ECONOMIC
ANALYSIS
FOR
THE
FINAL
WATER
QUALITY
STANDARDS
FOR
IDAHO
JULY
21,
1997
PREPARED
FOR:
U.
S.
Environmental
Protection
Agency
Office
of
Science
and
Technology
401
M
Street,
S.
W.
Washington,
D.
C.
20460
and
U.
S.
Environmental
Protection
Agency
Region
10
Office
of
Water
1200
Sixth
Avenue
Seattle,
Washington
98101
PREPARED
BY:
Science
Applications
International
Corporation
1710
Goodridge
Drive
McLean,
Virginia
22102
EPA
Contract
No.
68­
C4­
0046;
Work
Assignment
No.
2­
21
SAIC
Project
No.
01­
0833­
07­
7502­
211
i
TABLE
OF
CONTENTS
Page
1.
INTRODUCTION
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1­
1
1.1
BACKGROUND
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1­
1
1.2
PURPOSE
OF
THIS
ANALYSIS
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1­
2
1.3
SCOPE
OF
THE
ANALYSIS
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1­
3
1.4
OVERVIEW
OF
APPROACH
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1­
3
1.5
ORGANIZATION
OF
THIS
REPORT
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1­
4
2.
METHODOLOGY
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2­
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2.1
OVERVIEW
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2­
1
2.2
METHODOLOGY
TO
ESTIMATE
POTENTIAL
COSTS
RELATED
TO
NEW
USE
DESIGNATIONS
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2.2.1
Universe
of
Affected
Facilities
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2­
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2.2.2
Selection
of
Pollutants
of
Concern
for
Evaluation
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2­
3
2.2.3
Derivation
of
Effluent
Limits
Based
on
Revised
Use
Classifications
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2­
4
2.2.4
Estimation
of
Potential
Costs
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2­
5
2.2.5
Cost
Estimates
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2­
7
2.2.5.1
Treatment
Process
Optimization
Costs
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2­
7
2.2.5.2
Waste
Minimization/
Pollution
Prevention
Costs
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2­
8
2.2.5.3
Pretreatment
Program
Costs
(
Municipal
Only)
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2­
9
2.2.5.4
New/
Additional
Treatment
Systems
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2­
9
2.2.5.5
Costs
for
Alternative
Regulatory
Approaches
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2­
12
2.2.6
Calculation
of
Pollutant
Load
Reductions
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2­
12
2.2.6.1
Toxicity
Weighting
of
Baseline
Loads
and
Pollutant
Reductions
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2­
13
2.2.6.2
Determining
Cost­
Effectiveness
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2­
13
2.3
METHODOLOGY
TO
ESTIMATE
POTENTIAL
COSTS
RELATED
TO
NEW
TEMPERATURE
CRITERIA
TO
PROTECT
BULL
TROUT
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2­
13
2.3.1
Approach
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2­
14
2.3.2
Bull
Trout
Distribution
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2­
14
2.3.3
Collection
of
Data
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2­
16
2.3.3.1
PCS
Data
Set
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2­
16
2.3.3.2
Ambient
Water
Quality
Data
Sets
B
STORET
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2­
16
2.3.3.3
Ambient
Water
Quality
Data
Sets
B
USGS
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2­
19
ii
TABLE
OF
CONTENTS
(
Cont.)
Page
3.
RESULTS
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3­
1
3.1
RESULTS
FOR
WATERBODIES
WITH
SPECIFIC
USE
DESIGNATION
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3­
1
3.1.1
Estimated
Costs
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3­
1
3.1.2
Estimated
Pollutant
Load
Reductions
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3­
4
3.1.3
Analysis
of
Potential
Impact
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3­
4
3.2
RESULTS
FOR
WATERBODIES
WITH
NEW
TEMPERATURE
CRITERIA
FOR
BULL
TROUT
PROTECTION
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3­
7
iii
LIST
OF
EXHIBITS
Page
EXHIBIT
2­
1.
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
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2­
2
EXHIBIT
2­
2.
NEW
USE
DESIGNATIONS
FOR
THE
STATE
OF
IDAHO
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2­
3
EXHIBIT
2­
3.
SUMMARY
OF
WASTE
MINIMIZATION/
POLLUTION
PREVENTION
COSTS
USED
IN
DEVELOPING
COST
ESTIMATES
FOR
FACILITIES
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2­
8
EXHIBIT
2­
4.
RISE
IN
AMBIENT
TEMPERATURE
USING
EFFLUENT
TEMPERATURE
AND
RELATIVE
PERCENT
OF
QE/
QM.
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2­
15
EXHIBIT
2­
5.
DATA
SETS
USED
AND
EXAMINED
FOR
BULL
TROUT
STREAM
STUDY
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2­
17
EXHIBIT
2­
6.
NPDES
DISCHARGERS
TO
STREAMS
AFFECTED
BY
EPA
FINAL
RULE
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2­
18
EXHIBIT
3­
1.
SUMMARY
OF
ESTIMATED
ANNUAL
COSTS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
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3­
2
EXHIBIT
3­
2.
SUMMARY
OF
ESTIMATED
ANNUAL
COSTS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
BY
COST
CATEGORY
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3­
3
EXHIBIT
3­
3.
SUMMARY
OF
ESTIMATED
ANNUAL
COSTS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
BY
POLLUTANT
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3­
3
EXHIBIT
3­
4.
SUMMARY
OF
ESTIMATED
POLLUTANT
LOAD
REDUCTIONS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
BY
POLLUTANT
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3­
5
1­
1
1.
INTRODUCTION
This
report
presents
an
estimate
of
potential
costs
resulting
from
the
implementation
of
the
United
States
(
U.
S.)
Environmental
Protection
Agency's
(
EPA's)
water
quality
standards
applicable
to
waters
of
the
U.
S.
in
the
State
of
Idaho.
This
estimate
reflects
the
potential
incremental
costs
to
direct
point
source
dischargers
associated
with
projected
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
limits
that
could
be
derived
based
on
the
water
quality
criteria
and
designated
uses
contained
in
EPA's
regulation.

1.1
BACKGROUND
Under
Section
303
of
the
Clean
Water
Act
(
CWA),
States
are
required
to
develop
water
quality
standards
for
waters
of
the
U.
S.
within
the
State.
Section
303(
c)
provides
that
water
quality
standards
shall
include
the
designated
use
or
uses
to
be
made
of
the
water
and
criteria
necessary
to
protect
the
uses.
States
are
required
to
review
their
water
quality
standards
at
least
once
every
3
years
and,
if
appropriate,
revise
or
adopt
new
standards.
The
results
of
this
triennial
review
must
be
submitted
to
EPA,
and
EPA
must
approve
or
disapprove
of
any
new
or
revised
standards.

In
February
1997,
a
lawsuit
was
filed
against
EPA
for
failure
to
promulgate
standards
to
supersede
those
that
had
been
disapproved
by
EPA.
As
part
of
the
District
Court's
decision,
EPA
was
ordered
to
propose
new
water
quality
standards
by
April
1997
and
to
issue
final
standards
90
days
after
proposal
(
Idaho
Conservation
League
v.
Browner;
No.
C96­
807WD,
February
20,
1997).

In
April
1997,
EPA
proposed
water
quality
standards
for
those
disapproved
portions
of
Idaho's
water
quality
standards
(
62
FR
23003;
April
28,
1997).
Shortly
before
the
proposal
of
April
28,
1997,
Idaho
submitted
the
results
of
temporary
rulemaking
actions
to
address
certain
aspects
of
EPA's
June
25,
1996
disapproval.
On
June
19,
1997,
Idaho
adopted
another
temporary
rule
addressing
unclassified
waters,
mixing
zones,
temperature
criteria
for
bull
trout,
and
use
designations
for
29
specific
waterbodies
that
had
been
the
subject
of
EPA's
disapproval.
On
June
25,
1997,
Idaho
submitted
a
package
for
EPA's
approval
that
included
these
temporary
rulemakings,
as
well
as
use
attainability
analyses
for
certain
other
waterbodies
addressed
in
the
June
25,
1996
disapproval.
On
July
15,
1997,
EPA
issued
a
letter
conditionally
approving
the
unclassified
waters,
mixing
zones,
and
use
designation
aspects
of
the
State's
submittal
subject
to
both
the
completion
of
Endangered
Species
Act
section
7
consultation
and
the
State
is
taking
the
steps
necessary
to
convert
the
rule
from
temporary
to
permanent
status.

As
a
result
of
the
State
actions,
EPA's
final
rule
promulgates
new
use
designations
for
five
specified
waterbodies
in
the
State
of
Idaho,
as
well
as
a
variance
procedure
that
may
be
used
to
obtain
relief
from
those
use
designations.
EPA's
final
rule
also
establishes
temperature
criteria
applicable
to
bull
trout
spawning
and
rearing
in
specified
waterbodies.
1­
2
1.2
PURPOSE
OF
THIS
ANALYSIS
Under
Executive
Order
(
E.
O.)
12866
(
58
FR
51735;
October
4,
1993),
EPA
must
determine
whether
a
regulatory
action
is
"
significant"
and
therefore
subject
to
Office
of
Management
and
Budget
(
OMB)
review
and
the
requirements
of
the
E.
O.
The
Order
defines
"
significant
regulatory
action"
as
one
that
is
likely
to
result
in
a
rule
that
may:

(
1)
Have
an
annual
effect
on
the
economy
of
$
100
million
or
more
or
adversely
affect
in
a
material
way
the
economy,
a
sector
of
the
economy,
productivity,
competition,
jobs,
the
environment,
public
health
or
safety,
or
State,
local,
or
Tribal
governments
or
communities;

(
2)
Create
a
serious
inconsistency
or
otherwise
interfere
with
an
action
taken
or
planned
by
another
agency;

(
3)
Materially
alter
the
budgetary
impact
of
entitlements,
grants,
user
fees,
or
loan
programs
or
the
rights
and
obligations
of
recipients
thereof;
or
(
4)
Raise
novel
legal
or
policy
issues
arising
out
of
legal
mandates,
the
President's
priorities,
or
the
principles
set
forth
in
the
E.
O.

EPA's
final
rule
does
not
itself
establish
any
requirements
directly
applicable
to
regulated
entities.
In
addition,
there
is
significant
flexibility
and
discretion
in
how
the
final
rule
will
be
implemented
within
the
NPDES
permit
program.
While
implementation
of
the
water
quality
standard
rule
for
Idaho
may
ultimately
result
in
some
new
or
revised
NPDES
permit
conditions
for
some
dischargers,
EPA's
action
does
not
impose
any
of
these
as
yet
unknown
requirements
on
dischargers.
However,
consistent
with
the
intent
of
E.
O.
12866,
EPA
requested
that
a
study
be
performed
to
estimate
(
within
the
limits
of
these
uncertainties)
the
possible
indirect
costs
that
may
ultimately
result
from
the
final
rule.

The
designated
uses
and
water
quality
criteria
of
EPA's
final
rule
are
not
enforceable
requirements
until
separate
steps
are
taken
to
implement
them.
Therefore,
EPA's
final
rule
does
not
have
an
immediate
effect
on
dischargers
or
the
community.
Until
actions
are
taken
to
implement
these
designated
uses
and
criteria,
there
will
be
no
economic
effect
on
any
dischargers
or
the
community.

