ECONOMIC
ANALYSIS
OF
THE
REVISED
WATER
QUALITY
STANDARDS
FOR
THE
STATE
OF
IOWA
December
2001
Prepared
for:

U.
S.
Environmental
Protection
Agency
Office
of
Water
Office
of
Science
and
Technology
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460­
0001
Prepared
by:

Science
Applications
International
Corporation
11251
Roger
Bacon
Drive
Reston,
VA
20190­
5201
EPA
Contract
No.
68­
C­
99­
252
SAIC
Project
Number
01­
0833­
04­
2805­
xxx
December
2001
i
TABLE
OF
CONTENTS
Executive
Summary
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ES­
1
1.0
Introduction
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1­
1
1.1
Background
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1­
1
1.2
Purpose
of
this
Analysis
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1­
1
1.3
Scope
of
the
Analysis
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1­
2
1.4
Organization
of
the
Report
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1­
2
2.0
Potentially
Affected
Facilities
and
Sample
Selection
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2­
1
2.1
Facilities
Facing
New
Criteria
Only
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2­
1
2.2
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria
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2­
2
2.3
Data
Collection
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2­
3
3.0
Methodology
for
Estimating
Potential
Compliance
Costs
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3­
1
3.1
Facilities
Facing
New
Criteria
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3­
1
3.1.1
Determining
Reasonable
Potential
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3­
1
3.1.2
Calculating
Projected
Effluent
Limits
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3­
2
3.1.3
Estimating
Potential
Costs
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3­
2
3.2
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria
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3­
3
3.2.1
Fecal
Coliform
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3­
3
3.2.2
Ammonia
and
Dissolved
Oxygen
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3­
4
3.3
Estimating
Pollutant
Loadings
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3­
6
3.3.1
Toxic
Pollutants
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3­
6
3.3.2
Conventional
Pollutants
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3­
6
4.0
Results
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4­
1
4.1
Facilities
Facing
New
Criteria
Only
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4­
1
4.2
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria
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4­
1
4.3
Total
Statewide
Costs
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4­
4
5.0
References
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5­
1
APPENDICES
A.
Cost
Methodology
for
Toxic
Pollutants
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A­
1
B.
Cost
Methodology
for
Conventional
Pollutants
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B­
1
C.
Facility­
Level
Analyses
 
New
Criteria
Only
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C­
1
D.
Facility­
Level
Analyses
 
Designated
Use
Change
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D­
1
E.
Attainability
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E­
1
F.
Revisions
to
Iowa
WQS
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F­
1
December
2001
ii
LIST
OF
EXHIBITS
Exhibit
1­
1.
Pollutants
for
which
EPA
is
Proposing
Water
Quality
Criteria
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1­
3
Exhibit
2­
1.
Facilities
Facing
New
Criteria
Only:
Comparison
of
Universe
and
Sample
Facilities
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2­
2
Exhibit
2­
2.
Facilities
Facing
New
Criteria
Only:
Facilities
Selected
for
Evaluation
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2­
3
Exhibit
2­
3.
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria:
Comparison
of
Universe
and
Sample
Facilities
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2­
4
Exhibit
2­
4.
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria:
Facilities
Selected
for
Evaluation
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2­
4
Exhibit
4­
1.
Affected
Facilities
and
Estimated
Costs
Associated
with
Proposed
Revisions
to
Water
Quality
Criteria
(
2001
dollars)
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4­
1
Exhibit
4­
2.
Estimated
Costs
Associated
with
Proposed
Reclassified
Designated
Uses:
Sample
Facilities
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4­
2
Exhibit
4­
3.
Estimated
Costs
Associated
with
Proposed
Reclassified
Designated
Uses
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4­
3
Exhibit
4­
4.
Total
Estimated
Statewide
Costs
by
Provision
(
2001
$/
yr)
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4­
4
Exhibit
A­
1.
Cost
Decision
Framework
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A­
2
Exhibit
E­
1.
Number
of
Samples
for
Each
Parameter
for
Each
Station
within
15
Miles
of
Each
Discharge
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E­
1
1
The
47
facilities
in
this
latter
group
also
are
potentially
affected
by
the
new
water
quality
criteria,
but
EPA
believes,
based
on
the
results
of
its
analysis,
that
none
of
the
facilities
in
this
group
discharge
pollutants
for
which
EPA
is
proposing
to
revise
criteria.

December
2001
Executive
Summary
ES­
1
EXECUTIVE
SUMMARY
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
proposing
water
quality
standards
(
WQS)
applicable
to
waters
in
the
State
of
Iowa.
This
report
provides
estimates
of
potential
incremental
costs
that
point
source
dischargers
may
experience
as
a
result
of
the
final
rule.

EPA's
proposed
revisions
to
the
Iowa
WQS
would:
1)
change
or
add
water
quality
criteria
for
a
number
of
toxic
pollutants
in
receiving
waters
designated
for
aquatic
life
uses
and
in
receiving
waters
designated
for
potable
water
supply
use,
and
2)
assign
additional
or
new
designated
use
classifications
to
a
number
of
stream
segments
in
Iowa.

EPA
used
information
provided
by
the
Iowa
Department
of
Natural
Resources
as
the
basis
for
identifying
the
universe
of
potentially
affected
facilities.
EPA
estimated
a
universe
of
916
potentially
affected
facilities,
including:


869
facilities
potentially
affected
by
the
proposed
revisions
to
water
quality
criteria

47
facilities
potentially
affected
by
the
proposed
reclassification
of
designated
uses.
1
To
estimate
potential
compliance
costs,
EPA
employed
slightly
different
methodologies
and
assumptions
for
each
of
the
two
groups
of
facilities.

For
facilities
potentially
affected
by
the
new
water
quality
criteria,
EPA
identified
four
facilities
with
effluent
monitoring
data
or
existing
NPDES
permit
limits
for
the
pollutants
subject
to
the
criteria
revisions.
EPA
followed
a
decision
framework
to
ensure
consistency
in
estimating
the
types
of
controls
that
would
be
necessary
for
a
facility
to
comply
with
projected
water
quality
based
effluent
limits.
The
underlying
assumption
of
the
decision
framework
is
that
a
facility
would
examine
lower­
cost
alternatives
prior
to
incurring
the
expense
associated
with
adding
end­
of­
pipe
treatment
processes.
EPA
estimated
costs
for
each
alternative
including
capital
costs,
annual
costs
[
operation
and
maintenance
(
O&
M)
and
residuals
management],
and
monitoring
costs.

For
facilities
potentially
affected
by
the
proposed
reclassification
of
designated
uses,
EPA
selected
a
random
sample
of
11
facilities
and
evaluated
impacts
associated
with
toxic
pollutants
using
the
same
methodology
described
for
facilities
potentially
affected
by
the
new
water
quality
criteria.
In
addition,
EPA
analyzed
impacts
associated
with
conventional
pollutants
(
specifically,
fecal
coliform,
dissolved
oxygen,
and
ammonia)
for
these
facilities.
For
conventional
pollutants,
EPA
reviewed
discharge
monitoring
data
and
existing
treatment
systems
and
applied
computer
modeling
to
calculate
downstream
pollutant
concentrations.
Based
on
the
results
of
this
analysis,
EPA
made
estimates
regarding
the
need
to
add
new
treatment
systems
or
to
supplement
existing
treatment
systems.
For
conventional
pollutants,
EPA
determined
the
type
and
potential
cost
of
December
2001
Executive
Summary
ES­
2
treatment
for
the
sample
facilities
and
then
extrapolated
these
costs
to
the
estimated
universe
of
affected
facilities.

