ECONOMIC
ANALYSIS
OF
THE
PROPOSED
WATER
QUALITY
STANDARDS
RULE
FOR
PUERTO
RICO
October
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.
SAIC
Project
Number
01­
0833­
04­
2326­
xxx
October
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
2
1.3
Scope
of
the
Analysis
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1­
3
1.4
Organization
of
the
Report
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1­
3
2.0
Baseline
for
the
Analysis
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2­
1
2.1
Water
Quality
Standards
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2­
1
2.2
Point
Source
Dischargers
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2­
2
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
1
3.2
Potentially
Impacted
Facilities
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3­
1
4.0
Method
for
Estimating
Costs
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4­
1
4.1
Sample
Facilities
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4­
1
4.2
Identifying
Potential
Controls
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4­
1
4.3
Estimating
Costs
of
Controls
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4­
2
4.4
Total
Annual
Costs
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4­
4
4.5
Potential
Loading
Reductions
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4­
4
5.0
Results
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5­
1
5.1
Total
Costs
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5­
1
5.2
Limitations
of
the
Analysis
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5­
1
6.0
References
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6­
1
APPENDICES
Appendix
A
Facility
Analyses
Appendix
B
Total
Annual
Cost
Calculations
October
2003
ii
List
of
Exhibits
Exhibit
ES­
1.
Comparison
of
Current
Puerto
Rico
and
Proposed
EPA
Criteria
for
Six
Bays
and
Estuaries
and
the
Coastal
Ring
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ES­
2
Exhibit
ES­
2.
Potential
Costs
Attributable
to
the
Proposed
Rule
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ES­
3
Exhibit
2­
1.
Puerto
Rico
Water
Quality
Criteria
for
Class
SC
Waters
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2­
1
Exhibit
2­
2.
Summary
of
NPDES
Permitted
Direct
Dischargers
in
Puerto
Rico
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2­
2
Exhibit
3­
1.
Comparison
of
Current
Puerto
Rico
and
Proposed
EPA
Criteria
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3­
1
Exhibit
3­
2.
Estimated
Number
of
Facilities
Potentially
Affected
by
the
Proposed
Rule
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3­
2
Exhibit
4­
1.
Sample
Facilities
Evaluated
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4­
1
Exhibit
4­
2.
Process
Modification
Cost
Components
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4­
3
Exhibit
5­
1.
Potential
Costs
Attributable
to
the
Proposed
Rule
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5­
1
Exhibit
5­
2.
Limitations
of
the
Analysis
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5­
2
October
2003
iii
List
of
Acronyms
BOD
Biochemical
oxygen
demand
CWA
Clean
Water
Act
DMR
Discharge
monitoring
report
EPA
Environmental
Protection
Agency
EO
Executive
Order
EQB
Environmental
Quality
Board
mgd
Million
gallons
per
day
mL
milliliter
NPDES
National
Pollutant
Discharge
Elimination
System
NTU
Nephelometric
turbidity
units
O&
M
Operation
and
maintenance
PCS
Permit
compliance
system
POTW
Publicly
owned
treatment
works
PRWQSR
Puerto
Rico
Water
Quality
Standards
Rule
TSS
Total
suspended
solids
WQS
Water
quality
standards
October
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
Commonwealth
of
Puerto
Rico.
This
report
provides
estimates
of
potential
incremental
costs
that
point
source
dischargers
may
experience
as
a
result
of
the
proposed
rule.

In
August
1990,
the
Commonwealth
of
Puerto
Rico
adopted
revisions
to
the
Puerto
Rico
Water
Quality
Standards
Rule
(
PRWQSR).
The
revisions
were
sent
to
EPA
on
September
21,
1990,
with
a
caveat
from
the
Chairman
of
the
Puerto
Rico
Environmental
Quality
Board
(
EQB)
that
the
transmittal
may
not
be
the
final
submittal,
because
EQB
was
to
have
a
subsequent
public
hearing
on
November
1,
1990.
Therefore,
EPA
did
not
act
on
these
revisions
immediately.

The
requisite
certification
from
the
Commonwealth's
Secretary
of
Justice
was
ultimately
submitted
to
EPA
on
February
25,
2002.
Upon
receipt
of
this
certification,
EPA
took
final
action
on
all
new
and
revised
provisions
of
the
1990
PRWQSR
on
March
28,
2002.
These
revisions
included
11
separate
new
or
revised
provisions.
The
1990
revisions
to
the
PRWQSR,
however,
did
not
include
any
changes
to
the
designation
of
specific
water
body
segments,
including
any
upgrades
of
waters
from
Class
SC
(
secondary
contact
recreation)
to
Class
SB
(
primary
contact
recreation).

On
March
28,
2003,
EQB
submitted
additional
revisions
to
the
PRWQSR.
These
revisions
included
the
reclassification
of
ten
bays
and
estuaries
previously
classified
as
Class
SC
waters
to
Class
SB
(
Article
2.1.3).
EPA
approved
these
revisions
on
June
26,
2003.
However,
the
revisions
to
the
PRWQSR
did
not
address
the
6
bays
and
the
coastal
ring
(
i.
e.,
coastal
waters
from
500
meters
to
3
miles)
still
designated
Class
SC.
Consequently,
on
February
20,
2002,
a
complaint
was
filed
in
the
U.
S.
District
Court
for
the
District
of
Puerto
Rico
by
three
environmental
groups:
CORALations,
American
Littoral
Society,
and
the
American
Canoe
Association.
In
this
action,
the
plaintiffs
alleged,
among
other
things,
that
certain
actions
by
EPA
personnel
had
triggered
a
mandatory
duty
under
Section
303(
c)
of
the
CWA
to
prepare
and
propose
regulations
setting
forth
a
revised
water
quality
standard
for
any
coastal
waters
that
remained
classified
SC.
On
August
11,
2003,
the
Court
ordered
EPA
to
prepare
and
publish
new
or
revised
water
quality
standards
for
those
coastal
waters
which
are
currently
classified
as
Class
SC
waters.

