ECONOMIC
ANALYSIS
OF
THE
PROPOSED
WATER
QUALITY
STANDARDS
RULE
FOR
THE
STATE
OF
OREGON
September
2003
Prepared
for:

U.
S.
Environmental
Protection
Agency
Office
of
Water,
Office
of
Water
Science
1201
Constitution
Avenue,
N.
W.
5th
Floor
Connecting
Wing
Washington,
D.
C.
20460
Prepared
by:

Science
Applications
International
Corporation
11251
Roger
Bacon
Drive
Reston,
VA
20190
EPA
Contract
No.
68­
C­
99­
252
SAIC
Project
Number
01­
0833­
04­
6801­
xxx
September
2003
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
the
Analysis
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1­
3
1.3
Scope
of
the
Analysis
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1­
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1.4
Organization
of
the
Report
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1­
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2.0
Baseline
for
the
Analysis
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2­
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2.1
Water
Quality
Standards
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2­
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2.1.1
Temperature
Criteria
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2­
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2.1.2
IGDO
Criteria
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2­
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2.1.3
Beneficial
Use
Designations
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2­
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2.1.4
Antidegradation
Policy
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2­
6
2.3
Point
Source
Dischargers
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2­
6
3.0
Description
of
the
Proposed
Rule
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3­
1
3.1
Water
Quality
Criteria
and
Designated
Uses
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3­
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3.2
Antidegradation
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3­
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3.2
Antidegradation
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3­
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3.3
Potentially
Impacted
Facilities
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3­
5
4.0
Method
for
Estimating
Costs
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4­
1
4.1
Temperature
Criteria
and
Uses
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4­
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4.1.1
Sample
Facilities
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4­
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4.1.2
Determining
Effect
of
Discharges
on
Receiving
Water
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4­
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4.1.3
Identifying
Potential
Controls
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4­
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4.1.4
Estimating
Costs
of
Controls
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4­
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4.1.5
Total
Statewide
Costs
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4­
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4.2
IGDO
Criteria
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4­
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4.3
Antidegradation
Procedures
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4­
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4.3.1
Potential
Number
of
Antidegradation
Requests
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4­
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4.3.2
Antidegradation
Analysis
Requirements
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4­
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4.3.2.1
Financial
Analysis
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4­
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4.3.2.2Determination
of
Importance
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4­
11
5.0
Results
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5­
1
5.1
Temperature
Criteria
and
Uses
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5­
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5.2
IGDO
Criteria
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5­
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5.3
Antidegradation
Procedures
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5­
1
5.4
Total
Statewide
Costs
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5­
2
6.0
References
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6­
1
APPENDICES
Appendix
A
Facility
Analyses
Appendix
B
Statewide
Cost
Calculations
September
2003
ii
List
of
Exhibits
Exhibit
ES­
1.
Comparison
of
Current
Oregon
and
Proposed
EPA
Criteria
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ES­
1
Exhibit
ES­
2.
Estimated
Potential
Annual
Statewide
Costs
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ES­
5
Exhibit
2­
1.
Oregon
Water
Quality
Criteria
for
Temperature
and
IGDO
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2­
1
Exhibit
2­
2.
Oregon
Designated
Uses
(
and
Temperature
Criteria)
for
Salmonid
Habitat
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2­
2
Exhibit
2­
3.
Waters
Designated
by
the
State
of
Oregon
for
Salmonid
Rearing
and
Bull
Trout
Protection
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2­
5
Exhibit
2­
4.
Waters
Designated
by
the
State
of
Oregon
for
Salmonid
and
Bull
Trout
Spawning
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2­
5
Exhibit
2­
5.
NPDES
Permitted
Facilities
in
Oregon
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2­
6
Exhibit
2­
6.
Summary
of
NPDES
Permitted
Direct
Dischargers
in
Oregon
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2­
7
Exhibit
3­
1.
Comparison
of
Current
Oregon
and
Proposed
EPA
Criteria
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3­
1
Exhibit
3­
2.
Proposed
EPA
Criteria
for
Designating
Bull
Trout
and
Salmonid
Uses
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3­
2
Exhibit
3­
3.
Waters
EPA
Proposes
to
Designate
for
Salmonid
Rearing
and
Migration
and
Bull
Trout
Protection
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3­
4
Exhibit
3­
4.
Waters
EPA
Proposes
to
Designate
for
Salmonid
and
Bull
Trout
Spawning
.
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3­
4
Exhibit
3­
5.
Waters
EPA
Proposes
to
Designate
for
New
or
More
Stringent
Uses
and
Criteria
for
Temperature
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3­
7
Exhibit
3­
6.
Estimated
Number
of
Facilities
Potentially
Affected
by
the
Antidegradation,
IGDO,
and
Temperature
Provisions
of
the
Proposed
Rule
.
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3­
8
Exhibit
4­
1.
Sample
Facilities
Potentially
Affected
by
Revised
Temperature
Criteria
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4­
1
Exhibit
4­
2.
Estimated
Number
of
Potentially
Affected
Facilities
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4­
7
Exhibit
4­
3.
Estimated
Cost
per
Facility
to
Prepare
Antidegradation
Review
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4­
8
Exhibit
5­
1.
Estimated
Potential
Statewide
Costs
Attributable
to
the
Temperature
Provision
of
the
Proposed
Rule
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.
.
.
5­
1
Exhibit
5­
2.
Estimated
Potential
Facility
Costs
Attributable
to
the
Antidegradation
Provision
of
the
Proposed
Rule
($
2003/
yr)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
2
Exhibit
5­
3.
Estimated
Potential
Annual
Statewide
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
2
Exhibit
5­
4.
Limitations
of
the
Analysis
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
2
September
2003
iii
List
of
Acronyms
7Q10
Minimum
7­
day
average
flow
recurring
once
in
10
years
BMP
Best
management
practice
cfs
Cubic
feet
per
second
CWA
Clean
Water
Act
DO
Dissolved
oxygen
EA
Economic
analysis
EPA
Environmental
Protection
Agency
ENR
Engineering
News
Record
EO
Executive
Order
ESA
Endangered
Species
Act
FWS
Fish
and
Wildlife
Service
GIS
Geographic
information
system
IGDO
Intergravel
dissolved
oxygen
mgd
Million
gallons
per
day
MPS
Municipal
preliminary
screener
MWMC
Metropolitan
Wastewater
Management
Commission
NMFS
National
Marine
Fisheries
Service
NPDES
National
Pollutant
Discharge
Elimination
System
NOAA
National
Oceanic
and
Atmospheric
Administration
O&
M
Operation
and
maintenance
ODEQ
Oregon
Department
of
Environmental
Quality
ODFW
Oregon
Department
of
Fish
and
Wildlife
OMB
Office
of
Management
and
Budget
ONRW
Outstanding
natural
resource
water
P2
Pollution
Prevention
PCS
Permit
compliance
system
POTW
Publicly
owned
treatment
works
RMZ
Regulatory
mixing
zone
TMP
Temperature
management
plan
WQS
Water
quality
standards
September
2003
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
Oregon.
This
report
provides
estimates
of
potential
incremental
costs
that
point
source
dischargers
may
experience
as
a
result
of
the
proposed
rule.

On
July
23,
1996,
the
State
of
Oregon
submitted
revisions
to
its
water
quality
standards
to
EPA
for
review,
and
approval
or
disapproval,
pursuant
to
Clean
Water
Act
(
CWA)
section
303(
c)(
2)(
A).
Certain
of
these
revisions
identified
specific
numeric
temperature
criteria
to
protect
critical
life
stages
of
salmonids,
including
criteria
for
salmonid
rearing,
spawning,
bull
trout
rearing
and
spawning,
and
intergravel
dissolved
oxygen
(
IGDO)
to
protect
salmonid
incubation
and
fry
emergence.
EPA
approved
the
majority
of
the
revised
standards
submitted
by
Oregon,
including
approvals
of
the
temperature
and
dissolved
oxygen
standards.
EPA
took
no
action
with
respect
to
Oregon's
existing
antidegradation
implementation
plan
because
Oregon
had
not
submitted
new
or
revised
standards
in
1996
on
this
issue.

EPA's
approval
action
was
challenged
in
2001
by
Northwest
Environmental
Advocates.
The
plaintiff
also
alleged
that
EPA
had
a
nondiscretionary
duty
to
promulgate
an
implementation
plan
for
Oregon's
antidegradation
policy.
On
March
31,
2003,
the
U.
S.
District
Court
for
the
District
of
Oregon
ruled
that
EPA
had
violated
the
CWA
and
the
Endangered
Species
Act
(
ESA)
when
it
approved
certain
water
quality
standards
for
the
protection
of
salmonids
that
were
contained
in
Oregon's
1996
submission
because
Oregon
had
failed
to
designate
when
and
where
these
criteria
would
apply.
The
Court
directed
EPA
to
promulgate
new
temperature
water
quality
criteria
to
address
this
deficiency.
For
similar
reasons,
the
Court
also
vacated
EPA's
approval
of
a
water
quality
criterion
for
intergravel
dissolved
oxygen.
For
this
criterion,
the
Court
found
that
the
6
mg/
l
adopted
by
Oregon
would
not
adequately
protect
threatened
and
endangered
salmonid
species,
and
ordered
EPA
to
promulgate
new
water
quality
criteria
for
this
pollutant
parameter.
The
Court
also
ordered
EPA
to
promulgate
an
antidegradation
implementation
plan
for
Oregon
waters.
EPA's
proposed
rule
addresses
the
Court's
rulings.

In
evaluating
the
potential
impact
of
EPA's
proposed
rule,
EPA
calculated
the
incremental
costs
of
the
rule's
provisions
(
e.
g.,
the
cost
of
reducing
effluent
temperatures
based
on
current
State
standards
and
implementation
procedures
to
temperatures
that
would
be
required
under
EPA's
proposed
new
or
more
stringent
standards
and
implementation
procedures).
EPA
is
proposing
temperature
criteria
to
protect
salmon
and
bull
trout
life
stages
in
Oregon
waters,
an
intergravel
dissolved
oxygen
criterion
that
protects
salmonid
spawning,
and
the
locations
and
times
of
year
(
i.
e.,
"
when
and
where")
that
salmon
and
bull
trout
life
stages
occur
in
Oregon
waters.
Exhibit
ES­
1
shows
EPA's
proposed
salmonid
and
bull
trout
criteria
and
provides
the
State's
current
criteria
for
comparison.

Exhibit
ES­
1.
Comparison
of
Current
Oregon
and
Proposed
EPA
Criteria
Designated
Use
Oregon
Criteria
Proposed
EPA
Criteria1
Bull
Trout
Protection
10

C
12

C
spawning
and
rearing;
16

C
migration
Exhibit
ES­
1.
Comparison
of
Current
Oregon
and
Proposed
EPA
Criteria
Designated
Use
Oregon
Criteria
Proposed
EPA
Criteria1
September
2003
Executive
Summary
ES
 
2
Salmonid
Rearing
17.8

C
18

C;
16

C
core
juvenile
rearing
Salmonid
Spawning
12.8

C
6
mg/
L
IGDO
(
minimum)
13

C
8
mg/
L
IGDO
(
minimum)

Salmonid
Migration
none
20

C
1.
EPA
is
also
proposing
a
9

C
spawning
criterion
for
bull
trout
protection
on
a
limited
number
of
stream
segments
that
are
downstream
of
a
man­
made
reservoir.

EPA's
proposed
rule
also
establishes
implementation
procedures
for
providing
three
levels
of
water
quality
protection
under
the
State's
antidegradation
policy.
Under
these
procedures,
the
quality
of
high­
quality
waters
is
to
be
maintained
and
protected
unless
the
State
finds,
after
public
participation
and
intergovernmental
review,
that
allowing
lower
water
quality
is
necessary
to
accommodate
important
economic
or
social
development
in
the
area
in
which
the
waters
are
located.

The
water
quality
criteria
and
uses
in
EPA's
proposed
rule
may
affect
facilities
discharging
to
affected
waters.
EPA
assumed
that
only
facilities
that
discharge
to
rivers
and
streams
with
new
or
more
stringent
uses
and
criteria
may
be
affected
by
the
water
quality
criteria
and
designated
uses
provisions.
(
EPA
also
assumed
that
facilities
discharging
directly
to
the
Columbia
River
and
the
Pacific
Ocean
are
not
affected
by
this
proposed
rule,
except
for
portions
of
the
Columbia
River
where
spawning
occurs
that
would
be
affected
for
IGDO.)
For
IGDO,
the
current
criterion
of
6
mg/
L
is
less
stringent
than
the
revised
IGDO
criterion
of
8
mg/
L.
Therefore,
all
waters
designated
for
salmonid
spawning
are
potentially
affected
by
the
IGDO
provision
of
the
proposed
rule,
and
facilities
discharging
to
these
waters
are
included
in
the
set
of
potentially
affected
dischargers.

For
temperature,
the
State's
current
temperature
criteria
for
salmonid
rearing
is
17.8

C,
with
no
differentiation
for
core
juvenile
rearing.
The
proposed
rule
establishes
a
16

C
temperature
criterion
for
core
juvenile
rearing
(
and
18

C
otherwise
for
rearing).
Therefore,
EPA's
proposed
rule
provides
a
more
stringent
criterion
for
waters
it
designates
for
core
juvenile
rearing
(
16

C),
and
facilities
discharging
to
these
waters
may
be
affected.
For
salmonid
spawning,
the
current
State
criterion
of
12.8

C
is
slightly
more
stringent
than
EPA's
proposed
criterion
of
13

C.
However,
the
time
period
that
the
criterion
applies
may
differ
under
the
proposed
rule.
Therefore,
EPA
assumed
that
any
waters
for
which
it
is
designating
a
salmonid
spawning
period
that
is
earlier
or
later
than
currently
designated
by
the
State
(
e.
g.,
current
designation
from
October
1
to
May
31,
versus
a
proposed
designation
from
September
1
to
June
30)
would
be
affected
because
EPA's
criterion
would
apply
during
the
extended
time
period.
Facilities
discharging
to
these
waters
may
be
impacted.

For
antidegradation,
EPA
assumed
that
facilities
discharging
to
streams
not
listed
by
the
State
as
impaired
waters
(
i.
e.,
not
on
the
303(
d)
list)
are
affected.
Although
high­
quality
waters
are
not
yet
identified
by
the
State,
the
unimpaired
waters
provide
a
reasonable
approximation
of
high­
September
2003
Executive
Summary
ES
 
3
quality
waters
(
although
some
portion
of
these
will
be
ONWRs
and
not
affected
by
the
procedures
because
no
lowering
of
water
quality
is
allowed
for
ONWRs).

Temperature
Criteria
and
Uses
EPA
identified
a
total
of
48
facilities
(
4
majors
and
44
minors)
that
may
be
potentially
affected
by
the
proposed
uses
and
temperature
criteria.
EPA
evaluated
all
four
major
facilities
and
a
sample
of
minor
facilities
from
this
group
for
potential
cost
impacts
associated
with
the
proposed
rule.
For
each
facility
EPA
reviewed
discharge
monitoring
and
receiving
water
data
to
calculate
the
downstream
temperature
at
the
edge
of
the
regulatory
mixing
zone
(
RMZ)
because
Oregon's
current
WQS
state
that
a
discharge
may
not
cause
an
increase
in
the
surface
water
temperature
of
greater
than
0.14

C
in
waters
exceeding
the
applicable
criterion
[
OAR
340­
041­
0205
(
b)(
A)].
Therefore,
EPA
assumed
that
any
discharge
that
results
in
a
downstream
temperature
greater
than
0.14

C
above
the
applicable
criterion
would
require
additional
controls;
however,
this
is
a
conservative
assumption
with
respect
to
estimating
costs
(
i.
e.,
erring
on
the
side
of
higher
costs)
because
EPA's
proposed
rule
allows
an
increment
of
0.3

C
above
the
applicable
criterion.
Based
on
the
temperature
reductions
needed
for
compliance
with
the
proposed
criteria,
EPA
determined
the
necessary
controls
on
point
sources
to
reduce
effluent
temperatures.
For
minor
facilities,
EPA
extrapolated
sample
facility
costs
to
the
universe
of
potentially
affected
minor
facilities.
Total
potential
annual
costs
associated
with
the
temperature
provision
of
the
proposed
rule
are
$
198,920.

IGDO
Criteria
EPA
identified
a
total
of
192
facilities
(
43
major
and
149
minor)
that
may
potentially
be
affected
by
the
proposed
IGDO
criteria.
There
are
no
IGDO
data
available
for
any
of
the
affected
waters,
primarily
because
methods
to
measure
IGDO
have
only
recently
been
developed.
Therefore,
EPA
estimated
compliance
with
current
and
proposed
IGDO
criteria
based
on
an
estimated
3
mg/
L
differential
between
the
IGDO
and
dissolved
oxygen
(
DO)
in
the
overlying
water
[
based
on
EPA
(
1986)].
Using
this
differential,
the
current
Oregon
IGDO
criterion
of
6
mg/
L
corresponds
to
a
minimum
instream
DO
concentration
of
9
mg/
L,
and
the
EPA
IGDO
criterion
of
8
mg/
L
corresponds
to
a
minimum
instream
DO
concentration
of
11
mg/
L
(
U.
S.
EPA,
1986).

Current
Oregon
WQS
specify
a
minimum
water
column
DO
criterion
for
spawning
waters,
as
well
as
minimum
IGDO
criteria.
The
minimum
water
column
DO
for
protection
of
salmonid
spawning
is
11.0
mg/
L,
unless
the
minimum
IGDO
(
measured
as
a
spatial
median)
is
8
mg/
L,
then
the
minimum
DO
may
be
9
mg/
L,
or
conditions
of
barometric
pressure,
altitude,
and
temperature
preclude
attainment
of
11
or
9
mg/
L
standards,
then
the
minimum
DO
may
be
95%
of
saturation.

EPA's
proposed
rule
would
only
change
the
IGDO
criterion,
and
would
not
change
Oregon's
11
mg/
L
(
or
9
mg/
L)
instream
DO
criteria.
Thus,
if
a
stream
is
meeting
the
current
State
instream
WQS,
based
on
EPA
(
1986)
the
stream
would
also
meet
the
EPA's
proposed
IGDO
criterion,
and
no
costs
would
be
incurred
as
a
result
of
this
part
of
the
proposed
rule.
If
a
stream
is
not
meeting
the
current
WQS,
the
costs
of
attaining
compliance
would
be
associated
with
existing
Oregon
WQS,
not
as
a
result
of
the
proposed
rule.
Therefore,
EPA
estimated
the
cost
of
this
provision
to
be
zero.
September
2003
Executive
Summary
ES
 
4
Antidegradation
Procedures
EPA
estimated
that
152
facilities
(
22
major
and
130
minor)
may
discharge
to
high­
quality
waters.
NPDES
permits
are
issued
for
a
period
of
five
years,
after
which
they
must
be
renewed.
Therefore,
over
any
5
year
period,
all
152
existing
permit
holders
will
renew
their
permits.
Since
the
State
began
implementing
its
antidegradation
review
procedures,
few
facilities
have
requested
an
increase
in
discharge
to
a
high­
quality
water
such
that
an
antidegradation
review
was
required.
Based
on
the
frequency
of
past
reviews,
EPA
assumed
that
no
more
than
5%
of
facilities
that
discharge
to
high­
quality
waters
would
request
more
than
a
de
minimis
increase
in
loadings
when
they
renew
their
permit.
Thus,
of
the
152
permit
renewals
processed
over
any
5
year
period,
approximately
8
facilities
(
1
major
POTW,
1
major
industrial
facility,
3
minor
POTWs,
and
3
minor
industrial
facilities)
may
require
an
antidegradation
analysis.
However,
this
is
a
conservative
assumption
with
respect
to
estimating
cost
(
i.
e.,
erring
on
the
side
of
higher
costs)
because
it
implies,
as
a
baseline,
that
the
State
is
not
currently
implementing
its
antidegradation
policy
and
implementation
procedures,
when
in
fact
it
is.

To
estimate
the
potential
costs
of
completing
an
antidegradation
review,
EPA
first
calculated
the
average
capital
costs
to
facilities
it
identified
as
requiring
additional
controls
in
economic
analyses
of
recent
water
quality
standards
actions,
including
establishing
criteria
for
toxic
pollutants
and
upgrading
receiving
water
use
classifications
in
the
States
of
Alabama,
Iowa,
California,
and
Idaho
(
U.
S.
EPA,
2001a;
2001b;
1999;
and
1997).
EPA's
estimates
of
capital
costs
for
these
facilities
average
$
1
million
for
major
POTWs,
$
230,000
for
minor
POTWs,
$
2.4
million
for
major
industrial
facilities,
and
$
1
million
for
minor
industrial
facilities.
Thus,
preliminary
engineering
analysis
and
financial
analysis
costs
could
range
between
$
10,000
and
$
72,000
for
major
facilities,
and
between
$
2,300
and
$
30,000
for
minor
facilities.

Multiplying
the
potential
number
of
affected
facilities
with
the
estimated
per­
facility
analysis
costs
provides
an
estimate
of
the
potential
costs
of
the
antidegradation
provision
to
dischargers
in
the
State.
The
average
annual
cost
is
one­
fifth
of
the
5­
year
estimates,
or
$
14,180
to
$
42,540.
The
State
cost
to
review
8
antidegradation
requests
over
5
years
is
$
41,600,
based
on
EPA's
estimate
of
an
average
of
$
5,200
per
review.
The
average
annual
cost
is
one­
fifth
this
amount,
or
$
8,320.
The
total
annual
cost
for
the
antidegradation
provision
in
the
proposed
rule
equals
the
sum
of
the
entity
costs
(
ranging
from
$
14,180
to
$
42,540)
and
State
review
costs
($
8,320).
Thus,
potential
total
annual
cost
ranges
from
$
22,500
to
$
50,860.

Total
Statewide
Costs
EPA's
total
potential
Statewide
cost
of
the
proposed
rule
is
approximately
$
216,230
to
$
244,590
per
year
(
Exhibit
ES­
2).

Exhibit
ES­
2.
Estimated
Potential
Annual
Statewide
Costs
Attributable
to
the
Proposed
Rule
($
2003/
yr)

Provision
Estimated
Annual
Cost
Temperature
Uses
and
Criteria1
$
198,920
IGDO
Criteria
$
0
Exhibit
ES­
2.
Estimated
Potential
Annual
Statewide
Costs
Attributable
to
the
Proposed
Rule
($
2003/
yr)

Provision
Estimated
Annual
Cost
September
2003
Executive
Summary
ES
 
5
Antidegradation
Procedures2
$
22,500
­
$
50,860
Total
$
221,420
­
$
249,780
1.
Costs
are
annualized
at
7%
over
20
years.
2.
Costs
equal
one­
fifth
of
cost
estimates
calculated
for
a
five­
year
period.
September
2003
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
Oregon.
This
report
presents
EPA's
analysis
of
potential
costs
associated
with
the
proposed
rule.
Specifically,
the
report
provides
estimates
of
potential
incremental
costs
that
direct
point
source
dischargers
may
experience
as
a
result
of
the
proposed
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'
water
quality
standards
must
include
at
a
minimum:
(
1)
designated
uses
for
all
water
bodies
within
their
jurisdictions,
(
2)
water
quality
criteria
sufficient
to
protect
the
most
sensitive
of
the
uses,
and
(
3)
an
antidegradation
policy
consistent
with
the
regulations
at
40
CFR
131.12.
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
directs
the
EPA
Administrator
to
promulgate
WQS
to
supersede
State
standards
that
have
been
disapproved
or
in
cases
where
the
Administrator
determines
that
a
new
or
revised
standard
is
needed
to
meet
the
CWA's
requirements.