EPA
estimated
that
the
total
statewide
cost
of
all
provisions
of
the
proposed
rule
is
$
904,000
per
year.
In
the
analysis,
EPA
made
several
assumptions
that
would
tend
to
err
on
the
side
of
overstating
costs.
Thus,
EPA
believes
the
total
statewide
cost
is
a
reasonable,
but
conservatively
high
estimate.
Approximately
65%
of
the
total
costs
are
associated
with
the
proposed
revision
to
the
water
quality
criterion
for
a
single
pollutant,
aluminum.
These
costs
are
incurred
by
two
minor
industrial
facilities.
The
remaining
35%
of
the
total
is
associated
with
the
proposed
reclassification
of
designated
uses.
Nearly
all
of
this
35%
is
associated
with
additional
treatment
for
fecal
coliform
at
minor
POTWs.

These
expenditures
will
result
in
annual
reductions
of
558
pounds
of
aluminum,
915
pounds
of
ammonia,
and
2.65
x
1013
fecal
coliform
colonies
discharged
to
Iowa
surface
waters.
Aluminum
is
a
toxic
pollutant;
fecal
coliforms
present
risk
of
human
illness
associated
with
contact
or
ingestion;
and
ammonia
has
several
characteristics
which
can
be
deleterious
to
aquatic
life.
December
2001
1.0
Introduction
1­
1
1.0
INTRODUCTION
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
proposing
water
quality
standards
(
WQS)
applicable
to
waters
of
the
United
States
in
the
State
of
Iowa.
This
report
presents
EPA's
analysis
of
potential
economic
impacts
associated
with
the
Iowa
WQS
rule.
Specifically,
the
report
provides
estimates
of
potential
incremental
costs
that
point
source
dischargers
may
experience
as
a
result
of
the
rule
through
changes
to
their
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
limits.

1.1
Background
The
Clean
Water
Act
(
CWA)
directs
States,
with
oversight
by
EPA,
to
adopt
WQS
to
protect
the
public
health
and
welfare,
enhance
the
quality
of
water,
and
serve
the
purposes
of
the
CWA.
Under
Section
303,
States
are
required
to
develop
WQS
for
waters
within
their
boundaries.
Section
303(
c)
provides
that
WQS
shall
include
the
designated
use
or
uses
for
the
water
and
criteria
necessary
to
protect
those
uses.
States
are
also
required
to
hold
public
hearings
once
every
three
years
for
the
purpose
of
reviewing
applicable
water
quality
standards
and,
as
appropriate,
modifying
and
adopting
standards.
The
results
of
this
triennial
review
must
be
submitted
to
EPA
and
EPA
must
approve
or
disapprove
any
new
or
revised
standards.
Section
303(
c)
also
authorizes
the
EPA
Administrator
to
promulgate
WQS
to
supersede
State
standards
that
have
been
disapproved
or
that
the
Administrator
determines
that
a
new
or
revised
standard
is
needed
to
meet
the
CWA's
requirements.

EPA
is
proposing
revisions
to
the
Iowa
WQS
to:
1)
change
or
add
water
quality
criteria
for
a
number
of
pollutants
in
receiving
waters
designated
for
aquatic
life
uses
("
Class
B"
under
Iowa
regulations)
and
in
receiving
waters
designated
for
potable
water
supply
use
("
Class
C"
under
Iowa
regulations),
and
2)
assign
additional
or
new
designated
use
classifications
to
a
number
of
stream
segments
in
Iowa.

1.2
Purpose
of
this
Analysis
Under
Executive
Order
(
EO)
12866
(
58
FR
51735,
October
4,
1993),
the
Agency
must
determine
whether
a
regulatory
action
is
"
significant"
and,
therefore,
subject
to
the
requirements
of
the
order
(
drafting
an
Economic
Analysis
(
EA)
and
submitting
it
for
review
by
the
Office
of
Management
and
Budget
(
OMB)).
EO
12866
defines
"
significant"
as
those
actions
likely
to
lead
to
a
rule
having
an
annual
effect
on
the
economy
of
$
100
million
or
more,
or
adversely
and
materially
affecting
a
sector
of
the
economy,
productivity,
competition,
jobs,
the
environment,
public
health
or
safety,
or
state,
local,
or
tribal
governments
or
communities.

EPA's
rule
does
not
establish
any
requirements
directly
applicable
to
regulated
entities
and
the
State
has
flexibility
in
implementing
the
provisions
within
the
NPDES
permit
program.
Although
implementation
may
ultimately
result
in
new
or
revised
NPDES
permit
conditions
for
some
dischargers,
EPA's
action
does
not
impose
any
of
these
requirements.
Nonetheless,
in
the
spirit
of
EO
12866,
this
analysis
provides
EPA's
estimate
of
the
potential
cost
impact
that
may
ultimately
result
from
the
Iowa
WQS
rule.
In
the
absence
of
sufficient
instream
data
(
see
Appendix
E),
EPA
assumed
that
the
new
uses
and
criteria
would
be
attainable.
December
2001
1.0
Introduction
1­
2
1.3
Scope
of
the
Analysis
This
analysis
addresses
the
potential
costs
and
pollutant
loading
reductions
that
may
result
from
implementation
of
EPA's
rule.
Any
NPDES­
permitted
facility
discharging
to
stream
segments
reclassified
by
the
proposed
rule
or
discharging
pollutants
for
which
EPA
is
proposing
new
or
revised
criteria
may
be
affected
by
the
rule.
The
types
of
affected
facilities
may
include
industries
and
publicly
owned
treatment
works
(
POTWs)
discharging
pollutants
to
surface
waters
in
Iowa
(
i.
e.,
point
sources).

Water
Quality
Criteria
Revision
EPA
determined
that
Iowa's
current
water
quality
criteria
for
a
number
of
pollutants
are
not
protective
of
designated
uses.
Therefore,
EPA
is
proposing
to
revise
or
add
criteria
for
these
pollutants.
The
specific
pollutants
for
which
EPA
is
proposing
criteria
vary
by
designated
use
classification.
Exhibit
1­
1
lists
the
pollutants
by
classification.
The
proposed
values
for
the
criteria
are
presented
in
Appendix
F.