The
purpose
of
this
analysis
is
to
estimate
the
total
costs
of
control
measures
(
e.
g.,
pollution
prevention,
process
optimization,
end­
of­
pipe
treatment,
or
other
pollutant
controls)
needed
by
affected
point
sources
to
achieve
compliance
with
the
new
water
quality
standards.
To
estimate
the
potential
impact,
implementation
assumptions
were
made
about
how
future
NPDES
permits
would
be
written
and
enforced
by
the
NPDES
permitting
authority.
1
Further,
agricultural
and
forestry­
related
nonpoint
source
discharges
are
technically
difficult
to
model
and
evaluate
for
costing
purposes
because
they
are
intermittent,
highly
variable,
and
occur
under
different
hydrologic
or
climatic
conditions
than
continuous
discharges
from
industrial
and
municipal
facilities,
evaluated
under
critical
low
flow
or
drought
conditions.
Thus,
the
evaluation
of
agricultural
and
forestry­
related
nonpoint
source
discharges
and
their
effects
on
the
environment
are
highly
site­
specific
and
data
intensive.

1­
3
1.3
SCOPE
OF
THE
ANALYSIS
Any
facility
discharging
pollutants
to
waters
of
the
United
States
in
Idaho
could
be
indirectly
affected
by
EPA's
rule
since
water
quality
standards
are
used
in
determining
NPDES
permit
limits.
The
types
of
facilities
that
may
be
ultimately
affected
by
EPA's
final
rule
include
industries
and
publicly
owned
treatment
works
(
POTWs)
discharging
pollutants
to
surface
waters
in
Idaho
(
i.
e.,
point
sources).

Although
this
analysis
projects
the
potential
costs
to
point
sources,
EPA
also
received
several
comments
on
the
proposed
rule
related
to
the
potential
large
economic
impact
that
could
occur
as
a
result
of
the
new
temperature
criteria,
particularly
for
the
agricultural
and
forestry
segments
of
the
Idaho
economy.
As
described
later
in
this
analysis,
the
scope
of
the
new
temperature
criteria
has
resulted
in
a
limited
number
of
waterbody
segments
for
which
revised
temperature
criteria
are
required.
However,
EPA
has
only
estimated
costs
to
point
source
facilities
that
are
subject
to
numeric
water
quality­
based
effluent
limits
(
WQBELs)
included
in
NPDES
permits.

The
point
sources
evaluated
in
this
study
include
only
those
that
discharge
to
waters
within
Idaho
affected
by
EPA's
final
rule.
Under
the
CWA,
EPA
has
direct
authority
regarding
permits
issued
under
the
NPDES
permit
program.
This
analysis
did
not
consider
the
potential
costs
for
any
program
for
which
EPA
does
not
have
enforceable
authority,
such
as
agricultural
and
forestry­
related
nonpoint
sources.
1
1.4
OVERVIEW
OF
APPROACH
The
overall
approach
to
developing
a
cost
estimate
for
control
measures
for
point
sources
was
to
develop
detailed
cost
estimates
for
the
NPDES
permitted
facilities
discharging
to
the
five
affected
stream
segments.
To
estimate
costs
for
these
facilities,
existing
permit
limitations
or
existing
effluent
concentrations
were
compared
to
prospective
WQBELs
using
numeric
water
quality
criteria
and
a
set
of
assumed
implementation
procedures.
For
purposes
of
this
study,
the
methods
recommended
in
the
EPA
Technical
Support
Document
for
Water
Quality­
Based
Toxics
Control
(
EPA/
505/
2­
90­
001;
March
1991)
were
used.
The
control
measures
needed
to
provide
the
incremental
pollutant
removal
required
to
comply
with
the
projected
WQBELs
then
were
evaluated.
Finally,
costs
were
estimated
for
these
control
measures
based
on
information
on
treatment
technologies
and
cost
analyses
readily
available
in
the
literature.
1­
4
Some
simplifying
assumptions
were
made
to
facilitate
analysis
and
overcome
data
limitations,
where
necessary.
These
assumptions
were
generally
designed
to
be
"
conservative,"
that
is,
to
err
on
the
side
of
more
stringent
and
costly
controls.
For
example,
inexpensive
opportunities
to
employ
pollution
prevention
were
not
always
used.
Instead,
when
considered
technically
feasible,
more
traditional
end­
of­
pipe
technologies
provided
the
basis
for
cost
estimates.
More
detailed
discussions
of
assumptions
and
limitations
are
presented
in
Section
2.

1.5
ORGANIZATION
OF
THIS
REPORT
The
remainder
of
this
report
is
organized
into
two
sections.
Section
2
outlines
the
method
for
recalculating
permit
limitations,
determining
appropriate
pollutant
controls,
and
estimating
costs
for
these
controls.
Section
3
summarizes
the
results
of
the
cost
estimation
exercise.
2­
1
2.
METHODOLOGY
This
chapter
describes
the
methods
used
to
estimate
the
impact
to
point
source
dischargers
resulting
from
implementation
of
EPA's
final
water
quality
standards
for
the
State
of
Idaho.
EPA's
final
rule
establishes
new
use
designations
for
five
specified
waterbodies
and
new
temperature
criteria
applicable
to
bull
trout
spawning
and
rearing
in
1,877
specified
waterbodies.

2.1
OVERVIEW
Dischargers
may
be
affected
by
the
Idaho
water
quality
standards
if
their
current
permit
limits
or
concentrations
of
pollutants
in
their
effluent
exceed
water
quality­
based
effluent
limits
(
WQBELs),
which
are
based
on
water
quality
criteria
intended
to
protect
the
uses
designated
by
the
State
based
on
human
health
and
the
quality
of
aquatic
ecosystems.
Affected
dischargers
would
need
to
implement
measures
either
to
reduce
pollutant
concentrations
in
their
effluent
or
to
seek
alternative
regulatory
approaches,
such
as
phased
total
maximum
daily
loads
(
TMDLs),
sitespecific
criteria,
and
water
quality
variances.

The
actual
impact
of
the
Idaho
water
quality
regulation
will
depend
primarily
upon
the
procedures
used
to
implement
it.
These
procedures
typically
include
the
methods
to
determine
the
need
for
WQBELs
and,
if
WQBELs
are
required,
how
to
derive
WQBELs
from
applicable
water
quality
criteria.
The
implementation
procedures
used
for
this
study
are
based
on
the
methods
recommended
in
EPA's
Technical
Support
Document
for
Water
Quality­
Based
Toxics
Control
(
or
TSD)
(
EPA/
505/
2­
90­
001;
March
1991).
Because
the
methods
recommended
in
the
TSD
are
not
required
to
be
used,
implementation
procedures
can
vary
and
may
result
in
more
or
less
stringent
WQBELs.
Conservative
technical
assumptions
(
i.
e.,
stringent
interpretations)
and
liberal
cost
assumptions
(
i.
e.,
high
estimates)
were
generally
used
to
ensure
that
the
projected
costs
would
tend
to
represent
an
upper
bound
of
the
potential
impact
of
implementing
the
EPA's
final
rule.

2.2
METHODOLOGY
TO
ESTIMATE
POTENTIAL
COSTS
RELATED
TO
NEW
USE
DESIGNATIONS
This
section
presents
the
methodology
used
to
estimate
the
potential
costs
related
to
EPA's
new
use
designations
for
five
waterbodies
in
the
State
of
Idaho.

2.2.1
Universe
of
Affected
Facilities
According
to
the
EPA
Permit
Compliance
System
(
PCS),
156
facilities
possess
a
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
to
discharge
to
surface
waters
within
the
State
of
Idaho.
Of
the
156
facilities,
12
were
determined
to
discharge
to
the
five
waterbodies
with
new
use
designations
(
see
Exhibit
2­
1).
These
12
facilities
were
identified
by
searching
by
2
Under
the
NPDES
permit
program,
EPA
generally
treats
non­
municipal
facilities
as
major
or
minor
based
on
the
consideration
of
several
factors,
including
toxic
pollutant
potential,
flow/
stream
volume,
conventional
pollutant
loadings,
public
health
impact,
water
quality
factors,
and
proximity
to
near
coastal
waters.
Generally,
facilities
are
classified
as
major
dischargers
if
the
types
and/
or
quantities
of
toxic
and/
or
conventional
pollutants
could
impact
receiving
water
quality.

2­
2
receiving
waterbody
name
in
PCS.
As
shown
in
Exhibit
2­
1,
of
the
12
facilities,
six
are
classified
as
major
dischargers,
and
six
are
classified
as
minor
dischargers.
2
EXHIBIT
2­
1.
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS*

Facility
Name
NPDES
Permit
Number
Major
(
M)
or
Minor
(
m)
SIC
Code**
Receiving
Waterbody
South
Fork
Coeur
d'Alene
River
Sewer
District
­
Page
Wastewater
Treatment
Plant
ID0021300
M
4952
South
Fork
Coeur
d'Alene
J­
B's
Food
City
ID0025216
m
5399
South
Fork
Coeur
d'Alene
Bunker
Hill
Mining
ID0000078
M
1031
South
Fork
Coeur
d'Alene
Consolidated
Silver
Mine
ID0000159
M
1044
South
Fork
Coeur
d'Alene
Hecla
Mining
Company
(
Lucky
Friday
Mine
and
Mill)
ID0000175
M
1031
South
Fork
Coeur
d'Alene
City
of
Smelterville
ID0020117
m
4952
South
Fork
Coeur
d'Alene
South
Fork
Coeur
d'Alene
River
Sewer
District
­
Mullan
Sewage
Treatment
Plant
ID0021296
m
4952
South
Fork
Coeur
d'Alene
Hecla
Mining
Company
(
Star/
Morning
Mine
and
Mill)
ID0000167
M
1031
South
Fork
Coeur
d'Alene
Sunshine
Precious
Metals
ID0000060
M
1044
South
Fork
Coeur
d'Alene
Hooper
Elementary
School
ID0025666
m
4961
Soda
Creek
Monsanto
Chemical
ID0001198
m
2819
Soda
Creek
Mountain
Home
Air
Force
Base
ID0027642
m
9711
Canyon
Creek
*
Dischargers
were
identified
discharging
to
three
of
the
five
affected
waterbodies.
**
Standard
Industrial
Classification
(
SIC)
code
2­
3
2.2.2
Selection
of
Pollutants
of
Concern
for
Evaluation
Exhibit
2­
2
presents
the
five
waterbodies
for
which
EPA's
final
rule
specifies
new
use
designations.
As
shown
in
Exhibit
2­
2,
EPA's
final
rule
was
limited
to
establishing
cold
water
biota
designated
uses
for
each
of
the
five
waterbodies
affected
by
the
rule.
Therefore,
the
analysis
of
potential
costs
focused
only
on
those
pollutant
parameters
that
would
be
impacted
by
the
cold
water
biota
use
(
i.
e.,
only
those
pollutants
for
which
new
or
more
stringent
criteria
would
apply
to
the
receiving
waterbody).
The
surface
water
quality
criteria
for
the
protection
of
cold
water
biota
are
provided
in
Section
250
of
the
Idaho
Water
Quality
Standards
and
Wastewater
Treatment
Requirements.