With
respect
to
antidegradation,
EPA
requires
that
States
identify
implementation
procedures
to
provide
three
levels
of
water
quality
protection
under
their
policy.
The
first
level
of
protection
at
40
CFR
131.12(
a)(
1)
requires
the
maintenance
and
protection
of
existing
in­
stream
water
uses,
and
the
level
of
water
quality
necessary
to
protect
these
existing
uses
(
i.
e.,
those
uses
actually
attained
on
or
after
November
28,
1975).
The
second
level
of
protection
is
for
high­
quality
waters,
defined
in
40
CFR
131.12(
a)(
2)
as
waters
where
the
quality
of
the
water
exceeds
levels
necessary
to
support
the
propagation
of
fish,
shellfish,
and
wildlife,
and
recreation
in
and
on
the
water.
The
quality
of
high­
quality
waters
is
to
be
maintained
and
protected
unless
the
State
finds,
after
public
participation
and
intergovernmental
review,
that
allowing
lower
water
quality
is
necessary
to
accommodate
important
economic
or
social
development
in
the
area
in
which
the
waters
are
located.
Finally,
EPA
designates
the
third
and
highest
level
of
protection
for
Outstanding
National
Resource
Waters
(
ONRWs).
If
an
authorized
entity
determines
that
the
characteristics
of
a
water
body
constitute
an
outstanding
National
resource,
such
as
waters
of
National
and
State
parks,
wildlife
refuges,
and
waters
of
exceptional
recreational
or
ecological
significance,
those
characteristics
must
be
maintained
and
protected
(
see
40
CFR
131.12(
a)(
3)).

On
July
23,
1996,
the
State
of
Oregon
submitted
revisions
to
its
water
quality
standards
to
EPA
for
review,
and
approval
or
disapproval,
pursuant
to
CWA
section
303(
c)(
2)(
A).
Certain
of
these
revisions
identified
specific
numeric
temperature
criteria
to
protect
critical
life
stages
of
salmonids,
including
criteria
for
salmonid
rearing,
spawning,
bull
trout
rearing
and
spawning,
and
intergravel
dissolved
oxygen
(
IGDO)
to
protect
salmonid
incubation
and
fry
emergence.
Oregon
also
revised
the
temperature
criteria
for
salmonid
rearing
in
the
Lower
Willamette
River
from
September
2003
1.0
Introduction
1
 
2
70

F
(
21

C)
to
68

F
(
20

C).
In
addition,
Oregon
adopted
new
or
revised
narrative
criteria
and
other
provisions
establishing
a
process
for
adopting
site
specific
numeric
criteria
or
temporary
revisions
to
its
standards.

On
September
15,
1998,
prior
to
approving
or
disapproving
the
submitted
standards
revisions,
EPA
entered
into
formal
consultation
under
Section
7(
a)(
2)
of
the
Endangered
Species
Act
(
ESA)
with
both
the
National
Marine
Fisheries
Service
(
NMFS)
and
Fish
and
Wildlife
Service
(
FWS)
in
regard
to
listed
and
endangered
species
including
chinook,
coho,
sockeye,
chum,
coastal
cutthroat,
steelhead,
and
bull
trout.
On
July
1,
1999,
the
FWS
issued
a
biological
opinion
that
EPA's
approval
of
the
standards
revisions
was
not
likely
to
jeopardize
the
continued
existence
of
listed
threatened
and
endangered
species,
including
bull
trout.
On
July
7,
1999,
NMFS
issued
a
biological
opinion
that
EPA's
approval
of
the
standards
revisions
was
not
likely
to
jeopardize
the
continued
existence
of
listed
threatened
and
endangered
species,
including
Snake
River
sockeye
salmon,
Upper
Columbia
River
spring
chinook
salmon,
Upper
Columbia
River
steelhead,
Snake
River
spring/
summer
chinook
salmon,
Snake
River
fall
chinook
salmon,
Upper
Willamette
River
chinook
salmon,
Lower
Columbia
River
chinook
salmon,
Southern
Oregon/
California
Coastal
chinook
salmon,
Oregon
Coast
coho
salmon,
Southern
Oregon/
Northern
California
coho
salmon,
Snake
River
Basin
steelhead
trout,
Middle
and
Lower
Columbia
steelhead
trout,
Upper
Willamette
steelhead
trout,
Oregon
Coast
steelhead
trout,
Klamath
Mountains
Provice
steelhead
trout,
Columbia
River
chum
salmon,
Umpqua
River
sea­
run
cutthroat
trout,
southwestern
Washington/
Columbia
River
coastal
cutthroat
trout,
Columbia
River
Basin
bull
trout,
and
Klamath
River
Basin
bull
trout.
As
a
result
of
the
consultation,
EPA
and
the
State
of
Oregon
also
committed
to
perform
specific
conservation
measures
under
Section
7(
a)(
1)
of
the
ESA.
These
measures
were
designed
to
address
concerns
over
the
implementation
of
Oregon's
water
quality
standards,
and
also
to
further
investigate
uncertainties
regarding
the
water
temperatures
necessary
to
protect
specific
life
stages
of
endangered
species.

On
July
22,
1999,
EPA
approved
the
majority
of
the
revised
standards
submitted
by
Oregon,
including
approvals
of
the
temperature
and
dissolved
oxygen
standards.
EPA
disapproved
the
68

F
(
20

C)
numeric
criteria
for
salmonid
rearing
in
the
Lower
Willamette
River
because
it
did
not
include
a
justification
for
how
the
criterion
would
protect
salmonid
rearing
given
that
elsewhere
salmonid
rearing
was
protected
with
a
64

F
(
17.8

C)
criterion.
Furthermore,
EPA's
own
technical
analysis
of
the
criterion
showed
significant
adverse
impacts
to
salmonids.
EPA
took
no
action
with
respect
to
Oregon's
existing
water
quality
criteria
for
the
Columbia
River
or
its
antidegradation
implementation
plan
because
Oregon
had
not
submitted
new
or
revised
standards
in
1996
on
either
issue.

During
their
consultation,
EPA,
NMFS,
FWS,
and
others
found
that
there
was
some
scientific
uncertainty
regarding
the
precise
effects
of
various
temperature
regimes
on
the
life
stages
of
threatened
and
endangered
salmonids.
Therefore,
one
of
the
conservation
measures
specified
in
the
biological
opinion
required
EPA
to
establish
and
lead
a
region­
wide
effort
to
conduct
a
comprehensive
review
of
the
temperature
requirements
of
critical
life
stages
of
salmonids
in
the
Pacific
Northwest,
and
ultimately
to
issue
guidance
recommending
temperature
criteria
for
their
protection
that
could
be
used
as
a
basis
for
further
revision
of
Oregon's
standards
if
warranted.
The
resulting
two
and
one­
half
year
effort
concluded
in
April
2003
with
the
issuance
of
the
EPA
September
2003
1.0
Introduction
1
 
3
Region
10
Guidance
for
Pacific
Northwest
State
and
Tribal
Temperature
Water
Quality
Standards.

Both
EPA's
approval
action
and
NMFS
Biological
Opinion
of
"
no
jeopardy"
were
challenged
in
2001
by
Northwest
Environmental
Advocates.
The
plaintiff
also
alleged
that
EPA
had
a
nondiscretionary
duty
to
promulgate
Federal
water
quality
criteria
for
the
lower
Willamette
River
and
the
Columbia
River
and
to
promulgate
an
implementation
plan
for
Oregon's
antidegradation
policy.

On
March
31,
2003,
the
U.
S.
District
Court
for
the
District
of
Oregon
ruled
in
Northwest
Environmental
Advocates
v.
EPA
&
NMFS
(
No.
CV­
01­
510­
HA)
that
EPA
had
violated
the
CWA
and
the
ESA
when
it
approved
certain
water
quality
standards
for
the
protection
of
salmonids
that
were
contained
in
Oregon's
1996
submission.
Although
the
Court
deferred
to
EPA's
scientific
judgment
regarding
the
protectiveness
of
the
specific
numeric
temperatures,
the
Court
found
that
these
criteria
violated
EPA's
regulations
because
Oregon
had
failed
to
designate
when
and
where
these
criteria
would
apply.
The
Court
invalidated
EPA's
decision
to
approve
the
criteria
because
the
absence
of
such
"
time
and
place"
designations
failed
to
protect
the
use
categories
created
by
Oregon,
in
this
case
salmonid
rearing
and
bull
trout
rearing
and
spawning.
The
Court
directed
EPA
to
promulgate
new
temperature
water
quality
criteria
to
address
this
deficiency.

For
similar
reasons,
the
Court
also
vacated
EPA's
approval
of
a
water
quality
criterion
for
intergravel
dissolved
oxygen.
For
this
criterion,
the
Court
found
that
the
6
mg/
l
adopted
by
Oregon
would
not
adequately
protect
threatened
and
endangered
salmonid
species,
and
ordered
EPA
to
promulgate
new
water
quality
criteria
for
this
pollutant
parameter.
The
Court
also
ordered
EPA
to
promulgate
an
antidegradation
implementation
plan
for
Oregon
waters.
Finally,
the
Court
vacated
NMFS'
finding
of
"
no
jeopardy"
in
connection
with
EPA's
approval
of
these
standards,
and
ruled
that
EPA
had
violated
the
ESA
by
relying
on
NMFS's
erroneous
"
no
jeopardy"
finding.
EPA's
proposed
rule
addresses
the
Court's
rulings.

The
District
Court
ruled
in
favor
of
EPA
on
the
Plaintiff's
challenge
to
EPA's
failure
to
establish
Federal
water
quality
criteria
for
temperature
for
the
Columbia
River.
EPA
also
successfully
defended
its
decision
to
approve
certain
narrative
water
quality
criteria.
Finally,
the
Court
agreed
that
EPA
had
met
its
obligations
under
ESA
7(
a)(
1)
to
implement
programs
to
conserve
threatened
salmon.

1.2
Purpose
of
the
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.
1
Agricultural,
forestry­
related,
and
other
nonpoint
source
discharges,
as
well
as
storm
water
discharges,
are
technically
difficult
to
model
and
evaluate
for
potential
cost
impacts
because
they
are
intermittent,
highly
variable,
and
occur
under
different
hydrologic
or
climatic
conditions
than
continuous
discharges
from
industrial
and
municipal
facilities.

September
2003
1.0
Introduction
1
 
4
EPA's
proposed
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.
In
addition,
EPA
does
not
anticipate
an
annual
effect
on
the
economy
of
$
100
million
or
more.
Nonetheless,
consistent
with
the
intent
of
EO
12866,
EPA
typically
estimates
(
within
the
limits
of
these
uncertainties)
the
potential
costs
to
NPDES­
permitted
facilities,
and
the
associated
pollutant
reductions,
that
ultimately
may
result
from
its
water
quality
standards
rules
to
inform
the
public
regarding
these
potential
impacts.

1.3
Scope
of
the
Analysis
EPA's
analysis
addresses
NPDES
permitted
facilities
discharging
to
stream
segments
affected
by
the
proposed
rule.
The
types
of
affected
facilities
may
include
industries
and
publicly
owned
treatment
works
(
POTWs)
discharging
to
surface
waters
in
the
State
(
i.
e.,
point
sources).
Indirect
dischargers
to
POTWs
may
also
be
affected
as
a
result
of
tighter
controls
on
POTWs.
EPA
did
not
consider
the
potential
costs
for
sources
that
it
does
not
have
direct
authority
to
regulate
through
the
NPDES
program
(
i.
e.,
nonpoint
sources,
such
as
agricultural
and
forestry­
related
nonpoint
sources).
However,
EPA
recognizes
that
the
State
of
Oregon
regulates
forestry
and
agricultural
sources
through
its
Forest
Practices
Act
and
Agricultural
Water
Quality
Management
Program.
1
1.4
Organization
of
the
Report
This
report
is
organized
as
follows.
Section
2
outlines
the
baseline
for
the
analysis
by
describing
the
current
State
designated
uses
and
criteria.
Section
3
provides
a
description
of
the
proposed
rule
and
shows
the
potentially
affected
waters
and
point
source
dischargers.
Section
4
summarizes
the
method
for
estimating
costs,
and
Section
5
presents
the
results
of
the
analysis.
The
appendix
provides
detailed
analyses
for
the
derivation
of
costs
for
the
sample
facilities.
September
2003
2.0
Baseline
for
the
Analysis
2
 
1
2.0
Baseline
for
the
Analysis
The
section
describes
the
baseline
conditions
relevant
to
evaluating
the
potential
impact
of
EPA's
proposed
rule.
In
evaluating
this
impact,
EPA
calculated
the
incremental
costs
of
the
rule's
provisions
(
e.
g.,
the
cost
of
reducing
effluent
temperatures
based
on
current
State
standards
and
implementation
procedures
to
temperatures
that
would
be
required
under
EPA's
proposed
new
or
more
stringent
standards
and
implementation
procedures).
Thus,
this
section
describes
baseline
conditions
including
current
State
standards
and
implementation
procedures,
and
existing
dischargers
in
the
State.

2.1
Water
Quality
Standards
Exhibit
2­
1
summarizes
the
State's
current
criteria
for
waters
designated
for
the
protection
of
salmonid
and
bull
trout
spawning
and
rearing.
Oregon
WQS
(
OAR
340­
041­
0202
through
340­
041­
0962)
specify
that
the
criteria
shown
in
Exhibit
2­
1
apply
to
waters
identified
by
the
Oregon
Department
of
Environmental
Quality
(
ODEQ)
as
supporting
the
different
designated
uses.

Exhibit
2­
1.
Oregon
Water
Quality
Criteria
for
Temperature
and
IGDO
Parameter/
Use
Current
Oregon
Criteria
Temperature:
Bull
Trout
(
includes
spawning,
rearing,
and
migration)
50
°
F
(
10
°
C)

Temperature:
Salmonid
Spawning
55
°
F
(
12.8
°
C)

Temperature:
Salmonid
Rearing
64
°
F
(
17.8
°
C)

Temperature:
Lower
Willamette
68
°
F
(
20
°
C)

Intergravel
Dissolved
Oxygen
(
IGDO):
Salmonid
Spawning
6
mg/
L
2.1.1
Temperature
Criteria
Oregon's
WQS
include
temperature
criteria
for
the
protection
of
salmonid
spawning
and
rearing.
For
salmonid
spawning,
the
standards
specify
that
no
measurable
surface
water
temperature
increase
exceeding
55

F
(
12.8

C)
is
allowed
as
a
result
of
anthropogenic
activities
in
waters
determined
by
ODEQ
to
support
native
salmonid
spawning,
egg
incubation,
and
fry
emergence
from
eggs
and
from
gravels.
For
salmonid
rearing,
no
measurable
temperature
increase
exceeding
64

F
(
17.8

C)
is
allowed
in
a
basin
for
which
salmonid
rearing
is
a
designated
use.
A
measurable
temperature
increase
refers
to
an
increase
greater
than
0.25

F
(
0.14

C)
at
the
edge
of
the
regulatory
mixing
zone.

Current
WQS
also
specify
a
temperature
criterion
for
the
protection
of
bull
trout
habitat
(
i.
e.,
spawning,
rearing,
and
migration).
The
temperature
of
waters
identified
by
ODEQ
as
supporting
or
maintaining
the
viability
of
bull
trout
should
not
exceed
50

F
(
10

C)
at
any
time
during
the
year.
September
2003
2.0
Baseline
for
the
Analysis
2
 
2
2.1.2
IGDO
Criteria
Oregon's
current
WQS
for
salmonid
spawning
specify
an
absolute
minimum
criterion
for
IGDO
of
6
mg/
L.
Note
that
Oregon
uses
an
IGDO
concentration
of
less
than
8
mg/
L
to
identify
waters
that
may
be
impaired.
For
these
waters,
ODEQ
may
include
the
waters
on
the
State
303(
d)
list,
initiate
pollution
control
measures,
or
where
necessary,
implement
specific
best
management
practices
for
control
of
nonpoint
sources.

2.1.3
Beneficial
Use
Designations
Exhibit
2­
2
summarizes
the
current
designated
uses
for
each
basin
based
on
the
designated
use
tables
in
the
State's
WQS
and
a
1998
letter
from
ODEQ
to
EPA
Region
10
indicating
when
and
where
salmonid
spawning
and
rearing
apply.

Exhibit
2­
2.
Oregon
Designated
Uses
(
and
Temperature
Criteria1)
for
Salmonid
Habitat
Basin
Salmonid
Spawning
(
12.8
°
C)
(
Spawning
Time
Period)
Salmonid
Rearing
(
17.8
°
C)
2
Bull
Trout
(
10
°
C)
3
North
Coast

(
Sep
15­
May
31)

Mid
Coast

(
Sep
15­
May
31)

South
Coast

(
Oct
1­
May
31)

Umpqua
­
Umpqua
R.
Estuary
to
Head
of
Tidewater

­
Head
of
Tidewater
to
confluence
of
N.
and
S.
Umpqua
Rivers

(
Sep
15­
May
31)

­
N.
Umpqua
River
Mainstem

(
Sep
15­
May
31)

­
S.
Umpqua
River
Mainstem

(
Sep
15­
May
31)

­
All
other
tributaries
to
Umpqua,
N.
and
S.
Umpqua
Rivers

(
Sep
15­
May
31)

Rogue
­
Rogue
River
Estuary

­
Rogue
River
Estuary
to
Lost
Creek
Dam

(
Oct
1­
May
31)

­
Rogue
River
Mainstem
above
Lost
Dam
and
Tributaries

(
Oct
1­
May
31)

­
Bear
Creek
Mainstem

(
Oct
1­
May
31)

­
All
other
tributaries
to
Rogue
River
and
Bear
Creek

(
Oct
1­
May
31)

Willamette
­
Mouth
of
Willamette
to
Newberg

4
­
Willamette
River,
Newberg
to
Coast
Fork

(
Oct
1­
May
31)

­
Clackamas
R.,
Santiam
R.,
McKenzie
R.,
Molalla
R.,
Tualatin
R.,
and
all
other
streams
and
tributaries

(
Sep
15­
Jun
30)


­
Other
ecoregions

(
Oct
1­
May
31)


­
Mainstem
Columbia
R.
(
RM
86
to
120)

(
Oct
1­
May
31)

Sandy
­
Streams
forming
waterfalls
near
Columbia
River
Hwy

(
Sep
15­
Jun
30)

Exhibit
2­
2.
Oregon
Designated
Uses
(
and
Temperature
Criteria1)
for
Salmonid
Habitat
Basin
Salmonid
Spawning
(
12.8
°
C)
(
Spawning
Time
Period)
Salmonid
Rearing
(
17.8
°
C)
2
Bull
Trout
(
10
°
C)
3
September
2003
2.0
Baseline
for
the
Analysis
2
 
3
­
Sandy
River

(
Sep
15­
Jun
30)

­
Bull
Run
River
and
all
tributaries

(
Sep
15­
Jun
30)

­
all
other
tributaries
to
Sandy
River

­
Columbia
River
(
RM
120
to
147)

Hood
­
Columbia
River
(
RM
147
to
203)

­
Mainstem
Hood
River
to
Powderdale
Dam

(
Sep
15­
Feb
15)

­
Mainstem
Hood
R.
upstream
of
Powderdale
Dam
to
confluence
with
M.
and
E.
Fork

(
Sep
1­
Jul
15)

­
Middle
Fork
Hood
River

(
All
Year)


­
West
Fork
Hood
River

(
All
Year)

­
E.
Fork
Hood
R.
downstream
of
confluence
with
Emil
Cr,
Neal
Cr,
and
Whiskey
Cr

(
Sep
15­
Jul
15)

­
E.
Fork
Hood
R.
upstream
of
confluence
with
Emil
Creek

(
Sep
15­
Aug
31)

­
Miles
Creek
drainage

(
Oct
1­
Jun
30)

Deschutes
­
Columbia
River
(
RM
203
to
218)

­
Deschutes
River
and
east
side
tributaries

(
Oct
1­
June
30)


­
Deschutes
River
and
West
side
tributaries

(
Sep
1­
Jun
30)


John
Day
­
N.
Fork
John
Day
R.
upstream
to
Camas
Creek
and
Mouth
Middle
Fork
John
Day
R.
upstream
to
US
Highway
395

(
Mar
1­
Jul
15)


­
N.
Fork
John
Day
R.
above
Camas
Creek
and
Middle
Fork
John
Day
R.
above
US
Highway
395

(
Aug
15­
Jul
15)


­
All
other
tributaries

(
Oct
1­
Jun
30)


Umatilla
­
Umatilla
Subbasin

(
Oct
1­
Jun
30)


­
Willow
Creek
Subbasin

(
Oct
1­
Jun
30)


­
Columbia
River
(
RM
247
to
309)

(
Oct
1­
May
31)


Walla
Walla

(
Oct
1­
Jun
30)


Grande
Ronde
­
Imnaha
River
upstream
of
confluence
with
Big
Sheep
Cr

(
Oct
15­
Jul
15)


­
Imnaha
River
above
and
including
Big
Sheep
Creek

(
Aug
1­
Jul
15)


­
Mainstem
Snake
River
(
RM
176
to
260)

(
Oct
1­
June
30)

­
Mainstem
Grande
Ronde
River
(
RM
39
to
165)

(
Oct
1­
June
30)


­
All
other
basin
waters

(
Oct
1­
Jun
30)


Powder

(
Mar
1­
Jun
30)


Exhibit
2­
2.
Oregon
Designated
Uses
(
and
Temperature
Criteria1)
for
Salmonid
Habitat
Basin
Salmonid
Spawning
(
12.8
°
C)
(
Spawning
Time
Period)
Salmonid
Rearing
(
17.8
°
C)
2
Bull
Trout
(
10
°
C)
3
September
2003
2.0
Baseline
for
the
Analysis
2
 
4
­
Mainstem
Snake
River
(
RM
260
to
335)

(
Oct
1­
June
30)

­
All
other
basin
waters

(
Mar
1­
Jun
30)


Malheur
River
­
Malheur
R
(
Namorf
to
Mouth)/
Willow
Creek
(
Brogan
to
Mouth)/
Bully
Creek
(
Reservoir
to
Mouth)

­
Willow
Creek
(
Malhuer
Reservoir
to
Brogan)/
Malheur
R.
(
Beulah
Dam
and
Warm
Springs
Dam
to
Namorf)

(
Mar
1­
Jun
30)


­
Reservoirs

­
Malhuer
River
and
Tributaries
Upstream
of
Reservoirs

(
Mar
1­
Jun
30)


­
Snake
River
(
RM
335
to
395)

(
Oct
1­
Jun
30)

Owyhee
­
Snake
River
(
RM
295
to
409)

(
Oct
1­
Jun
30)

­
Owyhee
River
(
RM
0
to
18)

­
Reservoirs

5
­
Owyhee
River
(
RM
18
to
Dam),
Tributaries
Upstream
from
Owyhee
Reservoir,
and
Designated
Scenic
Waterway

5
(
Mar
1­
Jun
30)

5
Malheur
Lake
­
Natural
Lakes
­
All
Rivers
and
Tributaries

5
(
Mar
1­
Jun
30)

5
Goose
and
Summer
Lakes
­
Goose
Lake

5
­
Fresh
water
lakes,
reservoirs,
and
streams

5
(
Mar
1­
Jun
30)

5
­
Highly
alkaline
and
saline
lakes
Klamath
­
Klamath
R.
from
Klamath
Lake
to
Keno
Dam
and
Lost
R.
(
RM
5
to
65)
and
Lost
R.
Diversion
Channel
­
All
other
basin
waters

5
(
Mar
1­
Jun
30)

5

Source:
ODEQ
Water
Quality
Standards
Designated
Use
Tables,
Letter
from
ODEQ
to
EPA
Region
10
(
June
22,
1998)
1.
Criteria
apply
only
to
waters
where
use
occurs.
2.
Criterion
applies
all
year
round
unless
a
more
stringent
criterion
applies
for
part
of
the
year
or
the
waters
are
designated
for
bull
trout.
3.
Criterion
applies
all
year
round
for
protection
of
bull
trout
spawning,
rearing,
and
migration.
4.
This
section
of
the
basin
is
only
required
to
achieve
68

F.
5.
Salmon
and
steelhead
species
are
not
present.

Exhibits
2­
3
and
2­
4
show
the
waters
that
the
State
currently
designates
for
salmonid
rearing
and
spawning
and
bull
trout
use
protection
as
provided
in
Exhibit
2­
2.
September
2003
2.0
Baseline
for
the
Analysis
2
 
5
Exhibit
2­
3.
Waters
Designated
by
the
State
of
Oregon
for
Salmonid
Rearing
and
Bull
Trout
Protection
Exhibit
2­
4.
Waters
Designated
by
the
State
of
Oregon
for
Salmonid
and
Bull
Trout
Spawning
September
2003
2.0
Baseline
for
the
Analysis
2
 
6
Exhibit
2­
5.
NPDES
Permitted
Facilities
in
Oregon
2.1.4
Antidegradation
Policy
Oregon's
WQS
contain
an
Antidegradation
Policy
"...
to
guide
decisions
that
affect
water
quality
such
that
unnecessary
degradation
from
point
and
nonpoint
sources
of
pollution
is
prevented,
and
to
protect,
maintain,
and
enhance
existing
surface
water
quality
to
protect
all
existing
beneficial
uses"
(
OAR
340­
041­
0026).
This
policy
simply
states
that
the
State's
WQS
(
the
standards
and
policies
set
forth
in
OAR
340­
041­
0120
through
340­
041­
0962)
are
intended
to
implement
the
Antidegradation
Policy.