Designated
Use
Reclassification
The
CWA
requires
the
designation
of
aquatic
life
and
recreational
uses
for
all
waters
of
the
United
States,
where
attainable,
and
EPA
regulations
require
a
State
to
submit
a
use
attainability
analysis
(
UAA)
for
waters
that
it
does
not
designate
for
these
uses.
Iowa's
current
regulations
do
not
assign
designated
uses
for
a
number
of
segments,
meaning
they
fall
into
the
"
general
use"
classification
under
the
State's
regulations.
EPA
is
proposing
to
reclassify
these
general
use
segments
for
primary
contact
recreation
use
("
Class
A"
under
Iowa
regulations),
aquatic
life
use
("
Class
B"
under
Iowa
regulations),
and/
or
potable
water
use
("
Class
C
under
Iowa
regulations).
Class
B
designations
may
be
further
specified
as
significant
resource
warm
waters
["
Class
B(
WW)"]
or
lakes
and
wetlands
["
Class
B(
LW)"].
For
other
segments
covered
by
the
proposed
rule,
Iowa's
current
regulations
do
assign
a
designated
use,
but
EPA
is
proposing
a
new
or
additional
designated
use
classification.
For
example,
for
some
stream
segments
currently
designated
Class
B,
EPA
is
proposing
to
add
the
designation
Class
A.
In
total,
EPA
is
proposing
to
assign
new
or
additional
designated
uses
for
47
Iowa
stream
segments.
Appendix
F
provides
a
list
of
stream
segments
and
the
proposed
use
designations.

1.4
Organization
of
the
Report
The
report
is
organized
as
follows.
Chapter
2
describes
the
methodology
EPA
used
to
identify
potentially
affected
facilities
in
Iowa
and
select
a
sample
for
evaluating
cost
impacts.
Chapter
3
describes
the
methodology
for
estimating
the
potential
costs.
Chapter
4
describes
the
results
of
the
analysis.
Chapter
5
provides
references
and
several
appendices
provide
additional
information
related
to
the
analysis.
December
2001
1.0
Introduction
1­
3
Exhibit
1­
1.
Pollutants
for
which
EPA
Is
Proposing
Water
Quality
Criteria
Designated
Use
Classification
Pollutants
Aquatic
Life
Use:
Cold
Water
Aquatic
Life
(
Class
B(
CW))
Aluminum
Dieldrin
alpha­
Endosulfan
beta­
Endosulfan
Endosulfan
Sulfate
Endrin
Lindane
Pentachlorophenol
Toxaphene
Aquatic
Life
Use:
Significant
Resource
Warm
Water
(
Class
B(
WW))
Aluminum
Dieldrin
alpha­
Endosulfan
beta­
Endosulfan
Endosulfan
Sulfate
Endrin
Lindane
Pentachlorophenol
Aquatic
Life
Use:
Limited
Resource
Warm
Water
(
Class
B(
LR))
Aluminum
4,4'­
DDT
Dieldrin
Endrin
Heptachlor
Lindane
Pentachlorophenol
Toxaphene
Aquatic
Life
Use:
Lakes
and
Wetlands
(
Class
B(
LW))
Dieldrin
alpha­
Endosulfan
beta­
Endosulfan
Endosulfan
Sulfate
Endrin
Lindane
Pentachlorophenol
Potable
Water
Use
(
Class
C)
2,3,7,8­
TCDD
(
Dioxin)
alpha­
Endosulfan
beta­
Endosulfan
Endosulfan
Sulfate
Bromoform
Chlorodibromomethane
Chloroform
Dichlorobromomethane
December
2001
2.0
Potentially
Affected
Facilities
and
Sample
Selection
2­
1
2.0
POTENTIALLY
AFFECTED
FACILITIES
AND
SAMPLE
SELECTION
The
Iowa
Department
of
Natural
Resources
(
IDNR)
provided
listings
of
all
NPDES
dischargers
in
the
State,
along
with
their
discharge
category
(
major
or
minor),
receiving
waters,
and
current
designated
use
classification
for
the
receiving
waters.
IDNR
also
identified
those
facilities
that
discharge
to
stream
segments
for
which
EPA
is
proposing
to
reclassify
the
designated
use.
In
the
listings,
IDNR
separated
out
quarries
and
inactive
facilities.

EPA
used
the
information
provided
by
IDNR
as
the
basis
for
identifying
the
universe
of
potentially
affected
facilities.
EPA
removed
quarries
from
the
universe
because
these
facilities
do
not
discharge
pollutants
that
would
cause
them
to
be
affected
by
the
proposed
rule.
EPA
also
removed
inactive
facilities
from
the
universe
because
these
facilities
do
not
currently
discharge.
Finally,
EPA
removed
facilities
that
do
not
discharge
to
stream
segments
for
which
EPA
is
proposing
to
reclassify
the
designated
use
and
whose
receiving
waters
are
not
currently
designated
Class
B
or
Class
C
(
i.
e.,
whose
receiving
waters
are
of
a
class
for
which
EPA
is
not
proposing
revised
water
quality
criteria).
These
facilities
would
not
be
affected
by
either
provision
of
the
proposed
rule.
This
resulted
in
a
universe
of
916
potentially
affected
facilities.

EPA
used
data
from
its
Permit
Compliance
System
(
PCS)
database
to
categorize
each
potentially
affected
facility
as
a
POTW
or
industrial
facility
and
to
categorize
industrial
facilities
by
sector.
EPA
then
divided
the
universe
into
two
mutually
exclusive
groups:

1.
Facilities
that
do
not
discharge
to
stream
segments
for
which
EPA
is
proposing
to
reclassify
the
designated
use,
but
do
discharge
to
Class
B
or
Class
C
receiving
waters.
These
facilities
are
potentially
affected
by
the
proposed
revisions
to
the
water
quality
criteria,
but
not
by
the
proposed
reclassification
of
stream
(
hereafter
referred
to
as
"
facilities
facing
new
criteria
only)."

2.
Facilities
that
discharge
to
stream
segments
for
which
EPA
is
proposing
to
reclassify
the
designated
use.
These
facilities
are
potentially
affected
by
both
provisions
of
the
proposed
rule
(
hereafter
referred
to
as
"
facilities
facing
reclassified
designated
uses
and
new
criteria)."

EPA
evaluated
facilities
from
each
of
these
groups
to
estimate
the
potential
cost
impacts.
The
sections
below
describe
these
facilities.

2.1
Facilities
Facing
New
Criteria
Only
EPA
identified
a
total
of
869
potentially
affected
facilities
facing
new
criteria
only.
For
these
facilities,
EPA
searched
its
PCS
database
to
identify
facilities
with
effluent
monitoring
data
or
existing
NPDES
permit
limits
for
the
pollutants
subject
to
the
criteria
revisions.
EPA
found
four
such
facilities.
These
four
facilities
are
likely
the
only
facilities
affected
by
the
criteria
revisions.
Exhibit
2­
1
shows
the
universe
of
facilities
EPA
identified
as
the
facing
new
criteria
only.
Exhibit
2­
2
identifies
the
four
affected
facilities
by
name
and
permit
number.
December
2001
2.0
Potentially
Affected
Facilities
and
Sample
Selection
2­
2
Exhibit
2­
1.
Facilities
Facing
New
Criteria
Only:
Comparison
of
Universe
and
Affected
Facilities
Designated
Use
Class
Facility
Type
Number
in
Universe
Number
Potentially
Impacted1
Major
Dischargers
B(
WW)
POTW
37
0
Industrial
 
Food
Products
5
0
Industrial
 
Other
Manufacturing
12
0
Industrial
 
Electrical
Generation
10
0
B(
WW)
and
C
POTW
1
0
Industrial
3
2
B(
LR)
POTW
24
0
Minor
Dischargers
All
Classes
POTW
590
0
Industrial
 
Food
Products
46
0
Industrial
 
Other
Manufacturing
81
2
Industrial
 
Transportation,
Warehousing,
Pipelines
24
0
Industrial
 
Electrical
Generation
15
0
Industrial
 
Other
21
0
Total
869
4
1
Based
on
information
in
PCS.