EPA
is
proposing
to
establish
a
new
Federal
use
designation
for
primary
contact
recreation
use
and
applicable
water
quality
criteria
to
protect
primary
contact
recreation
for
selected
water
bodies
in
Puerto
Rico.
The
current
coliform
criteria
for
Class
SC
waters
are
intended
to
be
protective
of
secondary
contact
recreation,
and
the
remainder
of
the
criteria
are
intended
to
protect
other
uses,
such
as
aquatic
life
protection
or
human
health.
Therefore,
the
new
Federal
use
does
not
affect
any
of
these
criteria
designation,
except
for
the
bacteriological
criteria.
The
proposed
bacteriological
criteria
are
the
same
as
the
Commonwealth's
criteria
for
fecal
coliform
and
enterococci
associated
with
the
Class
SB
use
(
Section
3.2.2
of
the
PRWQSR).
Exhibit
ES­
1
shows
EPA's
proposed
criteria
and
provides
the
Commonwealth's
current
criteria
for
comparison.
1Potentially
affected
facilities
may
include
facilities
that
do
not
discharge
directly
to
affected
waters.
EPA
assumed
that
facilities
discharging
two
miles
or
less
upstream
of
the
six
bays
and
the
coastal
ring
could
potentially
impact
the
downstream
water
body.

October
2003
Executive
Summary
ES
 
2
Exhibit
ES­
1.
Comparison
of
Current
Puerto
Rico
and
Proposed
EPA
Criteria
for
Six
Bays
and
Estuaries
and
the
Coastal
Ring1
Designated
Use
Puerto
Rico
Criteria
Proposed
EPA
Criteria
Coliforms
10,000
colonies/
100
mL
of
total
coliform.
2,000
colonies/
100mL
of
fecal
coliforms.
Not
more
than
20%
of
fecal
coliform
samples
shall
exceed
4,000
colonies/
100
mL.
35
colonies
/
100
mL
enterococci
density.
200
colonies/
100mL
of
fecal
coliforms
Not
more
than
20%
of
fecal
coliform
samples
shall
exceed
400
colonies/
100
mL.

1.
Includes
Mayaguez
Bay
from
Punta
Guanajibo
to
Punta
Algarrobo,
Yabucoa
Port,
Guayanilla
and
Tallaboa
Bays
from
Cayo
Parguera
to
Punta
Verraco,
Ponce
Port
from
Punta
Carenero
to
Punta
Cuchara,
San
Juan
Port
from
the
mouth
of
Río
Bayamón
to
Punta
El
Morro,
and
the
coastal
ring
(
i.
e.,
coastal
waters
500
meters
to
3
miles).

In
evaluating
the
impact
of
its
proposed
rule,
EPA
calculated
the
cost
of
reducing
fecal
coliform
levels
based
on
current
Puerto
Rico
standards
to
levels
that
would
be
required
under
EPA's
proposed
more
stringent
standards.
The
water
quality
criteria
and
uses
in
EPA's
proposed
rule
may
impact
facilities
that
discharge
to
affected
waters.
EPA
assumed
that
only
facilities
that
have
the
potential
to
affect
(
i.
e.,
cause
an
increase
in
fecal
coliform
levels)
the
6
bays
for
which
EPA
is
designating
a
new
primary
contact
recreation
use
or
the
coastal
ring
(
i.
e.,
coastal
waters
from
500
meters
to
3
miles)
may
be
impacted.
1
EPA
identified
these
facilities
by
overlaying
facilities
in
its
permit
compliance
system
(
PCS)
database
with
the
potentially
affected
waters
and
their
tributaries
currently
designated
for
a
Class
SC
use
using
geographic
information
system
software.
EPA
assumed
that
only
wastewater
treatment
plants
or
military
facilities
with
similar
effluent
characteristics
(
i.
e.,
facilities
having
the
potential
to
discharge
fecal
coliforms)
could
potentially
be
affected
by
the
proposed
rule.

EPA
identified
a
total
of
32
facilities
(
20
majors
and
12
minors)
that
may
be
affected
by
the
proposed
primary
contact
designated
use,
and
evaluated
a
sample
of
facilities
from
this
group
for
potential
cost
impacts.
To
select
a
sample,
EPA
stratified
the
universe
by
discharge
type
(
major,
minor)
and
category
(
municipal,
military).
EPA
evaluated
the
two
major
municipal
facilities
with
the
greatest
flow,
thus
ensuring
that
the
facilities
with
the
largest
potential
costs
would
be
evaluated.
EPA
also
evaluated
the
only
major
facility
in
the
military
category.
For
the
remaining
facilities,
EPA
chose
a
random
sample
to
represent
discharger
type
and
category.