The
Court
found
this
policy
to
be
vague,
that
is,
that
the
State
is
lacking
implementation
procedures.
The
State
adopted
antidegradation
implementation
procedures
in
2001,
and
is
currently
implementing
its
antidegradation
policy
based
on
those
procedures.
EPA
identified
a
few
antidegradation
reviews
that
have
been
submitted
by
dischargers
and
reviewed
by
the
State.

2.3
Point
Source
Dischargers
EPA's
Permit
Compliance
System
(
PCS)
database
indicates
that
there
are
1,448
facilities
permitted
to
discharge
to
Oregon
surface
waters.
EPA
classifies
95%
of
these
facilities
as
minor
dischargers
(
facilities
discharging
less
than
1
million
gallons
per
day
(
mgd)
and
not
likely
to
discharge
toxic
pollutants
in
toxic
amounts)
or
general
permit
facilities
(
general
permits
are
permits
issued
an
entire
category
of
dischargers).
The
map
in
Exhibit
2­
5
shows
the
location
of
the
facilities
with
individual
permits.
Exhibit
2­
6
provides
a
summary
of
all
permits
by
industry
and
permit
type.
September
2003
2.0
Baseline
for
the
Analysis
2
 
7
Exhibit
2­
6.
Summary
of
NPDES
Permitted
Direct
Dischargers
in
Oregon1
Standard
Industrial
Classification
Number
of
Facilities2
Majors
Minors
Agriculture,
Forestry,
and
Fishing
01
Agricultural
Production
 
Crops
­
1
02
Agricultural
Production
 
Livestock
and
Animal
Specialties
­
3
07
Agricultural
Services
­
­
09
Fishing,
Hunting,
and
Trapping
­
4
Mining
10
Metal
Mining
­
1
13
Oil
and
Gas
Extraction
­
­
14
Nonmetallic
Minerals
­
6
Construction
15
General
Contractors
and
Operative
Builders
­
­
16
Heavy
Construction
­
­
Manufacturing
20
Food
and
Kindred
Products
2
11
24
Lumber
and
Wood
Products
1
30
26
Paper
and
Allied
Products
12
1
27
Printing
and
Publishing
­
­
28
Chemicals
and
Allied
Products
2
5
29
Petroleum
and
Coal
Products
­
­
32
Stone,
Clay,
and
Glass
Products
­
4
33
Primary
Metal
Industries
4
2
34
Fabricated
Metal
Products
­
2
35
Industrial
Machinery
and
Equipment
­
1
36
Electronic
and
Other
Electronic
Equipment
1
3
37
Transportation
Equipment
­
2
38
Measuring,
Analyzing,
and
Controlling
Instruments
­
1
Transportation
and
Public
Utilities
40
Railroad
Transportation
­
­
41
Local
and
Interurban
Passenger
Transit
­
­
42
Trucking
and
Warehousing
­
­
44
Water
Transportation
­
2
45
Transportation
by
Air
­
2
46
Pipelines,
except
Natural
Gas
­
­
47
Transportation
Services
­
­
48
Communications
­
­
49
Electric,
Gas,
and
Sanitary
Services;
except
4952
53
18
4952
Sewerage
Services
(
POTWs)
49
152
Wholesale
Trade
50
Wholesale
Trade
 
Durable
Goods
­
1
51
Wholesale
Trade
 
Nondurable
Goods
­
7
Exhibit
2­
6.
Summary
of
NPDES
Permitted
Direct
Dischargers
in
Oregon1
Standard
Industrial
Classification
Number
of
Facilities2
Majors
Minors
September
2003
2.0
Baseline
for
the
Analysis
2
 
8
Retail
Trade
52
Building
Materials,
Hardware,
Garden
Supply,
and
Mobile
Home
Dealers
­
­
53
General
Merchandise
Stores
­
­
54
Food
Stores
­
­
55
Automotive
Dealers
and
Service
Stations
­
­
59
Miscellaneous
Retail
­
­
Finance,
Insurance,
and
Real
Estate
65
Real
Estate
­
4
Services
70
Hotels
and
Other
Lodging
Places
­
3
73
Business
Services
­
­
75
Auto
Repair,
Services,
and
Parking
­
­
76
Miscellaneous
Repair
Services
­
1
79
Amusement
and
Recreational
Services
­
­
80
Health
Services
­
­
82
Educational
Services
­
4
83
Social
Services
­
2
84
Museums,
Botanical,
Zoological
Gardens
­
1
86
Membership
Organizations
­
­
87
Engineering,
Accounting,
Research,
Management,
and
Related
Services
­
1
Public
Administration
91
Executive,
Legislative
and
General
Government,
except
Finance
­
­
92
Justice,
Public
Order,
and
Safety
­
1
94
Administration
of
Human
Resource
Programs
­
­
95
Administration
of
Environmental
Quality
and
Housing
Programs
­
1
96
Administration
of
Economic
Programs
­
­
97
National
Security
and
International
Affairs
­
­
99
Nonclassifiable
Establishments
­
1
No
SIC
Code
(
blank
in
PCS)
­
28
Total
76
306
`­`
=
none
1.
Accessed
on
August
4,
2003.
2.
There
are
also
1,065
general
permit
dischargers
that
EPA
did
not
include
in
the
analysis.
Most
of
these
dischargers
are
small
commercial
facilities
(
e.
g.,
gas
stations
and
car
dealers),
individual
miners,
fish
hatcheries,
and
small
agricultural
operations
(
e.
g.,
cattle
feed
lots
and
dairy
farms).
Data
for
general
permit
facilities
are
extremely
limited,
and
flows
from
such
facilities
are
usually
negligible.
Also,
EPA
could
not
determine
if
any
of
these
facilities
discharge
to
affected
stream
segments
because
location
information
are
not
available
in
EPA's
PCS
database.
3.
Permitted
under
a
general
storm
water
permit.
September
2003
3.0
Description
of
the
Proposed
Rule
3
 
1
3.0
Description
of
the
Proposed
Rule
This
section
describes
EPA's
proposed
rule,
including
the
waters
affected
by
the
various
provisions.
This
section
also
provides
descriptions
of
the
facilities
that
discharge
to
affected
waters
and
that,
depending
on
State
implementation
of
EPA's
proposed
rule,
may
be
affected
by
the
proposed
water
quality
standards.

3.1
Water
Quality
Criteria
and
Designated
Uses
EPA
is
proposing
temperature
criteria
to
protect
salmon
and
bull
trout
life
stages
in
Oregon
waters,
an
intergravel
dissolved
oxygen
criterion
that
protects
salmonid
spawning,
and
the
locations
and
times
of
year
(
i.
e.,
"
when
and
where")
that
salmon
and
bull
trout
life
stages
occur
in
Oregon
waters.
Exhibit
3­
1
shows
EPA's
proposed
salmonid
and
bull
trout
criteria
and
provides
the
State's
current
criteria
for
comparison.
To
identify
when
and
where
salmonid
and
bull
trout
life
stages
occur,
EPA
developed
a
set
of
decision
rules
in
conjunction
with
the
ODEQ,
the
National
Oceanic
and
Atmospheric
Administration
(
NOAA),
and
the
U.
S.
FWS.
These
criteria
are
summarized
in
Exhibit
3­
2.
Exhibits
3­
3
and
3­
4
illustrate
the
waters
potentially
affected
by
the
proposed
rule.

Exhibit
3­
1.
Comparison
of
Current
Oregon
and
Proposed
EPA
Criteria
Designated
Use
Oregon
Criteria
Proposed
EPA
Criteria
Bull
Trout
Protection
10

C
12

C
spawning
and
rearing;
16

C
migration
Salmonid
Rearing
17.8

C
18

C;
16

C
core
juvenile
rearing
Salmonid
Spawning
12.8

C
6
mg/
L
IGDO
(
minimum)
13

C
8
mg/
L
IGDO
(
minimum)
Salmonid
Migration
none
20

C
1.
EPA
is
also
proposing
a
9

C
spawning
criterion
for
bull
trout
protection
on
a
limited
number
of
stream
segments
that
are
downstream
of
a
man­
made
reservoir.

3.2
Antidegradation
EPA's
proposed
rule
establishes
implementation
procedures
for
providing
three
levels
of
water
quality
protection
under
the
State's
antidegradation
policy.
The
first
level
of
protection
is
defined
at
40
CFR
131.12(
a)(
1)
and
requires
the
maintenance
and
protection
of
existing
in­
stream
water
uses
and
the
level
of
water
quality
necessary
to
protect
these
existing
uses.
Existing
uses
are
defined
as
those
uses
actually
attained
on
or
after
November
28,
1975.
This
first
level
of
protection
is
the
baseline
of
water
quality
protection
afforded
to
all
waters
of
the
United
States.
The
second
level
of
protection
is
for
high­
quality
waters.
EPA
defines
high­
quality
waters
in
40
CFR
131.12(
a)(
2)
as
those
where
the
quality
of
the
water
exceeds
levels
necessary
to
support
the
propagation
of
fish,
shellfish,
and
wildlife,
and
recreation
in
and
on
the
water.
Finally,
EPA
designates
the
third
and
highest
level
of
protection
for
ONRWs.
If
an
authorized
entity
determines
that
the
characteristics
of
a
water
body
constitute
an
ONRW,
such
as
waters
of
September
2003
3.0
Description
of
the
Proposed
Rule
3
 
2
National
and
State
parks
and
wildlife
refuges
and
waters
of
exceptional
recreational
or
ecological
significance,
those
characteristics
must
be
maintained
and
protected
[
see
40
CFR
131.12(
a)(
3)].

Exhibit
3­
2.
Proposed
EPA
Criteria
for
Designating
Bull
Trout
and
Salmonid
Uses
Designated
Use
and
Proposed
Criterion
Criteria
Bull
Trout
Spawning
and
Rearing
(
12

C
except
on
waters
where
spawning
occurs
downstream
of
a
manmade
reservoir
the
temperature
criterion
is
9

C)
°
Waters
where
ODEQ
distribution
and
Oregon
Department
of
Fish
and
Wildlife
(
ODFW)
timing
information
shows
summertime
bull
trout
current
and
potential
use.
°
Any
additional
waters
identified
by
U.
S.
FWS
as
spawning/
natal
stream
rearing
critical
habitat.
°
Waters
identified
by
U.
S.
FWS
for
bull
trout
spawning
use
downstream
of
man­
made
reservoirs.
°
All
waters
upstream
of
the
waters
identified
in
above,
except
where
a
relatively
large
tributary
not
identified
above
enters
the
downstream
portion
of
a
river
identified
above.

Core
Juvenile
Salmonid
Rearing
and
Bull
Trout
Migration
(
16

C)
°
Waters
where
ODFW
distribution
and
timing
information
shows
chinook
spawning
occurs
on
or
prior
to
Sept.
15.
°
Waters
where
ODEQ
distribution
and
ODFW
timing
information
shows
bull
trout
presence
(
i.
e.
bull
trout
migration,
foraging,
and/
or
sub­
adult
bull
trout
rearing)
in
July
or
August.
°
Waters
where
scientifically
credible
information
shows
high
density
salmon
or
steelhead
rearing.
°
All
waters
upstream
of
the
waters
identified
above,
except
where
a
relatively
large
river
not
identified
above
enters
the
downstream
portion
of
a
river
identified
above.

Non­
core
Juvenile
Salmonid
Rearing
and
Migration
(
18

C)
°
Waters
where
ODFW
distribution
and
timing
information
shows
chinook,
chum,
coho,
or
steelhead
rearing
occurring
in
July
or
August.
°
Waters
where
ODFW
distribution
information
shows
rainbow
or
coastal
cutthroat
trout
rearing
use
or
where
resident
trout
use
is
likely,
except
where
redband
or
lahotan
trout
is
the
only
trout
use
(
Note:
redband
and/
or
lahotan
trout
is
a
separate
use
designation
with
a
20

C
criterion
in
Oregon's
rule,
but
not
included
in
EPA's
proposed
rule).
°
All
waters
upstream
of
the
waters
identified
above.

Salmonid
Migration
(
20

C)
°
Waters
where
ODFW
distribution
and
timing
information
indicates
there
is
no
rearing
use
in
July
or
August
or
information
suggests
a
lower
mainstem
river
is
primarily
a
migration
corridor
during
the
period
of
summer
maximum
temperatures,
plus
there
is
some
evidence
that
temperatures
are
naturally
this
warm.
Exhibit
3­
2.
Proposed
EPA
Criteria
for
Designating
Bull
Trout
and
Salmonid
Uses
Designated
Use
and
Proposed
Criterion
Criteria
September
2003
3.0
Description
of
the
Proposed
Rule
3
 
3
Salmonid
Spawning
(
13

C)
in
Waters
with
a
Summer
Maximum
Criterion
of
16

C
°
Waters
where
ODFW
distribution
information
shows
chinook
spawning
occurs
(
and
no
steelhead
spawning
occurs)
from
2
weeks
after
beginning
of
spawning
(
unless
beginning
is
peak
spawning,
in
which
case
the
start
date
is
beginning
of
spawning)
or
Oct.
15
(
whichever
is
earlier)
to
May
15.
°
Waters
where
ODFW
distribution
information
shows
chinook
spawning
and
steelhead
spawning
occurs
from
2
weeks
after
beginning
of
chinook
spawning
(
unless
beginning
is
peak
spawning,
in
which
case
the
start
date
is
beginning
of
spawning)
or
Oct.
15
(
whichever
is
earlier)
to
June
15.
°
Waters
where
ODFW
distribution
information
shows
steelhead
spawning
occurs
(
and
no
chinook
spawning
occurs)
from
Oct.
15
to
June
15.
°
From
Oct.
15
to
May
15
for
any
other
waters
where
salmon
spawning
(
e.
g.,
coho
or
chum)
occurs.

Salmonid
Spawning
(
13

C)
in
Waters
with
a
Summer
Maximum
Criterion
of
18

C
°
Waters
where
ODFW
distribution
information
shows
salmon
(
chinook,
coho,
chum)
or
steelhead
spawning
from
Oct.
15
to
May
15.

Salmonid
Spawning
(
13

C)
in
Waters
with
a
Summer
Maximum
Criterion
of
20

C
°
Waters
where
ODFW
distribution
information
shows
salmon
or
steelhead
spawning
from
the
beginning
of
spawning
to
the
end
of
fry
emergence.
September
2003
3.0
Description
of
the
Proposed
Rule
3
 
4
Exhibit
3­
3.
Waters
EPA
Proposes
to
Designate
for
Salmonid
Rearing
and
Migration
and
Bull
Trout
Protection
Exhibit
3­
4.
Waters
EPA
Proposes
to
Designate
for
Salmonid
and
Bull
Trout
Spawning
September
2003
3.0
Description
of
the
Proposed
Rule
3
 
5
3.2
Antidegradation
EPA's
proposed
rule
establishes
implementation
procedures
for
providing
three
levels
of
water
quality
protection
under
the
State's
antidegradation
policy.
The
first
level
of
protection
is
defined
at
40
CFR
131.12(
a)(
1)
and
requires
the
maintenance
and
protection
of
existing
in­
stream
water
uses
and
the
level
of
water
quality
necessary
to
protect
these
existing
uses.
Existing
uses
are
defined
as
those
uses
actually
attained
on
or
after
November
28,
1975.
This
first
level
of
protection
is
the
baseline
of
water
quality
protection
afforded
to
all
waters
of
the
United
States.
The
second
level
of
protection
is
for
high­
quality
waters.
EPA
defines
high­
quality
waters
in
40
CFR
131.12(
a)(
2)
as
those
where
the
quality
of
the
water
exceeds
levels
necessary
to
support
the
propagation
of
fish,
shellfish,
and
wildlife,
and
recreation
in
and
on
the
water.
Finally,
EPA
designates
the
third
and
highest
level
of
protection
for
ONRWs.
If
an
authorized
entity
determines
that
the
characteristics
of
a
water
body
constitute
an
ONRW,
such
as
waters
of
National
and
State
parks
and
wildlife
refuges
and
waters
of
exceptional
recreational
or
ecological
significance,
those
characteristics
must
be
maintained
and
protected
[
see
40
CFR
131.12(
a)(
3)].

Under
these
procedures,
the
quality
of
high­
quality
waters
is
to
be
maintained
and
protected
unless
the
State
finds,
after
public
participation
and
intergovernmental
review,
that
allowing
lower
water
quality
is
necessary
to
accommodate
important
economic
or
social
development
in
the
area
in
which
the
waters
are
located.
In
allowing
this,
the
State
must
assure
that
the
resulting
water
quality
remains
adequate
to
fully
protect
existing
uses.
Further,
it
must
also
assure
that
all
applicable
statutory
and
regulatory
requirements
are
implemented
for
all
new
and
existing
point
sources,
and
all
cost­
effective
and
reasonable
best
management
practices
are
implemented
for
nonpoint
source
control.
No
degradation
of
ONRW
would
be
allowed.

3.3
Potentially
Impacted
Facilities
The
water
quality
criteria
and
uses
in
EPA's
proposed
rule
may
affect
facilities
discharging
to
affected
waters.
EPA
identified
these
facilities
using
its
PCS
database.
In
doing
so,
EPA
assumed
that
only
facilities
that
discharge
to
rivers
and
streams
with
new
or
more
stringent
uses
and
criteria
may
be
affected
by
the
water
quality
criteria
and
designated
uses
provisions.
(
EPA
also
assumed
that
facilities
discharging
directly
to
the
Columbia
River
and
the
Pacific
Ocean
are
not
affected,
except
for
portions
of
the
Columbia
River
where
spawning
occurs
that
would
be
affected
for
IGDO.)
For
IGDO,
the
current
criterion
of
6
mg/
L
is
less
stringent
than
the
revised
IGDO
criterion
of
8
mg/
L.
Therefore,
all
waters
designated
for
salmonid
spawning
(
see
Exhibit
3­
4)
are
potentially
affected
by
the
proposed
rule,
and
facilities
discharging
to
these
waters
are
included
in
the
set
of
potentially
affected
dischargers.
EPA
identified
these
facilities
by
overlaying
PCS
facilities
with
the
waters
designated
for
salmonid
spawning
using
geographic
information
system
(
GIS)
software.

To
identify
waters
for
which
the
proposed
rule
provides
new
or
more
stringent
uses
and
temperature
criteria
(
Exhibit
3­
5),
EPA
compared
criteria
and
uses
designated
for
salmonid
spawning
and
rearing
and
bull
trout
protection
for
waters
under
the
proposed
rule
with
those
criteria
and
uses
to
the
criteria
and
uses
for
waters
that
are
currently
designated
by
the
State
2EPA
is
also
proposing
for
a
limited
number
of
stream
segments
a
9

C
spawning
criterion
for
bull
trout
protection
downstream
of
man­
made
reservoirs.
EPA
identified
one
facility
that
discharges
below
a
reservoir
to
a
segment
designated
for
bull
trout
spawning
at
9

C.
However,
EPA
assumed
any
controls
necessary
for
compliance
with
the
current
State
bull
trout
criterion
of
10

C
would
also
enable
compliance
with
EPA's
proposed
bull
trout
temperature
criterion.
Therefore,
costs
associated
with
this
provision
of
the
proposed
rule
are
zero
because
controls
implemented
to
meet
the
current
State
criteria
will
also
achieve
EPA's
proposed
criteria.

September
2003
3.0
Description
of
the
Proposed
Rule
3
 
6
(
shown
in
Exhibits
2­
3
and
2­
4).
2
As
shown
in
Exhibit
2­
3,
the
State's
current
temperature
criteria
for
salmonid
rearing
is
17.8

C,
with
no
differentiation
for
core
juvenile
rearing.
The
proposed
rule
establishes
a
16

C
temperature
criterion
for
core
juvenile
rearing
(
and
18

C
otherwise
for
rearing).
Therefore,
EPA's
proposed
rule
provides
a
more
stringent
criterion
for
waters
it
designates
for
core
juvenile
rearing
(
16

C),
and
facilities
discharging
to
these
waters
may
be
affected.
EPA
identified
these
facilities
by
overlaying
PCS
facilities
with
the
waters
designated
for
core
juvenile
rearing
using
GIS
software.

For
salmonid
spawning
shown
in
Exhibit
2­
4,
the
current
State
criterion
of
12.8

C
is
slightly
more
stringent
than
EPA's
proposed
criterion
of
13

C.
However,
the
time
period
that
the
criterion
applies
may
differ
under
the
proposed
rule.
Therefore,
EPA
assumed
that
any
waters
for
which
it
is
designating
a
salmonid
spawning
period
that
is
earlier
or
later
than
currently
designated
by
the
State
(
e.
g.,
current
designation
from
October
1
to
May
31,
versus
a
proposed
designation
from
September
1
to
June
30)
would
be
affected
because
EPA's
criterion
would
apply
during
the
extended
time
period.
Facilities
discharging
to
these
waters
may
be
impacted.
EPA
identified
these
facilities
by
overlaying
PCS
facilities
with
the
waters
for
which
an
earlier
or
later
salmonid
spawning
period
applies
under
the
proposed
rule
using
GIS
software.