EXHIBIT
2­
2.
NEW
USE
DESIGNATIONS
FOR
THE
STATE
OF
IDAHO
Receiving
Waterbody
Name
Existing
Designated
Use(
s)*
New
Designated
Use(
s)**

Canyon
Creek
(
PB
121
­
Below
mining
impact)
Agricultural
Water
Supply
Cold
Water
Biota
(
Future)
Secondary
Contact
Recreation
Agricultural
Water
Supply
Cold
Water
Biota
Secondary
Contact
Recreation
South
Fork
Coeur
d'Alene
River
(
PB
140S
­
Daisy
Gulch
to
mouth)
Agricultural
Water
Supply
Cold
Water
Biota
(
Future)
Primary
Contact
Recreation
(
Future)
Secondary
Contact
Recreation
Agricultural
Water
Supply
Cold
Water
Biota
Primary
Contact
Recreation
(
Future)
Secondary
Contact
Recreation
Shields
Gulch
(
PB
148S
­
Below
mining
impact)
Cold
Water
Biota
(
Future)
Cold
Water
Biota
Blackfoot
River
(
USB
360
­
Equalizing
dam
to
mouth)
Agricultural
Water
Supply
Cold
Water
Biota
(
Future)
Salmonid
Spawning
(
Future)
Primary
Contact
Recreation
(
Future)
Secondary
Contact
Recreation
Agricultural
Water
Supply
Cold
Water
Biota
Salmonid
Spawning
(
Future)
Primary
Contact
Recreation
(
Future)
Secondary
Contact
Recreation
Soda
Creek
(
BB
310
­
Source
to
mouth)
Agricultural
Water
Supply
Secondary
Contact
Recreation
Agricultural
Water
Supply
Cold
Water
Biota
Secondary
Contact
Recreation
*
Based
on
uses
specified
in
Sections
110
­
160
of
the
Idaho
Water
Quality
Standards
and
Wastewater
Treatment
Requirements.
**
Based
on
EPA's
final
rule
new
use
designations.

2.2.3
Derivation
of
Effluent
Limits
Based
on
Revised
Use
Classifications
2­
4
The
actual
impact
of
EPA's
final
rule
will
depend
upon
the
procedures
and
policy
decisions
that
will
be
established
by
the
permitting
authority
to
implement
the
rule
and
upon
the
control
strategy
selected
by
the
discharger
to
bring
the
facility
into
compliance.
These
procedures
and
policy
decisions
established
by
the
permitting
authority
typically
provide
the
methods
to
determine
the
need
for
WQBELs
and,
if
WQBELs
are
required,
how
to
derive
WQBELs
from
applicable
water
quality
criteria.
The
implementation
procedures
used
to
derive
WQBELs
for
this
analysis
are
based
on
the
methods
recommended
in
EPA's
TSD.
Specifically,
a
projected
effluent
quality
(
PEQ)
was
calculated
and
compared
to
the
projected
WQBEL.
A
PEQ
is
considered
an
effluent
value
statistically
adjusted
for
uncertainty
to
estimate
a
maximum
value
that
may
occur.
The
PEQ
for
each
selected
pollutant
was
compared
to
the
projected
WQBEL.
If
the
PEQ
exceeded
the
projected
WQBEL,
a
reasonable
potential
existed
to
exceed
the
WQBEL.
Pollutants
with
a
reasonable
potential
to
exceed
then
were
analyzed
to
determine
potential
costs
to
achieve
projected
WQBELs.

For
each
facility,
an
evaluation
of
reasonable
potential
to
exceed
WQBELs
was
performed
based
on
applicable
water
quality
criteria
to
protect
new
use
classifications
(
i.
e.,
cold
water
biota).
Any
pollutant
for
which
water
quality
criteria
existed
and
for
which
data
were
available
was
considered.
It
was
assumed
that
reasonable
potential
existed
if
a
permit
limit
for
the
pollutant
of
concern
was
included
in
the
existing
permit
for
the
facility.
In
the
absence
of
a
permit
limit,
but
where
monitoring
data
were
available,
reasonable
potential
was
evaluated
based
on
the
monitoring
data
and
the
PEQ
procedures
contained
in
the
TSD.
Evaluation
of
the
reasonable
potential
to
exceed
the
applicable
dissolved
oxygen
criteria
was
not
possible
because
of
a
lack
of
ambient
data
to
evaluate
the
instream
impact.
However,
only
the
four
publicly
owned
treatment
works
(
POTWs)
discharge
oxygen
consuming
pollutants.
Because
of
the
large
ratio
of
receiving
stream
flow
to
effluent
flow
for
these
facilities,
it
was
assumed
that
the
dissolved
oxygen
criteria
would
not
be
violated.

To
calculate
WQBELs,
the
TSD
procedures
were
used
to
derive
maximum
daily
and
monthly
average
limits.
Background
concentrations
were
based
on
the
average
of
data
contained
in
the
EPA
Storage
and
Retrieval
Water
Quality
File
(
STORET)
for
upstream
monitoring
stations.
In
the
absence
of
data,
zero
was
assumed.
Critical
low
flows
were
calculated
from
data
contained
in
the
U.
S.
Geological
Survey
(
USGS)
Daily
Flow
file
data
base
for
nearby
stream
gauges.
The
1­
day
10­
year
low
flow
was
used
for
acute
aquatic
life
protection,
and
the
7­
day
10­
year
low
flow
was
used
for
chronic
aquatic
life
protection.
In
the
absence
of
stream
flow
data,
zero
low
flow
was
conservatively
assumed.
The
following
briefly
summarizes
the
TSD
approach
to
derive
WQBELs:


Concentration­
based
wasteload
allocations
(
WLAs)
were
calculated
based
on
the
protection
of
aquatic
life
(
cold
water
biota
criteria).


According
to
the
EPA
TSD,
direct
adoption
of
the
WLA
may
not
take
into
account
effluent
variability.
Therefore,
in
accordance
with
the
two­
value
WLA
methodology
recommended
in
the
TSD,
the
coefficient
of
variation
(
CV)
was
calculated
for
each
3
The
method
recommended
in
the
TSD
that
accounts
for
effluent
variability
to
derive
the
WLA
for
a
pollutant
tends
to
be
conservative
to
ensure
protection
of
the
receiving
water.
In
particular,
the
method
statistically
predicts
the
upper
end
of
the
distribution
of
effluent
discharge
concentrations
for
use
in
establishing
WLAs
that
will
achieve
applicable
water
quality
criteria.

2­
5
pollutant
for
which
a
reasonable
potential
was
established.
The
data
set
used
to
determine
reasonable
potential
also
was
used
for
this
analysis.
For
purposes
of
calculating
a
CV,
effluent
data
points
reported
as
below
the
analytical
detection
limit
were
assumed
to
have
concentrations
equal
to
the
reported
detection
limit.
If
fewer
than
10
data
points
were
available,
a
CV
of
0.6
was
assumed,
as
recommended
in
the
TSD.
3

Acute
and
chronic
WLA
values
were
converted
to
their
respective
long­
term
averages
(
LTAs)
using
the
appropriate
conversion
factors
from
the
TSD.
LTAs
were
selected
from
Table
5­
1
in
the
EPA
TSD
based
on
the
CVs
and
using
99th
percentile
values
for
acute
WLAs
and
95th
percentile
values
for
chronic
WLAs.


The
minimum
(
most
limiting)
LTA
was
used
to
calculate
the
maximum
daily
limit
(
MDL)
and
the
average
monthly
limit
(
AML)
from
Table
5­
2
of
the
EPA
TSD.
For
each
facility
and
pollutant,
the
minimum
LTA
was
based
on
an
acute
or
chronic
criterion,
and
the
appropriate
conversion
factor
from
the
TSD
was
used
to
convert
the
LTA
into
MDLs
and
AMLs.

2.2.4
Estimation
of
Potential
Costs
The
new
use
classifications,
by
themselves,
will
have
no
impact
or
effect.
However,
when
the
water
quality
criteria
to
protect
these
uses
are
applied
to
dischargers
through
the
NPDES
program,
then
costs
may
be
incurred
by
regulated
dischargers.
These
costs
can
vary
significantly
because
of
the
wide
range
of
control
strategies
available
to
the
dischargers.

Prior
to
estimating
compliance
costs,
an
engineering
analysis
of
how
each
facility
could
comply
with
the
projected
WQBEL
was
performed.
The
costs
were
then
estimated
based
on
the
decisions
and
assumptions
made
in
the
analysis.
To
ensure
consistency
and
reasonableness
in
estimating
the
general
types
of
controls
that
would
be
necessary
for
a
facility
to
comply
with
the
proposal,
as
well
as
to
integrate
into
the
cost
analysis
the
other
alternatives
available
to
the
regulated
facilities,
a
costing
decision
matrix
was
used
for
each
facility.
Specific
rules
were
established
in
the
matrix
to
provide
guidance
in
consistently
selecting
options.
This
decision
matrix
is
based
on
the
approach
used
in
the
EPA
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995).

Under
the
decision
matrix,
costs
for
minor
treatment
plant
operation
and
facility
changes
were
considered
first.
Minor,
low
cost
modification
or
adjustment
of
existing
treatment
was
determined
to
be
feasible
where
literature
indicated
that
the
existing
treatment
process
could
achieve
the
projected
WQBEL
and
where
the
additional
pollutant
reduction
was
relatively
small.
2­
6
Where
it
was
not
technically
feasible
to
simply
adjust
existing
operations,
the
next
most
appropriate
control
strategy
was
determined
to
be
waste
minimization/
pollution
prevention
controls.
However,
costs
for
these
controls
were
estimated
only
where
they
were
considered
feasible
based
upon
an
understanding
of
the
process(
es)
at
a
facility.
The
practicality
of
techniques
was
determined
based
on
several
criteria
established
in
the
decision
matrix.
Decision
considerations
included
the
level
of
pollution
reduction
achievable
through
waste
minimization/
pollution
prevention
techniques,
appropriateness
of
waste
minimization/
pollution
prevention
for
the
specific
pollutant,
and
knowledge
of
the
manufacturing
process(
es)
generating
the
pollutant
of
concern.

If
waste
minimization/
pollution
prevention
alone
was
deemed
not
feasible
to
reduce
pollutant
levels
to
those
needed
to
comply
with
the
projected
WQBELs,
a
combination
of
waste
minimization/
pollution
prevention,
simple
treatment,
and/
or
process
optimization
was
considered.
If
these
relatively
low
cost
controls
could
not
achieve
the
projected
WQBELs,
more
expensive
controls,
such
as
end­
of­
pipe
treatment,
were
considered.

Development
of
end­
of­
pipe
treatment
cost
estimates
constituted
a
review
of
the
existing
treatment
systems
at
each
facility.
Decisions
to
add
new
treatment
systems
or
to
supplement
existing
treatment
systems
were
based
on
this
initial
evaluation.
For
determining
the
need
for
additional
or
supplemental
treatment,
sources
of
performance
information
included
the
EPA
Office
of
Research
and
Development
(
ORD)
Risk
Reduction
Engineering
Laboratory's
(
RREL's)
Treatability
Database
(
Version
4.0)
and
EPA's
Treatability
Manual,
Volume
IV
­
Cost
Estimating
(
EPA­
600­
8­
80­
042D:
July
1980).
The
pollutant
removal
capabilities
of
the
existing
treatment
systems
and/
or
any
proposed
additional
or
supplemental
systems
were
evaluated
based
on
the
following
criteria:
1)
the
effluent
levels
that
were
being
achieved
currently
at
the
facility
and
2)
the
levels
that
are
documented
in
the
EPA
RREL
Treatability
Database.
If
this
analysis
showed
that
additional
treatment
was
needed,
unit
processes
that
would
achieve
compliance
with
the
projected
WQBELs
were
chosen
using
the
same
documentation.

Following
the
calculation
of
end­
of­
pipe
treatment
costs,
the
relationship
between
the
cost
of
adding
the
treatment
and
other
types
of
remedies
or
controls
was
considered.
Specifically,
if
the
estimated
annualized
cost
for
removing
a
pollutant
was
not
considered
cost­
effective,
the
decision
matrix
indicated
that
the
discharger
would
explore
the
use
of
other
remedies
or
controls
(
i.
e.,
pursue
alternative
regulatory
approaches
to
comply).
When
it
was
assumed
that
facilities
would
pursue
an
alternative
regulatory
approach,
no
treatment
cost
was
estimated
for
a
facility.
In
addition,
pollutant
load
reductions
were
not
calculated
or
credited
for
any
pollutant
for
which
an
alternative
was
assumed.