EPA
estimated
the
most
cost­
effective
control
strategy
for
each
sample
facility
to
achieve
compliance
with
the
proposed
criteria
on
a
case­
by­
case
basis.
EPA
assumed
that
projected
effluent
limits
for
fecal
coliform
would
be
applied
as
criteria
end­
of­
pipe
(
a
monthly
geometric
mean
of
200
colonies/
100
mL
and
not
more
than
20%
of
samples
exceeding
400
colonies/
100
mL)
because
the
facilities'
current
permits
apply
the
existing
criteria
in
the
same
manner.
EPA
assumed
that
a
sample
facility
would
incur
costs
if
average
monthly
effluent
concentrations
(
or
existing
permit
limit,
whichever
is
smaller)
indicate
that
the
facility
would
not
be
in
compliance
with
the
most
stringent
criterion.
October
2003
Executive
Summary
ES
 
3
EPA
determined
potential
compliance
with
the
projected
limit
for
each
sample
facility
based
on
the
relative
magnitude
of
the
maximum
average
monthly
values,
the
pattern
of
occurrence
of
such
values
(
i.
e.,
when
maximum
values
occurred),
and
current
treatment
performance
characteristics
[
e.
g.,
biochemical
oxygen
demand
(
BOD)
and
total
suspended
solids
(
TSS)
concentrations,
compliance
with
current
permit].
EPA
assumed
that
facilities
exceeding
their
current
limits
would
install
the
necessary
controls
for
compliance
with
current
standards,
and
would
incur
costs
for
additional
treatment
process
optimization
to
comply
with
the
projected
limit.
For
facilities
that
comply
with
their
current
permit
limits
but
would
not
comply
with
the
projected
limit,
EPA
also
assumed
that
process
optimization
of
their
chlorination
process
would
be
necessary
for
compliance
with
the
projected
limit.

EPA
extrapolated
the
results
for
each
type
and
category
of
sample
facility
to
all
facilities
in
the
universe.
EPA
estimated
that
the
total
annual
potential
cost
of
the
proposed
rule
is
approximately
$
2.7
million,
and
that
the
total
annual
costs
will
result
in
pollutant
loading
reductions
of
1.86
x
1015
fecal
coliform
colonies.
Fecal
coliforms
are
bacteria
that,
when
present,
indicate
contamination
of
receiving
waters
by
mammalian
feces,
including
human
feces.
At
high
numbers
of
fecal
coliform
bacteria
per
volume
of
water,
there
is
a
high
probability
that
human
pathogens
(
disease­
causing
organisms)
are
also
present,
resulting
in
an
increased
risk
of
disease
following
contact.
Ingestion
of
high
concentrations
of
fecal
coliform
bacteria
can
also
lead
directly
to
human
illness.
The
reductions
in
the
number
of
fecal
coliform
bacteria
as
a
result
of
the
proposed
rule
will
therefore
reduce
the
risk
of
human
disease
from
discharge
of
waste
from
wastewater
treatment
facilities.

Exhibit
ES­
2
provides
a
summary
of
the
number
of
potentially
affected
facilities
and
the
estimated
costs
associated
with
the
proposed
rule.

Exhibit
ES­
2.
Potential
Costs
Attributable
to
the
Proposed
Rule
(
millions
of
$
2003)
1
Category
Facilities
Evaluated
(
Total
Affected)
Total
Capital
Annual
O&
M
Total
Annual
Costs2
Major
Municipal
6
(
19)
$
2.5
$
2.4
$
2.6
Minor
Municipal
2
(
10)
$
0.5
$
0.1
$
0.1
Major
Military
1
(
1)
$
0.0
$
0.0
$
0.0
Minor
Military
1
(
2)
$
0.1
$
0.0
$
0.0
Total
10
(
32)
$
3.2
$
2.4
$
2.7
Note:
Detail
may
not
add
to
total
due
to
rounding.
O&
M
=
operation
and
maintenance.
1.
Costs
for
evaluated
facilities
extrapolated
to
all
potentially
affected
facilities.
2.
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.
October
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
Commonwealth
of
Puerto
Rico.
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
Section
303
(
33
U.
S.
C.
1313)
of
the
Clean
Water
Act
(
CWA)
directs
States
to
adopt
water
quality
standards
to
protect
the
public
health
and
welfare,
enhance
the
quality
of
water
and
serve
the
purposes
of
the
CWA.
Under
Section
303,
States
are
required
to
develop
WQS
for
waters
within
their
boundaries.
Section
303(
c)
provides
that
WQS
shall
include
the
designated
use
or
uses
for
the
water
and
criteria
necessary
to
protect
those
uses.
The
designated
uses
to
be
considered
by
States
in
establishing
water
quality
standards
are
specified
in
the
CWA
and
include
public
water
supplies,
propagation
of
fish
and
wildlife,
recreation,
agricultural
uses,
industrial
uses,
and
navigation.
States
are
required
to
review
their
water
quality
standards
at
least
once
every
three
years
and,
if
appropriate,
revise
or
adopt
new
standards.
The
results
of
this
triennial
review
must
be
submitted
to
EPA,
and
EPA
must
approve
or
disapprove
any
new
or
revised
standards.