For
antidegradation,
EPA
assumed
that
facilities
discharging
to
streams
not
listed
by
the
State
as
impaired
waters
(
i.
e.,
not
on
the
303(
d)
list)
are
affected.
Although
high­
quality
waters
are
not
yet
identified
by
the
State,
the
unimpaired
waters
provide
a
reasonable
approximation
of
highquality
waters
(
although
some
portion
of
these
will
be
ONWRs
and
not
affected
by
the
procedures
because
no
lowering
of
water
quality
is
allowed
for
ONWRs).
EPA
identified
these
facilities
by
overlaying
PCS
facilities
with
waters
that
are
not
on
the
State's
303(
d)
list
using
GIS
software.
Exhibit
3­
6
summarizes
the
potentially
affected
facilities
by
provision.
The
dischargers
are
grouped
by
discharger
type
(
e.
g.,
major
or
minor)
and
category
(
e.
g.,
POTW
or
industry
category).
Note
that
there
are
some
facilities
affected
by
more
than
one
provision.
September
2003
3.0
Description
of
the
Proposed
Rule
3
 
7
Exhibit
3­
5.
Waters
EPA
Proposes
to
Designate
for
New
or
More
Stringent
Uses
and
Criteria
for
Temperature
September
2003
3.0
Description
of
the
Proposed
Rule
3
 
8
Exhibit
3­
6.
Estimated
Number
of
Facilities
Potentially
Affected
by
the
Antidegradation,
IGDO,
and
Temperature
Provisions
of
the
Proposed
Rule
Category
Number
of
Facilities
Major
Minor
Total
Antidegradation1
Chemicals
­
4
4
Fishing
­
4
4
Food
1
5
6
Metals/
Metals
Manufacturing
1
2
3
Mining
­
3
3
POTWs
14
65
79
Public
Services
5
4
9
Pulp
and
Paper
­
­
­

Wood
and
Lumber
1
18
19
Miscellaneous
­
25
25
Total
22
130
152
IGDO2
Chemicals
1
3
4
Fishing
­
4
4
Food
1
5
6
Metals/
Metals
Manufacturing
3
1
4
Mining
­
2
2
POTWs
29
85
114
Public
Services
2
6
8
Pulp
and
Paper
7
­
7
Wood
and
Lumber
­
17
17
Miscellaneous
­
26
26
Total
43
149
192
Temperature3
Fishing
­
2
2
Food
­
1
1
POTWs
3
29
32
Pulp
and
Paper
1
­
1
Wood
and
Lumber
­
7
7
Miscellaneous
­
5
5
Total
4
44
48
1.
Estimated
as
facilities
discharging
to
waters
not
on
the
State's
303(
d)
list.
2.
Estimated
as
facilities
discharging
to
waters
designated
for
salmonid
spawning,
except
for
those
portions
of
the
Columbia
River
where
spawning
occurs.
3.
Estimated
as
facilities
discharging
to
waters
designated
for
core
juvenile
rearing,
or
an
extended
(
earlier,
later,
or
both)
spawning
period,
under
the
proposed
rule.
September
2003
4.0
Method
for
Estimating
Costs
4
 
1
4.0
Method
for
Estimating
Costs
This
section
describes
EPA's
method
for
estimating
potential
costs
to
the
NPDES­
permitted
facilities
identified
in
Section
3.

4.1
Temperature
Criteria
and
Uses
4.1.1
Sample
Facilities
EPA
identified
a
total
of
48
facilities
(
4
majors
and
44
minors)
that
may
be
potentially
affected
by
the
proposed
uses
and
temperature
criteria.
EPA
evaluated
all
four
major
facilities
and
a
sample
of
minor
facilities
from
this
group
for
potential
cost
impacts
associated
with
the
proposed
rule.
Exhibit
4­
1
identifies
the
sample
facilities
by
name
and
permit
number.

Exhibit
4­
1.
Sample
Facilities
Potentially
Affected
by
Revised
Temperature
Criteria
NPDES
Number
Facility
Name
Flow
(
mgd)
Type
Category
OR0026263
Medford
Regional
WRF
20
Major
POTW
OR0020427
Stayton
WWTP
3.9
Major
POTW
OR0020346
Sweet
Home
WWTP
1.4
Major
POTW
OR0000515
Weyerhaueser
Company
22.2
Major
Wood
and
Lumber
OR0030261
Douglas
County
DPW
0.28
Minor
POTW
OR0027791
Government
Camp
SD
0.10
Minor
POTW
OR0022314
Oakridge
WWTP
0.47
Minor
POTW
OR0030660
Shady
Cove
WWTP
0.45
Minor
POTW
OR0020419
Siletz
WWTP
0.16
Minor
POTW
4.1.2
Determining
Effect
of
Discharges
on
Receiving
Water
For
facilities
discharging
to
streams
with
more
stringent
uses
and
temperature
criteria,
including
an
extended
spawning
time
period,
EPA
evaluated
the
effect
of
the
discharge
on
the
receiving
water
using
monthly
effluent
and
receiving
water
data.
Oregon's
current
WQS
specify
that
numeric
temperature
criteria
be
measured
as
the
7­
day
moving
average
of
the
daily
maximum
temperatures.
If
there
are
insufficient
data
to
establish
a
7­
day
moving
average,
the
numeric
criteria
should
be
applied
as
an
instantaneous
maximum
(
OAR
340­
041­
0006).
When
possible,
EPA
calculated
the
average
of
the
maximum
7­
day
moving
averages
for
each
month.
In
other
words,
EPA
took
the
maximum
7­
day
moving
averages
for
each
month
in
a
given
year,
and
averaged
these
values
across
years
(
usually
the
last
three
years
of
data).
If
daily
temperature
data
were
not
available,
EPA
evaluated
the
average
of
the
maximum
monthly
values.
September
2003
4.0
Method
for
Estimating
Costs
4
 
2
T
T
DT
D
MZ
E
S
=
+
 
+
(
)

(
)
1
D
Q
Q
S
E
=
To
determine
the
effect
of
the
discharge
on
the
downstream
temperature,
EPA
calculated
the
temperature
at
the
edge
of
the
regulatory
mixing
zone
(
RMZ)
using
the
following
equation
(
ODEQ,
2001):

where,
T
MZ
=
temperature
at
the
edge
of
the
RMZ
T
E
=
effluent
temperature
T
S
=
stream
background
temperature
D
=
RMZ
dilution
ratio.

The
effluent
temperature
is
the
average
of
maximum
monthly
effluent
temperature
determined
above
(
e.
g.,
average
of
maximum
7­
day
moving
average,
average
of
maximum
monthly
temperature)
for
the
time
period
of
concern.
EPA
assumed
that
the
background
stream
temperature
is
the
applicable
criterion
when
the
water
body
currently
exceeds
the
criterion;
otherwise,
EPA
used
the
maximum
receiving
water
temperature
(
i.
e.,
average
of
maximum
7­
day
moving
average
temperatures,
average
of
maximum
monthly
temperatures)
in
those
situations
where
the
water
body
is
currently
attaining
the
criterion.
For
example,
if
the
receiving
water
is
designated
for
core
salmonid
rearing
and
the
maximum
receiving
water
temperature
for
July
and
August
is
17

C,
the
effluent
temperature
used
in
the
above
equation
would
be
the
maximum
monthly
effluent
temperature
between
July
and
August,
and
the
stream
temperature
would
be
16

C.
The
dilution
ratio
is
calculated
from
the
following
equation
(
ODEQ,
2001):

where,
Q
S
=
portion
of
stream
flow
available
for
dilution
Q
E
=
effluent
flow.

The
7Q10
(
minimum
7­
day
average
flow
recurring
once
in
10
years)
stream
flow,
and
the
average
effluent
flow
is
used
to
calculate
the
dilution
ratio,
when
necessary.
EPA's
proposed
rule
specifies
that
only
25%
of
the
7Q10
flow
be
used
in
the
dilution
calculation.
In
many
cases,
facilities
already
have
calculated
dilution
ratios
through
stream
modeling
(
e.
g.,
CORMIX)
or
mixing
zone
studies.
In
these
cases,
if
less
than
25%
of
the
7Q10
flow
is
used
in
the
model,
EPA
used
the
facility­
calculated
value,
otherwise
EPA
calculated
the
dilution
ratio
from
the
above
equation,
assuming
25%
of
the
stream
7Q10
low
flow
is
available
for
dilution.

4.1.3
Identifying
Potential
Controls
Oregon's
WQS
state
that
a
discharge
may
not
cause
an
increase
in
the
surface
water
temperature
of
greater
than
0.14

C
in
waters
exceeding
the
applicable
criterion
[
OAR
340­
041­
0205
(
b)(
A)].
Therefore,
EPA
assumed
that
any
discharge
that
results
in
a
downstream
temperature
greater
than
0.14

C
above
the
applicable
criterion
would
require
additional
controls;
however,
this
is
a
conservative
assumption
with
respect
to
estimating
costs
(
i.
e.,
erring
on
the
side
of
higher
costs)
because
EPA's
proposed
rule
specifies
an
increment
of
0.3

C
above
the
applicable
criterion.
The
September
2003
4.0
Method
for
Estimating
Costs
4
 
3
State's
current
WQS
also
require
facilities
discharging
to
impaired
waters
to
develop
and
implement
a
temperature
management
plan
(
TMP).
A
TMP
should
describe
the
best
management
practices,
measures,
and
control
technologies
that
would
be
implemented
by
the
facility
to
reduce
the
effect
that
their
effluent
temperature
has
on
downstream
temperatures.
Facilities
are
required
to
continue
implementation
of
the
measures
outlined
in
their
TMPs
until
stream
temperatures
are
lowered
to
criterion
levels
or
ODEQ
determines
that
all
feasible
steps
have
been
taken
to
meet
the
criterion
and
that
the
designated
uses
are
not
being
adversely
impacted
(
OAR
340­
041­
0026).

EPA
used
TMPs
from
facilities
that
have
already
developed
them
to
determine
the
necessary
controls
on
point
sources
to
reduce
effluent
temperatures.
For
example,
in
the
Metropolitan
Wastewater
Management
Commission
(
MWMC)
TMP,
both
short
and
long
term
control
options
are
discussed.
Short
term
temperature
control
options
include:

°
Identifying
treatment
management
procedures
that
could
be
altered
to
reduce
the
thermal
loads
to
the
waste
stream
(
i.
e.,
process
optimization
such
as
switching
to
fine
bubble
aeration,
installation
of
shade
cloths,
etc.)
°
Reviewing
temperature
characteristics
of
major
industrial
dischargers
(
i.
e.,
pollution
minimization
including
source
controls)
°
Developing
a
list
of
potential
alternative
discharge
options
(
e.
g.,
land
application,
storage
ponds).

The
long
term
options
include:

°
Reducing
the
volume
of
discharge
by
reusing
effluent
°
Recycling
certain
waste
streams
to
reduce
thermal
load
°
Using
some
or
all
of
the
effluent
for
irrigation
°
Storing
heated
wastewater
°
Off
stream
cooling/
evaporation
ponds
°
Installing
treatment
technology
to
reduce
temperatures.

EPA
considered
these
control
options,
as
well
as
options
from
other
TMPs
(
e.
g.,
land
application
of
effluent),
to
determine
the
most
cost­
effective
measure
for
reducing
temperatures
at
each
sample
facility.

To
determine
the
necessary
controls,
EPA
first
evaluated
whether
low
cost
control
options
would
be
feasible,
and
then
considered
more
costly
controls,
if
necessary.
EPA
considered
the
lowest
cost
option
to
be
the
adjustment
of
existing
treatment
(
process
optimization).
EPA
considered
process
optimization
feasible
where
relatively
low
temperature
reductions
on
the
order
of
1

C
to
2

C
were
needed
or
monitoring
data
indicate
that
influent
temperatures
increase
during
the
treatment
process
(
i.
e.,
net
positive
temperature
increase
from
influent
to
effluent).

If
adjusting
existing
operations
would
not
be
feasible
or
would
not
be
sufficient
to
achieve
the
desired
temperature
reductions,
EPA
considered
whether
waste
minimization/
pollution
prevention
would
achieve
standards.
Decision
considerations
for
pollution
prevention
(
P2)
included
the
level
of
temperature
reduction
achievable
through
waste
minimization/
pollution
prevention
techniques,
appropriateness
of
waste
minimization/
pollution
prevention
for
temperature
(
e.
g.,
high
influent
September
2003
4.0
Method
for
Estimating
Costs
4
 
4
temperatures),
and
knowledge
of
the
manufacturing
processes
generating
the
high
temperatures.
P2
measures
for
temperature
would
include
monitoring
of
influent
water
to
determine
the
source
contributing
to
high
influent
temperatures
(
e.
g.,
industrial
and
commercial
dischargers
to
a
POTW).
P2
would
also
include
the
implementation
of
best
management
practices
(
BMPs)
once
the
source
is
identified.

If
P2
measures
alone
would
not
reduce
pollutant
levels
to
those
needed
to
comply
with
projected
effluent
limits,
EPA
considered
a
combination
of
P2
and
process
optimization.
If
these
relatively
low­
cost
controls
could
not
achieve
the
projected
effluent
limits,
EPA
considered
additional
treatment
such
as
the
long
term
options
in
MWMC's
TMP.
EPA
evaluated
the
feasibility
of
various
options
to
determine
the
least
cost
method.
For
example,
an
evaporation
pond
may
not
be
feasible
for
a
major
facility
with
a
large
flow
because
the
necessary
amount
of
land
may
not
be
available.

4.1.4
Estimating
Costs
of
Controls
For
facilities
contributing
to
an
exceedance
of
the
current
State
WQS
(
i.
e.,
downstream
temperature
greater
than
0.14

C
above
the
State
criterion,
if
applicable),
EPA
first
estimated
the
controls
necessary
for
compliance
with
the
current
criterion.
EPA
then
determined
if
those
controls
would
also
enable
the
facility
to
meet
the
proposed
revised
criterion.
If
those
controls
enable
compliance
with
the
proposed
criterion,
EPA
assumed
that
the
facility
would
not
incur
costs
associated
with
the
proposed
rule
(
i.
e.,
all
control
costs
are
associated
with
meeting
the
current
standards).
Otherwise,
EPA
estimated
the
incremental
costs
associated
with
meeting
the
proposed
criterion,
that
is,
the
additional
costs
required
(
after
compliance
with
the
State's
current
designated
uses
and
criteria)
to
achieve
a
new
limit
based
on
EPA's
proposed
uses
and
criteria.

EPA
estimated
the
cost
of
pollution
controls
for
point
sources
using
available
estimates
from
the
literature.
EPA
did
not
conclude
that
treatment
process
optimization
or
waste
minimization/
pollution
prevention
would
be
used
by
any
of
the
sample
facilities
to
achieve
EPA's
proposed
uses
and
criteria.

EPA
estimated
capital
costs
for
those
facilities
for
which
new/
additional
treatment
was
needed.
EPA
evaluated
the
feasibility
and
costs
of
controls
such
as
prohibiting
discharge
during
the
months
of
concern
and
cooling
towers.

The
no­
discharge
options
include
land
application
or
effluent
reuse.
Costs
for
land
application
and
reuse
include
excavation,
backfill,
piping,
and
pumps.
EPA
assumed
facilities
would
need
to
transport
wastewater
about
one
mile
to
the
land
application
or
reuse
site.
EPA
used
R.
S.
Means
(
2001)
unit
costs
for
each
of
the
components
and
calculated
the
unit
measurements
from
the
effluent
flow
being
treated.
Capital
costs
include
the
cost
of
the
equipment,
labor,
installation,
and
a
markup
for
overhead
and
profit.
Operation
and
maintenance
(
O&
M)
costs
are
annual
costs
associated
with
maintaining
the
equipment
and
monitoring.
EPA
assumed
annual
O&
M
costs
would
equal
5%
of
the
total
capital
costs.

Cooling
towers
costs
are
based
on
the
following
cost
equations
developed
for
EPA's
proposed
316(
b)
Phase
II
rule
(
2002b):
September
2003
4.0
Method
for
Estimating
Costs
4
 
5
Capital
Q
Q
=
 
×
+
+
 
4
10
63
263
23209
5
2
*
.
*

O
M
Q
Q
&
*
.
*
=
 
×
+
+
 
7
10
65037
12041
6
2
where,
Q
=
effluent
flow
in
gpm
(
gallons
per
minute).

These
are
the
cost
equations
for
nonfouling,
film
fill
fiberglass
cooling
towers
with
no
blow
down.
Capital
costs
are
multiplied
by
5%
to
account
for
contingencies
(
i.
e.,
unforeseeable
costs)
and
another
20%
to
incorporate
retrofit
costs
because
the
equations
shown
above
provide
capital
cost
estimates
for
towers
at
new
facilities
(
U.
S.
EPA,
2002b).

EPA
escalated
all
costs
to
2003
dollars
using
the
Engineering
News
Record
(
ENR)
Construction
Cost
Index.

4.1.5
Total
Statewide
Costs
EPA
evaluated
the
potential
cost
impacts
for
the
four
major
facilities
potentially
affected
by
the
proposed
rule.
For
minor
facilities
EPA
only
evaluated
a
sample
and
therefore
extrapolated
the
results
to
all
minor
facilities.
EPA
calculated
a
per­
facility
cost
by
dividing
the
total
costs
by
the
number
of
sample
facilities.
EPA
then
multiplied
the
per­
facility
cost
by
the
total
number
of
minor
facilities.

4.2
IGDO
Criteria
There
are
no
IGDO
data
available
for
any
of
the
affected
waters,
primarily
because
methods
to
measure
IGDO
have
only
recently
been
developed.
Therefore,
EPA
estimated
compliance
with
current
and
proposed
IGDO
criteria
based
on
an
estimated
3
mg/
L
differential
between
the
IGDO
and
dissolved
oxygen
(
DO)
in
the
overlying
water
[
based
on
EPA
(
1986)].
Using
this
differential,
the
current
Oregon
IGDO
criterion
of
6
mg/
L
corresponds
to
a
minimum
instream
DO
concentration
of
9
mg/
L.
The
EPA
IGDO
criterion
of
8
mg/
L
corresponds
to
a
minimum
instream
DO
concentration
of
11
mg/
L
(
U.
S.
EPA,
1986).

Current
Oregon
WQS
specify
a
minimum
water
column
DO
criterion
for
spawning
waters,
as
well
as
minimum
IGDO
criteria.
The
minimum
water
column
DO
for
protection
of
salmonid
spawning
is
11.0
mg/
L,
unless:

°
The
minimum
IGDO
(
measured
as
a
spatial
median)
is
8
mg/
L,
then
the
minimum
DO
may
be
9
mg/
L
°
Conditions
of
barometric
pressure,
altitude,
and
temperature
preclude
attainment
of
11
or
9
mg/
L
standards,
then
the
minimum
DO
may
be
95%
of
saturation.

EPA's
proposed
rule
would
only
change
the
IGDO
criterion,
and
would
not
change
Oregon's
11
mg/
L
(
or
9
mg/
L)
instream
DO
criteria.
Thus,
if
a
stream
is
meeting
the
current
State
instream
WQS,
based
on
EPA
(
1986)
the
stream
would
also
meet
the
EPA's
proposed
IGDO
criterion,
September
2003
4.0
Method
for
Estimating
Costs
4
 
6
and
no
costs
would
be
incurred
as
a
result
of
this
part
of
the
proposed
rule.
If
a
stream
is
not
meeting
the
current
WQS,
the
costs
of
attaining
compliance
would
be
associated
with
existing
Oregon
WQS,
not
as
a
result
of
the
proposed
rule.
Therefore,
EPA
estimated
the
cost
of
this
provision
to
be
zero.

4.3
Antidegradation
Procedures
Under
the
proposed
rule,
before
the
lowering
of
water
quality
can
be
permitted,
an
antidegradation
review
must
be
conducted.
The
result
of
this
review
must
be
that
no
costeffective
pollution
prevention
alternatives
and
enhanced
treatment
techniques
are
available
to
the
entity
that
would
eliminate
or
significantly
reduce
the
extent
to
which
the
increased
loading
results
in
a
lowering
of
water
quality.
In
addition,
the
review
must
show
that
the
pollution
controls
necessary
to
maintain
the
existing
water
quality
will
interfere
with
economic
and/
or
social
development
in
the
area,
and
that
this
economic
and
social
development
is
important.

Therefore,
to
develop
an
estimate
of
the
incremental
impact
of
the
proposed
rule,
EPA
first
estimated
the
number
of
facilities
located
on
high­
quality
waters
that
might
request
an
increase
in
loadings
when
they
renew
their
permit.
Second,
EPA
estimated
the
costs
of
preparing
an
antidegradation
analysis
to
justify
the
need
for
these
facilities
to
increase
discharges,
as
well
as
State
costs
to
review
the
analysis
and
make
a
determination.

4.3.1
Potential
Number
of
Antidegradation
Requests
As
shown
in
Section
3,
EPA
estimated
that
22
major
facilities
and
130
minor
facilities
may
discharge
to
high­
quality
waters.
NPDES
permits
are
issued
for
a
period
of
five
years,
after
which
they
must
be
renewed.
Therefore,
over
any
five
year
period,
all
152
existing
permit
holders
will
renew
their
permits.
For
this
analysis,
EPA
assumed
that
all
current
dischargers
will
remain
active
(
although
some
existing
facilities
may
cease
operations,
new
facilities
may
begin
discharging
such
that
the
net
effect
on
the
total
number
of
dischargers
to
high
quality
waters
is
unchanged).

Since
the
State
began
implementing
its
antidegradation
review
procedures,
few
facilities
have
requested
an
increase
in
discharge
to
a
high­
quality
water
such
that
an
antidegradation
review
was
required.
Based
on
the
frequency
of
past
reviews,
EPA
assumed
that
no
more
than
5%
of
facilities
that
discharge
to
high­
quality
waters
would
request
more
than
a
de
minimis
increase
in
loadings
when
they
renew
their
permit.
The
proposed
rule
allows
for
certain
de
minimis
changes
that
do
not
constitute
a
"
lowering"
of
water
quality
sufficient
to
trigger
an
antidegradation
review.
Thus,
of
the
152
permit
renewals
processed
over
any
5
year
period,
EPA
assumed
that
approximately
8
facilities
would
require
an
antidegradation
analysis.
However,
this
is
a
conservative
assumption
with
respect
to
estimating
cost
(
i.
e.,
erring
on
the
side
of
higher
costs)
because
it
implies,
as
a
baseline,
that
the
State
is
not
currently
implementing
its
antidegradation
policy
and
implementation
procedures,
when
in
fact
it
is.
The
breakdown
of
potentially
affected
facilities
by
discharge
category
is
shown
in
Exhibit
4­
2.
September
2003
4.0
Method
for
Estimating
Costs
4
 
7
Exhibit
4­
2.
Estimated
Number
of
Potentially
Affected
Facilities
Number
of
Facilities
Total
Municipal
Facilities
(
POTWs)
1
Industrial
Facilities
Major
Minor
Major
Minor
Total
Permitted
Facilities
152
14
65
8
65
Expected
Number
of
Antidegradation
Reviews
Every
Five
Years2
8
1
3
1
3
Note:
Detail
may
not
add
to
total
due
to
rounding.
1.
EPA
included
small,
sanitary
discharges
from
apartment
complexes
and
other
residential
and
commercial
complexes
in
the
minor
POTW
category
because
they
are
more
similar
to
municipal
facilities
than
industrial
facilities.
2.
Estimated
as
5%
of
permit
renewals,
based
on
information
from
the
State,
and
rounded
to
the
nearest
whole
facility.

4.3.2
Antidegradation
Analysis
Requirements
The
cost
impact
of
the
proposed
rule
includes
only
the
cost
of
performing
the
analyses
that
implement
the
antidegradation
procedures.
Entities
seeking
an
antidegradation
review
will
incur
costs
to
develop
financial
and
economic
and
social
impact
analyses,
and
the
State
will
incur
costs
to
review
the
analyses
and
make
a
determination.