In
developing
and
using
the
cost
decision
matrix,
it
is
acknowledged
that
granting
relief
from
WQBELs
is
dependent
upon
the
specific
circumstances
at
a
facility,
as
well
as
the
judgment
and
implementing
procedures
of
the
permitting
authority.
It
also
is
acknowledged
that
opportunities
for
waste
minimization
are
dependent
upon
the
specific
circumstances
at
a
facility.
For
this
study,
a
$
200
per
toxic
pounds­
equivalent
trigger
was
used
for
each
facility
that
assumes
2­
7
the
regulatory
flexibility
would
be
available
and
granted
to
all
facilities
that
exceed
the
cost
trigger.
The
cost
estimate
based
on
the
$
200
per
toxic
pounds­
equivalent
trigger
for
a
facility
was
considered
representative
of
compliance
costs
attributable
to
the
implementation
of
EPA's
water
quality
criteria.
For
purposes
of
this
analysis,
estimated
costs
for
3
of
the
12
facilities
exceeded
the
$
200
trigger
for
alternative
regulatory
approaches.
As
a
result,
the
estimated
costs
were
replaced
with
the
cost
to
pursue
alternative
regulatory
approaches
(
considered
to
result
in
a
lowend
estimate
of
costs).
Acknowledging
that
the
use
of
alternative
regulatory
approaches
may
also
be
limited
depending
upon
particular
circumstances
at
a
facility,
costs
also
were
estimated
under
a
higher
cost
scenario
that
assumes
no
regulatory
alternatives
would
be
granted
to
a
facility
(
considered
to
result
in
a
high­
end
estimate
of
costs).

To
facilitate
the
cost
analysis,
available
NPDES
file
information
for
each
facility
was
collected
from
the
EPA
Region
10
office.
To
estimate
costs
for
each
facility,
data
were
obtained
from
NPDES
permit
files,
including
the
permit
application,
permit,
permit
fact
sheet
(
or
statement
of
basis
for
minor
facilities),
and
applicable
inspection
reports.
Discharge
monitoring
report
(
DMR)
data
were
downloaded
from
PCS;
downloads
from
STORET
were
used
to
retrieve
receiving
stream
monitoring
data.

2.2.5
Cost
Estimates
Subsequent
to
evaluating
the
potential
control
options
for
a
given
sample
facility
using
the
compliance
cost
decision
matrix,
costs
were
developed
to
reflect
the
control
options.
This
section
describes
how
the
costs
were
estimated
for
each
of
the
potential
control
options
considered
in
the
compliance
cost
decision
matrix.

2.2.5.1
Treatment
Process
Optimization
Costs
Treatment
process
optimization
refers
to
measures
facilities
can
implement
to
modify
or
adjust
the
operating
efficiency
of
their
wastewater
treatment
process.
Such
measures
usually
involve
engineering
analysis
of
the
existing
treatment
process
to
identify
minor
adjustments
to
enhance
pollutant
removal
or
reduce
chemical
additions
that
can
result
in
toxic
byproducts,
followed
by
implementation
of
such
adjustments.
The
costs
for
treatment
process
optimization
will
vary
according
to
the
specific
type
of
treatment
process
used
at
a
site.
However,
the
information
necessary
to
estimate
these
site­
specific
costs
was
not
available
for
this
study
in
the
permit
files.
Therefore,
it
was
assumed
that
the
average
cost
per
facility
for
process
optimization
was
$
100,000.

2.2.5.2
Waste
Minimization/
Pollution
Prevention
Costs
Where
information
was
lacking
for
developing
alternative
treatment
or
where
existing
effluent
concentrations
were
close
to
projected
WQBELs
(
i.
e.,
generally
less
than
10
to
25
2­
8
percent
of
the
current
discharge
levels),
it
was
assumed
that
it
would
be
more
appropriate
and
technically
efficient
for
a
facility
to
conduct
a
waste
minimization
or
pollution
prevention
study
rather
than
provide
additional
or
supplemental
treatment
units.
It
also
was
assumed
that
as
a
result
of
this
study,
a
facility
would
incur
costs
to
implement
a
waste
minimization
or
pollution
prevention
practice
that
would
be
adequate
to
comply
with
the
projected
WQBEL.
For
purposes
of
this
study,
waste
minimization
or
pollution
prevention
practices
are
considered
techniques
that
could
include
the
installation
of
equipment,
best
management
practices,
and
production/
process
changes.

The
costs
for
implementing
waste
minimization/
pollution
prevention
controls
were
estimated
based
on
the
analysis
performed
in
the
EPA
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Proposed
Great
Lakes
Water
Quality
Guidance
(
April
16,
1993).
Exhibit
2­
3
summarizes
the
unit
waste
minimization/
pollution
prevention
costs
used
for
this
analysis.
The
high­
end
of
the
range
of
estimated
unit
costs
was
selected
for
use
in
this
analysis
to
yield
a
conservative,
higher
cost,
estimate.

EXHIBIT
2­
3.
SUMMARY
OF
WASTE
MINIMIZATION/
POLLUTION
PREVENTION
COSTS
USED
IN
DEVELOPING
COST
ESTIMATES
FOR
FACILITIES
Category
Estimated
Cost*

Mining
$
200,000
Food
and
Food
Products
$
200,000
Inorganic
Chemicals
$
300,000
Steam
Electric
$
400,000
Miscellaneous
$
300,000
Publicly
Owned
Treatment
Works
$
400,000
*
Based
on
cost
for
the
highest
flow
strata
for
a
discharge
category
contained
in
the
EPA
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Proposed
Great
Lakes
Water
Quality
Guidance
(
April
16,
1993).

The
limitation
in
assuming
waste
minimization
practices
would
be
used
is
that
without
process­
specific
information,
it
is
unknown
if
waste
minimization
is
technically
feasible.
However,
this
limitation
is
not
considered
significant,
as
it
has
been
shown
that
relatively
simple,
inexpensive,
source
controls,
best
management
practices,
and
process
changes
can
result
in
significant
pollutant
reductions,
as
well
as
resource
savings
in
raw
materials.
2­
9
2.2.5.3
Pretreatment
Program
Costs
(
Municipal
Only)

In
addition
to
waste
minimization/
pollution
prevention
measures
that
could
be
applied
to
treatment
plant
operations,
pretreatment
program
measures
also
could
be
used
to
comply
with
projected
WQBELs
at
POTWs.
Costs
related
to
a
pretreatment
program
that
would
be
incurred
by
POTWs
consist
of
the
expenses
involved
in
administering
the
pretreatment
program.
Such
expenses
include
one­
time
costs
associated
with
conducting
special
studies
(
e.
g.,
mass
audit
studies,
local
limit
studies)
and
ongoing
costs
to
administer,
educate,
train,
monitor,
inspect,
and
enforce
activities
involving
indirect
dischargers.

Local
limit
studies
are
conducted
by
POTWs
when
there
is
a
basis
for
presuming
that
indirect
dischargers
are
discharging
excessive
amounts
of
pollutants
and
that
more
stringent
limits
need
to
be
imposed
on
the
indirect
dischargers
for
the
POTW
to
meet
its
NPDES
permit.
The
main
objective
of
these
studies
is
to
determine
limits
on
the
pollutant
loadings
that
indirect
dischargers
are
permitted
to
discharge.
Local
limit
studies
cost
approximately
$
15,000
per
pollutant
analyzed
based
on
the
middle
of
the
cost
range
presented
in
the
EPA
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Proposed
Great
Lakes
Water
Quality
Guidance
(
April
16,
1993).

2.2.5.4
New/
Additional
Treatment
Systems
Capital
Costs
Capital
costs
were
estimated
for
those
facilities
where
the
compliance
cost
decision
matrix
indicated
that
new/
additional
treatment
was
needed.
After
the
treatment
system
was
chosen,
capital
costs
were
estimated
by
extracting
the
costs
from
readily
available
cost
curves
available
in
the
EPA
Treatability
Manual,
Volume
IV:
Cost
Estimating
(
EPA/
600/
8­
80­
042d;
July
1980).

Capital
costs
were
presented
as
total
capital
costs
and
included
all
of
the
expenses
associated
with
installing
the
needed
equipment,
including
the
initial
capital
outlay,
the
cost
of
the
equipment,
and
design
and
installation.
Costs
then
were
escalated
to
first
quarter
1997
dollars
using
the
Engineering
News
Record
(
ENR)
Construction
Cost
Index.

Annual
Costs
Estimated
for
the
treatment
unit
processes
being
installed,
annual
costs
include
expenditures
involved
in
operation
and
maintenance
(
O&
M),
additional
monitoring
that
would
be
required
for
ensuring
compliance
with
the
projected
WQBELs,
and
the
management
of
any
residuals
that
may
be
generated
as
a
result
of
installing
treatment
units.
2­
10
$
Operation
and
Maintenance
O&
M
costs
are
annual
costs
associated
with
installing
additional
or
supplemental
treatment
systems.
These
expenses
were
estimated
from
cost
curves
taken
from
the
EPA
Treatability
Manual,
Volume
IV:
Cost
Estimating
(
EPA/
600/
8­
80­
04d;
July
1980),
from
which
capital
costs
were
estimated.
O&
M
costs
estimate
the
annual
expenditures
for
operating
and
maintaining
the
equipment,
treatment
chemicals,
and
energy.
For
this
evaluation,
depreciation
and
the
cost
of
the
capital
initially
spent
were
not
included
in
the
O&
M
costs.
Costs
estimated
from
cost
curves
then
were
escalated
to
first
quarter
1997
dollars
using
the
ENR
Construction
Cost
Index.

$
Monitoring
Monitoring
costs
were
estimated
based
on
the
pollutants
determined
to
need
projected
WQBELs.
First,
a
review
was
conducted
to
determine
current
sampling
and
monitoring
frequencies
for
those
pollutants
of
concern
that
have
current
permit
limits
or
monitoring
requirements.
Then,
based
on
the
potential
for
the
treatment
plant
to
exceed
the
projected
WQBEL,
the
variability
of
the
flow,
the
treatment
employed,
the
type
of
pollutant,
and
the
need
for
more
frequent
monitoring
were
evaluated.
In
most
cases,
existing
monitoring
requirements
in
the
permit
were
deemed
adequate,
as
Regional
or
State
policy
often
dictated
the
frequency
of
monitoring
used
in
a
permit.
Also,
if
other
parameters
were
added,
the
monitoring
frequencies
were
established
at
a
similar
frequency
to
the
existing
monitoring
requirements
of
these
parameters.

Unit
monitoring
costs
were
obtained
from
the
EPA
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Proposed
Great
Lakes
Water
Quality
Guidance
(
April
16,
1993).
These
unit
monitoring
costs
were
taken
from
a
previous
study
conducted
in
June
1991
for
the
EPA
Office
of
Wastewater
Enforcement
and
Compliance
(
OWEC)
in
support
of
the
development
of
the
NPDES
Permit
Application,
Form
2A,
and
represent
the
average
costs
of
12
laboratories
that
submitted
costs
for
66
analytical
methods.

$
Residuals
Management
For
those
sample
facilities
for
which
additional
treatment
units
were
assumed
to
be
needed
to
comply
with
the
projected
WQBELs,
costs
also
will
be
incurred
to
handle
any
residuals
related
to
the
treatment
process.
Therefore,
an
attempt
was
made
to
roughly
estimate
the
costs
to
handle
any
residuals
generated
from
assumed
treatment
processes.
Although
several
different
types
of
treatment
units
were
assumed
to
be
needed
by
facilities,
each
generating
its
own
type
of
residuals,
the
most
common
treatment
unit
added
to
facilities
was
chemical
precipitation
for
4
For
purposes
of
this
analysis,
the
potential
costs
associated
with
storing
and
transporting
sludge
were
not
considered.
These
costs
will
vary
depending
upon
the
sludge
handling
techniques
used
by,
and
the
location
of,
the
facility.