Exhibit
2­
2.
Facilities
Facing
New
Criteria
Only:
Affected
Facilities
Facility
Name
Permit
Number
Discharger
Category
Designated
Use
Class
Facility
Type
Alcoa,
Inc.
IA0003395
Major
B(
WW)
and
C
Industrial
Roquette
America,
Inc.
IA0000256
Major
B(
WW)
and
C
Industrial
Maytag
Appliances­
Newton
Laundry
Products­
Plant
2
IA0000582
Minor
B(
LR)
Industrial:
other
manufacturing
Winnebago
Industries,
Inc.
IA0067229
Minor
B(
WW)
Industrial:
other
manufacturing
2.2
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria
EPA
identified
a
total
of
47
potentially
affected
facilities
facing
reclassified
both
designated
uses
and
new
criteria.
EPA
selected
a
stratified
random
sample
of
11
facilities
from
this
group
for
analysis
and
stratified
these
facilities
according
to
discharge
category,
designated
use
class,
and
facility
type.
The
number
of
randomly
selected
facilities
in
each
stratum
is
based
on
the
total
number
of
facilities
of
each
type
in
the
universe
of
potentially
affected
facilities.
Exhibit
2­
3
December
2001
2.0
Potentially
Affected
Facilities
and
Sample
Selection
2­
3
compares
the
universe
and
sample
facilities
in
this
group.
Exhibit
2­
4
identifies
the
sample
facilities
by
name
and
permit
number.
Exhibit
2­
3.
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria:
Comparison
of
Universe
and
Sample
Facilities
New
Designated
Use
Class
Discharger
Category
Facility
Type
Number
in
Universe
Sample
Size
A
Major
POTW
1
1
Minor
POTW
22
3
Industrial
5
1
A,
B(
LW)
Minor
POTW
1
1
B(
WW)
Major
POTW
1
1
Minor
POTW
13
2
Industrial
4
2
Total
47
11
Exhibit
2­
4.
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria:
Facilities
Selected
for
Evaluation
Facility
Name
Permit
Number
New
Designated
Use
Class
Discharger
Category
Facility
Type
Greenfield,
City
of
STP
IA0021369
A
Major
POTW
Cedar
Falls
Mobile
Home
Village
IA0064033
A
Minor
POTW
Grand
River,
City
of
STP
IA0066346
A
Minor
POTW
Roland,
City
of
STP
IA0032425
A
Minor
POTW
Green
Valley
Chemical
Corporation
IA0003964
A
Minor
Industrial
Atalissa,
City
of
STP
IA0070998
A
and
B(
LW)
Minor
POTW
New
Hampton,
City
of
STP
IA0028525
B(
WW)
Major
POTW
Stockton,
City
of
STP
IA0033464
B(
WW)
Minor
POTW
Thompson,
City
of
STP
IA0068683
B(
WW)
Minor
POTW
Van
Diest
Supply
Co.
IA0070033
B(
WW)
Minor
Industrial
North
Star
Steel
Iowa
IA0061972
B(
WW)
Minor
Industrial
2.3
Data
Collection
For
each
of
the
facilities
identified
in
Exhibits
2­
2
and
2­
4,
EPA
obtained
permit
file
information
from
IDNR
and
EPA's
Region
7
offices.
This
information
included
copies
of
each
facility's
NPDES
permit,
permit
application,
permit
fact
sheet,
supporting
documentation,
and
a
limited
quantity
of
discharge
monitoring
data.
EPA
obtained
complete
discharge
monitoring
data
for
each
facility
from
its
PCS
database.
As
needed
according
to
the
analytical
methodology
(
see
December
2001
2.0
Potentially
Affected
Facilities
and
Sample
Selection
2­
4
Section
3.0),
EPA
also
obtained
background
water
quality
data
from
STORET
and
stream
characteristics
(
flow
and
dimensions)
from
the
U.
S.
Geological
Survey
(
USGS)
National
Water
Information
System
(
http://
water.
usgs.
gov/
nwis).
December
2001
3.0
Methodology
3­
1
3.0
METHODOLOGY
FOR
ESTIMATING
POTENTIAL
COMPLIANCE
COSTS
This
chapter
describes
EPA's
methodology
for
estimating
potential
costs
and
pollutant
loading
reductions
that
may
result
from
implementation
of
the
proposed
rule.
As
discussed
in
Section
2,
EPA
identified
two
groups
of
facilities
potentially
affected
by
the
proposed
rule.
The
sections
below
describe
the
methodologies
applicable
to
each
group.

3.1
Facilities
Facing
New
Criteria
The
facilities
facing
new
criteria
might
require
additional
treatment
for
toxic
pollutants.
The
specific
toxic
pollutants
of
concern
are
those
for
which
EPA
is
proposing
new
or
revised
water
quality
criteria
(
see
Exhibit
1­
1
for
the
identity
of
the
specific
pollutants).
For
each
of
the
potentially
affected
facilities
and
each
pollutant
of
concern,
EPA
analyzed
the
need
for
and
cost
of
this
additional
treatment
using
the
following
steps:


Determining
reasonable
potential
to
exceed
water
quality
criteria

Calculating
projected
effluent
limits
for
pollutants
with
reasonable
potential

Estimating
the
potential
costs
of
required
compliance
actions
for
facilities
expected
to
exceed
their
projected
effluent
limits.

3.1.1
Determining
Reasonable
Potential
When
a
facility
had
discharge
monitoring
data
for
any
of
the
toxic
pollutants
of
concern,
EPA
analyzed
the
reasonable
potential
to
exceed
water
quality
criteria.
EPA
calculated
a
projected
effluent
quality
(
PEQ)
value,
an
effluent
value
statistically
adjusted
for
uncertainty,
which
EPA
used
to
estimate
a
maximum
value.
The
methodology
to
derive
a
PEQ
is
based
on
EPA's
Technical
Support
Document
for
Water
Quality­
based
Toxics
Control
(
TSD)
(
1991).
EPA
also
used
the
following
assumptions
to
estimate
the
PEQ:

1.
The
coefficient
of
variation
(
CV)
is
equal
to
0.6
for
a
pollutant
with
10
or
fewer
data
points.

2.
The
CV
is
based
on
the
log­
transformed
effluent
data
for
a
pollutant
with
11
to
20
data
points.

3.
The
99th
percentile
value
of
the
effluent
data
set
represents
the
PEQ
for
pollutants
with
more
than
20
data
points.

For
pollutants
with
20
or
fewer
data
points,
EPA
calculated
a
reasonable
potential
multiplying
factor
(
MF)
based
on
the
99%
confidence
level
and
the
99%
probability
basis.
This
factor
is
a
function
of
the
CV
and
the
number
of
effluent
samples.
MFs
for
a
range
of
CVs
and
number
of
samples
are
presented
in
Table
3
 
1
of
the
TSD
(
U.
S.
EPA,
1991).
EPA
obtained
the
PEQ
by
multiplying
the
maximum
effluent
concentration
(
MEC)
by
the
MF.
2
Assuming
a
translator
of
one
is
a
conservative
assumption
used
to
simplify
this
stage
of
the
analysis.
For
pollutants
found
to
have
reasonable
potential,
EPA
applied
pollutant­
specific
translators
in
the
next
stage
of
the
analysis
as
described
in
Section
3.1.2.