U.
S.
EPA
(
1995)
contains
guidelines
for
completing
the
financial
and
economic
and
social
impact
analyses
and
interpreting
the
results.
Most
of
the
information
required
for
these
analyses
is
available
from
easily
accessible
sources.
The
socioeconomic
indicators,
and
the
information
required
to
calculate
the
various
ratios,
are
often
available
on
the
Internet
or
by
directly
contacting
sources
such
as
the
U.
S.
Census
Bureau,
Standard
&
Poors,
Moody's,
the
Bureau
of
Labor
Statistics,
and
State
and
local
government
agencies.
The
portion
of
the
analysis
requiring
estimation
of
pollution
control
costs
may
be
performed
by
the
entity
if
a
qualified
staff
member
is
available.
A
facility
may
also
wish
to
utilize
a
consultant
to
estimate
the
pollution
control
cost
and
develop
the
financial
analysis.

An
antidegradation
review
of
a
proposed
development
that
would
result
in
a
lowering
of
water
quality
must
address
two
factors.
First,
the
review
must
establish
that
the
pollution
controls
necessary
to
maintain
the
high
quality
of
a
water
will
interfere
with
the
proposed
development.
Second,
the
review
must
demonstrate
that
the
development
would
be
an
important
economic
and
social
one.

The
first
factor
can
be
addressed
through
an
financial
impact
analysis.
The
entity
proposing
to
increase
their
loadings
must
determine
what
pollution
controls
would
be
necessary
to
prevent
lowering
of
water
quality.
Those
controls
must
be
the
most
appropriate
and
cost­
effective
means
of
maintaining
water
quality.
The
entity
then
calculates
the
annual
cost
of
the
pollution
controls,
which
includes
the
annualized
capital
cost,
if
any,
as
well
as
the
annual
operation
and
maintenance
costs.
In
addition,
public
entities
determine
how
these
costs
are
passed
on
in
annual
household
service
fees.

The
second
factor
requires
an
analysis
of
changes
in
social
and
economic
measures
that
would
be
foregone
if
the
proposed
development
that
would
lower
water
quality
is
not
allowed.
This
might
September
2003
4.0
Method
for
Estimating
Costs
4
 
8
include
estimates
of
foregone
increases
in
tax
revenue,
employment,
personal
income,
and
property
values
in
the
affected
community.

EPA
assumed
that
the
cost
incurred
by
facilities
in
complying
with
the
proposed
rule
is
the
cost
of
a
preliminary
engineering
analysis
and
the
subsequent
financial
analysis
for
which
EPA
provides
guidance
and
a
workbook.
The
engineering
analysis
comprises
an
analysis
of
the
existing
industrial
processes
at
a
facility,
the
treatment
processes
used
to
treat
wastes
generated,
and
the
current
effluent
quality.
The
analysis
must
identify
the
least­
cost
controls
for
attaining
no
increase
in
loadings,
and
develop
approximate
costs
for
implementing
required
controls.
However,
detailed
design
work
is
not
required
to
develop
these
likely
cost
estimates
 
cost
estimates
based
on
a
pre­
conceptual
design
analysis
will
provide
sufficient
information
for
the
financial
analysis.
EPA
assumed
that
this
level
of
analysis,
in
conjunction
with
the
financial
impact
analyses
described
below,
could
cost
between
1%
and
3%
of
the
installed
cost
of
additional
pollution
controls.

To
estimate
the
potential
analytical
costs,
EPA
first
calculated
the
average
capital
costs
to
facilities
it
identified
as
requiring
additional
controls
in
economic
analyses
of
recent
water
quality
standards
actions,
including
establishing
criteria
for
toxic
pollutants
and
upgrading
receiving
water
use
classifications
in
the
States
of
Alabama,
Iowa,
California,
and
Idaho
(
U.
S.
EPA,
2001a;
2001b;
1999;
and
1997).
EPA's
estimates
of
capital
costs
for
these
facilities
average
$
1
million
for
major
POTWs,
$
230,000
for
minor
POTWs,
$
2.4
million
for
major
industrial
facilities,
and
$
1
million
for
minor
industrial
facilities.
Thus,
preliminary
engineering
analysis
and
financial
analysis
costs
could
range
between
$
10,000
and
$
72,000
for
major
facilities,
and
between
$
2,300
and
$
30,000
for
minor
facilities
(
see
Exhibit
4­
3).

Exhibit
4­
3.
Estimated
Cost
per
Facility
to
Prepare
Antidegradation
Review
Cost
Municipal
Facilities
(
POTWs)
Industrial
Facilities
Major
Minor
Major
Minor
Installed
Controls1
$
1,000,000
$
230,000
$
2,400,000
$
1,000,000
Low
Estimate
of
Review
Cost
(
1%
of
Installed
Capital
Cost)
$
10,000
$
2,300
$
24,000
$
10,000
High
Estimate
of
Review
Cost
(
3%
of
Installed
Capital
Cost)
$
30,000
$
6,900
$
72,000
$
30,000
1.
Average
capital
costs
to
facilities
that
EPA
identified
as
requiring
additional
pollution
controls
in
analyses
of
recent
water
quality
standards
actions,
including
establishing
criteria
for
toxic
pollutants
and
upgrading
receiving
water
use
classifications,
in
the
States
of
Alabama,
Iowa,
California,
and
Idaho
(
U.
S.
EPA,
2001a;
2001b;
1999;
1997).

4.3.2.1
Financial
Analysis
Once
the
entity
has
estimated
its
potential
pollution
control
costs,
a
financial
analysis
then
indicates
whether
or
not
these
costs
would
result
in
a
substantial
financial
impact.
The
required
financial
analysis
is
different
for
public
sector
and
private
sector
facilities.

Public
Sector
September
2003
4.0
Method
for
Estimating
Costs
4
 
9
Public
sector
facilities
perform
a
preliminary
analysis
in
which
they
calculate
a
Municipal
Preliminary
Screener
(
MPS)
value:

MPS
=
Average
Total
Pollution
Control
Cost
per
Household/
Median
Household
Income.

The
average
total
pollution
control
cost
per
household
is
the
sum
of
the
existing
costs
(
i.
e.,
current
sewer
rates)
plus
those
attributable
to
the
proposed
pollution
control.
The
value
of
the
MPS
is
evaluated
against
thresholds
of
1%
and
2%,
and
in
conjunction
with
the
secondary
test,
described
below.
If
the
MPS
is
less
than
1%,
then
the
control
requirements
are
not
expected
to
have
a
substantial
financial
impact
on
households
or
interfere
with
economic
development
unless
the
secondary
test
indicates
a
fairly
weak
economy.
MPS
values
above
2%
are
an
indicator
that
the
impact
could
be
substantial,
and
values
in
between
are
indeterminate,
placing
greater
emphasis
on
the
health
of
the
local
economy.

The
secondary
analysis
provides
an
indication
of
a
community's
socioeconomic
health
and
its
ability
to
obtain
financing.
Specific
indicators
are
used
to
demonstrate
the
debt,
socioeconomic,
and
financial
management
conditions
within
the
community:

°
Debt
indicators

bond
rating
­
a
measure,
if
available,
of
the
credit
worthiness
of
the
community

overall
net
debt
as
a
percent
of
full
market
value
of
taxable
property
­
a
measure
of
debt
burden
on
residents
within
the
community
°
Socioeconomic
indicators

unemployment
rate
­
a
measure
of
the
general
economic
health
of
the
community

median
household
income
­
a
measure
of
the
wealth
of
the
community
°
Financial
management
indicators

property
tax
revenue
as
a
percent
of
full
market
value
of
taxable
property
­
a
measure
of
the
funding
capacity
available
to
support
debt
based
on
the
wealth
of
the
community

property
tax
collection
rate
­
a
measure
of
how
well
the
local
government
is
administered.

In
the
analysis,
each
indicator
is
assigned
a
score
from
1
to
3.
Indicator
values
judged
to
be
weak
receive
a
score
of
1,
a
score
of
2
is
for
indicators
judged
to
be
midrange,
and
3
is
for
strong
indicators.
The
workbook
in
U.
S.
EPA
(
1995)
provides
guidelines
for
assigning
values
to
each
indicator
based
on
comparisons
to
established
values,
or
to
national
and
state
indicator
values.
The
scores
are
totaled
and
divided
by
six
to
obtain
a
mean
score,
which
is
used
to
indicate
overall
conditions
within
the
affected
community.
An
average
of
less
than
1.5
is
termed
weak,
1.5
to
2.5
is
termed
midrange,
and
greater
than
2.5
is
termed
strong.

A
joint
consideration
of
the
secondary
test
score
and
the
MPS
is
used
to
determine
whether
implementing
pollution
controls
would
have
a
substantial
financial
impact.
If
the
results
indicate
that
pollution
controls
would
have
adverse
financial
impacts
on
the
community
and,
therefore,
interfere
with
the
proposed
development,
then
the
entity
must
also
show
that
the
development
would
be
of
economic
and
social
importance
to
the
community.
September
2003
4.0
Method
for
Estimating
Costs
4
 
10
Private
Sector
Primary
and
secondary
tests
are
also
performed
for
private
sector
entities.
The
primary
measure
of
impact
for
private
sector
entities
is
the
estimated
decline
in
the
profit
ratio
[
measured
as
pre­
tax
earnings
(
revenues
minus
costs)
divided
by
revenues]
expected
as
a
result
of
incurring
the
pollution
control
expenditures.
However,
unlike
the
financial
analysis
for
public
sector
entities,
there
is
no
established
standard
by
which
to
categorize
the
potential
loss
of
profits
as
significant
or
insignificant.
Instead,
the
profit
ratios
with
and
without
pollution
controls
can
be
compared
with
industry­
wide
profit
ratios
to
evaluate
the
relative
strength
of
the
entity
and
how
incremental
pollution
control
costs
might
affect
its
financial
strength.
However,
if
the
discharger
was
already
in
financial
trouble
(
i.
e.,
not
profitable
or
profit
far
below
industry
norms),
it
may
not
claim
that
substantial
financial
impacts
are
caused
by
compliance
with
water
quality
standards
(
U.
S.
EPA,
1995).

Three
secondary
measures
are
utilized
to
further
define
the
financial
impact
of
the
pollution
control
project.
The
recommended
liquidity
measure
indicates
how
easily
an
entity
can
pay
its
short­
term
expenses,
and
is
measured
using
the
current
ratio:

Current
Ratio
=
Current
Assets/
Current
Liabilities.

An
entity
is
considered
liquid
if
its
current
ratio
is
greater
than
2.
Ratio
values
less
than
2
indicate
potential
liquidity
problems.
However,
the
ratio
value
should
be
compared
with
industry
averages
as
well
as
this
rule­
of­
thumb
value.

Solvency
is
a
measure
of
how
easily
an
entity
can
pay
its
fixed
and
long­
term
liabilities.
Although
there
are
various
solvency
ratios,
the
recommended
one
is
the
Beaver's
Ratio
(
U.
S.
EPA,
1995),
which
is
an
indicator
of
bankruptcy:

Beaver's
Ratio
=
Cash
Flow/
Total
Liabilities.

An
entity
is
considered
solvent
if
its
Beaver's
Ratio
is
greater
than
0.20.
A
ratio
of
less
than
0.15
indicates
insolvency
and
a
high
bankruptcy
risk.
A
ratio
between
0.15
and
0.20
is
indeterminate,
but
indicates
some
bankruptcy
risk.

An
additional
solvency
or
leverage
ratio,
the
debt­
to­
equity
ratio,
provides
insight
into
how
much
debt
is
held
relative
to
equity,
whether
additional
debt
can
be
obtained,
and
whether
existing
debt
can
be
paid.
The
term
leverage
refers
to
the
use
of
debt
to
leverage
equity
to
acquire
more
assets
and
hopefully
provide
a
bigger
return
on
equity.
One
of
the
various
forms
of
the
debt­
to­
equity
ratio
is:

Debt­
to­
Equity
Ratio
=
Long­
term
Liabilities/
Owner's
Equity.

The
ratio
value
should
be
compared
to
similar
businesses
in
the
region
or
industry
averages
to
determine
whether
the
entity's
degree
of
leverage
is
typical
or
whether
it
is
highly
leveraged,
which
indicates
an
increased
risk
of
business
failure
as
well
as
a
higher
difficulty
in
borrowing
to
finance
incremental
control
costs.
September
2003
4.0
Method
for
Estimating
Costs
4
 
11
If
these
financial
tests
indicate
that
pollution
controls
would
have
adverse
financial
impacts
on
the
business
entity
and,
therefore,
interfere
with
the
proposed
development,
then
an
entity
must
also
show
that
the
development
would
be
of
economic
and
social
importance
to
the
community.

4.3.2.2
Determination
of
Importance
This
part
of
the
analysis
also
proceeds
differently
for
public
and
private
sector
entities.
In
both
cases,
the
entity
must
first
identify
the
relevant
geographical
area.
For
public
sector
entities,
this
is
usually
the
municipality
served
by
the
entity.
For
private
sector
entities,
it
is
typically
the
area
in
which
most
of
the
affected
workers
live
and
where
dependent
businesses
are
located.
However,
the
workbook
only
provides
guidelines;
it
does
not
provide
a
quantitative
means
for
making
a
determination
of
importance
for
either
public
or
private
sector
entities.

Public
Sector
U.
S.
EPA
(
1995)
suggests
using
the
following
socioeconomic
indicators
to
determine
whether
or
not
the
development
would
be
important
to
the
affected
community.
Each
indicator
is
analyzed
as
to
how
it
would
change
due
to
the
proposed
development:


median
household
income

community
unemployment
rate

overall
net
debt
as
a
percentage
of
full
market
value
of
taxable
property

percent
of
households
below
the
poverty
line

impact
on
community
development
potential

impact
on
property
values.

Private
Sector
U.
S.
EPA
(
1995)
suggests
using
the
level
of
employment
that
would
be
gained,
as
well
as
any
potential
decrease
in
the
need
for
social
services
such
as
unemployment
insurance
claims
or
subsidized
housing
due
to
the
development,
as
indicators
of
importance.
Other
factors
to
consider
include
potential
impacts
on
local
tax
revenues
and
service
fees
that
might
help
improve
the
level
of
services
throughout
the
area.

4.3.2.3
State
Review
Costs
for
the
proposed
antidegradation
provision
will
include
the
cost
of
the
State
review.
EPA
assumed
that
the
State's
review
of
the
engineering
cost
analysis
and
financial
impact
analysis
could
require
up
to
24
hours.
The
review
process
includes
validating
source
data
and
checking
calculations,
as
well
as
evaluating
the
engineering
design
and
the
conclusions
regarding
potential
financial
and
community
impacts.
The
State
will
also
need
to
evaluate
the
information
provided
regarding
the
importance
of
the
proposed
development
to
the
economic
and
social
conditions
of
the
affected
community.
The
proposed
rule
also
recommends
a
notification
and
public
comment
period.
Based
on
time
estimates
to
review
and
respond
to
comments
on
an
individual
permit
issue
to
a
single
concentrated
animal
feeding
operation
(
U.
S.
EPA,
2002a),
EPA
assumed
that,
on
September
2003
4.0
Method
for
Estimating
Costs
4
 
12
average,
the
notification
and
response
to
comments
activities
will
require
an
average
of
100
hours.
Thus,
the
total
time
requirement
to
process
each
request
is
124
hours.

EPA
assumed
a
national
average
hourly
compensation
rate
of
$
42.24
to
estimate
the
cost
of
State
activities
(
BLS,
2003).
This
rate
is
for
State
and
local
government
workers
in
professional
speciality
and
technical
occupations
(
for
first
quarter
of
2003).
The
hour
requirement
and
compensation
rate
estimates
result
in
an
average
cost
of
$
5,200
per
review.
September
2003
5.0
Results
5
 
1
5.0
Results
This
section
presents
the
results
of
the
analysis,
and
describes
the
limitations
and
uncertainties
associated
with
these
results.

5.1
Temperature
Criteria
and
Uses
Exhibit
5­
1
provides
a
summary
of
the
number
of
potentially
affected
facilities
and
the
estimated
potential
costs
associated
with
the
temperature
provisions
of
the
proposed
rule.
Appendix
A
provides
detailed
analyses
for
each
of
the
sample
facilities.
(
A
data
appendix,
provided
under
separate
cover,
contains
underlying
data
for
the
facility
analyses.)
Appendix
B
shows
the
extrapolation
of
costs
for
minor
dischargers.

Exhibit
5­
1.
Estimated
Potential
Statewide
Costs
Attributable
to
the
Temperature
Provision
of
the
Proposed
Rule
($
2003)
1
Category
Facilities
Evaluated
(
Total
Affected)
Annual
Capital
Annual
O&
M
Total
Annual
Costs
Major
Municipal
3
(
3)
$
0
$
5,190
$
5,190
Major
Industrial
1
(
1)
$
421,500
$
34,260
$
74,050
Minor
Dischargers2
5
(
44)
$
0
$
119,680
$
119,680
Total
8
(
48)
$
421,500
$
159,130
$
198,920
1.
Annual
costs
represent
total
potential
costs
for
all
facilities
affected
by
the
proposed
rule.
Total
annual
costs
are
the
sum
of
annual
capital
costs
(
i.
e.,
total
capital
costs
that
have
been
annualized
at
7%
over
20
years)
and
annual
O&
M
expenditures.
2.
Costs
for
evaluated
facilities
extrapolated
to
all
affected
potentially
facilities.

5.2
IGDO
Criteria
Potential
costs
associated
with
meeting
the
revised
minimum
IGDO
standard
of
8
mg/
L
are
zero.

5.3
Antidegradation
Procedures
Multiplying
the
potential
number
of
affected
facilities
from
Exhibit
4­
2
with
the
estimated
perfacility
analysis
costs
(
Exhibit
4­
3)
provides
estimates
of
the
potential
costs
of
the
antidegradation
provision
to
dischargers
in
the
State
(
Exhibit
5­
2).
Over
a
5­
year
period,
the
cost
estimates
range
from
$
70,900
to
$
212,700.
The
average
annual
cost
is
one­
fifth
of
the
5­
year
estimates,
or
$
14,180
to
$
42,540.

The
State
cost
to
review
8
antidegradation
requests
over
five
years
is
$
41,600,
based
on
EPA's
estimate
of
an
average
of
$
5,200
per
review.
The
average
annual
cost
is
one­
fifth
this
amount,
or
$
8,320.
The
total
annual
cost
for
the
antidegradation
provision
in
the
proposed
rule
equals
the
sum
of
the
entity
costs
(
ranging
from
$
14,180
to
$
42,540)
and
State
review
costs
($
8,320).
Thus,
potential
total
annual
cost
ranges
from
$
22,500
to
$
50,860.
September
2003
5.0
Results
5
 
2
Exhibit
5­
2.
Estimated
Potential
Facility
Costs
Attributable
to
the
Antidegradation
Provision
of
the
Proposed
Rule
($
2003/
yr)

Facility
Type
Low
Estimate
High
Estimate
Major
Minor
Major
Minor
Municipal
(
POTWs)
1,2
$
10,000
$
6,900
$
30,000
$
20,700
Industrial2
$
24,000
$
30,000
$
72,000
$
90,000
Subtotal
$
34,000
$
36,900
$
102,000
$
110,700
Total
Every
5
Years
$
70,900
$
212,700
Average
Annual
Cost3
$
14,180
$
42,540
1.
EPA
included
small,
sanitary
discharges
from
apartment
complexes
and
other
residential
and
commercial
complexes
in
the
minor
POTW
category
because
they
are
more
similar
to
municipal
facilities
than
industrial
facilities.
2.
The
cost
estimates
are
based
on
number
of
facilities
estimated
to
require
antidegradation
reviews
over
a
5­
year
period.
3.
Average
annual
costs
equal
one­
fifth
of
the
5­
year
costs.

5.4
Total
Statewide
Costs
EPA's
total
potential
Statewide
cost
of
the
proposed
rule
is
approximately
$
216,230
to
$
244,590
per
year
(
Exhibit
5­
3).

Exhibit
5­
3.
Estimated
Potential
Annual
Statewide
Costs
Attributable
to
the
Proposed
Rule
($
2003/
yr)

Provision
Estimated
Annual
Cost
Temperature
Uses
and
Criteria1
$
198,920
IGDO
Criteria
$
0
Antidegradation
Procedures2
$
22,500
­
$
50,860
Total
$
221,420
­
$
249,780
1.
Costs
are
annualized
at
7%
over
20
years.
2.
Costs
equal
one­
fifth
of
cost
estimates
(
to
discharger
and
State)
calculated
for
a
five­
year
period.

EPA's
estimate
is
subject
to
a
number
of
limitations
associated
with
the
data
available
for
the
analysis.
These
uncertainties
are
described
in
Exhibit
5­
4.
September
2003
5.0
Results
5
 
3
Exhibit
5­
4.
Limitations
of
the
Analysis
Limitation/
Assumption
Potential
Impact
on
Costs
Comment
EPA
did
not
consider
cost
savings
where
the
proposed
uses
and
criteria
are
less
stringent
than
the
current
State
uses
and
criteria
(
e.
g.,
EPA
temperature
criterion
for
bull
trout
protection
is
12

C
and
the
current
State
criterion
is
10

C).

Facilities
may
be
allowed
to
discharge
at
higher
temperatures
under
the
proposed
uses
and
criteria
than
under
current
State
uses
and
criteria,
and
may
therefore
incur
cost
savings
associated
with
fewer
controls.

EPA
did
not
consider
cost
savings
where
the
proposed
implementation
procedures
are
less
stringent
than
the
current
State
implementation
procedures
(
e.
g.,
EPA
allows
a
discharger
to
increase
the
downstream
temperature
by
0.3

C
and
the
current
State
procedures
only
allow
0.14

C).

Facilities
may
be
allowed
to
discharge
at
higher
temperatures
under
the
proposed
implementation
procedures
than
under
current
State
implementation
procedures,
and,
may
therefore
incur
cost
savings
associated
with
fewer
controls.

Receiving
water
data
may
not
be
representative
of
current
stream
conditions.
?
Monitoring
stations
may
be
several
miles
upstream
of
the
discharge
before
confluences
with
major
tributaries.
STORET
data
are
only
as
recent
as
1998.

The
average
annual
requests
for
antidegradation
review
may
be
higher
or
lower
than
EPA's
estimate.
?
EPA
based
its
estimate
of
the
annual
reviews
on
the
frequency
of
requests
among
dischargers
in
Oregon
over
a
limited
time
period.
More
frequent
requests
in
the
future
could
result
in
higher
annual
costs;
less
frequent
requests
could
result
in
lower
costs.

The
State
effort
for
antidegradation
review
is
based
on
an
estimate
of
the
average
amount
of
time
to
process
an
individual
permit,
which
may
over
or
understate
the
average
review
hours.
?
EPA
used
an
hour
estimate
from
a
final
NPDES
rule
for
CAFOs.
The
average
amount
of
time
required
to
documentation
submitted
for
an
antidegradation
review
may
be
higher
or
lower.

Key:
+
=
Costs
are
potentially
overstated
?
=
Affect
on
costs
is
unknown.
September
2003
6.0
References
6
 
1
6.0
References
Bureau
of
Labor
Statistics
(
BLS).
2003.
Employer
Costs
for
Employee
Compensation.
http://
data.
bls.
gov/
servlet/
SurveyOutputServlet?
jrunsessionid=
1061853963147268772,
accessed
8/
25/
03.

Oregon
Department
of
Environmental
Quality
(
ODEQ).
2001.
Temperature
Management
Plans:
Internal
Directive
for
Existing
Point
Source
Dischargers.

