this
summary
are
based
on
a
design
flow
of
65
MGD
since
the
monitoring
data
used
in
the
model
were
collected
for
those
flows.
Valley
Creek
WWTP
has
five
permitted
outfalls
on
Valley
Creek.
In
the
facility's
2000
permit,
limits
for
outfall
001
(
treated
wastewater)
are
based
on
the
more
stringent
of
Federal
guidelines
[
40
CFR
133.102],
ADEM
Disinfection
Strategy
Toxicity
Strategy,
or
water
quality
requirements.
There
are
no
numeric
limits
for
outfalls
002
 
005
(
storm
water).
Flows
(
in
cfs)
in
Valley
Creek
are
as
follows:
average:
20.0,
harmonic
mean:
8.94,
1Q10:
2.2,
7Q10:
2.98,
7Q2:
3.04.

Existing
Treatment
Processes
Information
from
the
fact
sheet
for
the
2001
permit
indicates
that
the
facility's
existing
treatment
consists
of
bar
screen,
grinding,
grit
removal,
preaeration,
primary
clarification,
a
two­
stage
biological
treatment
system,
chlorination/
dechlorination
(
which
would
be
replaced
by
UV
disinfection
with
the
proposed
20
MGD
addition),
anaerobic
digesters,
filter
belt
press,
drying
beds,
lime
stabilization,
and
final
disposal
of
the
biosolids
to
the
Jefferson
County
beneficial
land
use
site.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
35
summarizes
effluent
monitoring
data
from
January
1998
through
April
2001
for
outfall
001.
The
facility's
2001
permit
does
not
include
numeric
limits
or
monitoring
requirements
for
toxic
pollutants.
However,
monitoring
data
for
some
toxic
pollutants
are
included
in
the
facility's
discharge
monitoring
reports.
These
are
shown
in
Exhibit
1.

Exhibit
F­
35.
Compliance
Summary,
Valley
Creek
WWTP
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Ammonia
42
42
0.54
0.15
3.0
Yes
Fecal
Coliform
 
 
 
 
 
 
Hexavalent
Chromium
4
4
30
15
 
 
Total
Cyanide
1
1
10,800
 
 
 
1Detected
values
only
(`
 
`
indicates
not
applicable).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
93
Exhibit
F­
36
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Projected
effluent
limits
for
the
current
use
(
A&
I)
only
differ
from
current
permit
limits
if
data
indicate
that
all
applicable
criteria
are
not
reflected
in
the
facility's
permit.
Only
pollutants
with
reasonable
potential
for
which
data
indicate
that
a
reduction
in
effluent
concentrations
is
needed
(
Exhibit
F­
37)
are
shown.

Exhibit
F­
36.
Projected
Effluent
Limits,
Valley
Creek
WWTP
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Hexavalent
Chromium
30
 
8.1
8.1
8.1
Total
Cyanide
10,800
 
11
4.4
4.4
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
permit.
`
 
`
indicates
no
limit
Exhibit
F­
37.
Required
Effluent
Reductions,
Valley
Creek
WWTP
(
pounds
per
year)

Pollutant
Projected
Pollutant
Loading
Reductions
Current
Permit1
A&
I2
LWF
F&
W
Hexavalent
Chromium
 
4,330
0
0
Total
Cyanide
 
2,130,000
1,350
0
1Reductions
needed
to
meet
current
limit
indicate
noncompliance.
2Reductions
needed
to
m
eet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.
`
 
`
indicates
not
applicable.

Controls
Needed
Cyanide:
There
is
only
one
observation
recorded
at
Valley
Creek
WTTP
(
10,800
µ
g/
l).
Although
this
observation
is
a
few
orders
of
magnitude
higher
than
the
projected
limits,
there
is
insufficient
information
to
conclude
that
additional
controls
are
needed
for
cyanide.

Hexavalent
chromium:
Four
(
4)
observations
were
recorded
at
the
discharge
(
30,
10,
10,
and
10
µ
g/
l).
The
projected
limits
are
estimated
at
8.2
µ
g/
l
for
A&
I,
LWF,
and
F&
W.
Based
on
these
data,
a
20%
reduction
is
needed.
A
waste
minimization
study
should
be
implemented
to
control
hexavalent
chromium
at
Valley
Creek
WTTP.

Fecal
Coliform:
The
F&
W
fecal
coliform
geometric
mean
criterion
is
marginally
exceeded
in
Valley
Creek.
Process
optimization
of
chlorination
should
allow
the
criterion
to
be
met.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
94
Mercury:
The
human
health
criterion
for
mercury
is
exceeded
in
Valley
Creek.
Although
there
are
no
discharge
data
indicating
that
this
facility
discharges
mercury,
mercury
is
a
common
pollutant
in
POTW
effluents.
Therefore
a
waste
minimization
program
for
mercury
should
be
implemented
to
meet
the
F&
W
citerion.