December
2001
3.0
Methodology
3­
2
EPA
then
calculated
a
waste
load
allocation
(
WLA)
based
on
the
proposed
chronic
criterion.
In
calculating
the
WLA,
EPA
used
7Q10
flows
for
the
receiving
stream
reported
in
each
facility's
permit
file.
If
7Q10
flow
information
was
not
available
in
the
permit
file,
EPA
calculated
7Q10
flows
from
monitoring
data
contained
in
the
USGS
daily
flow
file
database
for
nearby
stream
gauges.
When
flow
data
was
not
available
for
a
nearby
stream
gauge,
EPA
contacted
IDNR
to
provide
a
7Q10
flow.
For
metals,
the
WLAs
used
in
the
reasonable
potential
analysis
are
expressed
in
dissolved
form
(
i.
e.,
a
translator
of
one
is
used
to
convert
criteria
from
dissolved
to
total).
2
EPA
also
calculated
the
receiving
water
concentration
(
RWC)
as
the
product
of
the
PEQ
and
dilution
ratio.
EPA
estimated
that
a
pollutant
has
reasonable
potential
to
exceed
the
water
quality
criterion
if
the
PEQ
exceeds
the
WLA
or
the
RWC
exceeds
the
water
quality
criterion.

3.1.2
Calculating
Projected
Effluent
Limits
For
facilities
with
pollutants
with
a
reasonable
potential
to
exceed
water
quality
criteria,
EPA
calculated
projected
effluent
limits
based
on
the
methods
recommended
in
EPA's
TSD
(
1991)
and
the
following
assumptions:

1.
Establishing
water
quality
criteria
for
metals
as
total
concentrations
by
multiplying
each
metal
dissolved
concentration
criterion
by
a
translator
based
on
theoretical
partitioning
coefficients
(
U.
S.
EPA,
1984)

2.
Using
a
CV
of
0.6
for
pollutants
with
less
than
10
data
points
3.
Calculating
the
CV
of
the
log­
transformed
effluent
data
for
a
pollutant
with
more
than
10
effluent
data
points
4.
Calculating
long­
term
averages
(
LTA)
based
on
the
proposed
water
quality
criteria
by
multiplying
the
WLA
by
WLA
multipliers
values
(
See
Table
5
 
1
of
U.
S.
EPA,
1991)

5.
Calculating
the
maximum
daily
limit
(
MDL)
and
the
average
monthly
limit
(
AML)
by
multiplying
the
LTA
by
LTA
multipliers
based
on
the
99th
percentile
for
the
MDL
and
the
95th
percentile
for
the
AML
(
assuming
that
the
effluent
is
monitored
4
times
per
month).

3.1.3
Estimating
Potential
Costs
Dischargers
may
be
affected
by
EPA's
action
if
their
current
permit
limits
or
concentrations
of
toxic
pollutants
in
their
effluents
exceed
projected
effluent
limits.
Affected
dischargers
would
need
to
implement
measures
to
reduce
pollutant
concentrations
in
their
effluent.
December
2001
3.0
Methodology
3­
3
To
estimate
potential
cost
impacts,
EPA
estimated
pollution
control
costs
in
situations
where
the
MEC
exceeded
projected
effluent
limits
and
used
the
MEC
as
the
baseline
effluent
quality
value.
However,
if
the
MEC
exceeded
an
existing
permit
limit,
EPA
used
the
existing
permit
limit
as
a
baseline
concentration
to
avoid
including
costs
that
are
associated
with
complying
with
current
State
regulations.
EPA
estimated
costs
based
on
the
incremental
pollutant
loading
reductions
required
to
achieve
the
projected
limits.

EPA
followed
a
decision
framework
based
on
the
assumption
that
a
facility
would
pursue
lower
cost
control
strategies
prior
to
adding
end­
of­
pipe
treatment.
This
framework
is
presented
in
Appendix
A.
Appendix
A
also
provides
unit
cost
estimates
for
the
control
strategies
considered.

3.2
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria
The
facilities
facing
reclassified
designated
uses
and
new
criteria
might
require
additional
treatment
for
toxic
pollutants
and/
or
conventional
pollutants.
EPA's
methodology
for
analyzing
the
compliance
cost
associated
with
the
control
of
toxic
pollutants
is
nearly
identical
to
that
described
for
facilities
facing
new
criteria
only
(
see
Section
3.1).
The
only
difference
is
that
EPA
conducted
the
analysis
for
all
toxic
pollutants
that
have
water
quality
criteria
under
each
facility's
reclassified
designated
use,
rather
than
just
the
pollutants
for
which
EPA
is
proposing
revised
criteria.
EPA's
methodology
for
analyzing
compliance
cost
for
conventional
pollutants
varied
depending
on
the
pollutant.
The
specific
conventional
pollutants
of
concern
are
fecal
coliform
(
for
designated
use
class
A)
and
dissolved
oxygen
and
ammonia
(
for
designated
use
class
B).

3.2.1
Fecal
Coliform
Facilities
discharging
to
receiving
waters
that
EPA
is
proposing
to
designate
as
Class
A
might
require
additional
treatment
for
fecal
coliform.
To
analyze
the
need
for
and
potential
cost
of
this
treatment,
EPA
calculated
an
estimated
fecal
coliform
concentration
in
the
receiving
waters
resulting
from
the
discharge
from
each
sample
facility
facing
reclassification
to
Class
A.
This
calculation
is
based
on
the
fecal
coliform
concentration
in
the
facility's
effluent,
the
background
fecal
coliform
concentration
in
the
receiving
stream,
the
facility's
discharge
flow
rate,
and
the
7Q10
flow
of
the
receiving
stream.
EPA
made
the
following
assumptions
in
performing
this
calculation:

1.
Discharge
monitoring
data
for
fecal
coliform
were
not
available
for
any
of
the
sample
facilities.
Therefore,
EPA
obtained
fecal
coliform
discharge
monitoring
data
for
similar
Iowa
facilities
(
similar
size
and
industry)
for
the
last
five
years
from
its
PCS
database.
EPA
assumed
an
effluent
concentration
equal
to
the
95th
percentile
value
from
this
data.

2.
For
receiving
streams
for
which
background
monitoring
data
were
not
available,
EPA
assumed
a
background
fecal
coliform
concentration
of
zero.