R.
S.
Means.
2001.
Cost
Works
Building
Construction
Cost
Data.

U.
S.
EPA.
2002a.
Supporting
Statement
for
the
Information
Collection
Request
for
the
Final
Regulatory
Revisions
to
the
National
Pollutant
Discharge
Elimination
System
Regulations
for
Concentrated
Animal
Feeding
Operations
and
Feedlot
Effluent
Limitations
Guidelines.
Washington,
D.
C.:
U.
S.
EPA,
Office
of
Water.

U.
S.
EPA.
2002b.
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
II
Existing
Facilities
Rule.
Office
of
Water,
EPA
821­
R­
02­
003.

U.
S.
EPA.
2001a.
Economic
Analysis
of
the
Proposed
Water
Quality
Standards
Rule
for
the
State
of
Alabama.
Washington,
D.
C.:
U.
S.
EPA,
Office
of
Water.

U.
S.
EPA.
2001b.
Economic
Analysis
of
the
Revised
Water
Quality
Standards
Rule
for
the
State
of
Iowa.
Washington,
D.
C.:
U.
S.
EPA,
Office
of
Water.

U.
S.
EPA.
1999.
Economic
Analysis
of
the
California
Toxics
Rule.
Washington,
D.
C.:
U.
S.
EPA,
Office
of
Science
and
Technology.

U.
S.
EPA.
1997.
Economic
Analysis
of
the
Final
Water
Quality
Standards
for
Idaho.
Washington,
D.
C.:
U.
S.
EPA,
Office
of
Science
and
Technology.

U.
S.
EPA.
1995.
Interim
Economic
Guidance
for
Water
Quality
Standards,
Workbook.
Office
of
Water,
EPA­
823­
B­
95­
002.

U.
S.
EPA.
1986.
Ambient
Aquatic
Life
Water
Quality
Criteria
for
Dissolved
Oxygen
(
Freshwater).
Office
of
Water
Regulations
and
Standards,
Criteria
and
Standards
Division.
EPA
440/
5­
86­
003.
Appendix
A:
Facility
Analyses
Glide­
Idleyld
Park
(
Douglas
County
Public
Works)
Government
Camp
Sanitary
District
Medford
Regional
Water
Reclamation
Facility
Oakridge
Sewage
Treatment
Plant
Shady
Cove
Sewage
Treatment
Plant
Siletz
Sewage
Treatment
Plant
Stayton
Wastewater
Treatment
Plant
Sweet
Home
Wastewater
Treatment
Plant
Weyerhaeuser
Company
September
2003
Appendix
A.
Facility
Analyses
A
 
1
Glide­
Idleyld
Park
(
Douglas
County
Public
Works)

Facility
Description
Glide­
Idleyld
Park
(
NPDES
No.
OR0030261)
is
located
in
Glide,
Oregon.
The
facility
is
owned
and
operated
by
the
Douglas
County
Public
Works
Department.
The
facility
was
built
in
1980
and
treats
domestic
wastewater
and
septic
tank
effluent
from
about
500
households
from
Glide
and
Idleyld
Park.
EPA
classifies
the
discharge
as
a
minor
discharge.
The
facility
has
an
average
dry
weather
design
flow
of
0.28
mgd,
and
discharges
to
the
North
Umpqua
River
at
river
mile
29
in
the
Umpqua
basin.

Treatment
Processes
The
facility's
2000
permit
evaluation
sheet
indicates
that
current
treatment
processes
consist
of
two
parallel
oxidation
ditches
with
clarification,
aerobic
digestion,
sedimentation,
filtration,
and
gas
chlorination.

Applicable
Designated
Uses
and
Criteria
The
North
Umpqua
River
is
currently
designated
for
salmonid
spawning
from
September
15
to
May
31
and
salmonid
rearing
the
remainder
of
the
year.
EPA
revised
the
time
period
for
which
the
salmonid
spawning
criterion
apply
to
September
1
to
May
15,
and
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
Exhibit
A­
1
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
1.
Designated
Use
and
Applicable
Criteria,
Glide­
Idleyld
Park
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Spawning
Temperature
12.8

C,
Sep
15
­
May
31
13

C,
Sep
1
­
May
15
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
and
Limits
There
are
no
effluent
temperature
data
available
for
this
facility.
The
facility
does
not
have
a
limit
for
temperature
in
their
2000
permit.
However,
the
North
Umpqua
River
at
river
mile
29.0
is
currently
listed
on
the
State's
303(
d)
list
for
salmonid
rearing
during
the
summer.

Summary
of
Receiving
Water
Data
There
is
no
receiving
water
monitoring
station
with
recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
available.
3EPA's
proposed
implementation
procedures
would
result
in
a
dilution
ratio
of
365:
1.
Given
the
high
dilution
allowed,
the
facility
is
not
likely
to
cause
an
increase
of
greater
than
0.14

C
above
the
applicable
criterion.

September
2003
Appendix
A.
Facility
Analyses
A
 
2
Controls
Needed
No
effluent
data
exist
for
this
facility.
However
in
1997,
ODEQ
evaluated
the
impact
of
the
effluent
on
the
receiving
water
and
determined
that
because
of
the
high
dilution
ratio
(
1452:
1
under
current
implementation
procedures),
the
effluent
was
not
contributing
to
a
measurable
temperature
increase
instream.
3
Therefore,
the
facility
would
not
likely
incur
costs
associated
with
this
rule.
September
2003
Appendix
A.
Facility
Analyses
A
 
3
Government
Camp
Sanitary
District
Facility
Description
Government
Camp
Sanitary
District
(
NPDES
No.
OR0027791)
is
located
in
Clackamas
County
in
Oregon.
In
2000,
the
facility
expanded
by
moving
to
a
new
site
and
constructing
a
new
sequencing
batch
reactor
(
SBR)
plant
with
ultraviolet
(
UV)
disinfection.
The
facility
has
an
annual
average
daily
flow
of
0.104
mgd
and
treats
domestic
wastewater
for
a
population
of
753
residents
in
Government
Camp.
EPA
classifies
the
discharge
as
a
minor
discharge.
The
facility
intermittently
discharges
treated
wastewater
(
for
15­
30
minutes
about
10
times
per
day)
to
Camp
Creek
at
river
mile
6.0
in
the
Sandy
basin.

Treatment
Processes
The
facility's
2002
permit
renewal
application
indicates
that
current
treatment
processes
consist
of
screens,
sequencing
batch
reactors,
aerobic
digestion,
equalization,
and
UV
disinfection.
Sludge
is
sent
to
a
lime
stabilization
tank
and
is
then
land
applied.

Applicable
Designated
Uses
and
Criteria
Camp
Creek
is
currently
designated
for
salmonid
rearing
all
year
round.
EPA
revised
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
Exhibit
A­
2
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
2.
Designated
Use
and
Applicable
Criteria,
Government
Camp
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
3
shows
maximum
7­
day
moving
averages
of
effluent
temperature
for
the
facility
for
each
month
from
July
2000
through
June
2003
(
in
months
where
data
are
available).
The
exhibit
also
shows
the
average
of
the
maximum
monthly
temperatures.
The
underlying
daily
temperatures
are
provided
in
a
separate
data
appendix.

Exhibit
A­
3.
Maximum
Average
Effluent
Temperatures,
Government
Camp
(

C)
1
Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
2000
na
na
na
na
na
na
15.9
16.1
15.1
13.4
11.0
na
2001
9.6
9.0
9.0
8.6
13.0
15.1
17.1
18.4
18.6
17.1
10.6
10.0
2002
9.6
8.0
9.7
9.1
8.9
13.7
18.0
na
15.7
13.0
10.0
9.0
2003
9.0
9.3
8.9
8.1
11.9
14.5
na
na
na
na
na
na
Exhibit
A­
3.
Maximum
Average
Effluent
Temperatures,
Government
Camp
(

C)
1
Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
September
2003
Appendix
A.
Facility
Analyses
A
 
4
Average2
9.4
8.8
9.2
8.6
11.2
14.5
17.0
17.3
16.5
14.5
10.5
9.5
Source:
Government
Camp
Discharge
Monitoring
Reports,
2000­
2003.
na
=
data
not
available.
1.
Maximum
7­
day
moving
averages
for
each
month.
2.
Average
of
maximum
7­
day
moving
averages
for
each
month
where
data
are
available.

Summary
of
Receiving
Water
Data
The
only
applicable
receiving
water
monitoring
station
with
recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
is
located
just
upstream
of
the
facility's
discharge,
at
Station
No.
26424.
Exhibit
A­
4
summarizes
the
maximum
of
the
7­
day
moving
averages
for
temperature
recorded
at
that
monitoring
station
for
June
2001
through
September
2001.
The
underlying
daily
data
are
provided
in
a
separate
data
appendix.

Exhibit
A­
4.
Maximum
Average
Temperatures
Upstream
of
Government
Camp
at
Station
No.
26424,
June­
September
2001
(

C)

Pollutant
Maximum
7­
Day
Moving
Averages
Jun
Jul
Aug
Sep
Temperature
9.4
9.8
9.9
9.1
Source:
ODEQ
(
2003).

Controls
Needed
Exhibit
A­
4
indicates
that
the
stream
temperature
is
currently
below
the
proposed
core
rearing
criteria.
Therefore
given
the
low
flow
of
the
discharge
(
0.1
mgd)
in
relation
to
the
flow
of
the
stream
(
3.7
mgd),
it
is
unlikely
that
the
facility
would
cause
a
temperature
increase
of
greater
than
0.14

C
above
the
summer
maximum
criterion
of
16

C.
September
2003
Appendix
A.
Facility
Analyses
A
 
5
Medford
Regional
Water
Reclamation
Facility
Facility
Description
The
City
of
Medford
Wastewater
Treatment
Plant
(
NPDES
No.
OR0026263)
is
located
in
Central
Point,
Oregon.
The
existing
treatment
plant
was
initially
constructed
in
1970,
and
has
been
expanded
several
times
since
1980.
The
facility's
average
dry
weather
design
flow
is
20
mgd.
The
facility
treats
wastewater
from
Medford,
Central
Point,
Jacksonville,
Talent,
Phoenix,
Eagle
Point,
the
White
City
Sanitary
District,
Bear
Creek
Valley
Sanitary
District,
and
some
unincorporated
areas
of
Jackson
County,
and
also
accepts
leachate
from
the
Dry
Creek
Landfill.
EPA
classifies
the
discharge
as
a
major
discharge.
The
facility
discharges
to
the
Rogue
River
at
river
mile
130.5
through
a
multiport
diffuser.

Treatment
Processes
The
facility's
1997
permit
evaluation
report
indicates
that
current
treatment
processes
consist
of
headworks,
grit
removal,
primary
treatment,
trickling
filtration/
activated
sludge
secondary
treatment,
secondary
clarification,
chorine
disinfection,
and
dechlorination.
Solids
are
dewatered
with
a
gravity
belt
thickener
and
anaerobically
digested.
Sludge
is
then
dried
in
storage
lagoons
and
drying
beds
before
being
land
applied.

Applicable
Uses
and
Criteria
The
Rogue
River
at
river
mile
130.5
is
currently
designated
for
salmonid
rearing
all
year
round.
EPA
revised
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
(
Note
that
the
Rogue
River
is
also
designated
for
salmonid
spawning,
however,
the
time
period
that
EPA
has
designated
is
less
stringent
than
the
current
spawning
time
period.)
Exhibit
A­
5
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
5.
Designated
Use
and
Applicable
Criteria,
Medford
RWRF
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
Effluent
temperature
data
are
not
available
from
EPA's
PCS
database.
However,
the
facility's
temperature
management
plan
(
TMP)
provides
a
summary
of
the
maximum
of
the
7­
day
moving
averages
of
maximum
daily
temperature
recordings
for
each
year
from
1996
to
1999
(
Exhibit
A­
6).
September
2003
Appendix
A.
Facility
Analyses
A
 
6
Exhibit
A­
6.
Maximum
Average
Effluent
Temperatures,
Medford
RWRF
(

C)

Year
7­
Day
Moving
Average
Temperatures
Maximum
Yearly
Week
of
Maximum
Yearly
1996
24.2
7/
25
­
7/
31
1997
24.2
8/
1
­
8/
6
and
8/
12
­
8/
18
1998
23.9
8/
30
­
9/
5
1999
23.6
8/
23
­
8/
29
Source:
West
Yost
and
Associates
(
2001).

Summary
of
Receiving
Water
Data
Recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
from
upstream
of
the
discharge
are
available
from
the
facility's
TMP.
The
monitoring
station
is
located
200
feet
upstream
of
the
outfall
on
the
south
side
of
the
river.
Exhibit
A­
7
summarizes
the
maximum
of
the
7­
day
moving
average
of
the
daily
maximum
temperature
for
each
year
from
1996
to
2000.

Exhibit
A­
7.
Maximum
Average
Temperatures
200
ft.
Upstream
of
Medford
RWRF
Discharge
(

C)

Year
7­
Day
Moving
Average
Temperatures
Maximum
Yearly
Week
of
Maximum
Yearly
1996
18.3
7/
21
­
7/
27
1997
19.3
8/
3
­
8/
9
and
8/
12
­
8/
18
1999
18.6
8/
16
­
8/
22
2000
20.2
7/
22
­
7/
28
Source:
West
Yost
and
Associates
(
2001).

Controls
Needed
Oregon's
current
WQS
prohibit
any
receiving
water
temperature
increase
greater
than
0.14

C
above
the
applicable
criterion.
Exhibit
A­
8
summarizes
how
the
effluent
is
most
likely
affecting
stream
temperature
compared
to
the
current
criteria
and
the
proposed
criteria.

Exhibit
A­
8
indicates
that
the
facility's
current
discharge
would
contribute
to
an
instream
temperature
exceedance
of
greater
than
0.14

C
above
current
or
revised
criteria.
To
meet
the
current
State
criterion
for
rearing,
the
facility
would
have
to
decrease
its
average
maximum
7­
day
moving
average
effluent
temperature
during
the
summer
to
19.9

C
(
about
a
4

C
reduction).
An
additional
2.8

C
decrease
in
temperature
(
an
effluent
temperature
of
17.1

C)
would
be
necessary
to
meet
the
revised
rearing
criterion.
September
2003
Appendix
A.
Facility
Analyses
A
 
7
Exhibit
A­
8.
Effect
of
Effluent
on
Receiving
Water,
Medford
RWRF
Parameter
Current
Criterion
EPA
Proposed
Criterion
7Q10
Stream
Flow
(
cfs)
846
846
Stream
Temperature/
Criterion
(

C)
17.8
16.0
Effluent
Flow
(
cfs)
30.9
30.9
Effluent
Temperature
(

C)
1
24.0
24.0
Dilution
Ratio
13.9:
12
6.8:
13
Temperature
at
Edge
of
Mixing
Zone
(

C)
18.22
17.03
Increase
above
Applicable
Criterion
(

C)
0.42
1.03
Effluent
Temperature
Needed
for
Compliance
with
Applicable
Criterion
(

C)
19.9
17.1
Reduction
in
Current
Effluent
Temperature
Necessary
(

C)
4.1
6.9
cfs
=
cubic
feet
per
second
1.
Average
of
maximum
7­
day
moving
average
temperatures
in
Exhibit
A­
6.
2.
Dilution
at
edge
of
RMZ.
From
facility's
TMP,
calculated
using
Cormix
modeling
(
West
Yost
and
Associates,
2001).
3.
Dilution
at
edge
of
RMZ.
Calculated
using
25%
of
7Q10
flow.

Under
current
State
WQS
the
facility
was
required
to
develop
a
TMP
that
outlines
the
measures
it
will
take
to
reduce
the
thermal
load
to
the
Rogue
River.
The
facility
has
developed
two
alternatives
for
reducing
effluent
temperatures
to
the
necessary
levels:

°
Alternative
1
­
effluent
reuse
for
irrigation
of
most
agricultural
crops
except
food
crops,
processed
food
crops,
and
orchards
and
vineyards
during
the
dry
weather
season
°
Alternative
2
­
effluent
cooling
through
installation
of
cooling
towers
and
chillers.

The
facility
recommends
the
implementation
of
the
reuse
alternative
as
the
lowest
cost
option
for
meeting
the
current
State
core
rearing
criterion.
Implementing
this
option
would
also
enable
compliance
with
EPA's
proposed
core
rearing
criterion.
Therefore,
the
facility
would
not
likely
incur
costs
associated
with
this
rule
because
controls
implemented
to
meet
the
current
State
criterion
will
also
achieve
EPA's
revised
criterion.
September
2003
Appendix
A.
Facility
Analyses
A
 
8
Oakridge
Sewage
Treatment
Plant
Facility
Description
The
Oakridge
Sewage
Treatment
Plant
(
NPDES
No.
OR0022314)
is
located
in
Lane
County,
Oregon.
The
facility
was
originally
constructed
in
1968,
and
upgraded
from
an
activated
sludge
plant
with
chlorination
to
a
sequencing
batch
reactor
with
ultraviolet
disinfection
in
1994.
The
facility
has
an
average
dry
weather
flow
of
0.47
mgd
and
treats
wastewater
from
the
City
of
Oakridge,
mainly
west
of
Jones
Road
and
south
of
the
Southern
Pacific
Railroad.
EPA
classifies
this
discharge
as
a
minor
discharge.
The
facility
discharges
to
the
Middle
Fork
Willamette
River
at
river
mile
39.8.
At
this
location,
the
river
segment
is
not
currently
water
quality
limited
for
any
parameter.

Treatment
Processes
The
facility's
2001
permit
evaluation
report
indicates
that
current
treatment
processes
consist
of
screens,
activated
sludge
sequencing
batch
reactors,
aeration,
settling,
and
ultraviolet
disinfection.
Sludge
is
treated
in
an
aerobic
digestion
system
and
a
lined
sludge
holding
lagoon
before
being
land
applied
on
forested
United
States
Forest
Service
land
adjacent
to
the
treatment
plant.

Applicable
Uses
and
Criteria
The
Middle
Fork
Willamette
River
is
currently
designated
for
salmonid
spawning
from
October
1
to
May
31
and
salmonid
rearing
the
remainder
of
the
year.
EPA
revised
the
time
period
for
which
the
salmonid
spawning
criterion
apply
to
September
15
to
May
15,
and
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
Exhibit
A­
9
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
9.
Designated
Use
and
Applicable
Criteria,
Oakridge
STP
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Spawning
Temperature
12.8

C,
Oct
1
­
May
31
13

C,
Sep
15
­
May
15
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
Exhibit
A­
10
shows
the
maximum
monthly
effluent
temperature
for
the
facility
from
October
2000
through
March
2003.
The
exhibit
also
shows
the
average
of
the
maximum
monthly
temperatures.
The
complete
daily
temperature
data
are
provided
in
a
separate
data
appendix.

Exhibit
A­
10.
Maximum
Monthly
Effluent
Temperatures,
Oakridge
STP
(

C)

Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
2000
na
na
na
na
na
na
na
na
na
18.4
16.1
13.3
2001
12.1
12.6
12.9
13.3
16.7
19.5
19.7
20.7
20.1
18.4
18.4
14.1
Exhibit
A­
10.
Maximum
Monthly
Effluent
Temperatures,
Oakridge
STP
(

C)

Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
September
2003
Appendix
A.
Facility
Analyses
A
 
9
2002
12.8
12.1
12.4
14.5
17.0
20.0
20.7
19.9
20.1
18.1
15.8
14.2
2003
12.9
13.0
13.4
na
na
na
na
na
na
na
na
na
Average1
12.6
12.6
12.9
13.9
16.9
19.8
20.2
20.3
20.1
18.3
16.8
13.9
Source:
ODEQ
(
2003).
na
=
not
available.
1.
Average
of
maximum
monthly
values.

Summary
of
Receiving
Water
Data
There
is
no
receiving
water
monitoring
station
with
recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
available.
The
Middle
Fork
Willamette
is
not
on
the
State's
303(
d)
at
river
mile
39.8,
however,
segments
upstream
and
downstream
are
on
the
303(
d)
list
for
temperature.
Therefore,
since
it
is
likely
that
the
receiving
steam
segment
would
be
on
the
State's
303(
d)
list
for
temperature
if
recent
data
were
available,
EPA
assumed
that
the
stream
is
exceeding
the
State's
rearing
and
spawning
criteria.

Controls
Needed
Oregon's
current
WQS
prohibit
any
receiving
water
temperature
increase
greater
than
0.14

C
above
the
applicable
criterion
in
waters
that
exceed
the
criterion.
Exhibit
A­
11
summarizes
how
the
effluent
is
most
likely
affecting
stream
temperature
compared
to
the
current
criteria
and
the
proposed
criteria.

Exhibit
A­
11.
Effect
of
Effluent
on
Receiving
Water,
Oakridge
STP
Parameter
Current
Oregon
Criteria
EPA
Proposed
Criteria
Rearing
(
Jul/
Aug)
Spawning
(
Oct
1­
May
31)
Rearing
(
Jul/
Aug)
Spawning
(
Sep
15­
May
15)

Stream
Temperature/
Criterion
(

C)
17.8
12.8
16.0
13.0
Effluent
Temperature
(

C)
20.3
18.3
20.3
20.01
Dilution
Ratio2
10:
1
10:
1
10:
1
10:
1
Temperature
at
Edge
of
Mixing
Zone
(

C)
18.03
13.3
16.39
13.64
Increase
above
Applicable
Criterion
(

C)
0.23
0.50
0.39
0.64
Effluent
Temperature
Needed
for
Compliance
with
Applicable
Criterion
(

C)
19.3
14.3
17.5
14.5
Reduction
in
Current
Effluent
Temperature
Necessary
(

C)
1.0
4.0
2.8
5.5
1.
Represents
average
of
maximum
recorded
temperatures
for
September
15,
2001
­
May
15,
2002
and
September
15,
2002
­
May
15,
2003.
2.
Dilution
at
edge
of
RMZ.
Dilution
calculated
using
Cormix
modeling
(
ODEQ,
1998a).
September
2003
Appendix
A.
Facility
Analyses
A
 
10
Exhibit
A­
11
indicates
that
the
facility's
current
discharge
would
contribute
to
an
instream
temperature
exceedance
of
greater
than
0.14

C
above
current
or
revised
criteria.
To
meet
the
current
State
criterion
for
rearing,
the
facility
would
have
to
decrease
their
average
maximum
effluent
temperature
during
the
summer
to
19.3

C
(
about
1

C).
An
additional
1.8

C
decrease
in
temperature
(
an
effluent
temperature
of
17.5

C)
would
be
necessary
to
meet
EPA's
proposed
rearing
criterion.
For
compliance
with
the
State
spawning
criterion,
the
facility
would
have
to
reduce
their
average
maximum
effluent
temperature
from
October
to
May
to
14.3

C
(
about
4

C).
For
compliance
with
EPA's
proposed
spawning
criterion,
the
facility
would
need
to
reduce
its
effluent
another
1.5

C
from
September
15
to
October
1
(
an
additional
two­
week
period).