5
Source:
The
State
of
Garbage
in
America.
1995
Nationwide
Survey.
BIOCYCLE;
April
1996,
No.
4,
Volume
57,
p.
615.

6
The
$
200,000
per
pollutant
cost
represents
the
mid­
range
of
costs
for
a
number
of
alternative
regulatory
approaches.
The
costs
estimated
by
the
Regions
and
States
for
the
alternative
approaches
ranged
from
$
20,000
for
2­
11
the
removal
of
metals.
Therefore,
emphasis
was
placed
on
estimating
costs
for
the
handling
of
the
residuals
(
sludges)
resulting
from
chemical
precipitation.

The
quantity
of
sludge
generated
depends
on
the
solids
content
of
the
influent
to
the
treatment
system.
The
quantity
of
sludge
also
depends
on
the
precipitating
agent
(
e.
g.,
lime,
iron
compounds,
aluminum
compounds)
and
can
vary
significantly
among
agents.
Because
lime
precipitation
generally
yields
the
largest
quantities
of
sludge,
it
was
assumed
conservatively
that
lime
was
used
for
all
chemical
precipitation.

Based
on
data
contained
in
the
literature,
a
sludge
generation
rate
of
500
pounds
per
million
gallons
(
lbs/
MG)
was
assumed.
This
generation
rate
was
used
to
estimate
the
total
quantity
of
sludge
for
each
applicable
sample
facility.

The
cost
for
disposing
of
sludge
depends
on
whether
or
not
the
sludge
is
hazardous
and
the
disposal
method
to
be
used.
4
Because
of
limitations
in
the
time
and
resources
allowed
for
analysis,
two
simplifying
assumptions
were
made.
Specifically,
it
was
assumed
that
all
sludges
generated
would
be
non­
hazardous
and
that
sludge
would
be
disposed
of
in
municipal
landfills.
The
assumption
that
chemical
precipitation
sludges
are
non­
hazardous
wastes
would
tend
to
underestimate
the
actual
disposal
costs
for
sludge,
as
some
of
the
sludges
could
be
hazardous
and
require
more
costly
disposal.
This
is
particularly
true
for
industrial
facilities,
where
a
higher
potential
exists
for
precipitation
sludges
to
be
hazardous.
Although
a
variety
of
options
exist
for
the
disposal
of
non­
hazardous
sludges,
landfilling
is
a
common,
reasonably
priced
disposal
method.
The
costs
for
landfill
disposal
of
the
sludge
were
estimated
to
be
$
31
per
ton
based
on
the
technical
literature.
5
2.2.5.5
Costs
for
Alternative
Regulatory
Approaches
Based
upon
estimates
provided
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995),
the
typical
cost
to
facilities
pursuing
alternative
regulatory
approaches
to
projected
WQBELs
was
estimated
to
be
$
200,000
per
pollutant.
6
These
costs
reflect
expenses
associated
with
conducting
additional
criteria
modifications
to
$
1,000,000
per
pollutant
for
phased­
TMDLs.

7
Incidental
removals
of
conventional
and
non­
conventional
pollutants
were
not
taken
into
account
in
this
analysis.

2­
12
monitoring,
special
studies,
and
other
activities
to
support
requests
from
facilities
for
relief
from
the
projected
WQBEL.

2.2.6
Calculation
of
Pollutant
Load
Reductions
Once
the
low­
end
and
the
high­
end
estimates
of
costs
were
generated,
corresponding
loadings
reductions
of
pollutants
were
estimated
for
each
scenario.
For
the
low­
and
the
high­
end
scenarios,
the
baseline
loadings
represent
the
existing
permit
limit,
or
existing
pollutant
discharge
level
in
the
absence
of
an
existing
permit
limit.
The
difference
between
the
baseline
and
the
potential
load
from
projected
WQBELs
represents
the
reduction
from
implementation
of
EPA's
final
rule.
Both
baseline
loads
and
load
reductions
are
expressed
in
toxic
pounds­
equivalent,
which
is
a
normalized
measurement
of
pollutants
that
accounts
for
relative
toxicities
among
pollutants.
7
To
determine
the
annual
baseline
load
for
both
the
low­
and
high­
end
scenarios,
the
baseline
value,
expressed
in
concentration
units,
was
converted
to
an
annual
loading
(
in
pounds
per
year)
by
multiplying
the
baseline
concentration
(
in
micrograms
per
liter)
by
the
average
daily
flow
rate
(
in
million
gallons
per
day)
or,
for
POTWs,
by
the
design
flow,
a
conversion
factor
(
0.00834),
and
365
days
per
year.

To
determine
the
pollutant
loading
reduction
for
a
facility,
the
difference
between
the
most
stringent
existing
permit
limitation
(
or
the
maximum
reported
effluent
concentration)
and
the
most
stringent
projected
WQBEL
(
in
concentration
units)
was
converted
to
pounds
per
year
by
multiplying
the
difference
by
the
facility's
average
daily
flow
rate
(
design
flow
rate
for
municipals),
a
conversion
factor,
and
365
days
per
year.
Annual
pollutant
loading
reductions
were
calculated
for
each
pollutant
analyzed
at
each
facility
for
which
costs
were
estimated.
8
National
water
quality
criteria
have
changed
over
the
years,
resulting
in
corresponding
changes
in
toxic
weights.
To
maintain
a
general
level
of
comparability
between
EPA's
final
rule
and
previous
rules,
this
study
used
previously
calculated
toxic
weights.

2­
13
2.2.6.1
Toxicity
Weighting
of
Baseline
Loads
and
Pollutant
Reductions
Baseline
and
pollutant
loading
reductions
were
weighted
using
EPA
toxic
weights.
Toxic
weight
factors
are
derived
primarily
from
EPA
chronic
freshwater
aquatic
criteria
and
toxicity
values.
However,
EPA
human
health
criteria
also
are
used
in
cases
where
a
human
health
criterion
has
been
established
for
the
consumption
of
fish.
Generally,
toxic
weights
are
derived
by
EPA
through
standardizing
these
criteria
using
copper
as
the
standard
pollutant
(
the
original
EPA
criterion
for
copper,
5.6
ug/
L,
is
used
as
the
water
quality
criterion
and
the
standardization
factor).

For
this
study,
toxic
weights
for
pollutants
were
taken
from
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995).
The
toxic
weights
presented
in
the
Great
Lakes
analysis
were
used
to
allow
comparability
among
effluent
guidelines
and
previous
regulatory
efforts.
8
The
toxic
weights
used
in
the
Great
Lakes
analysis
represent
toxic
weights
calculated
by
EPA's
Office
of
Science
and
Technology
(
OST)
in
1988
using
pollutant
criteria
employed
in
various
EPA
regulatory
efforts.

To
calculate
toxic
pound­
equivalents
for
each
pollutant,
the
pollutant
loading
reduction
for
each
facility
was
multiplied
by
the
appropriate
toxic
weight
for
that
pollutant.
Toxic
poundequivalents
were
determined
for
each
pollutant
for
the
baseline
pollutant
loadings,
as
well
as
the
pollutant
reductions
based
on
low­
and
high­
end
scenarios.

2.2.6.2
Determining
Cost­
Effectiveness
Cost­
effectiveness
values
were
calculated
by
dividing
the
total
annual
costs
by
the
annual
toxic­
weighted
pollutant
reductions.
The
cost­
effectiveness
then
estimates
the
"
dollar­
per­
poundremoved
resulting
from
implementing
EPA's
final
rule.

2.3
METHODOLOGY
TO
ESTIMATE
POTENTIAL
COSTS
RELATED
TO
NEW
TEMPERATURE
CRITERIA
TO
PROTECT
BULL
TROUT
Large
quantities
of
heat
discharged
to
waterbodies
have
the
potential
for
causing
ecological
harm.
It
is
for
such
a
reason
that
the
rule
of
a
maximum
weekly
maximum
temperature
(
MWMT)
of
10o
C
for
initial
rearing
in
natural
streams
and
adult
spawning
of
bull
trout
was
established
by
EPA's
final
rule.
Estimating
costs
associated
with
EPA's
rule
for
all
affected
NPDES
dischargers
in
Idaho
requires
the
calculation
of
excess
heat
that
would
need
to
be
removed
from
discharge
effluents
and
the
cost
associated
with
such
removal.
The
resulting
water
temperature
of
a
given
waterbody
at
the
discharge
point
(
outfall)
depends
on
the
background
and
2­
14
effluent
heat
(
a
function
of
flow
and
temperature).
For
a
sound
and
defensible
estimate
of
the
excess
heat
to
be
removed
from
an
effluent,
development
of
long­
term
monthly
averages
of
temperature
and
flow
for
the
specific
receiving
water
and
effluents
is
necessary.
Determining
the
background
temperature
and
flow
distribution
for
each
waterbody
and
discharger
is
difficult
and
often
impossible
because
of
the
lack
of
observed
data.
The
average
monthly
ambient
temperature
may
vary
from
year
to
year.
The
use
of
only
limited
temperature
observations
does
not
depict
the
long­
term
thermal
regime
of
a
specific
stream.
Without
ambient
and
effluent
monitoring
data,
accurately
assessing
whether
effluent
is
altering
ambient
stream
temperature
is
difficult.

2.3.1
Approach
The
thermal
regime
of
a
waterbody
depends
on
influences
from
climate,
hydraulic
characteristics,
and
temperatures
of
water
inputs.
In
its
simplest
form,
the
temperature
of
a
stream
is
a
combination
of
heat
from
upstream
and
heat
from
a
discharge
input
(
i.
e.,
effluent).
If
the
specific
gravity
and
density
of
water
are
assumed
to
be
constant,
the
equation
is
further
simplified
to
include
flow
and
temperature
of
both
the
upstream
and
discharge
inputs.
To
understand
the
influence
of
an
effluent
from
a
discharger
on
the
thermal
regime
of
a
waterbody,
flow
and
temperature
information
for
both
the
upstream
(
ambient)
and
the
effluent
are
needed.
A
simple
equation
can
be
generated
to
calculate
the
theoretical
rise
in
temperature.
Exhibit
2­
4
shows
the
expected
temperature
change
when
the
difference
in
ambient
and
effluent
temperature,
and
the
ratio
of
effluent
to
total
flow,
is
known.
This
matrix
was
developed
to
be
used
in
conjunction
with
the
EPA
MWMT
rule
to
examine
if
compliance
is
not
met.
If
compliance
is
not
met,
the
temperature
above
the
MWMT
can
be
used
to
calculate
the
amount
of
heat
to
be
removed.