3.
7Q10
flows
were
obtained
as
described
in
Section
3.1.1.
December
2001
3.0
Methodology
3­
4
For
facilities
located
upstream
of
segments
that
EPA
is
proposing
to
designate
as
Class
A,
EPA
calculated
the
fecal
coliform
concentration
at
the
discharge
point
as
described
above.
EPA
then
calculated
the
fecal
coliform
concentration
at
the
location
of
the
segment
subject
to
reclassification,
based
on
the
distance
from
the
discharge
point,
stream
temperature
and
velocity,
and
the
resulting
decay
rate
for
fecal
coliform.
Stream
temperatures
were
obtained
from
STORET,
and
stream
velocities
were
obtained
from
the
USGS
National
Water
Information
System.
EPA
made
the
following
assumption
in
performing
this
calculation:


For
receiving
streams
for
which
temperature
was
not
available,
EPA
assumed
a
stream
temperature
of
20
degrees
C
(
the
reference
temperature
in
the
modeling
equations
and
approximately
the
average
stream
temperature
of
the
sample
facilities).

EPA
then
compared
the
calculated
receiving
stream
concentration
to
Iowa's
criterion
for
fecal
coliform.
This
criterion
applies
from
April
1
to
October
31
and
is
200
colonies/
100
ml,
except
for
waters
"
materially
affected
by
surface
runoff."
For
waters
materially
affected
by
surface
runoff,
facilities
may
not
cause
an
increase
of
more
than
200
colonies/
100
ml.
Waters
materially
affected
by
surface
runoff
could
not
be
identified
due
to
a
lack
of
data.
Consequently,
EPA
conservatively
assumed
that
all
relevant
waters
were
materially
affected.
EPA
calculated
the
in­
stream
fecal
coliform
concentration,
based
on
background
and
effluent
concentrations
for
each
facility
and
then
compared
this
value
to
the
background
fecal
coliform
concentration.
If
any
facility
would
cause
an
increase
of
more
than
200
colonies/
100
ml,
EPA
assumed
that
additional
treatment
would
be
needed.

For
facilities
requiring
additional
treatment,
EPA
determined
the
type
and
potential
cost
of
treatment
using
the
same
methodology
developed
for
the
Agency's
economic
analysis
of
its
final
rule
promulgating
revised
water
quality
standards
for
the
State
of
Kansas
(
EPA,
2001).
This
methodology
is
described
in
Appendix
B.

3.2.2
Ammonia
and
Dissolved
Oxygen
Facilities
discharging
to
receiving
waters
that
EPA
is
proposing
to
designate
as
Class
B
might
require
additional
treatment
for
ammonia
and/
or
dissolved
oxygen.
To
analyze
the
need
for
and
potential
cost
of
this
treatment,
EPA
performed
computer
modeling
to
calculate
the
maximum
ammonia
concentration
and
minimum
dissolved
oxygen
concentration
in
the
receiving
waters
resulting
from
the
discharge
from
each
sample
facility
facing
reclassification
to
Class
B.
The
computer
model
accounted
for
the
following
input
data:


Effluent
concentrations
of
biochemical
oxygen
demand
(
BOD),
dissolved
oxygen,
and
ammonia,


Background
concentrations
of
BOD,
dissolved
oxygen,
and
ammonia,


Discharge
flow
rate,


7Q10
flow
of
the
receiving
stream,
and

Receiving
stream
depth
and
width.
December
2001
3.0
Methodology
3­
5
EPA
made
the
following
assumptions
in
developing
the
input
data
for
the
model:

1.
Discharge
monitoring
data
for
dissolved
oxygen
were
not
available
for
any
of
the
sample
facilities.
Therefore,
EPA
obtained
dissolved
oxygen
discharge
monitoring
data
for
similar
Iowa
facilities
(
similar
size
and
industry)
for
the
last
five
years
from
its
PCS
database.
EPA
assumed
an
effluent
concentration
equal
to
the
5th
percentile
value
from
these
data.

2.
Discharge
monitoring
data
for
ammonia
were
available
for
only
one
of
the
sample
facilities.
This
facility's
maximum
observed
ammonia
concentrations
were
in
excess
of
its
corresponding
existing
permit
limits.
EPA,
therefore,
assumed
an
effluent
concentration
equal
to
the
facility's
maximum
daily
summertime
ammonia
limit.

3.
Discharge
monitoring
data
for
ammonia
were
not
available
for
the
remaining
sample
facilities.
Therefore,
EPA
obtained
ammonia
discharge
monitoring
data
for
similar
Iowa
facilities
(
similar
size
and
industry)
for
the
last
five
years
from
its
PCS
database.
EPA
assumed
an
effluent
concentration
equal
to
the
95th
percentile
value
from
these
data.

4.
The
maximum
observed
BOD
concentrations
at
all
facilities
were
in
excess
of
their
corresponding
existing
permit
limits.
EPA,
therefore,
assumed
an
effluent
concentration
for
each
facility
equal
to
the
facility's
maximum
daily
BOD
limit.

5.
Background
concentrations
of
ammonia
and/
or
dissolved
oxygen
were
not
available
for
some
receiving
streams.
When
ammonia
data
were
unavailable,
EPA
assumed
a
background
concentration
of
zero.
When
dissolved
oxygen
data
were
unavailable,
EPA
assumed
a
background
concentration
of
5.0
mg/
L
(
i.
e.,
equal
to
the
criterion
for
dissolved
oxygen).

6.
7Q10
flows
were
obtained
as
described
in
Section
3.1.1.

7.
Stream
width
and
depth
were
taken
from
nearby
USGS
stream
gauges
for
dates
when
observed
stream
flows
were
at
or
near
the
7Q10
flow.

EPA
calculated
receiving
stream
concentrations
of
ammonia
and
dissolved
oxygen
for
the
segment
of
the
receiving
stream
subject
to
reclassification.
That
is,
if
a
facility
was
located
six
miles
upstream
of
the
stream
segment
subject
to
reclassification,
EPA
used
the
model
results
for
a
distance
six
miles
and
greater
from
the
discharge
point.

EPA
then
compared
the
calculated
receiving
stream
concentration
to
Iowa's
criteria.
Iowa's
criterion
for
the
Class
B(
CW),
B(
WW),
and
B(
LW)
designated
use
classifications
is
a
minimum
DO
of
5.0
mg/
L
at
any
time
during
every
24­
hour
period.
For
Class
B(
LW)
lake
designations,
the
criteria
only
applies
to
the
upper
layer
of
stratification.
Iowa's
criteria
for
ammonia
are
dependent
on
stream
temperature
and
pH.
Therefore,
for
ammonia,
EPA
estimated
the
applicable
criterion
using
the
highest
summertime
temperature
and
pH
values
observed
for
each
stream
in
STORET.
EPA
selected
the
chronic
ammonia
criterion
corresponding
to
these
values.
EPA
estimated
that
additional
treatment
would
be
required
for
facilities
if
their
discharge
would
cause
an
in­
stream
December
2001
3.0
Methodology
3­
6
concentration
of
ammonia
greater
than
the
estimated
ammonia
criterion
and/
or
an
in­
stream
concentration
of
dissolved
oxygen
of
less
than
5.0
mg/
L.

None
of
the
sample
facilities
required
additional
treatment
for
dissolved
oxygen.
For
facilities
requiring
additional
treatment
for
ammonia,
EPA
determined
the
type
and
potential
cost
of
treatment
using
the
methodology
developed
for
a
previous
analysis
of
potential
impacts
resulting
from
revised
water
quality
standards
(
EPA,
2001).
This
methodology
is
described
in
Appendix
B.