The
facility
does
not
currently
have
a
temperature
management
plan
(
TMP).
Under
current
State
WQS,
the
facility
would
be
required
to
develop
a
TMP
because
it
has
been
shown
that
the
discharge
is
contributing
to
an
exceedance
of
the
current
criteria.
Based
on
TMPs
from
similar
facilities,
the
facility
would
most
likely
pursue
low­
cost
options
first.
EPA
assumed
that
the
facility
would
most
likely
pursue
process
optimization
or
a
waste
minimization
program
to
reduce
temperatures
to
meet
the
current
rearing
criterion
(
since
only
a
1

C
decrease
is
necessary).
To
meet
the
current
spawning
criterion,
EPA
assumed
that
the
facility
would
use
a
combination
of
land
application/
water
reuse
and
discharge
in
October,
November,
and
May.
Based
on
current
effluent
temperatures
and
available
dilution,
EPA
calculated
that
the
facility
could
discharge
to
the
receiving
water
up
to
0.12
mgd
in
October
and
0.17
mgd
in
November
and
May,
with
the
remaining
discharge
(
about
0.35
mgd
in
October
and
0.30
mgd
in
November
and
May)
being
land
applied
or
reused
by
another
facility
(
e.
g.,
industrial
facility,
park,
farm).
These
measures
would
also
reduce
effluent
temperatures
to
the
levels
necessary
for
compliance
with
the
revised
criterion.
However
the
facility
would
incur
incremental
costs
of
extending
such
treatment
options
to
a
greater
flow
(
for
the
greater
temperature
reduction
in
September
for
spawning)
or
a
longer
time
period
(
change
in
spawning
time
period
and
addition
of
June,
July,
and
August
rearing
months).

Exhibit
A­
12
summarizes
the
control
costs
associated
with
reducing
effluent
temperatures
to
the
required
levels.
EPA
assumed
that
the
facility
would
land
apply
or
reuse
the
portion
of
the
effluent
it
could
not
discharge.
The
costs
represent
the
incremental
costs
necessary
for
land
application
or
effluent
reuse
for
June,
July,
August,
and
the
second
half
of
September.

Exhibit
A­
12.
Summary
of
Compliance
Costs
($
2003),
Oakridge
STP
Control
Total
Capital
Annual
O&
M
Total
Annual
Incremental
Land
Application/
Water
Reuse
­
$
13,6001
$
13,600
Source:
R.
S.
Means
(
2001).
1.
Represents
costs
to
monitor
and
maintain
the
system
for
an
additional
3.5
months.
September
2003
Appendix
A.
Facility
Analyses
A
 
11
Shady
Cove
Sewage
Treatment
Plant
Facility
Description
The
Shady
Cove
Sewage
Treatment
Plant
(
NPDES
No.
OR0030660)
is
located
in
Jackson
County,
Oregon.
The
activated
sludge
facility
began
operation
in
1980,
and
has
not
been
expanded
or
upgraded
recently.
The
facility
treats
domestic
wastewater
from
residential
and
commercial
facilities
in
the
City
of
Shady
Cove.
Two
homes
from
outside
the
city
limits
are
also
connected
to
the
sewer
system
due
to
failed
septic
systems.
EPA
classifies
the
discharge
as
a
minor
discharge.
The
facility
has
an
average
dry
weather
design
flow
of
0.45
mgd,
and
discharges
to
the
Rogue
River
at
river
mile
143.1
in
the
Rogue
basin.

Treatment
Processes
The
facility's
1997
permit
evaluation
report
indicates
that
current
treatment
processes
consist
of
preliminary
screening,
aeration,
secondary
clarification,
sand
filtration,
and
chlorination.
Waste
secondary
sludge
is
aerobically
digested
and
dewatered
by
a
vertical
screw
thickener.
The
thickened
sludge
is
then
sent
to
a
paved
and
covered
drying
bed.
Dried
biosolids
that
meet
vector
attraction
and
pathogen
reduction
requirements
are
land
applied
at
selected
sites
in
Jackson
County.

Applicable
Designated
Uses
and
Criteria
River
mile
143.1
of
the
Rogue
River
is
currently
designated
for
salmonid
spawning
from
October
1
to
May
31
and
for
salmonid
rearing
the
remainder
of
the
year.
EPA
revised
the
time
period
for
which
the
salmonid
spawning
criterion
apply
to
September
15
to
June
15,
and
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
Exhibit
A­
13
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
13.
Designated
Use
and
Applicable
Criteria,
Shady
Cove
STP
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Spawning
Temperature
12.8

C,
Oct
1
­
May
31
13

C,
Sep
15
­
Jun
15
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
14
shows
maximum
7­
day
moving
averages
of
effluent
temperature
for
the
facility
for
each
month
from
June
2000
through
May
2003.
The
exhibit
also
shows
the
average
of
the
maximum
monthly
7­
day
averages.
The
underlying
daily
temperatures
are
provided
in
a
separate
data
appendix.
September
2003
Appendix
A.
Facility
Analyses
A
 
12
Exhibit
A­
14.
Maximum
Average
Effluent
Temperatures,
Shady
Cove
STP
(

C)
1
Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
2000
na
na
na
na
na
23.2
24.0
24.6
22.8
21.1
17.2
14.2
2001
12.7
12.8
15.6
16.8
21.4
21.5
23.6
24.1
23.1
21.2
17.6
12.8
2002
12.0
12.1
15.0
16.6
19.5
22.5
24.2
23.2
23.0
20.1
16.4
14.6
2003
12.9
12.3
13.9
14.7
19.6
na
na
na
na
na
na
na
Average2
12.6
12.4
14.8
16.0
20.1
22.4
23.9
24.0
23.0
20.8
17.1
13.9
Source:
Shady
Cove
Discharge
Monitoring
Reports,
2000­
2003.
na
=
not
available
1.
Maximum
7­
day
moving
average
temperature
for
each
month.
2.
Average
of
maximum
7­
day
moving
averages
for
each
month
where
data
are
available.

Summary
of
Receiving
Water
Data
There
is
no
upstream
receiving
water
monitoring
station
with
recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
available
for
this
facility.
However,
recent
and
sufficient
data
exist
for
a
receiving
water
monitoring
station
(
No.
402093)
about
5
miles
downstream
of
the
facility's
discharge.
Exhibit
A­
15
summarizes
the
maximum
monthly
temperatures
for
February
1990
through
November
1998.
A
separate
data
appendix
contains
the
daily
temperature
recordings.

Exhibit
A­
15.
Average
of
Maximum
Monthly
Temperatures
Downstream
of
Shady
Cove
STP
at
Station
No.
402093
(

C)
1
Pollutant
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Temperature
7.5
9.5
8.0
10.5
11.5
17.0
17.5
15.0
12.5
8.0
9.5
8.0
Source:
U.
S.
EPA
(
2003).
1.
Maximum
monthly
values.

Controls
Needed
Although
there
are
no
upstream
temperature
data
available,
Exhibit
A­
15
indicates
that
the
water
downstream
of
the
discharge
is
meeting
the
current
State
rearing
and
spawning
criterion.
However,
the
stream
is
exceeding
EPA's
proposed
rearing
criterion
in
July
and
August
and
the
proposed
spawning
criterion
in
June.

Oregon's
current
WQS
prohibit
any
receiving
water
temperature
increase
greater
than
0.14

C
above
the
applicable
criterion
in
waters
that
exceed
the
criterion.
However,
if
the
stream
is
not
exceeding
the
criterion,
EPA
assumed
that
no
increase
in
temperature
at
the
edge
of
the
mixing
zone
is
allowed.
Exhibit
A­
16
summarizes
how
the
effluent
is
most
likely
affecting
stream
temperature
compared
to
the
current
criteria
and
the
proposed
criteria.
September
2003
Appendix
A.
Facility
Analyses
A
 
13
Exhibit
A­
16
indicates
that
the
facility's
current
discharge
would
not
cause
a
temperature
increase
above
the
current
State
criteria
at
the
edge
of
the
mixing
zone,
and
would
not
contribute
to
an
instream
exceedance
of
greater
than
0.14

C
above
EPA's
revised
criteria.
Therefore,
the
facility
would
not
likely
incur
costs
associated
with
EPA's
proposed
rule.

Exhibit
A­
16.
Effect
of
Effluent
on
Receiving
Water,
Shady
Cove
STP
Parameter
Current
Oregon
Criteria
EPA
Proposed
Criteria
Rearing
(
Jul/
Aug)
Spawning
(
Oct
1­
May
31)
Rearing
(
Jul/
Aug)
Spawning
(
Sep
15­
Jun
15)

7Q10
Stream
Flow
(
cfs)
846
846
846
846
Stream
Temperature/
Criterion
(

C)
17.51
11.51
16.0
13.0
Effluent
Flow
(
cfs)
0.7
0.7
0.7
0.7
Effluent
Temperature
(

C)
24.0
20.8
24.0
22.62
Dilution
Ratio3
161:
1
161:
1
161:
1
161:
1
Temperature
at
Edge
of
Mixing
Zone
(

C)
17.54
11.56
16.05
13.06
Increase
above
Applicable
Criterion
(

C)
0.0
0.0
0.05
0.06
cfs
=
cubic
feet
per
second
1.
EPA
used
the
maximum
stream
temperature
because
the
receiving
water
is
not
currently
exceeding
the
applicable
criterion.
For
facilities
discharging
to
waters
attaining
temperature
standards,
EPA
applied
the
current
State
and
EPA
proposed
criteria
at
the
edge
of
the
mixing
zone.
2.
Represents
average
of
maximum
7­
day
moving
average
temperatures
for
September
15,
2000
­
June
15,
2001,
September
15,
2001
­
June
15,
2002,
and
September
15,
2002
­
June
15,
2003
(
where
data
are
available).
3.
Dilution
at
edge
of
RMZ.
Dilution
calculated
using
Cormix
modeling
(
ODEQ,
1998b).
September
2003
Appendix
A.
Facility
Analyses
A
 
14
Siletz
Sewage
Treatment
Plant
Facility
Description
The
Siletz
Sewage
Treatment
Plant
(
NPDES
No.
OR0020419)
is
located
in
Lincoln
County,
Oregon.
The
facility
has
an
average
dry
weather
design
flow
of
0.157
mgd
and
treats
domestic
wastewater
from
the
City
of
Siletz.
With
the
exception
of
a
local
microbrewery,
there
are
no
significant
commercial
or
industrial
dischargers,
and
the
facility
does
not
receive
septage.
The
facility
discharges
to
the
Siletz
River
at
river
mile
38.1
in
the
Mid
Coast
basin.
EPA
classifies
the
discharge
as
a
minor
discharge.

Treatment
Processes
The
facility's
1998
permit
evaluation
sheet
indicates
that
current
treatment
processes
consist
of
headworks,
surge
basin,
continuous
feed
sequencing
batch
reactor
activated
sludge,
and
ultraviolet
disinfection.
All
biosolids
are
stored
in
a
synthetic
lined
facultative
sludge
lagoon.
The
lagoon
has
been
in
operation
for
five
years,
and
no
biosolids
have
been
removed.

Applicable
Designated
Uses
and
Criteria
The
Siletz
River
is
currently
designated
for
salmonid
spawning
from
September
15
to
May
31,
and
for
salmonid
rearing
the
remainder
of
the
year.
EPA
revised
the
time
period
for
which
the
salmonid
spawning
criterion
apply
to
September
1
to
June
15,
and
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
Exhibit
A­
17
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
17.
Designated
Use
and
Applicable
Criteria,
Siletz
STP
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Spawning
Temperature
12.8

C,
Sep
15
­
May
31
13

C,
Sep
1
­
Jun
15
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
18
shows
maximum
7­
day
moving
average
effluent
temperatures
for
the
facility
for
each
month
from
May
2000
through
May
2003.
The
exhibit
also
shows
the
average
of
the
maximum
7­
day
averages
for
each
month.
A
separate
data
appendix
contains
the
daily
temperature
recordings.

Exhibit
A­
18.
Maximum
Average
Effluent
Temperatures,
Siletz
WWTP
(

C)
1
Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
2000
na
na
na
na
15.7
18.4
19.5
20.2
19.7
17.9
16.4
13.7
2001
13.7
12.1
13.1
13.9
15.6
16.9
18.3
19.9
19.9
18.3
15.8
13.3
2002
13.0
12.6
12.0
13.5
16.3
18.5
19.7
19.8
19.3
17.7
15.4
13.7
Exhibit
A­
18.
Maximum
Average
Effluent
Temperatures,
Siletz
WWTP
(

C)
1
Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
September
2003
Appendix
A.
Facility
Analyses
A
 
15
2003
13.1
12.5
12.8
13.6
17.3
na
na
na
na
na
na
na
Average2
13.3
12.4
12.6
13.7
16.1
17.9
19.2
20.0
19.6
18.0
15.9
13.6
Source:
Siletz
Discharge
Monitoring
Reports,
2000­
2003.
na
=
not
available.
1.
Maximum
7­
day
moving
averages
for
each
month.
2.
Average
of
maximum
7­
day
moving
averages
for
each
month
where
data
are
available.

The
facility
does
not
currently
have
an
effluent
limit
for
temperature.

Summary
of
Receiving
Water
Data
Recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
from
upstream
of
the
discharge
are
available.
However,
the
exact
location
of
the
upstream
station
is
unknown.
Exhibit
A­
19
shows
the
maximum
monthly
temperatures
recorded
from
May
2000
through
May
2003.
A
separate
data
appendix
contains
the
daily
temperature
recordings.

Exhibit
A­
19.
Maximum
Monthly
Temperatures
Upstream
of
Siletz
WWTP
Discharge
(

C)

Year
May
Jun
Jul
Aug
Sep
Oct
2000
14.4
17.8
18.3
20.0
19.4
15.6
2001
14.4
17.8
22.2
20.6
17.8
15.6
2002
12.8
17.8
18.9
18.9
18.3
13.3
2003
15.6
na
na
na
na
na
Average1
14.3
17.8
19.8
19.8
18.5
14.8
Source:
Siletz
Discharge
Monitoring
Reports,
2000­
2003.
na
=
not
available
1.
Average
of
monthly
maximum
temperatures,
for
months
where
data
are
available.

Controls
Needed
Exhibit
A­
19
indicates
that
the
stream
does
not
meet
the
current
State
or
revised
rearing
criteria
in
July
and
August
(
typically
the
warmest
months
of
the
year).
The
stream
also
does
not
meet
the
current
State
or
revised
spawning
criterion
of
12.8

C
in
September,
October,
and
May.
EPA
could
not
determine
if
the
current
spawning
criterion
is
being
met
November
through
April
because
the
facility
only
records
upstream
temperatures
from
May
through
October.

Oregon's
current
WQS
prohibit
any
receiving
water
temperature
increase
greater
than
0.14

C
above
the
applicable
criterion.
Exhibit
A­
20
summarizes
how
the
effluent
is
most
likely
affecting
stream
temperature
compared
to
the
current
criteria
and
the
proposed
criteria.
September
2003
Appendix
A.
Facility
Analyses
A
 
16
Exhibit
A­
20.
Effect
of
Effluent
on
Receiving
Water,
Siletz
WWTP
Parameter
Current
Oregon
Criteria
EPA
Proposed
Criteria
Rearing
(
Jul/
Aug)
Spawning
(
Sep
15­
May
31)
Rearing
(
Jul/
Aug)
Spawning
(
Sep
1­
Jun
15)

7Q10
Stream
Flow
(
cfs)
61
61
61
61
Stream
Temperature/
Criterion
(

C)
17.8
12.8
16.0
13.0
Effluent
Flow
(
cfs)
0.21
0.21
0.21
0.21
Effluent
Temperature
(

C)
20.0
19.11
20.0
19.6
Dilution
Ratio2
57:
1
57:
1
57:
1
57:
1
Temperature
at
Edge
of
Mixing
Zone
(

C)
17.84
12.91
16.07
13.11
Increase
above
Applicable
Criterion
(

C)
0.04
0.11
0.07
0.11
cfs
=
cubic
feet
per
second
1.
Represents
average
of
maximum
7­
day
moving
average
temperatures
after
September
15.
2.
Dilution
at
edge
of
RMZ.
Calculated
assuming
that
20%
of
stream
flow
is
available
for
mixing
(
ODEQ,
1998c).

Exhibit
A­
20
indicates
that
the
facility's
current
discharge
would
not
contribute
to
an
instream
temperature
exceedance
of
greater
than
0.14

C
above
the
current
or
revised
criteria.
Therefore,
the
facility
would
likely
not
incur
costs
associated
with
EPA's
proposed
rule.
September
2003
Appendix
A.
Facility
Analyses
A
 
17
Stayton
Wastewater
Treatment
Plant
Facility
Description
The
City
of
Stayton
Wastewater
Treatment
Plant
(
NPDES
No.
OR0020427)
is
located
in
Marion
County,
Oregon.
The
treatment
plant
began
operation
in
1996,
and
a
second
phase
of
construction
is
planned
to
handle
increased
flow
or
loadings.
The
facility
serves
about
7,000
residents
in
the
City
of
Stayton.
EPA
classifies
the
discharge
as
a
major
discharge.
The
facility
has
a
peak
wet
weather
design
flow
of
3.91
mgd,
and
discharges
to
the
North
Santiam
River
at
river
mile
15.0
through
a
multiport
diffuser.

Treatment
Processes
The
facility's
1998
permit
evaluation
report
indicates
that
current
treatment
processes
consist
of
headworks,
oxidation
ditch,
secondary
clarification
consisting
of
sequencing
batch
reactors,
and
ultraviolet
disinfection.
Solids
are
dewatered
with
a
belt
filter
press
and
aerobically
digested.
Sludge
is
stabilized
with
lime
and
sent
to
storage
before
being
land
applied.

Applicable
Uses
and
Criteria
The
North
Santiam
River
at
river
mile
15.0
is
currently
designated
for
salmonid
spawning
from
September
15
to
June
30
and
salmonid
rearing
the
remainder
of
the
year.
EPA
revised
the
time
period
for
which
the
salmonid
spawning
criterion
apply
to
September
1
to
June
15,
and
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
Exhibit
A­
21
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
21.
Designated
Use
and
Applicable
Criteria,
Stayton
WWTP
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Spawning
Temperature
12.8

C,
Sep
15
­
Jun
30
13

C,
Sep
1
­
Jun
15
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
Exhibit
A­
22
shows
maximum
effluent
temperatures
for
the
facility
for
each
month
from
February
2000
through
May
2003.
The
exhibit
also
shows
the
average
of
the
maximum
monthly
temperatures
for
each
month.
A
separate
data
appendix
contains
the
daily
temperature
recordings.

Exhibit
A­
22.
Maximum
Monthly
Effluent
Temperatures,
Stayton
WWTP
(

C)

Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
2000
na
13.5
na
13.7
17.2
21
20.9
21.4
21.8
20.6
17.7
15.7
2001
15.1
14.2
15.2
15.9
19.5
18.2
20.2
22.4
21.2
20.7
17.6
15.9
Exhibit
A­
22.
Maximum
Monthly
Effluent
Temperatures,
Stayton
WWTP
(

C)

Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
September
2003
Appendix
A.
Facility
Analyses
A
 
18
2002
14.5
13.6
19.7
20.2
18.8
19.1
20.5
21.0
20.4
19.1
17.7
16.8
2003
14.5
14.7
14.2
15.8
16.6
na
na
na
na
na
na
na
Average1
14.7
14.0
16.4
16.4
18.0
19.4
20.5
21.6
21.1
20.1
17.7
16.1
Source:
Stayton
Discharge
Monitoring
Reports,
2000­
2003.
na
=
not
available
1.
Average
of
maximum
monthly
values.

The
facility
does
not
currently
have
an
effluent
limit
for
temperature.

Summary
of
Receiving
Water
Data
The
only
applicable
receiving
water
station
with
recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
is
located
about
7.5
miles
upstream
of
the
facility.
Exhibit
A­
23
summarizes
the
maximum
monthly
temperatures
from
June
2000
through
September
2001.
A
separate
data
appendix
contains
the
underlying
daily
temperature
recordings.

Exhibit
A­
23.
Maximum
Monthly
Temperatures
Upstream
of
Stayton
WWTP
at
Station
No.
25977
(

C)
1
Year
Jun
Jul
Aug
Sep
2000
13.1
17.7
17.8
19.9
2001
15.6
19.2
20.3
19.3
Average
14.3
18.4
19.1
19.6
Source:
ODEQ
(
2003).
1.
Values
represent
maximum
7­
day
moving
averages
for
months
where
consecutive
daily
data
are
available
(
June
2000,
July
2000,
July
2001,
August
2001,
September
2001)
or
maximum
monthly
temperatures
for
months
where
consecutive
daily
data
are
not
available
(
August
2000,
September
2000,
June
2001).

Controls
Needed
Exhibit
A­
23
indicates
that
the
stream
does
not
meet
the
current
and
revised
rearing
criterion
in
July,
August,
and
September
(
usually
the
warmest
months
of
the
year),
and
also
does
not
meet
the
current
and
revised
spawning
criterion
in
September
and
June.
There
are
no
receiving
water
data
for
the
remaining
spawning
time
period
of
October
to
May.

Oregon's
current
WQS
prohibit
any
receiving
water
temperature
increase
greater
than
0.14

C
above
the
applicable
criterion.
Exhibit
A­
24
summarizes
how
the
effluent
is
most
likely
affecting
stream
temperature
compared
to
the
current
criteria
and
the
proposed
criteria.

Exhibit
A­
24
indicates
that
the
facility's
current
discharge
would
contribute
to
an
instream
temperature
exceedance
of
greater
than
0.14

C
above
current
or
revised
criteria.
To
meet
the
current
State
criterion
for
rearing,
the
facility
would
have
to
decrease
its
average
maximum
September
2003
Appendix
A.
Facility
Analyses
A
 
19
monthly
effluent
temperature
during
the
summer
to
21.4

C
(
less
than
1

C).
An
additional
1.8

C
decrease
in
temperature
(
an
effluent
temperature
of
19.6

C)
would
be
necessary
to
meet
the
revised
rearing
criterion.
For
compliance
with
the
State
spawning
criterion
the
facility
would
have
to
reduce
their
average
maximum
effluent
temperature
from
September
15
to
June
30
to
16.4

C
(
about
4.2

C).
For
compliance
with
EPA's
proposed
spawning
criterion,
the
facility
would
need
to
extend
the
temperature
reduction
for
an
additional
two­
week
period
(
September
1
to
June
15).

Exhibit
A­
24.
Effect
of
Effluent
on
Receiving
Water,
Stayton
WWTP
Parameter
Current
Oregon
Criteria
EPA
Proposed
Criteria
Rearing
(
Jul/
Aug)
Spawning
(
Sep
15­
Jun
30)
Rearing
(
Jul/
Aug)
Spawning
(
Sep
1­
Jun
15)

7Q10
Stream
Flow
(
cfs)
337
337
337
337
Stream
Temperature/
Criterion
(

C)
17.8
12.8
16.0
13.0
Effluent
Flow
(
cfs)
1
3.38
3.38
3.38
3.38
Effluent
Temperature
(

C)
21.6
20.72
21.6
21.1
Dilution
Ratio3
25:
1
25:
1
25:
1
25:
1
Temperature
at
Edge
of
Mixing
Zone
(

C)
17.95
13.1
16.22
13.31
Increase
above
Applicable
Criterion
(

C)
0.15
0.30
0.22
0.31
Effluent
Temperature
Needed
for
Compliance
with
Applicable
Criterion
(

C)
21.4
16.4
19.6
16.6
Reduction
in
Current
Effluent
Temperature
Necessary
(

C)
0.2
4.3
2.0
4.5
cfs
=
cubic
feet
per
second
1.
Average
dry
weather
design
flow
not
available.
Represents
average
of
monthly
maximum
effluent
flows.
2.
Represents
average
of
maximum
temperatures
after
September
15.
3.
Dilution
at
edge
of
RMZ.
Calculated
assuming
that
25%
of
stream
flow
is
available
for
mixing.