Water
quality
standards
establish
the
"
goals"
for
a
water
body
through
the
establishment
of
designated
uses.
Designated
uses,
in
turn,
determine
what
water
quality
criteria
apply
to
specific
water
bodies.
Section
101(
a)(
2)
of
the
CWA
establishes
as
a
national
goal
"
water
quality
which
provides
for
the
protection
and
propagation
of
fish,
shellfish,
and
wildlife
and
recreation
in
and
on
the
water,"
wherever
attainable.
These
national
goals
are
commonly
referred
to
as
the
"
fishable/
swimmable"
goals
of
the
Act.
Section
303(
c)(
2)(
A)
requires
water
quality
standards
to
"
protect
the
public
health
and
welfare,
enhance
the
quality
of
water,
and
serve
the
purposes
of
this
Act."
EPA's
regulations
at
40
CFR
131
interpret
and
implement
these
provisions
by
requiring
that
water
quality
standards
provide
for
fishable/
swimmable
uses
unless
those
uses
have
been
shown
to
be
unattainable.
The
mechanism
in
EPA's
regulations
used
to
overcome
this
presumption
is
a
use
attainability
analysis.

In
August
1990,
the
Commonwealth
of
Puerto
Rico
adopted
revisions
to
the
Puerto
Rico
Water
Quality
Standards
Rule
(
PRWQSR).
The
revisions
were
sent
to
EPA
on
September
21,
1990,
with
a
caveat
from
the
Chairman
of
the
Puerto
Rico
Environmental
Quality
Board
(
EQB)
that
the
transmittal
may
not
be
the
final
submittal,
because
EQB
was
to
have
a
subsequent
public
hearing
on
November
1,
1990.
Therefore,
EPA
did
not
act
on
these
revisions
immediately
because
of
the
public
hearing,
and
because
the
requisite
certification
(
required
by
40
CFR
131.6(
e))
from
the
Commonwealth's
Secretary
of
Justice
was
not
submitted
with
the
revisions.

From
1991
to
1993,
EPA
Region
2
worked
with
EQB
on
a
series
of
draft
revisions
to
the
PRWQSR.
However,
these
drafts
were
never
adopted
by
Puerto
Rico.
In
1992,
EPA
included
October
2003
1.0
Introduction
1
 
2
Puerto
Rico
in
the
National
Toxics
Rule,
mainly
because
EPA
did
not
consider
the
1990
revisions
to
be
officially
adopted.

The
requisite
certification
from
the
Commonwealth's
Secretary
of
Justice
was
ultimately
submitted
to
EPA
on
February
25,
2002.
Upon
receipt
of
this
certification,
EPA
took
final
action
on
all
new
and
revised
provisions
of
the
1990
PRWQSR
on
March
28,
2002.
These
revisions
included
11
separate
new
or
revised
provisions.
The
1990
revisions
to
the
PRWQSR,
however,
did
not
include
any
changes
to
the
designation
of
specific
water
body
segments,
including
any
upgrades
of
waters
from
Class
SC
(
secondary
contact
recreation)
to
Class
SB
(
primary
contact
recreation).

On
March
28,
2003,
EQB
submitted
additional
revisions
to
the
PRWQSR.
These
revisions
included
the
reclassification
of
ten
bays
and
estuaries
previously
classified
as
Class
SC
waters
to
Class
SB
(
Article
2.1.3),
including:
Aguadilla
Bay
(
from
Punta
Boquerón
to
Punta
Borinquen);
Arecibo
Bay
(
from
Punta
Maracayo
to
Punta
Caracoles);
Fajardo
Bay
(
from
Playa
Sardinera
to
Playa
de
Fajardo);
Roosevelt
Roads
(
from
Punta
Cabra
de
Tierra
to
Punta
Cascajo);
Port
of
Naguabo
(
from
Playa
de
Naguabo
to
El
Morrillo);
Jobos
Bay
and
Laguna
de
la
Mareas
(
from
Punta
Rodeo
to
Punta
Colchones);
Guánica
Bay
inland
waters
north
of
the
mouth
of
the
river;
Port
of
Dewey
in
Culebra;
and
Port
of
Isabel
Segunda
in
Vieques
and
Puerto
Real
in
Vieques
between
Cayo
de
Tierra
and
Cayo
Real.
EPA
approved
these
revisions
on
June
26,
2003.

While
the
March
28,
2003
revisions
to
the
PRWQSR
did
address
10
bays
and
estuaries
that
were
previously
classified
as
Class
SC
waters
by
reclassifying
them
to
Class
SB,
Puerto
Rico
recognized
that
the
6
bays
and
the
coastal
ring
(
i.
e.,
coastal
waters
from
500
meters
to
3
miles)
still
needed
to
be
addressed.
In
an
effort
to
address
these
remaining
Class
SC
waters,
EQB,
in
its
State
Fiscal
Year
2003
CWA
Section
604(
b)
Consolidated
Workplan,
committed
to
develop
a
plan
that
would
outline
a
schedule
for
data
collection
and
analysis,
and
identify
the
applicable
regulatory
actions
for
these
waters.
EQB
is
currently
completing
this
plan.

However,
on
February
20,
2002
a
complaint
was
filed
in
the
U.
S.
District
Court
for
the
District
of
Puerto
Rico
by
three
environmental
groups:
CORALations,
American
Littoral
Society,
and
the
American
Canoe
Association.
In
this
action,
the
plaintiffs
alleged,
among
other
things,
that
certain
actions
by
EPA
personnel
had
triggered
a
mandatory
duty
under
Section
303(
c)
of
the
CWA
to
prepare
and
propose
regulations
setting
forth
a
revised
water
quality
standard
for
any
coastal
waters
that
remained
classified
SC.
Consequently,
the
Court,
in
its
August
11,
2003
Opinion
and
Order,
ordered
EPA
to
prepare
and
publish
new
or
revised
water
quality
standards
for
those
coastal
waters
which
are
currently
classified
as
Class
SC
waters.