3.3
Estimating
Pollutant
Loadings
3.3.1
Toxic
Pollutants
EPA
estimated
loading
reductions
as
the
difference
between
the
baseline
concentration
and
the
projected
water
quality
based
effluent
limit
(
WQBEL).
Note,
however,
that
this
convention
likely
results
in
an
upper
bound
estimate
of
loading
reductions
because
facilities
typically
discharge
at
levels
below
the
maximum
effluent
concentration
(
MEC).
EPA
estimated
annual
loadings
by
multiplying
the
pollutant
concentration
by
the
facility
effluent
flow
(
in
million
gallons
per
day,
MGD),
a
conversion
factor
(
0.00834),
and
365
days
per
year.
The
estimated
loading
reduction
is
based
on
the
difference
between
the
MEC
(
or
the
current
effluent
limit
if
the
MEC
is
greater
than
the
current
limit)
and
the
projected
effluent
limit.

3.3.2
Conventional
Pollutants
EPA
estimated
loading
reductions
as
the
difference
between
the
baseline
concentration
and
the
projected
WQBEL.
Note
that
this
conversion
results
in
an
estimated
loading
reduction
only
because
the
baseline
concentration
is
based
on
assumptions
about
discharge
concentration
and
because
the
effluent
limit
varies
by
season
(
and,
for
ammonia,
by
pH
and
temperature).
For
ammonia,
EPA
estimated
loadings
in
pounds
per
year
by
multiplying
the
pollutant
concentration
(
in
mg/
L)
by
the
facility
effluent
flow
(
in
MGD),
a
conversion
factor
(
8.34),
and
365
days
per
year.
For
fecal
coliform,
EPA
estimated
loadings
in
number
of
colonies
per
year
by
multiplying
the
pollutant
concentration
(
in
colonies/
100
ml)
by
the
facility
effluent
flow
(
in
MGD),
a
conversion
factor
(
3.79
x
107),
and
365
days
per
year.
The
estimated
loading
reduction
is
based
on
the
difference
between
the
MEC
(
or
the
current
effluent
limit
if
the
MEC
is
greater
than
the
current
limit)
and
the
projected
effluent
limit.
December
2001
4.0
Results
4­
1
4.0
RESULTS
This
chapter
presents
estimates
of
the
potential
costs
of
EPA's
rule.
Appendices
C
and
D
provides
the
facility­
level
analyses
upon
which
these
results
are
based.

4.1
Facilities
Facing
New
Criteria
Only
EPA
estimated
that,
of
the
four
facilities
believed
most
likely
to
be
affected
by
the
proposed
revisions
to
water
quality
criteria,
two
minor
industrial
facilities
might
bear
compliance
costs
associated
with
additional
treatment.
While
the
other
two
facilities
discharge
pollutants
for
which
EPA
is
proposing
to
change
criteria,
EPA
estimates
that
these
facilities
would
not
require
additional
treatment
given
existing
permit
limits
and
discharge
concentrations.
Exhibit
4­
1
summarizes
the
potential
treatment
costs
associated
with
the
revisions
to
water
quality
criteria.

Exhibit
4­
1.
Total
Estimated
Costs
of
Proposed
Revisions
to
Water
Quality
Criteria
Treatment
Costs
(
Thousands
of
Year
2001
Dollars)
1
Total
Capital
O&
M
Total
Annualized2
NaOH
Precipitation
and
GAC
$
585.00
$
224.00
$
279.22
Sedimentation
with
Alum
Addition
$
1,100.00
$
200.00
$
303.83
Total
$
1,685.00
$
424.00
$
583.05
1EPA
estimated
that
two
facilities
in
the
universe
of
potentially
affected
facilities
will
incur
treatment
costs.
2Annual
O&
M
costs
plus
capital
costs
annualized
at
7%
over
20
years.

The
estimated
annual
cost
of
about
$
583,000
per
year
is
associated
with
additional
end­
of­
pipe
treatment
to
meet
the
proposed
revision
to
the
water
quality
criteria
for
aluminum.
As
a
result
of
this
additional
treatment,
EPA
estimates
pollutant
loading
reductions
of
558
pounds
per
year
of
aluminum.

4.2
Facilities
Facing
Reclassified
Designated
Uses
and
New
Criteria
EPA
estimated
that
3
of
the
11
sample
facilities
might
bear
compliance
costs
associated
with
additional
treatment.
While
the
facilities
in
this
group
are
potentially
affected
by
the
new
water
quality
criteria,
EPA
believes,
based
on
its
review
of
PCS
data
and
the
sample
facilities,
that
none
of
the
facilities
in
this
group
discharge
pollutants
for
which
EPA
is
proposing
to
revise
criteria.
Therefore,
the
costs
estimated
in
this
section
are
associated
entirely
with
the
proposed
reclassification
of
designated
uses.

Exhibit
4­
2
summarizes
the
estimated
costs
for
the
sample
facilities
and
Exhibit
4­
3
shows
how
these
costs
extrapolate
(
based
on
the
average
annual
cost
per
facility
in
each
category)
to
the
potentially
affected
universe
of
facilities.
December
2001
4.0
Results
4­
2
Exhibit
4­
2.
Estimated
Costs
to
Sample
Facilities
Affected
by
Proposed
Reclassified
Designated
Uses
New
Designated
Use
Class
Discharger
Category
Facility
Type
Sample
Size
Estimated
Number
Installing
Treatment
Costs
(
2001
Dollars)

Total
Capital
Costs
($
1,000s)
O&
M
Costs
($
1,000s/
yr)
Total
Annualized
Costs1
($
1,000s/
yr)
Annualized
Costs
per
Sample
Facility
($
1,000s/
yr)

A
Major
POTW
1
0
$
0.00
$
0.00
$
0.00
$
0.00
A
Minor
POTW
3
2
$
357.97
$
8.15
$
41.94
$
13.98
A
Minor
Industrial
1
0
$
0.00
$
0.00
$
0.00
$
0.00
A,
B(
LW)
Minor
POTW
1
1
$
127.31
$
1.91
$
13.93
$
13.93
B(
WW)
2
Major
POTW
1
0
$
0.00
$
0.00
$
0.00
$
0.00
B(
WW)
Minor
POTW
2
0
$
0.00
$
0.00
$
0.00
$
0.00
B(
WW)
Minor
Industrial
2
0
$
0.00
$
0.00
$
0.00
$
0.00
1
Annual
O&
M
costs
plus
capital
costs
annualized
at
7%
over
20
years.