Exhibit
F­
38.
Annual
Cost
of
Required
Effluent
Reductions,
Valley
Creek
WWTP
(
Millions
of
Year
2001
Dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Waste
Minimization
(
hexavalent
chromium,
mercury)
0.98
0.09
 
0.09
Chlorination
Optimization
0.53
0.05
 
0.05
TOTAL
1.51
0.14
 
0.14
1Annualized
at
7%
over
20
years.
`
 
`
indicates
not
applicable
(
only
a
one
time
capital
cost
applies).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
95
Village
Creek
WWTP
Description
Jefferson
County
Village
Creek
Wastewater
Treatment
Plant
(
NPDES
permit
number
AL0023647),
located
in
Birmingham,
Alabama,
is
a
60
mgd
facility
that
discharges
to
Village
Creek.
The
facility
currently
has
one
permitted
outfall.
In
the
fact
sheet
for
the
facility's
2001
permit,
limits
for
outfall
DSN001
are
based
on
the
facility's
previous
permit,
Federal
effluent
guidelines
[
40
CFR
133.102],
a
waste
load
allocation
model,
ADEM's
Disinfection
Strategy
Toxicity
Strategy,
and
best
professional
judgment.
The
facility's
2001
permit
also
includes
limits
for
outfall
DSN002
for
a
new
peak
flow
wastewater
treatment
facility
capable
of
handling
flows
up
to
340
MGD.
This
facility
is
slated
for
completion
by
2003.
There
is
no
discussion
of
the
basis
for
limits
at
outfall
DSN002.
Flows
(
in
cfs)
in
Village
Creek
are
as
follows:
average:
87.36,
harmonic
mean:
39,
1Q10:
9.75,
7Q10:
13,
7Q2:
13.26.

Existing
Treatment
Processes
According
to
the
fact
sheet
for
the
facility's
2001
permit,
existing
treatment
at
Village
Creek
WWTP
includes
bar
screen,
grinding,
grit
removal,
preaeration,
primary
clarification,
a
two­
stage
biological
treatment
system,
chlorination/
dechlorination,
thickener,
anaerobic
digesters,
mechanical
dewatering
facility,
drying
beds,
and
final
disposal
of
the
biosolids
to
the
Jefferson
County
beneficial
land
use
site.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
39
summarizes
effluent
monitoring
data
from
February
1997
through
November
2000
for
outfall
DSN001.

Exhibit
F­
39.
Compliance
Summary,
Village
Creek
WWTP
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
Ammonia
 
mg/
l
37
37
0.4
0.21
2.0
Yes
Chromium,
Hexavalent
10
9
20
11.11
 
 
Cyanide,
Total
5
4
8,500
5,752
 
 
1Detected
values
only
(
`
 
`
indicates
not
applicable).

Exhibit
F­
40
summarizes
projected
effluent
limits
for
the
facility
under
different
use
classifications.
Only
pollutants
for
which
data
indicate
that
a
reduction
in
effluent
concentrations
is
needed
are
shown.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
96
Exhibit
F­
40.
Projected
Effluent
Limits,
Village
Creek
WWTP
(
all
values
in
µ
g/
l
unless
otherwise
noted)

Pollutant
MEC1
Current
Lim
it
Projected
Effluent
Limit2
A&
I
LWF
F&
W
Chromium,
Hexavalent
20
None
8.8
8.8
8.8
Cyanide,
Total
8,500
None
11.8
4.25
4.25
1Maximum
effluent
concentration.
2Projected
A&
I
limit
differs
from
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
permit.

Exhibit
F­
41.
Required
Effluent
Reductions,
Village
Creek
WWTP
(
pounds
per
year)

Pollutant
Projected
Pollutant
Loading
Reductions
Reduction
Needed
to
Meet
Current
Permit1
A&
I2
LWF
F&
W
Chromium,
Hexavalent
NA
2,046
0
0
Cyanide,
Total
NA
1,550,000
1,380
0
1Reductions
needed
to
meed
current
limit
indicate
noncompliance.
2Reductions
needed
to
m
eet
A&
I
differ
from
reductions
needed
to
meet
current
limit
if
data
indicate
all
applicable
criteria
are
not
reflected
in
current
limit.

Controls
Needed
Hexavalent
Chromium:
The
projected
limits
are
estimated
at
8.8
µ
g/
l
for
A&
I,
LWF,
and
F&
W.
Based
on
the
data,
a
20%
reduction
is
needed.
A
waste
minimization
study
should
be
implemented
for
controlling
hexavalent
chromium
at
Valley
Creek
WWTP.