2.3.2
Bull
Trout
Distribution
EPA
determined
bull
trout
spawning
and
rearing
distribution
by
using
two
separate
databases:
the
1994­
1995
Interior
Columbia
Basin
Ecosystems
Management
Project
(
ICBEMP)
(
Quigley
and
Arbelbide,
in
press)
"
Key
Salmonid"
database,
and
the
updated
Idaho
Department
of
Fish
and
Game
(
IDFG)
Digital
Bull
Trout
Distribution
database
(
April
1997).
Combination
of
these
two
databases
resulted
in
a
list
of
streams
known,
suspected,
and/
or
predicted
to
serve
as
spawning
and
juvenile
rearing
areas
and
waterbodies
that
serve
as
habitat
for
all
life
stages
of
bull
trout.
The
resulting
list
of
streams
was
reduced
by
the
removal
of
those
used
for
other
than
spawning
and
juvenile
rearing,
such
as
migratory
corridors.
Streams
were
removed
from
the
list
that
the
ICBEMP
database
denoted
the
presence
of
all
life
stages
of
bull
trout
but
did
not
overlap
with
the
IDFG
database.
Based
on
the
literature
review
done
by
the
EPA,
it
was
determined
that
bull
trout
do
not
use
mainstem
large
river
systems.
Therefore,
mainstem
streams
were
removed
from
the
list
of
bull
trout
streams.
As
a
result,
many
dischargers
were
eliminated
from
the
study
because
they
discharge
to
streams
not
deemed
as
bull
trout
spawning
and
rearing
waterbodies.
2­
15
EXHIBIT
2­
4.
RISE
IN
AMBIENT
TEMPERATURE
USING
EFFLUENT
TEMPERATURE
AND
RELATIVE
PERCENT
OF
QE/
QM
Tb
=
Average
Temperature
for
HUC
Reach
(
upstream
of
Discharger)

Te
=
Average
Temperature
for
Effluent
(
Based
on
Specific
Discharge
Type)

Qe
=
Flow
of
Discharger
Qm
=
Flow
of
Discharger
and
Qb
(
flow
upstream
of
Discharger)

(
Te­
Tb)

Qe/
Qm
­
5.00
­
4.00
­
3.00
­
2.00
­
1.00
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
9.00
10.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.05
­
0.25
­
0.20
­
0.15
­
0.10
­
0.05
0.00
0.05
0.10
0.15
0.20
0.25
0.30
0.35
0.40
0.45
0.50
0.10
­
0.50
­
0.40
­
0.30
­
0.20
­
0.10
0.00
0.10
0.20
0.30
0.40
0.50
0.60
0.70
0.80
0.90
1.00
0.15
­
0.75
­
0.60
­
0.45
­
0.30
­
0.15
0.00
0.15
0.30
0.45
0.60
0.75
0.90
1.05
1.20
1.35
1.50
0.20
­
1.00
­
0.80
­
0.60
­
0.40
­
0.20
0.00
0.20
0.40
0.60
0.80
1.00
1.20
1.40
1.60
1.80
2.00
0.25
­
1.25
­
1.00
­
0.75
­
0.50
­
0.25
0.00
0.25
0.50
0.75
1.00
1.25
1.50
1.75
2.00
2.25
2.50
0.30
­
1.50
­
1.20
­
0.90
­
0.60
­
0.30
0.00
0.30
0.60
0.90
1.20
1.50
1.80
2.10
2.40
2.70
3.00
0.35
­
1.75
­
1.40
­
1.05
­
0.70
­
0.35
0.00
0.35
0.70
1.05
1.40
1.75
2.10
2.45
2.80
3.15
3.50
0.40
­
2.00
­
1.60
­
1.20
­
0.80
­
0.40
0.00
0.40
0.80
1.20
1.60
2.00
2.40
2.80
3.20
3.60
4.00
0.45
­
2.25
­
1.80
­
1.35
­
0.90
­
0.45
0.00
0.45
0.90
1.35
1.80
2.25
2.70
3.15
3.60
4.05
4.50
0.50
­
2.50
­
2.00
­
1.50
­
1.00
­
0.50
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
4.00
4.50
5.00
0.55
­
2.75
­
2.20
­
1.65
­
1.10
­
0.55
0.00
0.55
1.10
1.65
2.20
2.75
3.30
3.85
4.40
4.95
5.50
0.60
­
3.00
­
2.40
­
1.80
­
1.20
­
0.60
0.00
0.60
1.20
1.80
2.40
3.00
3.60
4.20
4.80
5.40
6.00
0.65
­
3.25
­
2.60
­
1.95
­
1.30
­
0.65
0.00
0.65
1.30
1.95
2.60
3.25
3.90
4.55
5.20
5.85
6.50
0.70
­
3.50
­
2.80
­
2.10
­
1.40
­
0.70
0.00
0.70
1.40
2.10
2.80
3.50
4.20
4.90
5.60
6.30
7.00
0.75
­
3.75
­
3.00
­
2.25
­
1.50
­
0.75
0.00
0.75
1.50
2.25
3.00
3.75
4.50
5.25
6.00
6.75
7.50
0.80
­
4.00
­
3.20
­
2.40
­
1.60
­
0.80
0.00
0.80
1.60
2.40
3.20
4.00
4.80
5.60
6.40
7.20
8.00
0.85
­
4.25
­
3.40
­
2.55
­
1.70
­
0.85
0.00
0.85
1.70
2.55
3.40
4.25
5.10
5.95
6.80
7.65
8.50
0.90
­
4.50
­
3.60
­
2.70
­
1.80
­
0.90
0.00
0.90
1.80
2.70
3.60
4.50
5.40
6.30
7.20
8.10
9.00
0.95
­
4.75
­
3.80
­
2.85
­
1.90
­
0.95
0.00
0.95
1.90
2.85
3.80
4.75
5.70
6.65
7.60
8.55
9.50
1.00
­
5.00
­
4.00
­
3.00
­
2.00
­
1.00
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
9.00
10.00
2­
16
2.3.3
Collection
of
Data
The
evaluation
of
facilities
discharging
to
bull
trout
streams
was
conducted
with
water
quality
data
from
PCS,
STORET,
and
three
USGS
data
sets
not
contained
in
STORET.
The
three
USGS
data
sets
are
from
the
National
Water
Quality
Assessment
(
NAWQA),
the
National
Water
Quality
Networks
(
NQN)
(
which
includes
the
National
Stream
Quality
Accounting
Network
[
NASQAN]
and
the
Hydrological
Benchmark
Network
[
HBN]),
and
a
specific
data
request
of
continuously
monitored
temperature
made
to
the
Idaho
USGS.
Exhibit
2­
5
presents
the
data
sets
used
and
examined
in
this
study.

2.3.3.1
PCS
Data
Set
The
PCS
data
comprised
three
files.
The
first
file
contained
the
facility
information,
the
second
file
contained
permit
issuance
information
and
parameter
descriptions,
and
the
third
file
contained
actual
monitoring
data.
A
list
of
facilities
that
discharge
to
bull
trout
streams
was
created
using
the
bull
trout
stream
distribution
list,
a
geographic
information
system
(
GIS)
map
of
the
bull
trout
stream
information
overlaid
with
USGS
Hydrological
Unit
Codes
(
HUCs),
and
the
descriptive
information
for
the
PCS
file
containing
facility
information
(
i.
e.,
stream
name,
latitude/
longitude,
and
HUC).
Thirty­
two
facilities
and
five
questionable
facilities
(
due
to
lack
of
latitude/
longitude
and
HUC
information)
were
determined
to
discharge
to
bull
trout
streams
based
on
the
above
methodology.
Exhibit
2­
6
identifies
these
facilities.
Once
the
facilities
were
determined,
the
NPDES
permit
number
was
used
to
link
with
PCS
monitoring
data
contained
in
the
third
PCS
file.
Of
the
37
facilities,
only
three
were
found
to
have
PCS
temperature
and
flow
data.

2.3.3.2
Ambient
Water
Quality
Data
Sets
B
STORET
The
next
step
involved
gathering
ambient
water
temperature
and
flow
for
the
streams
on
which
the
three
facilities
are
located.
Monitoring
data
from
STORET
were
extracted
for
temperature
and
flow
for
all
stations
in
Idaho.
The
STORET
dataset
contained
two
files.
The
first
file
contained
station
information,
location,
HUC,
latitude/
longitude,
and
a
stream
name/
description.
The
second
file
contained
the
actual
water
quality
information.
The
HUC
number
from
the
three
facilities
given
in
the
PCS
dataset
was
used
to
extract
data
for
specific
monitoring
stations
in
STORET.
This
was
done
by
determining
what
stations
in
the
STORET
file
had
the
same
HUC
number
with
dischargers
in
the
PCS
file.
The
station
number
was
then
used
to
extract
monitoring
data
from
the
second
STORET
file
that
contained
water
temperature
and
flow.
Temperature
data
were
not
found
for
any
monitoring
stations
in
STORET
that
share
an
HUC
with
the
three
facilities
that
discharge
to
bull
trout
streams.
Flow
data
were
found,
but
most
of
the
monitoring
was
done
during
the
1960s
and
1970s.
2­
17
EXHIBIT
2­
5.
DATA
SETS
USED
AND
EXAMINED
FOR
BULL
TROUT
STREAM
STUDY
Dataset
Acronym
Subset
Variables
and
Information
on
Type
Years
Number
of
Stations
Number
of
Observations
Interior
Columbia
Ecosystem
Management
Project
ICBEMP
Basin
Name
Stream
Name
Absence/
Presence
N/
A
N/
A
1,747
streams
Idaho
Department
of
Fish
and
Game
Digital
Bull
Trout
Distribution
Database
IDFG
Basin
Name
Stream
Name
Absence/
Presence
N/
A
N/
A
679
streams
Permit
Compliance
System
PCS
pcsfac
Facility
Information
N/
A
444
N/
A
pcslim
Permit
and
Data
Description
N/
A
444
6,458
pcsmon
Date
and
Monitoring
Data
444
129,373
EPA
Storage
and
Retrieval
Water
Quality
File
STORET
sta
Station
Information
N/
A
3,948
N/
A
values
Date
and
Monitoring
Data
up
to
30
years
3,948
39,351
National
Water
Quality
Assessment
NAWQA
Temperature
up
to
3
years
28
20
per
day
(
7,300
per
year)

National
Water
Quality
Network
NQN
NASQAN
Temperature
and
Flow
up
to
15
years
12
Mean
Daily
Flow
HBN
Monthly
Temperature
Specific
Data
Request
to
IDAHO
USGS
N/
A
Temperature
Min
and
Max
Daily
up
to
15
years
21
N/
A
­
Not
Applicable
2­
18
EXHIBIT
2­
6.
NPDES
DISCHARGERS
TO
STREAMS
AFFECTED
BY
EPA
FINAL
RULE
NPDES
Permit
Number
Major
(
M)
or
Minor
(
m)
Facility
Name
SIC
Code
Hydrological
Unit
Code
(
HUC)
Receiving
Waterbody
ID0026492
m
No
Name
Provided
1531
17050123
Big
Creek
ID0020567
m
No
Name
Provided
4941
17010302
Big
Creek
ID0026671
m
Camas
Resources
Ltd
1041
17060302
Big
Creek
and
Crooked
River
ID0000060
M
Sunshine
Precious
Metals
1044
17010302
Big
Creek
and
S.
F.
Coeur
d'Alene
River
ID0022012
m
No
Name
Provided
4952
17060305
Big
Elk
Creek
ID0025259
M
Blackbird
Mine
1061
17060203
Blackbird
Creek
ID0000817
m
Kooskia
Natl
Fish
Hatchery
921
17060304
Clear
Creek
ID0027499
M
Stibnite
Mine
Project
1041
17060208
E.
F.
and
South
Fork
Salmon
River
ID0026221
m
No
Name
Provided
1044
17060201
Kinnikinic
Creek
ID0023604
m
Wastewater
Treatment
Facility
4952
17060306
Little
Bear
Creek
(
West
Fork)