The
facility
does
not
currently
have
a
temperature
management
plan
(
TMP).
Under
current
State
WQS,
the
facility
would
be
required
to
develop
a
TMP
because
it
has
been
shown
that
the
discharge
is
contributing
to
an
exceedance
of
the
current
criteria.
Based
on
TMPs
from
similar
facilities,
the
facility
would
most
likely
pursue
low­
cost
options
first.
EPA
assumed
that
the
facility
would
most
likely
pursue
process
optimization
or
a
waste
minimization
program
to
reduce
temperatures
to
meet
the
current
State
rearing
criterion
(
since
only
a
0.2

C
decrease
is
necessary).
To
meet
the
current
State
spawning
criterion,
EPA
assumed
that
the
facility
would
use
a
combination
of
land
application/
water
reuse
and
discharge
in
September
(
after
the
15th),
October,
November,
May,
and
June.
Based
on
current
effluent
temperatures,
peak
effluent
flows,
and
available
dilution,
EPA
calculated
that
the
facility
could
discharge
to
the
receiving
water
up
to
1.5
mgd
in
May,
1.6
mgd
in
November,
and
about
1.0
mgd
in
September,
October,
and
June,
with
the
remaining
discharge
(
1.6
mgd
in
May,
3.5
mgd
in
November,
about
0.26
mgd
in
October
and
June,
and
0.36
mgd
in
September)
being
land
applied
or
reused
by
another
facility
(
e.
g.,
industrial
facility,
park,
farm).
September
2003
Appendix
A.
Facility
Analyses
A
 
20
These
measures
would
also
reduce
effluent
temperatures
to
the
levels
necessary
for
compliance
with
EPA's
proposed
spawning
and
rearing
criteria.
However
the
facility
would
incur
incremental
costs
of
extending
such
treatment
options
to
a
longer
time
period
(
change
in
spawning
time
period
and
addition
of
rearing
months).

Exhibit
A­
25
summarizes
the
control
costs
associated
with
reducing
effluent
temperatures
to
the
required
levels.
EPA
assumed
that
the
facility
would
land
apply
or
reuse
the
portion
of
the
effluent
it
could
not
discharge.
The
costs
represent
the
incremental
costs
necessary
for
land
application
or
effluent
reuse
for
July,
August,
and
the
first
half
of
September.

Exhibit
A­
25.
Summary
of
Compliance
Costs
($
2003),
Stayton
WWTP
Control
Total
Capital
Annual
O&
M
Total
Annual
Incremental
Land
Application/
Water
Reuse
­
$
5,1901
$
5,190
Sources:
R.
S.
Means
(
2001).
1.
Represents
costs
to
operate
and
monitor
for
an
additional
2.5
months.
September
2003
Appendix
A.
Facility
Analyses
A
 
21
Sweet
Home
Wastewater
Treatment
Plant
Facility
Description
The
Sweet
Home
WWTP
(
NPDES
No.
OR0020346)
is
located
in
Linn
County,
Oregon.
The
facility
was
constructed
in
1947
and
upgraded
to
an
activated
sludge
treatment
plant
in
1974.
The
facility
has
an
average
dry
weather
design
flow
of
1.38
mgd
and
treats
domestic
and
industrial
wastewater
from
the
Sweet
Home
area.
EPA
classifies
the
discharge
as
a
major
discharge.
The
facility
discharges
to
the
South
Santiam
River
at
river
mile
33.6
in
the
Willamette
basin.

Treatment
Processes
The
facility's
1998
permit
fact
sheet
indicates
that
current
treatment
processes
consist
of
headworks,
aeration,
secondary
clarification,
sand
filtration,
and
chlorination/
dechlorination.
Sludge
is
digested
and
dewatered
in
a
belt
filter
press.
Lime
is
added
to
the
pressed
sludge
prior
to
land
application.

Applicable
Criteria
and
Designated
Uses
The
South
Santiam
River
is
currently
designated
for
salmonid
spawning
from
September
15
to
May
31,
and
for
salmonid
rearing
the
remainder
of
the
year.
EPA
revised
the
time
period
for
which
the
salmonid
spawning
criterion
apply
to
September
1
to
May
15,
and
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
applies
as
a
summer
maximum.
Exhibit
A­
26
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
26.
Designated
Use
and
Applicable
Criteria,
Sweet
Home
WWTP
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Spawning
Temperature
12.8

C,
Sep
15
­
May
31
13

C,
Sep
1
­
May
15
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
27
summarizes
maximum
effluent
temperatures
for
the
facility
for
each
month
from
September
2000
through
April
2003.
The
exhibit
also
shows
the
average
of
the
maximum
temperatures
for
each
month.
A
separate
data
appendix
contains
the
underlying
daily
temperature
recordings.

Exhibit
A­
27.
Maximum
Monthly
Effluent
Temperatures,
Sweet
Home
STP
(

C)

Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
2000
na
na
na
na
na
na
na
na
16
15
13
10
2001
9
9
11
11
13
14
15
16
16
14
14
12
2002
10
10
9
11
14
14
15
15
15
14
na
12
Exhibit
A­
27.
Maximum
Monthly
Effluent
Temperatures,
Sweet
Home
STP
(

C)

Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
September
2003
Appendix
A.
Facility
Analyses
A
 
22
2003
12
11
10
14
na
na
na
na
na
na
na
na
Average1
10.3
10.0
10.0
12.0
13.5
14.0
15.0
15.5
15.7
14.3
13.5
11.3
Source:
Sweet
Home
Discharge
Monitoring
Reports,
2000­
2003.
1.
Average
of
maximum
monthly
values.

The
facility
does
not
currently
have
an
effluent
limit
for
temperature.

Summary
of
Receiving
Water
Data
The
only
applicable
receiving
water
station
with
recent
(
e.
g.,
data
from
1990
or
later)
and
sufficient
temperature
data
is
located
about
3.8
miles
upstream
of
the
facility.
Exhibit
A­
28
summarizes
the
maximum
monthly
temperatures
from
June
2000
through
September
2000.
A
separate
data
appendix
contains
the
underlying
daily
temperature
recordings.

Exhibit
A­
28.
Maximum
Monthly
Temperatures
Upstream
of
Sweet
Home
STP
at
Station
No.
23788,
June
­
September
2000
(

C)

Pollutant
Jun
Jul
Aug
Sep
Temperature1
11.7
12.7
12.9
12.7
Source:
ODEQ
(
2003).
1.
Values
represent
the
average
of
the
maximum
7­
day
moving
averages
for
months
where
consecutive
daily
data
are
available
(
June
­
August)
and
the
maximum
monthly
temperatures
for
month
where
consecutive
daily
data
are
not
available
(
September).

Controls
Needed
Exhibit
A­
28
indicates
that
the
stream
meets
the
current
and
revised
rearing
criteria.
The
stream
also
meets
the
current
and
revised
spawning
criteria
in
September.
There
are
no
data
for
the
spawning
months
of
October
through
May.

The
facility
is
currently
discharging
at
temperatures
below
16

C,
and
therefore,
would
not
likely
incur
costs
associated
with
the
revised
rearing
criterion.
However,
the
facility
could
have
the
potential
to
cause
an
increase
in
temperature
during
the
spawning
period
because
effluent
temperatures
during
the
spawning
time
period
exceed
the
spawning
temperature
criterion.

Oregon's
current
WQS
prohibit
any
receiving
water
temperature
increase
greater
than
0.14

C
above
the
applicable
criterion
in
waters
exceeding
the
criterion.
In
waters
attaining
the
criterion,
EPA
assumed
that
no
increase
above
the
criterion
is
allowed
at
the
edge
of
the
mixing
zone.
Exhibit
A­
30
summarizes
how
the
effluent
is
most
likely
affecting
stream
temperature
compared
to
the
current
and
proposed
spawning
criteria.

Exhibit
A­
29
indicates
that
the
facility's
current
discharge
would
contribute
to
an
instream
temperature
exceedance
above
the
current
spawning
criterion
of
12.8

C.
To
meet
the
current
September
2003
Appendix
A.
Facility
Analyses
A
 
23
State
criterion
for
spawning,
the
facility
would
have
to
decrease
its
average
maximum
effluent
temperature
during
the
second
half
of
September
and
October
to
14.0

C
(
1

C).
The
facility
is
currently
in
compliance
with
EPA's
proposed
spawning
criterion
of
13

C.

The
facility
does
not
currently
have
a
temperature
management
plan
(
TMP).
Under
current
State
WQS,
the
facility
would
be
required
to
develop
a
TMP
because
the
discharge
is
contributing
to
an
exceedance
of
the
current
spawning
criterion.
Based
on
TMPs
from
similar
facilities
and
the
relatively
small
temperature
reductions
needed
to
meet
the
current
criterion,
the
facility
would
most
likely
pursue
process
optimization
(
e.
g.,
switch
to
fine
bubble
aeration,
install
shade
cloths,
etc).
These
measures
would
also
ensure
compliance
with
EPA's
revised
spawning
criterion
as
well.
Therefore,
the
facility
would
not
likely
incur
costs
associated
with
this
rule
because
controls
implemented
to
meet
the
current
State
criteria
will
also
achieve
EPA's
proposed
criteria.

Exhibit
A­
29.
Effect
of
Effluent
on
Receiving
Water,
Sweet
Home
WWTP
Parameter
Current
Oregon
Criterion
(
Sep
15­
May
31)
EPA
Proposed
Criterion
(
Sep
1­
May
15)

7Q10
Stream
Flow
(
cfs)
515
515
Stream
Temperature/
Criterion
(

C)
12.71
12.71
Effluent
Flow
(
cfs)
2.14
2.14
Effluent
Temperature
(

C)
15.02
15.7
Dilution
Ratio3
12:
1
12:
1
Temperature
at
Edge
of
Mixing
Zone
(

C)
12.88
12.93
Increase
above
Applicable
Criterion
(

C)
0.08
0.0
Effluent
Temperature
Needed
for
Compliance
with
Applicable
Criterion
(

C)
14.0
NA
Reduction
in
Current
Effluent
Temperature
Necessary
(

C)
1.0
NA
cfs
=
cubic
feet
per
second
NA
=
Not
applicable
1.
EPA
used
the
maximum
stream
temperature
because
the
receiving
water
is
not
currently
exceeding
the
applicable
criteria.
For
facilities
discharging
to
waters
attaining
temperature
standards,
EPA
applied
the
current
State
and
EPA
proposed
criteria
at
the
edge
of
the
mixing
zone.
2.
Average
of
maximum
monthly
values
after
September
15.
3.
Dilution
at
edge
of
RMZ.
Calculated
assuming
that
5%
of
stream
flow
is
available
for
mixing
(
ODEQ,
1998d).
September
2003
Appendix
A.
Facility
Analyses
A
 
24
Weyerhaeuser
Company
Facility
Description
The
Weyerhaeuser
Paper
Company
(
NPDES
No.
OR0000515)
is
located
in
Springfield,
Oregon.
The
facility
manufactures
unbleached
linerboard
in
weights
from
30.7#
­
96#
per
thousand
square
feet
for
high
performance,
export,
and
white
top
grades.
The
facility
has
seven
permitted
outfalls.
Outfall
001
is
process
water,
outfall
001A
is
a
combination
of
process
water,
storm
water,
and
treated
groundwater,
outfalls
002
and
003
are
cooling
water,
and
outfalls
004,
005,
and
006
are
made
up
of
steam
condensate,
eye
wash,
treated
river
water,
and
drinking
fountain
water.
Only
outfalls
001,
001A,
and
002
are
discharged
into
the
McKenzie
River
(
the
remaining
outfalls
enter
a
storm
ditch
and
are
treated
as
storm
water).
Outfalls
001
and
001A
have
a
maximum
summer
flow
of
about
13.8
mgd
and
outfall
002
has
a
maximum
summer
flow
of
about
12.7
mgd.
Outfalls
001
and
001A
discharge
to
the
McKenzie
River
at
river
mile
14.7,
and
outfall
002
discharges
at
river
mile
15.5.

Treatment
Processes
Site­
specific
treatment
process
information
is
not
available
for
this
facility.
However,
the
facility's
permit
renewal
application
indicates
that
all
process
wastewater
and
other
miscellaneous
chemicals
associated
with
the
production
operations
are
treated
in
a
biological
effluent
treatment
system
prior
to
discharge.
Non­
contact
cooling
water
(
outfall
002)
is
sent
to
cooling
ponds
prior
to
discharge.

Applicable
Uses
and
Criteria
The
McKenzie
River
is
currently
designated
for
salmonid
rearing
all
year
round.
EPA
revised
the
salmonid
rearing
criteria
to
16

C
(
from
17.8

C)
for
core
juvenile
rearing.
The
rearing
criterion
is
applied
as
a
summer
maximum.
Exhibit
A­
30
summarizes
the
applicable
criterion
and
designated
uses.

Exhibit
A­
30.
Designated
Use
and
Applicable
Criteria,
Weyerhaeuser
Designated
Use
Parameters
Affected
Current
Oregon
Criteria
EPA
Proposed
Criteria
Salmonid
Rearing
Temperature
17.8

C
Core
juvenile
rearing:
16
°
C
Summary
of
Effluent
Data
Exhibit
A­
31
shows
the
average
of
maximum
monthly
effluent
temperatures
for
outfalls
001
and
002
from
January
1999
through
May
2003.
The
individual
monthly
maximum
temperatures
are
presented
in
a
separate
data
appendix.

The
facility's
1995
permit
indicates
that
the
maximum
daily
temperature
limit
for
outfalls
001
and
001A
is
37.8

C
and
46.1

C
for
outfall
002.
September
2003
Appendix
A.
Facility
Analyses
A
 
25
Exhibit
A­
31.
Average
of
Maximum
Monthly
Effluent
Temperatures,
Weyerhaeuser
(

C)
1
Discharge
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Outfall
001
20.8
21.1
22.2
24.1
27.8
27.9
29.0
28.8
26.8
24.9
21.7
19.9
Outfall
002
20.9
21.6
27.0
25.3
28.1
31.4
32.4
30.4
31.0
27.6
23.6
21.4
Source:
Calculated
from
EPA
PCS
database.
1.
Average
of
maximum
monthly
values.

Summary
of
Receiving
Water
Data
The
only
applicable
receiving
water
station
with
recent
(
e.
g.,
from
1990
or
later)
and
sufficient
temperature
data
is
located
about
4.2
miles
upstream
of
the
facility.
Exhibit
A­
32
summarizes
the
maximum
7­
day
moving
average
temperatures
from
July
to
October
2001.
A
separate
data
appendix
contains
the
underlying
daily
temperature
recordings.

Exhibit
A­
32.
Water
Temperatures
Upstream
of
Weyerhaeuser
at
Station
No.
26757,
July­
October
2001
(

C)

Pollutant
Maximum
7­
Day
Moving
Average
Jul
Aug
Sep
Oct
Temperature
(

C)
18.8
18.3
17.2
14.3
Source:
ODEQ
(
2003).

Controls
Needed
Exhibit
A­
32
indicates
that
the
stream
does
not
meet
the
current
or
the
revised
rearing
criteria
in
July
and
August
(
typically
the
warmest
months
of
the
year).
Exhibit
A­
33
summarizes
how
the
effluent
is
most
likely
affecting
stream
temperature
compared
to
the
current
and
proposed
rearing
criteria.

Oregon's
current
WQS
prohibit
any
receiving
water
temperature
increase
greater
than
0.14

C
above
the
applicable
criterion,
however,
the
facility's
current
permit
allows
a
temperature
increase
of
1.1

C
downstream
of
outfall
001.
Exhibit
A­
33
indicates
that
the
facility's
current
discharges
from
both
outfall
001
and
outfall
002
would
contribute
to
an
instream
temperature
exceedance
of
greater
than
0.14

C
above
current
and
revised
rearing
criteria.
To
meet
the
current
State
criterion
for
rearing,
the
facility
would
have
to
decrease
its
average
maximum
effluent
temperature
for
outfall
001
to
21.9

C,
and
30.8

C
for
outfall
002.
For
compliance
with
EPA's
proposed
rearing
criterion,
the
facility
would
need
an
additional
2.3

C
decrease
in
effluent
temperature
for
outfall
001,
from
21.9

C,
and
an
additional
10.7

C
decrease
for
outfall
002,
from
30.8

C
(
to
19.6

C
and
20.1

C,
respectively).
September
2003
Appendix
A.
Facility
Analyses
A
 
26
Exhibit
A­
33.
Effect
of
Effluent
on
Receiving
Water,
Weyerhaeuser
Parameter
Current
Oregon
Criterion
EPA
Proposed
Criterion
Outfall
001
Outfall
002
Outfall
001
Outfall
002
7Q10
Stream
Flow
(
cfs)
1,848
1,848
1,848
1,848
Stream
Temperature/
Criterion
(

C)
17.8
17.8
16
16
Effluent
Flow
(
cfs)
18.2
16.2
18.2
16.2
Effluent
Temperature
(

C)
29.0
32.4
29.0
32.4
Dilution
Ratio
28:
11
92:
11
25:
12
28.5:
12
Temperature
at
Edge
of
Mixing
Zone
(

C)
18.19
17.96
16.50
16.56
Increase
above
Applicable
Criterion
(

C)
0.39
0.17
0.50
0.56
Effluent
Temperature
Needed
for
Compliance
with
Applicable
Criterion
(

C)
21.9
30.8
19.6
20.1
Reduction
in
Current
Effluent
Temperature
Necessary
(

C)
7.1
1.9
9.4
12.3
cfs
=
cubic
feet
per
second
1.
Dilution
at
edge
of
RMZ.
Outfall
002
dilution
from
mixing
zone
study
(
CH2MHill,
1997).
Outfall
001
dilution
calculated
from
outfall
002
dilution,
7Q10
flow,
and
stream
width.
2.
Dilution
at
edge
of
RMZ.
EPA
assumed
that
only
25%
of
the
stream
flow
is
available
for
dilution.

The
facility
does
not
currently
have
a
temperature
management
plan
(
TMP).
Under
current
State
WQS
the
facility
would
be
required
to
develop
a
TMP
because
the
discharge
is
contributing
to
an
exceedance
of
the
current
rearing
criterion.
EPA
assumed
that
under
its
TMP
the
facility
would
install
cooling
towers
for
a
portion
of
the
flows
from
outfalls
001
and
002
to
reduce
effluent
temperatures
to
the
necessary
levels
for
compliance
with
the
current
standards.
The
cooling
towers
would
also
reduce
effluent
temperatures
to
the
levels
necessary
for
compliance
with
EPA's
proposed
criterion.
However
the
facility
would
incur
incremental
costs
of
extending
such
treatment
options
to
a
greater
flow
(
for
the
greater
temperature
reduction).
Exhibit
A­
34
summarizes
the
control
costs
associated
with
reducing
effluent
temperatures
to
the
required
levels.

Exhibit
A­
34.
Summary
of
Compliance
Costs
($
2003),
Weyerhaeuser
Control
Total
Capital
Annual
O&
M
Total
Annual1
Incremental
Cooling
Tower
Costs
$
421,500
$
34,260
$
74,050
Sources:
U.
S.
EPA
(
2002)
1.
Costs
are
annualized
at
7%
over
20
years.
September
2003
Appendix
A.
Facility
Analyses
A
 
27
References
CH2M
Hill.
1997.
Outfall
002
Mixing
Zone
Study:
Weyerhaeuser
Springfield
Mill,
NPDES
Permit
No.
101081.

ODEQ.
2003.
Oregon
Temperature
Data
from
1998
to
2001,
sent
via
email
by
ODEQ
Laboratory
Technical
Services.

ODEQ.
1998a.
Oakridge
STP
Reasonable
Potential
Analysis.

ODEQ.
1998b.
Shady
Cove
STP
Reasonable
Potential
Analysis.

ODEQ.
1998c.
Siletz
STP
Reasonable
Potential
Analysis.

ODEQ.
1998d.
Sweet
Home
WWTP
Reasonable
Potential
Analysis.

R.
S.
Means.
2001.
Cost
Works
Building
Construction
Cost
Data.

U.
S.
EPA.
2003.
STORET
Legacy
Data
Center.
Accessed
June
2003.
Online
at
http://
www.
epa.
gov/
storpubl/
legacy/
gateway.
htm.

U.
S.
EPA.
2002.
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
II
Existing
Facilities
Rule.
Office
of
Water,
EPA
821­
R­
02­
003.

West
Yost
and
Associates.
2001.
Temperature
Management
Plan
for
the
Regional
Water
Reclamation
Facility:
City
of
Medford,
Oregon.
Appendix
B
Statewide
Cost
Calculations
September
2003
Appendix
B.
B
 
1
Appendix
B.
Statewide
Cost
Calculations
This
appendix
provides
a
summary
of
the
potential
cost
impacts
of
the
temperature
provision
of
the
proposed
rule
to
the
sample
facilities.
The
appendix
also
provides
an
explanation
of
the
extrapolation
of
costs
for
the
five
minor
sample
facilities
to
the
total
number
of
minor
facilities
(
as
described
in
Section
4.1.5).
Exhibit
B­
1
summarizes
the
total
capital,
O&
M,
and
annual
costs
for
each
sample
facility.

Exhibit
B­
1.
Summary
of
Potential
Costs
to
Sample
Facilities
Associated
with
the
Proposed
Rule
NPDES
No.
Facility
Type
Total
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
OR0026263
Medford
RWRF
Major
$
0
$
0
$
0
OR0020427
Stayton
WWTP
Major
$
0
$
5,190
$
5,190
OR0020346
Sweet
Home
WWTP
Major
$
0
$
0
$
0
OR0000515
Weyerhaeuser
Paper
Company
Major
$
421,500
$
34,260
$
74,050
OR0030261
Glide­
Idelyld
Park
Minor
$
0
$
0
$
0
OR0027791
Government
Camp
Sanitation
District
Minor
$
0
$
0
$
0
OR0022314
Oakridge
STP
Minor
$
0
$
13,600
$
13,600
OR0030660
Shady
Cove
STP
Minor
$
0
$
0
$
0
OR0020419
Siletz
STP
Minor
$
0
$
0
$
0
1.
Represents
capital
costs
annualized
at
7%
over
20
years,
plus
annual
O&
M
costs
The
total
annual
cost
for
all
5
minor
sample
facilities
is
$
13,600
per
year.
To
calculate
an
annual
cost
per
minor
facility
of
$
2,720,
EPA
divided
the
total
annual
cost
by
the
total
number
of
minor
facilities
in
the
sample
($
13,600
÷
5
=
$
2,720).
EPA
then
multiplied
the
per
facility
cost
by
the
total
number
of
minor
facilities
affected
to
calculate
a
total
annual
cost
for
minor
facilities
of
$
119,680
($
2,720
*
44
=
$
119,680).
Exhibit
B­
2
summarizes
the
total
statewide
costs
associated
with
the
temperature
provision
of
the
proposed
rule.
September
2003
Appendix
B.
B
 
2
Exhibit
B­
2.
Potential
Costs
to
Sample
Facilities
Potentially
Affected
by
the
Temperature
Provision
of
the
Proposed
Rule
Discharger
Category
Sample
Size
Number
in
Sample
with
Costs
Total
Sample
Facility
Annual
Cost
Annual
Cost
per
Facility
Number
Potentially
Affected
Statewide
Annual
Cost
Major
POTW
3
1
$
5,190
NA
3
$
5,190
Major
Industrial
1
1
$
74,050
NA
1
$
74,050
Minor
Discharger
5
1
$
13,600
$
2,720
44
$
119,680
Total
8
4
$
92,840
NA
48
$
198,920
NA
=
not
applicable.
(
This
calculation
is
not
needed
because
EPA
evaluated
all
major
facilities
and
does
not
need
to
extrapolate
costs.)