Cyanide:
Village
Creek
does
not
have
an
existing
limit
for
cyanide.
The
discharge
is
not
in
compliance
with
the
projected
A&
I
limits.
End
of
pipe
treatment
is
not
economically
feasible
due
to
the
large
reductions
required
to
meet
the
projected
A&
I,
LWF,
and
F&
W
limits.
The
cyanide
is
most
likely
not
being
generated
at
the
facility,
but
is
entering
the
plant
through
the
influent
from
an
industrial
discharger.
Therefore,
a
waste
minimization
study
should
be
implemented
to
reduce
the
cyanide
concentrations
to
sufficient
levels.

Mercury:
The
human
health
criterion
for
mercury
is
exceeded
in
Village
Creek.
Although
there
are
no
discharge
data
indicating
that
this
facility
discharges
mercury,
mercury
is
a
common
pollutant
in
POTW
effluents.
Therefore
a
waste
minimization
program
for
mercury
should
be
implemented
to
meet
the
F&
W
criterion.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
97
Exhibit
F­
42.
Annual
Cost
of
Required
Effluent
Reductions,
Village
Creek
WWTP
(
Millions
of
Year
2001
Dollars)

Control
(
pollutant)
Total
Capital
Annualized
Capital1
O&
M
Total
Annual
Cost
Waste
Minimization
(
hexavalent
chromium,
cyanide,
mercury)
1.5
0.14
 
0.14
TOTAL
1.5
0.14
 
0.14
1Annualized
at
7%
over
20
years.
`
 
`
indicates
not
applicable
(
only
a
one
time
capital
cost
applies).
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
98
Westpoint­
Stevens
 
Opelika
Finishing
Plant
Description
Westpoint­
Stevens
is
a
supplier
of
bed
and
bath
fashions.
The
Opelika
Finishing
Plant
is
responsible
for
dying
and
finishing
sheets.
Opelika
Finishing
Plant
(
NPDES
permit
number
AL0002968),
located
in
Opelika,
Alabama,
is
a
2.75
mgd
facility
that
discharges
to
the
Pepperell
Branch
of
Soughahatchee
Creek.
The
facility
has
three
permitted
outfalls.
In
ADEM's
permit
rationale
for
the
facilty's
1999
draft
permit,
limits
for
outfall
DSN001
(
process
wastewater,
boiler
blowdown,
and
noncontact
cooling
water)
are
based
on
the
more
stringent
of
Federal
effluent
guidelines
or
water
quality
requirements
and
ADEM
Administrative
Code
R.
335­
6­
10­.
09.
Limits
for
outfalls
DSN002
and
DSN003
(
storm
water
associated
with
the
manufacture
of
textile
products)
are
based
on
previous
permit
limits
and
best
professional
judgment
and
are
considered
equivalent
to
BAT/
BCT.
The
permit
also
requires
a
best
management
practices
plan
to
minimize
the
potential
for
pollutants
coming
in
contact
with
storm
water
runoff.
Flows
(
in
cfs)
in
Pepperell
Branch
are
as
follows:
average:
3.44,
harmonic
mean:
1.53,
1Q10:
0.46,
7Q10:
0.51,
7Q2:
0.52.

Existing
Treatment
Processes
Information
from
U.
S.
EPA
Region
4
indicates
that
Opelika
Finishing
Plant
has
two
process
streams.
For
one
stream,
the
facility
utilizes
BAF
and
polymer
addition
for
color
removal.
Beginning
in
summer
2001,
this
stream
will
be
piped
to
a
municipal
treatment
plant.
The
other
waste
stream
is
treated
in
a
three
cell
lagoon
system.
Treatment
in
the
lagoon
system
includes
aeration
with
solids
recycling,
and
chlorination
at
the
end
of
the
treatment
train.
In
addition,
Opelika
Finishing
Plant
is
currently
constructing
a
brackish
constructed
wetland
for
additional
effluent
polishing.

Summary
of
Effluent
Data
and
Limits
Exhibit
F­
43
summarizes
effluent
monitoring
data
from
January
1996
through
February
2001
for
outfall
DSN001
for
toxic
pollutants
with
existing
limits.
The
facility's
permit
includes
seasonal
limits
for
this
outfall.

Total
recoverable
copper,
total
recoverable
lead,
and
total
recoverable
zinc
are
also
limited
at
outfall
DSN001,
but
because
there
are
no
Alabama
criteria
for
these
pollutants,
there
would
be
no
change
associated
with
a
change
in
use,
and
they
are
not
considered
further.