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
and
submitting
it
for
review
by
the
Office
of
Management
and
Budget).
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
2
Agricultural
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.

October
2003
1.0
Introduction
1
 
3
the
economy,
productivity,
competition,
jobs,
the
environment,
public
health
or
safety,
or
state,
local,
or
tribal
governments
or
communities.

EPA's
proposed
rule
does
not
establish
any
requirements
directly
applicable
to
regulated
entities.
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
water
bodies
affected
by
the
proposed
rule.
The
types
of
affected
facilities
may
include
industries
and
publicly
owned
treatment
works
(
POTWs)
discharging
sanitary
wastewater
to
surface
waters
in
the
Commonwealth
(
i.
e.,
point
sources).
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
nonpoint
sources).
2
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,
and
the
point
sources
that
are
subject
to
that
criteria
Section
3
provides
a
description
of
the
proposed
rule
and
the
potentially
affected
dischargers.
Section
4
summarizes
the
method
for
estimating
costs,
and
Section
5
presents
the
results
of
the
analysis.
Several
appendices
provide
detailed
information
on
the
sample
facilities
and
the
estimation
of
costs.
October
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.
EPA
calculated
the
incremental
costs
of
the
rule's
provisions
as
the
cost
of
reducing
fecal
coliform
levels
based
on
current
Puerto
Rico
standards
to
levels
that
would
be
required
under
EPA's
proposed
more
stringent
standards.
Thus,
this
section
describes
the
current
Commonwealth
standards,
and
the
existing
dischargers
in
the
Commonwealth.

2.1
Water
Quality
Standards
Exhibit
2­
1
summarizes
Puerto
Rico's
current
criteria
for
waters
designated
as
Class
SC.
Coastal
waters
designated
as
Class
SC
are
"
intended
for
uses
where
the
human
body
may
come
in
indirect
contact
with
the
water
(
such
as
fishing,
boating,
etc.),
and
for
use
in
propagation
and
preservation
of
desirable
species,
including
threatened
or
endangered
species."
EQB
applies
the
Class
SC
designation
in
coastal
waters
from
the
zone
subject
to
the
ebb
and
flow
of
tides
(
e.
g.,
mean
sea
level)
to10.3
nautical
miles
seaward.

Exhibit
2­
1.
Puerto
Rico
Water
Quality
Criteria
for
Class
SC
Waters
Parameter
Current
Puerto
Rico
Criteria
Dissolved
Oxygen
Not
less
than
4
mg/
L
(
except
when
natural
conditions
prohibit
attainment).

Coliforms
The
geometric
mean
of
a
series
of
representative
samples
(
at
least
5
samples)
taken
sequentially
shall
not
exceed
10,000
colonies/
100
mL
of
total
coliforms
or
2,000
colonies/
100mL
of
fecal
coliforms.
Not
more
than
20%
of
fecal
coliform
samples
shall
exceed
4,000
colonies/
100
mL.

pH
Between
7.3
and
8.5
(
except
when
caused
by
natural
phenomena).

Color
Shall
not
be
altered
by
other
than
natural
phenomena
except
when
it
can
be
proven
that
such
change
in
color
is
harmless
to
biota
and
aesthetically
acceptable.

Turbidity
Shall
not
exceed
10
NTU.

Taste
and
Odor
Shall
not
be
present
in
amounts
that
will
render
any
undesirable
taste
or
odor
to
edible
aquatic
life.

Sulfates
Shall
not
exceed
2,800
mg/
L
(
applies
to
estuarine
waters).

Surfactants
as
MBAS
Shall
not
exceed
500
µ
g/
L.

NTU
=
nephelometric
turbidity
units
MBAS
=
methylene
blue
active
substances
Under
current
WQS,
Class
SC
criteria
apply
to
segments
of
the
following
coastal
waters
in
the
zone
subject
to
the
ebb
and
flow
of
tides
(
mean
sea
level)
to
10.3
nautical
miles
seaward:

°
Mayaguez
Bay
from
Punta
Guanajibo
to
Punta
Algarrobo.
October
2003
2.0
Baseline
for
the
Analysis
2
 
2
°
Yabucoa
Port
°
Guayanilla
and
Tallaboa
Bays
from
Cayo
Parguera
to
Punta
Verraco
°
Ponce
Port
from
Punta
Carenero
to
Punta
Cuchara
°
San
Juan
Port
from
the
mouth
of
Río
Bayamón
to
Punta
El
Morro.

2.2
Point
Source
Dischargers
EPA's
Permit
Compliance
System
(
PCS)
database
indicates
that
there
are
593
facilities
permitted
to
discharge
to
Puerto
Rican
surface
waters.
EPA
classifies
86%
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
to
an
entire
category
of
dischargers).
Exhibit
2­
2
provides
a
summary
of
all
permits
by
industry
and
permit
type.