2
One
facility
is
required
to
conduct
monitoring
and
a
PMP
since
no
effluent
data
exist
but
the
permit
indicates
limits
exist
for
pollutants
of
concern.
December
2001
4.0
Results
4­
3
Exhibit
4­
3.
Estimated
Extrapolated
Costs
Associated
with
Proposed
Reclassified
Designated
Uses
New
Designated
Use
Class
Discharger
Category
Facility
Type
Number
of
Facilities
in
Universe
Average
Annual
Cost
per
Facility1
($
1,000s/
yr)
Estimated
Total
Annual
Cost
($
1,000s/
yr)

A
Major
POTW
1
$
0.00
$
0.00
A
Minor
POTW
22
$
13.98
$
307.56
A
Minor
Industrial
5
$
0.00
$
0.00
A,
B(
LW)
Minor
POTW
1
$
13.93
$
13.93
B(
WW)
Major
POTW
1
$
0.00
$
0.00
B(
WW)
Minor
POTW
13
$
0.00
$
0.00
B(
WW)
Minor
Industrial
4
$
0.00
$
0.00
Total
47
 
$
321.49
1
From
Exhibit
4­
2.

Based
on
this
extrapolation,
EPA
estimated
total
annual
costs
of
from
approximately
$
321,000
as
a
result
of
the
proposed
reclassification
of
designated
uses.
EPA
estimates
that
only
one
facility
would
require
additional
treatment
to
meet
the
ammonia
criterion.
No
facilities
would
require
additional
treatment
for
toxic
pollutants
or
to
meet
the
dissolved
oxygen
criterion.

EPA
estimates
pollutant
loading
reductions
of
2.65
x
1013
fecal
coliform
colonies.
Fecal
coliforms
are
bacteria
that,
when
present,
indicate
contamination
of
receiving
waters
by
mammalian
feces,
including
human
feces.
At
high
numbers
of
fecal
coliform
bacteria
per
volume
of
water,
there
is
a
high
probability
that
human
pathogens
(
disease­
causing
organisms)
are
also
present,
resulting
in
an
increased
risk
of
disease
following
contact.
Ingestion
of
high
concentrations
of
fecal
coliform
bacteria
can
also
lead
directly
to
human
illness.
The
reductions
in
the
number
of
fecal
coliform
bacteria
as
a
result
of
the
proposed
rule
will
therefore
reduce
the
risk
of
human
disease
from
discharge
of
waste
from
wastewater
treatment
facilities.

EPA
also
estimates
pollutant
loading
reductions
of
915
pounds
per
year
of
ammonia.
Ammonia
has
three
characteristics
that
affect
receiving
waters:
1)
it
is
a
nutrient
that
stimulates
the
growth
of
plants
and
algae,
and
can
lead
to
algal
blooms,
2)
the
un­
ionized
portion
of
ammonia
is
toxic
to
aquatic
animals,
and
at
temperatures
approaching
30
°
C
and
pH
above
about
7.8,
a
substantial
portion
of
the
ammonia
is
in
the
un­
ionized
form,
and
3)
the
nitrification
(
conversion)
of
ammonia
to
nitrite
by
bacteria
consumes
oxygen
in
the
stream
(
and
allows
for
the
further
nitrification
of
nitrite
to
nitrate
which
also
consumes
receiving
water
oxygen).
All
of
these
effects
are
generally
deleterious
to
aquatic
life.
The
reductions
in
ammonia
discharges
as
a
result
of
the
rule
will
improve
the
quality
of
freshwater
habitat
for
aquatic
life,
leading
to
more
balanced
aquatic
ecosystems.
December
2001
4.0
Results
4­
4
4.3
Total
Statewide
Costs
Exhibit
4­
4
shows
the
total
estimated
statewide
costs
of
the
rule.
Total
costs
are
$
904,000
per
year.
Approximately
65%
of
the
total
costs
are
associated
with
the
proposed
revision
to
the
water
quality
criterion
for
a
single
pollutant,
aluminum.
These
costs
are
incurred
by
two
minor
industrial
facilities.
The
remaining
35%
of
the
total
is
associated
with
the
proposed
reclassification
of
designated
uses.
Nearly
all
of
this
35%
is
associated
with
additional
treatment
for
fecal
coliform
at
minor
POTWs.

Exhibit
4­
4.
Total
Estimated
Statewide
Costs
of
Proposed
Water
Quality
Standards
(
2001
$/
yr)

Provision
Estimated
Annualized
Cost
1
Revisions
to
Water
Quality
Criteria
$
583,000
Reclassification
of
Designated
Uses
$
321,000
Total
$
904,000
1
Costs
are
annualized
at
7%
over
20
years.

EPA
made
several
assumptions
in
the
analysis
that
may
affect
the
estimated
total
statewide
cost.
Most
of
the
assumptions
would
tend
to
overstate
the
cost
of
the
proposed
rule.
These
assumptions
are
as
follows:

1.
Although
the
State
has
flexibility
in
implementing
the
rule,
EPA
assumed
no
regulatory
relief
would
be
afforded
to
these
facilities.
Alternative
compliance
options
may
lower
costs
to
these
facilities.

2.
Discharge
monitoring
data
were
not
available
for
the
sample
facilities
for
fecal
coliform,
dissolved
oxygen,
or
ammonia
(
with
one
exception
for
ammonia).
Therefore,
EPA
assumed
reasonable
worst­
case
discharge
concentrations
for
these
pollutants
based
on
observed
concentrations
for
similar
Iowa
facilities
as
described
in
Section
3.2.
Affected
facilities
may,
in
fact,
discharge
at
lower
concentrations
than
those
assumed.
As
a
result,
the
analysis
may
overestimate
the
need
for
additional
treatment
for
these
pollutants.
For
fecal
coliform
in
particular,
this
overestimation
may
have
a
significant
effect
on
the
total
statewide
cost
estimated,
because
fecal
coliform
accounts
for
nearly
45%
of
the
total
cost.

3.
Iowa's
criterion
for
fecal
coliform
varies
depending
on
whether
receiving
waters
are
"
materially
affected
by
surface
runoff."
EPA's
assumption
that
waters
are
not
materially
affected
by
surface
runoff
may
overestimate
total
statewide
costs.
December
2001
5.0
References
5­
1
5.0
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Eddy.
1995.
Wastewater
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LIST
OF
ACRONYMS
AML
average
monthly
limit
BOD
biochemical
oxygen
demand
CV
coefficient
of
variation
CWA
Clean
Water
Act
EA
economic
analysis
EO
Executive
Order
EPA
U.
S.
Environmental
Protection
Agency
IDNR
Iowa
Department
of
Natural
Resources
LTA
long­
term
average
MDL
maximum
daily
limit
MEC
maximum
effluent
concentration
MF
multiplying
factor
MGD
million
gallons
per
day
NPDES
National
Pollutant
Discharge
Elimination
System
NWIS
National
Water
Information
System
O&
M
operation
and
maintenance
OMB
Office
of
Management
and
Budget
PCS
Permit
Compliance
System
(
EPA
database
of
NPDES
permit
information)

PEQ
projected
effluent
quality
POTW
publicly
owned
treatment
works
RWC
receiving
water
concentration
STORET
Storage
and
Retrieval
System
(
EPA
database
of
water
quality
data)

STP
sewage
treatment
plant
TMDL
total
maximum
daily
load
TSD
EPA's
Technical
Support
Document
for
Water
Quality­
based
Toxics
Control
UAA
use
attainability
analysis
USGS
U.
S.
Geological
Survey
WLA
waste
load
allocation
WQBEL
water
quality­
based
effluent
limit
WQC
water
quality
criterion
WQS
water
quality
standards