ID0024325
m
No
Name
Provided
4952
17060306
Lochsa
River
ID0025381
m
No
Name
Provided
1041
17060305
Moose
Creek
ID0021512
M
Dworshak
Natl
Fish
Hatchery
921
17060308
N
.
F.
and
MID
Fork
Clearwater
River
ID0027651
m
Dworkshak
Dam
4911
17060308
N.
F.
Clearwater
River
ID0000108
m
No
Name
Provided
1031
17010304
Nine
Mile
Creek
ID0027197
m
No
Name
Provided
921
17060306
N.
F.
Clearwater
River
ID0025089
m
Mccall
Fish
Hatchery
921
17050123
N.
F.
Payette
River
ID0020206
m
Pierce,
City
of
4952
17060306
Orofino
Creek
ID0022527
m
Pahsimeroi
River
Rearing
Ponds
921
17060202
Pahsimeroi
River
ID0021491
M
Wastewater
Treatment
Facility
4952
17060108
Paradise
Creek
ID0027154
m
No
Name
Provided
4971
17060108
Paradise
Creek
ID0026468
M
Sunbeam
Mine
1041
17060205
Pinyon
Basin,
Jordan
Creek
ID0000451
m
Jaype
Plywood
Unit
2436
17060307
Quartz
River
ID0020699
m
No
Name
Provided
4952
17060305
Red
River
ID0027707
m
Clear
Water
Forest
Industries
2421
S.
F.
Clearwater
River
ID0021814
m
Kooskia,
City
of
4952
17060305
S.
F.
Cork
Clearwater
River
ID0025861
m
No
Name
Provided
1041
17060207
Slaughter
Creek
ID0000205
m
Clark
Fork
Hatchery
921
17010213
Spring
Creek
EXHIBIT
2­
6.
NPDES
DISCHARGERS
TO
STREAMS
AFFECTED
BY
EPA
FINAL
RULE
NPDES
Permit
Number
Major
(
M)
or
Minor
(
m)
Facility
Name
SIC
Code
Hydrological
Unit
Code
(
HUC)
Receiving
Waterbody
2­
19
ID0025402
M
Thompson
Creek
Mining
Company
1061
17060201
Thompson/
Squaw
Creeks/
Salmon
River
ID0020036
m
Crangeville,
City
of
4952
17060305
Three
Mile
Creek
ID0027022
M
Beartrack
Gold
Project
1041
17060203
Ward
and
Smith
Gulch
(
Tributary
to
Napia)

ID0026077
m
No
Name
Provided
1041
17060207
Warren
Creek
ID0027740
m
Death
Creek
Sewage
Disposal
4953
Not
Available
Death
Creek
ID0025470
m
No
Name
Provided
1041
Not
Available
Bear
Creek
ID0026921
m
Golden
Chariot
Mine
1041
Not
Available
Bear
Creek
ID0026310
m
No
Name
Provided
4952
Not
Available
Fourmile
Creek
ID0025739
m
No
Name
Provided
1041
Not
Available
Mores
Creek
2.3.3.3
Ambient
Water
Quality
Data
Sets
B
USGS
Ambient
temperature
and
stream
data
were
examined
for
the
three
USGS
data
sets.
NAWQA
monitoring
took
place
for
1
to
3
years,
during
the
years
1993­
1995.
Observation
frequency
involved
20
measurements
of
temperature
per
day
for
every
day
of
the
year.
Flow
was
not
included
in
the
data.
Data
from
NAWQA
were
organized
and
the
average,
minimum,
and
maximum
monthly
temperatures
were
calculated.
Temperature
distributions
were
created
for
each
of
the
18
stations.
The
monitoring
station
HUC
numbers
were
compared
with
HUCs
contained
in
PCS
for
similarity.
No
monitoring
stations
had
HUC
codes
similar
to
those
of
the
PCS
dischargers.
Though
the
distributions
were
not
used,
they
were
helpful
in
addressing
questions
involving
the
temperature
ranges
and
seasonality
for
a
single
stream
and
comparison
among
different
streams.
The
NQN
contained
both
temperature
and
flow
data.
Temperature
data
consisted
of
monthly
measurements.
The
NASQAN
data
set
contained
mean
daily
flows.
Both
temperature
and
flow
were
monitored
for
periods
ranging
from
several
years
to
more
than
30
years
at
one
station.
The
NASQAN
data
set
contained
12
monitoring
stations.
However,
none
of
these
monitoring
stations
was
in
the
same
HUC
as
the
three
PCS
dischargers
of
interest.
The
specific
data
request
of
continuously
monitored
temperature
made
to
the
Idaho
USGS
resulted
in
an
extensive
data
set.
The
HUCs
of
monitoring
stations
were
compared
with
PCS
facility
HUCs,
with
no
similar
HUCs
found.
9
The
results
of
the
analyses
for
the
individual
facilities
are
provided
in
the
Technical
Support
Document
that
served
as
the
basis
for
the
report
analyses.

3­
1
3.
RESULTS
This
chapter
presents
the
results
of
the
analysis
of
potential
costs
resulting
from
EPA's
final
water
quality
standards
for
selected
waterbodies
in
the
State
of
Idaho.
Section
3.1
identifies
the
potential
costs
associated
with
new
use
designations
for
five
waterbodies
within
the
State.
Section
3.2
discusses
the
potential
costs
related
to
the
new
temperature
criteria
established
to
protect
bull
trout.

3.1
RESULTS
FOR
WATERBODIES
WITH
SPECIFIC
USE
DESIGNATION
This
section
describes
the
costs
and
pollutant
load
reductions
resulting
from
EPA's
final
rule.
This
section
also
discusses
the
potential
economic
impact
resulting
from
these
costs.

3.1.1
Estimated
Costs
Exhibit
3­
1
presents
the
results
of
the
cost
evaluation
of
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permitted
facilities
that
may
be
impacted
as
a
result
of
the
new
designation
for
the
five
waterbody
segments.
As
shown
in
Exhibit
3­
1,
annual
costs
are
expected
to
range
from
$
1.2
million
to
$
10.5
million.
Under
the
low­
end
cost
scenario,
the
costs
for
individual
facilities
ranged
from
$
0
(
i.
e.,
no
projected
impact)
to
just
over
$
640,000.9
Under
the
low­
end
scenario,
three
facilities
were
assumed
to
pursue
alternative
regulatory
approaches.
Under
the
high­
end
scenario,
the
costs
for
individual
facilities
ranged
from
$
0
(
i.
e.,
no
projected
impact)
to
just
over
$
5,700,000.
Under
the
high­
end
scenario,
no
facilities
were
assumed
to
pursue
alternative
regulatory
approaches.

Exhibit
3­
2
summarizes
the
estimated
potential
costs
across
specific
categories.
As
shown
in
Exhibit
3­
2
under
the
low­
end
scenario,
capital
and
operation
and
maintenance
(
O&
M)
costs
accounted
for
over
66
percent
of
the
annual
costs.
Costs
for
pursuing
regulatory
alternatives
accounted
for
just
under
34
percent
of
the
total
annual
costs.
Consistent
with
the
intent
of
the
high­
end
scenario,
capital
and
O&
M
costs
account
for
100
percent
of
the
total
annual
costs.

As
shown
in
Exhibit
3­
3,
under
the
low­
and
high­
end
scenarios,
cadmium,
lead,
and
zinc
accounted
for
approximately
74
and
69
percent
of
the
total
annual
costs,
respectively.
Just
over
15
percent
of
the
total
costs
under
the
low­
end
scenario
are
from
conventional
and
nonconventional
pollutants
(
temperature,
ammonia,
and
total
residual
chlorine).
Under
the
high­
end
scenario,
conventional
and
non­
conventional
pollutants
account
for
less
than
2
percent
of
the
total
costs.
3­
2
EXHIBIT
3­
1.
SUMMARY
OF
ESTIMATED
ANNUAL
COSTS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
Facility
Name
NPDES
Permit
Number
Estimated
Annualized
Costs
(
1st
Quarter
$
1997)

Low­
End
High­
End
Page
Wastewater
Treatment
Plant
ID0021300
$
0
$
0
J­
B's
Food
City
ID0025216
$
0
$
0
Bunker
Hill
Mining
ID0000078
$
142,400
$
5,706,693
Consolidated
Silver
Mine
ID0000159
$
0
$
0
Hecla
Mining
Company
(
Lucky
Friday
Mine
and
Mill)
ID0000175
$
113,920
$
2,323,132
City
of
Smelterville
ID0020117
$
0
$
0
Mullan
Sewage
Treatment
Plant
ID0021296
$
51,463
$
51,463
Hecla
Mining
Company
(
Star/
Morning
Mine
and
Mill)
ID0000167
$
644,438
$
644,438
Sunshine
Precious
Metals
ID0000060
$
170,880
$
1,589,159
Hooper
Elementary
School
ID0025666
$
0
$
0
Monsanto
Chemical
ID0001198
$
36,360
$
36,360
Mountain
Home
Air
Force
Base
ID0027642
$
100,000
$
100,000
TOTAL
$
1,259,461
$
10,451,245
3­
3
EXHIBIT
3­
2.
SUMMARY
OF
ESTIMATED
ANNUAL
COSTS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
BY
COST
CATEGORY*

Category
of
Cost
Low­
End
Scenario
High­
End
Scenario
Annual
Costs
Percent
of
Total
Annual
Costs
Percent
of
Total
Annual
Capital
Costs
$
332,425
26.4%
$
2,979,783
28.5%

Operations
and
Maintenance
$
499,836
39.7%
$
7,471,462
71.5%

Regulatory
Alternative
Approach
$
427,200
33.9%
$
0
0%

Total
$
1,259,461
100.0%
$
10,451,245
100.0%

*
All
costs
in
1st
Quarter
1997
dollars
EXHIBIT
3­
3.
SUMMARY
OF
ESTIMATED
ANNUAL
COSTS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
BY
POLLUTANT*

Pollutant
Low­
End
Scenario
High­
End
Scenario
Annual
Costs
Percent
of
Total
Annual
Costs
Percent
of
Total
Cadmium
$
300,253
24.0%
$
2,189,400
20.9%

Copper
$
56,960
4.5%
$
1,406,198
13.5%

Lead
$
328,733
26.1%
$
2,807,365
26.9%

Mercury
$
56,960
4.5%
$
1,406,199
13.5%

Silver
$
28,480
2.3%
$
264,860
2.5%

Zinc
$
300,252
23.8%
$
2,189,400
20.9%

Temperature
$
36,360
2.9%
$
36,360
0.3%

Total
Residual
Chlorine
$
51,463
4.1%
$
51,463
0.5%
EXHIBIT
3­
3.
SUMMARY
OF
ESTIMATED
ANNUAL
COSTS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
BY
POLLUTANT*

Pollutant
Low­
End
Scenario
High­
End
Scenario
Annual
Costs
Percent
of
Total
Annual
Costs
Percent
of
Total
3­
4
Ammonia
$
100,000
7.9%
$
100,000
1.0%

Total
$
1,259,461
100.0%
$
10,451,245
100.0%

*
All
costs
in
1st
Quarter
1997
dollars
3.1.2
Estimated
Pollutant
Load
Reductions
Exhibit
3­
4
presents
the
estimated
baseline
and
pollutant
load
reductions
attributable
to
EPA's
water
quality
standard
regulation.
As
shown
in
this
exhibit,
the
baseline
pollutant
load
for
the
12
facilities
is
just
over
71,000
toxic
pound­
equivalents
per
year.
The
pollutant
load
reduction
under
the
low­
end
scenario
is
21
percent
or
14,800
toxic
pound­
equivalents
per
year.
Cadmium,
lead,
and
mercury
account
for
87
percent
of
the
total
pollutant
load
reduction
under
the
low­
end
scenario.
Under
the
high­
end
scenario,
the
pollutant
load
reduction
is
98
percent
or
70,200
toxic
pound­
equivalents
per
year.
Lead,
mercury,
and
silver
account
for
over
80
percent
of
the
total
pollutant
load
reduction
under
the
high­
end
scenario.