Exhibit
2­
2.
Summary
of
NPDES
Permitted
Direct
Dischargers
in
Puerto
Rico
Standard
Industrial
Classification
Number
of
Facilities1
Majors
Minors
Construction
15
General
Contractors
and
Operative
Builders
­
1
16
Heavy
Construction
­
1
Manufacturing
20
Food
and
Kindred
Products
5
6
21
Tobacco
Products
­
1
27
Printing
and
Publishing
­
1
28
Chemicals
and
Allied
Products
9
2
29
Petroleum
and
Coal
Products
6
1
32
Stone,
Clay,
and
Glass
Products
5
­
34
Fabricated
Metal
Products
­
2
36
Electronic
and
Other
Electronic
Equipment
1
­
Transportation
and
Public
Utilities
49
Electric,
Gas,
and
Sanitary
Services;
except
4952
12
106
4952
Sewerage
Services
(
POTWs)
38
33
Wholesale
Trade
50
Wholesale
Trade
 
Durable
Goods
1
­
51
Wholesale
Trade
 
Nondurable
Goods
3
2
Finance,
Insurance,
and
Real
Estate
65
Real
Estate
­
1
Services
70
Hotels
and
Other
Lodging
Places
­
3
79
Amusement
and
Recreational
Services
­
2
80
Health
Services
1
2
82
Educational
Services
­
21
84
Museums,
Botanical,
Zoological
Gardens
­
2
Exhibit
2­
2.
Summary
of
NPDES
Permitted
Direct
Dischargers
in
Puerto
Rico
Standard
Industrial
Classification
Number
of
Facilities1
Majors
Minors
October
2003
2.0
Baseline
for
the
Analysis
2
 
3
87
Engineering,
Accounting,
Research,
Management,
and
Related
Services
­
1
Public
Administration
91
Executive,
Legislative
and
General
Government,
except
Finance
1
1
92
Justice,
Public
Order,
and
Safety
1
2
97
National
Security
and
International
Affairs
1
3
No
SIC
Code
(
blank
in
PCS)
­
7
Total
84
201
Source:
U.
S.
EPA
(
2003a).
`­`
=
none.
1.
There
are
also
308
general
permit
dischargers
that
EPA
did
not
include
in
the
analysis.
Most
of
these
dischargers
are
construction
sites
and
storm
water
discharges.
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
PCS.
3Potentially
affected
facilities
may
include
facilities
that
do
not
discharge
directly
to
an
affected
waters.
EPA
assumed
that
facilities
discharging
two
miles
or
less
upstream
of
the
six
bay
and
the
coastal
ring
could
potentially
impact
the
downstream
water
body.

October
2003
3.0
Description
of
the
Proposed
Rule
3
 
1
3.0
Description
of
the
Proposed
Rule
This
section
describes
EPA's
proposed
rule
and
the
facilities
that
discharge
to
affected
waters
that,
depending
on
EPA
Region
2'
s
implementation
of
EPA's
proposed
rule,
may
be
affected
by
the
proposed
WQS.

3.1
Water
Quality
Criteria
and
Designated
Uses
EPA
is
proposing
to
establish
a
new
Federal
use
designation
for
primary
contact
recreation
use
and
applicable
water
quality
criteria
to
protect
primary
contact
recreation
for
selected
water
bodies
in
Puerto
Rico.
The
current
coliform
criteria
for
Class
SC
waters
are
intended
to
be
protective
of
secondary
contact
recreation.
The
remainder
of
the
criteria
applicable
to
Class
SC
designated
waters
are
intended
to
protect
other
uses,
such
as
aquatic
life
protection
through
the
maintenance
of
a
sufficient
level
of
dissolved
oxygen
in
the
water
column,
or
human
health
from
the
consumption
of
fish
based
on
the
level
of
toxic
pollutants
in
the
water
and
the
fish
tissue.
Therefore,
the
new
Federal
use
designation
does
not
affect
any
of
these
criteria,
except
for
the
bacteriological
criteria.
The
proposed
bacteriological
criteria
are
the
same
as
the
Commonwealth's
criteria
for
fecal
coliform
and
enterococci
associated
with
the
Class
SB
use
(
Section
3.2.2
of
the
PRWQSR).
Exhibit
3­
1
shows
EPA's
proposed
criteria
and
provides
the
Commonwealth's
current
criteria
for
comparison.

Exhibit
3­
1.
Comparison
of
Current
Puerto
Rico
and
Proposed
EPA
Criteria
for
Six
Bays
and
Estuaries
and
the
Coastal
Ring1
Designated
Use
Puerto
Rico
Criteria
Proposed
EPA
Criteria
Coliforms
10,000
colonies/
100
mL
of
total
coliform.
2,000
colonies/
100mL
of
fecal
coliforms.
Not
more
than
20%
of
fecal
coliform
samples
shall
exceed
4,000
colonies/
100
mL.
35
colonies
/
100
mL
enterococci
density.
200
colonies/
100mL
of
fecal
coliforms
Not
more
than
20%
of
fecal
coliform
samples
shall
exceed
400
colonies/
100
mL.

1.
Includes
Mayaguez
Bay
from
Punta
Guanajibo
to
Punta
Algarrobo,
Yabucoa
Port,
Guayanilla
and
Tallaboa
Bays
from
Cayo
Parguera
to
Punta
Verraco,
Ponce
Port
from
Punta
Carenero
to
Punta
Cuchara,
San
Juan
Port
from
the
mouth
of
Río
Bayamón
to
Punta
El
Morro,
and
the
coastal
ring
(
i.
e.,
coastal
waters
500
meters
to
3
miles).