Ammonia
and
total
chromium
comply
with
the
existing
limits.
Only
one
observation
(
49
µ
g/
l)
does
not
comply
with
the
current
limit.
Therefore
there
are
no
costs
associated
with
Westpoint­
Stevens
Opelika
Finishing
Plant.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
99
Exhibit
F­
43.
Compliance
Summary,
Westwood­
Stevens
 
Opelika
Finishing
Plant
Pollutant
Number
of
Observations
Effluent
Concentrations1
(
µ
g/
L
unless
noted)
Existing
Limit
Comply
with
Existing
Lim
it?
Total
Detect
Maximum
Mean
BOD
 
mg/
l
20
20
15.9
11.2
37.5
Yes
May
 
November
Ammonia
 
mg/
l
21
21
1.07
0.25
2.75
Yes
Total
Phenols
21
19
180
26
930
Yes
Total
Chromium2
18
9
31
20
930
Yes
December
 
April
Ammonia
 
mg/
l
17
17
1.92
0.41
2.75
Yes
Total
Phenols
24
21
493
15
43
Yes
Total
Chromium2
18
11
38
20
43
Yes
1Detected
values
only.
2There
is
no
Alabama
criterion
for
total
chromium.
As
a
conservative
estimate,
we
assumed
all
chromium
in
the
waste
stream
to
be
trivalent
chromium.
3Outlier;
all
other
observations
below
limit.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
100
Appendix
G.
Nonpoint
Source
Control
Costs
Exhibits
G­
1,
G­
2,
and
G­
3
provide
land
use
and
costs
of
nonpoint
source
controls
for
the
three
creeks
for
which
there
are
instream
exceedances
of
pollutants.
EPA
determined
that
urban
sources
likely
deliver
the
pollutants
of
concern.

Exhibit
G­
1.
Cost
of
Nonpoint
Source
Controls,
Five
Mile
Creek
Land
Use
Acres1
Cost
per
Acre
Total
Cost
(
millions)

Cropland
922
$
0
$
0
Forest
50,595
$
0
$
0
High­
Density
Commercial/
Industrial/
Transportation
2,150
$
10,6002
$
22.8
High­
Density
Residential
1,285
$
10,6002
$
13.6
Low­
Density
Residential
6,669
$
4,0002
$
26.7
Pasture
1,354
$
0
$
0
Transitional
223
$
0
$
0
Water
135
$
0
$
0
Total
63,333
$
63.1
1Source:
U.
S.
EPA
Region
IV.
2Source:
Analysis
of
data
provided
in
Livingston
(
1999)
for
urban
storm
water
retrofit
projects.

Exhibit
G­
2.
Cost
of
Nonpoint
Source
Controls,
Valley
Creek
Land
Use
Percent
of
Area1
Acres2
Cost
per
Acre
Total
Cost
Open
water
1.35
1,666
$
0
$
0
Low­
Intensity
Industrial/
Residential
7.32
9,032
$
4,0003
$
36.1
High­
Intensity
Residential
2.43
2,998
$
10,6003
$
31.8
Commercial/
Industrial/
Transport
3.57
4,405
$
10,6003
$
46.7
Quarry/
StripMine/
GravelPits
0.9
1,110
$
0
$
0
Transitional
Barren
0.7
864
$
0
$
0
Deciduous
Forest
32.46
40,051
$
0
$
0
Evergreen
Forest
18.4
22,703
$
0
$
0
Mixed
Forest
26.09
32,192
$
0
$
0
Pasture/
Hay
3.1
3,825
$
0
$
0
Row
Crops
1.7
2,098
$
0
$
0
Other
Grasses
1.98
2,443
$
0
$
0
Emergent
Wetland
0.01
12
$
0
$
0
Total
100.01
123,387
$
114.6
1Source:
U.
S.
EPA
Region
IV.
2
Estimated
as
percent
of
area
times
total
watershed
area
(
based
on
USG
S
data).
3Source:
Analysis
of
data
provided
in
Livingston
(
1999)
for
urban
storm
water
retrofit
projects.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama
101
Exhibit
G­
3.
Cost
of
Nonpoint
Source
Controls,
Village
Creek
Land
Use
Acres1
Cost
per
Acre
Total
Cost
Cropland
1,106
$
0
$
0
Forest
42,056
$
0
$
0
High­
Density
Commercial/
Industrial/
Transportation
5,892
$
10,6002
$
62.5
High­
Density
Residential
3,269
$
10,6002
$
34.6
Low­
Density
Residential
9,768
$
4,0002
$
39.1
Pasture
1,005
$
0
$
0
Transitional
223
$
0
$
0
Water
291
$
0
$
0
Total
63,610
$
136.2
1Source:
U.
S.
EPA
Region
IV.
2Source:
Analysis
of
data
provided
in
Livingston
(
1999)
for
urban
storm
water
retrofit
projects.