3.1.3
Analysis
of
Potential
Impact
EPA's
water
quality
standards
regulations
at
40
CFR
Part
131
allow
States
to
establish
uses
inconsistent
with
the
Section
101(
a)(
2)
goals
of
the
Clean
Water
Act
if
the
more
stringent
technology
to
meet
the
goals
will
cause
substantial
and
widespread
economic
and
social
impact.
In
other
words,
there
are
circumstances
under
which
States
may
change
the
designated
use
of
a
waterbody
or
issue
a
variance
from
the
standard
upon
demonstration
that
attaining
the
designated
use
will
result
in
substantial
and
widespread
social
and
economic
impacts
or
will
interfere
with
important
social
and
economic
development.
Because
EPA's
final
rule
changes
the
10
Given
the
short
court­
ordered
deadlines
associated
with
development
of
EPA's
final
rule,
a
relatively
simple
examination
of
potential
economic
impact
was
performed
for
this
analysis.
If
proper
time
had
been
allowed,
then
the
procedures
contained
in
the
EPA
Interim
Economic
Guidance
for
Water
Quality
Standards:
Workbook
(
EPA­
823­
F­
97­
002;
February
1997)
could
be
used
to
determine
the
economic
impact
of
EPA's
rule.

3­
5
EXHIBIT
3­
4.
SUMMARY
OF
ESTIMATED
POLLUTANT
LOAD
REDUCTIONS
FOR
THE
NPDES
PERMITTED
FACILITIES
DISCHARGING
TO
THE
FIVE
WATERBODIES
WITH
NEW
USE
DESIGNATIONS
BY
POLLUTANT*

Pollutant
Low­
End
Scenario
High­
End
Scenario
Baseline
Reduction
Baseline
Reduction
Cadmium
11,679
4,000
11,679
11,469
Copper
1,461
89
1,461
1,269
Lead
22,146
8,531
22,146
21,961
Mercury
20,201
1,762
20,201
19,978
Silver
14,273
0
14,273
14,259
Zinc
1,488
388
1,488
1,242
Temperature
N/
A
N/
A
N/
A
N/
A
Total
Residual
Chlorine
<
1
<
1
<
1
<
1
Ammonia
<
1
<
1
<
1
<
1
Total
71,250
14,772
71,250
70,180
N/
A
­
Not
Applicable
*
All
units
in
toxic
pound­
equivalents
per
year
designated
uses
for
several
waterbodies,
a
simple
examination
of
the
potential
impact
was
performed.
10
To
determine
the
possible
impact
of
potential
costs
associated
with
implementation
of
EPA's
final
rule,
publicly
available
information
regarding
affiliate
and
financial
status
was
collected
for
each
of
the
facilities
for
which
compliance
costs
were
estimated.
Information
was
available
for
only
3
of
the
12
facilities.
The
following
summarizes
the
information
collected:
3­
6

Sunshine
Precious
Metals
(
ID0000060):
Located
in
Kellogg,
Idaho,
is
a
subsidiary
of
Sunshine
Mining
and
Refining
Company
located
in
Boise,
Idaho.
The
1997
Directory
of
Corporate
Affiliations
reports
that
the
parent
company
has
approximate
revenues
of
$
14,214,000,
assets
of
$
105,486,000,
and
a
net
worth
(
assets
minus
liabilities)
of
$
57,863,000.
Sunshine
Precious
Metals
is
reported
to
have
approximate
sales
of
$
46,000,000.
Thus,
the
high­
end
estimated
annual
compliance
cost
of
$
1.6
million
represents
approximately
3.5
percent
of
Sunshine
Precious
Metals
sales
and
approximately
1.5
percent
of
its
parent
company's
assets
(
or
2.8
percent
of
its
parent
company's
net
worth).


Hecla
Mining
Company
(
ID
0000175
and
ID0000167):
The
Lucky
Friday
Mine
and
Mill
in
Mullan,
Idaho,
is
one
of
a
number
of
operations
of
Hecla
Mining
Company,
located
in
Coeur
d'Alene,
Idaho.
Hecla
Mining
Company
also
has
joint
ventures
and
a
non­
U.
S.
holding.
The
1997
Directory
of
Corporate
Affiliations
reports
that
Hecla
Mining
Company
has
approximate
revenues
of
$
166,882,000,
assets
of
$
268,393,000,
and
a
net
worth
of
$
145,508,000.
Thus,
the
estimated
annual
compliance
cost
of
$
2,344,000
for
the
Lucky
Friday
Mine
and
Mill
and
the
Morningstar
Mine
and
Mill
(
the
directory
does
not
reference
the
Morningstar
Mine
and
Mill)
represents
approximately
1.4
percent
of
the
parent
company's
revenues,
0.9
percent
of
its
assets,
and
1.6
percent
of
its
net
worth.


Monsanto
Company
(
ID0001198):
The
Monsanto
Company,
located
in
St.
Louis,
Missouri,
is
an
operating
company
of
Monsanto
Company,
also
located
in
St.
Louis,
Missouri.
The
parent
company
has
numerous
subsidiaries,
operating
companies,
and
non­
U.
S.
holdings.
The
1997
Directory
of
Corporate
Affiliations
reports
that
The
Monsanto
Company
has
approximate
sales
of
$
4.1
billion
and
the
parent
company
has
approximate
sales
of
$
9.3
billion,
assets
of
$
11.2
billion,
and
a
net
worth
of
$
3.7
billion.
Thus,
the
estimated
annual
compliance
cost
of
$
36,000
represents
a
negligible
portion
(
less
than
0.001
percent)
of
sales
for
either
company.

In
addition
to
the
financial
information
described
above,
some
information
regarding
the
Bunker
Hill
Mine
was
collected.
The
Bunker
Hill
Mine,
a
Superfund
site
in
southern
Idaho,
filed
for
bankruptcy
in
1991
and
is
no
longer
in
operation.
Pintlar,
Inc.
(
a
subsidiary
of
Gulf
Resources
&
Chemical)
is
responsible
for
the
Superfund
cleanup
of
the
Bunker
Hill
smelter
site.
The
owner
of
Placer
Mining
Company
in
Bellvue,
Washington,
bought
the
mineral
rights
to
the
mining
site
in
1992.
No
further
information
related
to
the
Bunker
Hill
site
could
be
collected
and
reviewed
for
the
analysis.
However,
because
the
site
is
currently
subject
to
all
applicable,
relevant
and
appropriate
regulations
(
ARARs)
related
to
water
quality,
it
is
assumed
that
EPA's
final
rule
will
not
have
a
significant
impact
on
current
cleanup
efforts.

3.2
RESULTS
FOR
WATERBODIES
WITH
NEW
TEMPERATURE
CRITERIA
FOR
BULL
TROUT
PROTECTION
3­
7
There
are
1,877
waterbody
segments
for
which
EPA
has
established
new
temperature
criteria
for
the
protection
of
bull
trout.
Based
on
data
contained
in
PCS,
37
NPDES
permitted
facilities
are
located
on
these
1,877
waterbody
segments.
Of
the
37
NPDES
dischargers,
8
facilities
are
classified
as
major
dischargers,
and
29
are
classified
as
minor
dischargers.
The
largest
categories
of
dischargers
that
make
up
the
37
dischargers
are
mine
sites
(
15
total:
6
majors
and
9
minors),
municipal
wastewater
treatment
plants
(
9
total:
1
major
and
8
minors),
and
fish
hatcheries
(
6
total:
1
major
and
5
minors).

As
described
in
Section
2.3,
an
intensive
data
search
was
conducted
involving
the
use
and
examination
of
seven
different
data
sets
to
collect
ambient
temperature
data.
The
methodology
used
to
evaluate
these
data
allowed
for
merging
of
the
differing
data
sets
to
determine
the
potential
impact
of
EPA's
final
rule
temperature
criteria.
Examination
of
this
ambient
water
monitoring
revealed
that
ambient
temperatures
were
close
to
or
exceeded
the
EPA
criteria
for
the
protection
of
bull
trout.
The
monitoring
data
indicate
that
July,
August,
and
September
are
the
critical
period
in
which
EPA's
final
rule
maximum
weekly
maximum
temperature
is
likely
not
to
be
met.

According
to
PCS,
of
the
37
NPDES
permitted
facilities
that
discharge
to
bull
trout
waterbodies,
3
facilities
(
1
major
mine,
1
major
municipal
wastewater
treatment
plant,
and
1
minor
municipal
wastewater
treatment
plant)
contained
permit
limits
for
temperature
discharges.
There
were
no
ambient
monitoring
stations
with
data
for
flow
and
temperature
that
were
in
the
same
Hydrological
Unit
Code
(
HUC)
as
the
three
dischargers.

An
accurate
evaluation
of
the
need
and
cost
for
temperature
controls
requires
extensive
data
for
both
ambient
conditions
(
air
and
water)
and
the
effluent
discharge.
Because
the
specific
data
were
not
readily
available
for
the
final
rule
analysis
for
any
of
the
NPDES
permitted
facilities,
the
following
discussion
describes
the
potential
range
of
costs
that
could
result
from
implementation
of
the
final
temperature
criteria
for
protection
of
bull
trout.

If
it
is
assumed
that
each
of
37
permitted
facilities
were
to
pursue
alternative
regulatory
approaches
to
comply
with
the
temperature
criteria,
the
total
annual
costs
are
estimated
to
be
just
over
$
1
million.
Alternative
regulatory
approaches
would
be
considered
feasible
for
a
facility
should
ambient
receiving
water
conditions
indicate
that
criteria
can
not
be
achieved
(
e.
g.,
habitat
unsuitable
for
bull
trout,
natural
background
temperatures
higher
than
criteria,
etc.).
In
fact,
as
described
above,
the
limited
background
ambient
temperature
data
that
were
available
indicated
that
some
waters
(
based
on
limited,
historical
data)
may
naturally
exceed
the
temperature
to
protect
bull
trout.
Under
these
circumstances,
a
facility
could
pursue
alternatives
such
as
the
derivation
of
a
site­
specific
criterion.
The
cost
for
a
facility
to
pursue
regulatory
alternatives
was
based
on
those
used
in
the
Regulatory
Impact
Analysis
prepared
for
the
final
Great
Lakes
Water
Quality
Guidance.

Alternatively,
if
it
is
assumed
that
each
of
the
37
facilities
were
to
conservatively
incur
costs
to
install
and
operate
temperature
control
equipment,
the
total
annual
costs
are
estimated
to
3­
8
be
just
under
$
9
million
per
year.
This
high­
end
cost
estimate
is
based
upon
the
installation
and
operation
of
cooling
towers
at
each
facility.
This
assumption
is
considered
a
worst­
case
scenario
for
several
reasons.
First,
not
all
types
of
facilities
produce
wastewater
with
elevated
temperatures
that
would
require
reduction
(
e.
g.,
fish
hatcheries,
mining
sites
that
do
not
include
milling
operations
that
require
cooling
waters,
and
minor
municipal
dischargers).
Second,
because
many
of
the
facilities
that
discharge
to
bull
trout
protection
streams
are
classified
as
minor
dischargers,
they
are
not
expected
to
discharge
wastewater
at
a
volume
or
at
a
temperature
that
would
affect
the
receiving
water
quality.
Finally,
the
incremental
decrease
in
temperatures
would
be
expected
to
be
relatively
small
for
most
discharges,
with
the
possible
exception
of
cooling
water
discharges.
As
such,
the
use
of
cooling
towers
for
all
discharges
is
unrealistic
and
most
likely
not
cost
efficient
(
i.
e.,
there
are
other
relatively
simple
and
inexpensive
practices,
such
as
cooling
ponds
or
canals,
that
could
be
used
in
place
of
cooling
towers
to
adequately
reduce
temperatures).
Therefore,
the
total
annual
costs
to
comply
with
the
temperature
criteria
in
EPA's
final
rule
will
most
likely
be
at
the
lower
end
of
the
cost
range.