3.2
Potentially
Impacted
Facilities
The
water
quality
criteria
and
uses
in
EPA's
proposed
rule
may
impact
facilities
discharging
to
affected
waters.
EPA
identified
these
facilities
using
its
PCS
database.
In
doing
so,
EPA
assumed
that
only
facilities
that
have
the
potential
to
affect
(
i.
e.,
cause
an
increase
in
fecal
coliform
levels)
the
6
bays
for
which
EPA
is
designating
a
new
primary
contact
recreation
use
or
the
coastal
ring
(
i.
e.,
coastal
waters
from
500
meters
to
3
miles)
may
be
impacted.
3
EPA
identified
these
facilities
by
overlaying
PCS
facilities
with
the
potentially
affected
waters
and
their
tributaries
currently
designated
for
a
Class
SC
use
using
geographic
information
system
software.
October
2003
3.0
Description
of
the
Proposed
Rule
3
 
2
EPA
assumed
that
only
wastewater
treatment
plants
or
military
facilities
with
similar
effluent
characteristics
(
i.
e.,
facilities
having
the
potential
to
discharge
fecal
coliforms)
could
potentially
be
impacted
by
the
proposed
rule.
Exhibit
3­
2
summarizes
the
universe
of
potentially
affected
facilities
by
type
and
category.

Exhibit
3­
2.
Estimated
Number
of
Facilities
Potentially
Affected
by
the
Proposed
Rule
Category
Number
of
Facilities
Major
Minor
Total
Military
1
2
3
Municipal
19
10
29
Total
20
12
32
October
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
Sample
Facilities
EPA
identified
a
total
of
32
facilities
(
20
majors
and
12
minors)
that
may
be
affected
by
the
proposed
primary
contact
designated
use.
EPA
evaluated
a
sample
from
this
group
for
potential
cost
impacts
associated
with
the
proposed
rule.
To
select
a
sample,
EPA
stratified
the
universe
by
discharge
type
(
major,
minor)
and
category
(
POTW,
military).
EPA
evaluated
the
two
major
municipal
facilities
with
the
greatest
flow,
thus
ensuring
that
the
facilities
with
potential
for
the
largest
costs
would
be
evaluated.
EPA
also
evaluated
the
only
major
facility
in
the
military
category.
For
the
remaining
facilities,
EPA
chose
a
random
sample
to
represent
discharger
type
and
category.
Exhibit
4­
1
summarizes
the
sample
facilities
selected
by
type
and
category.

Exhibit
4­
1.
Sample
Facilities
Evaluated
NPDES
No.
Name
Flow
(
mgd)
Type
Category
PR0021555
Puerto
Nuevo
Regional
Wastewater
Treatment
Plant
72
Major
Municipal
PR0023752
Carolina
Wastewater
Treatment
Plant
45
Major
Municipal
PR0023728
Bayamon
Regional
Wastewater
Treatment
Plant
30
Major
Municipal
PR0025445
Guayama
Regional
Wastewater
Treatment
Plant
10
Major
Municipal
PR0025399
Humacao
Regional
Sewage
Treatment
Plant
8
Major
Municipal
PR0021679
Vega
Baja
Wastewater
Treatment
Plant
2.2
Major
Municipal
PR0020486
Guanica
Wastewater
Treatment
Plant
0.8
Minor
Municipal
PR0023442
Boquerón
Wastewater
Treatment
Plant
0.3
Minor
Municipal
PR0020010
U.
S.
Naval
Station
­
Roosevelt
Roads
2
Major
Military
PR0020044
Fort
Allen
Training
Annex
(
Puerto
Rico
National
Guard)
0.2
Minor
Military
4.2
Identifying
Potential
Controls
EPA
estimated
the
most
cost­
effective
control
strategy
for
each
sample
facility
to
achieve
compliance
with
the
proposed
criteria
on
a
case­
by­
case
basis.
EPA
assumed
that
projected
effluent
limits
for
fecal
coliform
would
be
applied
as
criteria
end­
of­
pipe
(
a
monthly
geometric
mean
of
200
colonies/
100
mL
and
not
more
than
20%
of
samples
exceeding
400
colonies/
100
mL)
because
the
facilities'
current
permits
apply
the
existing
criteria
in
the
same
manner.
EPA
assumed
that
a
sample
facility
would
incur
costs
if
average
monthly
effluent
concentrations
(
or
existing
permit
limit,
whichever
is
smaller)
indicate
that
the
facility
would
not
be
in
compliance
with
the
most
stringent
criterion.

EPA
evaluated
each
facility's
potential
compliance
with
projected
permit
limits
based
on
available
monthly
average
fecal
coliform
values
from
its
PCS
database.
If
monthly
average
values
are
not
October
2003
4.0
Method
for
Estimating
Costs
4
 
2
available,
EPA
evaluated
potential
compliance
based
on
maximum
monthly
values.
Note
that
the
existing
and
proposed
fecal
coliform
criteria
should
be
measured
as
a
geometric
mean
of
five
consecutive,
representative
samples.
However,
EPA
did
not
have
the
actual
data
that
the
average
monthly
values
in
PCS
are
calculated
from
so
that
a
geometric
mean
could
be
used.
Instead,
EPA
used
the
average
value,
which
results
in
a
conservative
estimate
of
compliance
(
i.
e..,
tending
to
overstate
the
potential
magnitude
of
reductions
needed
for
compliance).

EPA
determined
potential
compliance
with
the
projected
limit
for
each
sample
facility
based
on
the
relative
magnitude
of
the
maximum
average
monthly
values,
the
pattern
of
occurrence
of
such
values
(
e.
g.,
when
maximum
values
occurred),
and
current
treatment
performance
characteristics
[
e.
g.,
biochemical
oxygen
demand
(
BOD)
and
total
suspended
solids
(
TSS)
concentrations,
compliance
with
current
permit].
EPA
assumed
that
facilities
exceeding
their
current
limits
would
install
the
necessary
controls
for
compliance
with
current
standards,
and
would
incur
costs
for
additional
treatment
process
optimization
to
comply
with
the
projected
limit.
For
facilities
that
comply
with
their
current
permit
limits
but
would
not
comply
with
the
projected
limit,
EPA
also
assumed
that
process
optimization
of
their
chlorination
process
would
be
necessary
for
compliance
with
the
projected
limit.

Treatment
process
optimization
refers
to
measures
that
facilities
can
implement
to
enhance
the
operating
efficiency
of
their
wastewater
treatment
process.
Process
optimization
usually
involves
process
analysis
and
process
modifications.
Process
analysis
is
an
investigation
of
the
performance­
limiting
factors
of
the
treatment
process,
and
is
a
key
factor
in
achieving
optimum
treatment
efficiency.
Performance­
limiting
factors
for
chlorination
may
include
operator
training,
response
to
changes
in
wastewater
quality,
treatment
efficiency
of
other
individual
treatment
units,
maintenance
activities,
automation,
and
process
control
testing.
The
cost
of
process
analysis
includes
the
cost
of
additional
monitoring
throughout
the
treatment
process,
and
a
treatment
performance
evaluation.

Process
modifications
include
activities
short
of
adding
new
treatment
technology
units
(
conventional
or
unconventional)
to
the
treatment
train.
For
chlorination,
process
modifications
might
include
adjusting
the
chlorine
dose,
improving
mixing
conditions
(
e.
g.,
addition
of
baffles
to
chlorine
contract
chamber),
improving
BOD
and
TSS
removal
efficiencies,
increasing
contact
time,
equalizing
flow,
training
operators,
and
installing
automation
equipment
including
necessary
hardware
and
software.
Several
months
of
adjustments
may
be
needed
to
achieve
a
desired
level
of
process
optimization
due
to
potential
difficulties
(
e.
g.,
synchronizing
chlorine
dose
with
varied
levels
of
pollutant
concentrations
such
as
BOD,
TSS,
and
flow).

4.3
Estimating
Costs
of
Controls
EPA
determined
the
necessary
controls
on
point
sources
to
reduce
fecal
coliform
concentrations
to
the
required
level
by
first
evaluating
whether
low
cost
control
options
would
be
feasible,
and
then
considering
more
costly
controls,
if
necessary.
EPA
considered
the
lowest
cost
option,
adjustment
of
existing
treatment
(
process
optimization),
to
be
feasible
if
literature
indicates
that
the
existing
treatment
process
can
achieve
the
revised
effluent
limit.
October
2003
4.0
Method
for
Estimating
Costs
4
 
3
EPA
assumed
that
all
the
sample
facilities
would
pursue
process
optimization
to
reduce
fecal
coliform
levels
because
they
all
currently
chlorinate
their
effluents
prior
to
discharge,
and
literature
indicates
that
chlorination,
when
operated
properly,
should
produce
effluent
fecal
coliform
concentrations
below
200
colonies/
100
mL
(
WERF,
1995).

For
facilities
exceeding
their
current
permit
limits,
EPA
first
estimated
the
controls
necessary
for
compliance
with
the
current
permit
limit.
EPA
then
determined
if
those
controls
would
also
enable
the
facility
to
meet
the
projected
effluent
limit.
If
those
controls
enable
compliance
with
the
projected
limit,
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
reducing
fecal
coliform
levels
to
the
projected
limit,
that
is,
the
additional
costs
required
(
after
compliance
with
the
State's
current
standards)
to
achieve
a
new
limit
based
on
EPA's
proposed
standards.

EPA
estimated
the
cost
of
process
optimization
for
point
sources
using
available
estimates
from
the
literature,
and
developed
estimates
for
each
facility
based
on
the
reductions
needed
and
current
treatment
processes.
For
most
of
the
facilities,
EPA
does
not
have
specific
information
regarding
the
chlorination
process,
such
as
chlorine
dose
used,
volume
of
contact
chamber,
contact
time,
mixing
conditions,
type
of
chlorine
used,
or
maintenance
procedures.
Therefore,
EPA
assumed
that
facilities
are
operating
at
a
minimal
treatment
level
(
e.
g.,
using
the
lowest
recommended
chlorine
dose
or
contact
time
for
type
of
treatment
processes,
poor
mixing,
cleaning
once
every
two
years).

EPA
estimated
process
analysis
costs
assuming
a
two­
month
analysis
of
the
facility's
treatment
processes.
EPA
assumed
that
a
wastewater
treatment
plant
operator
would
work
full
time
for
three
months
monitoring
the
wastewater
at
different
stages
throughout
the
treatment
plant
and
determining
the
process
modifications
necessary.
EPA
used
a
labor
rate
of
$
15.79
for
a
water
and
liquid
waste
treatment
plant
and
system
operator
in
Puerto
Rico,
which
includes
employer
benefits
(
BLS,
2002).
Thus,
EPA
assumed
that
process
analysis
costs
of
$
7,579
would
be
incurred
(
480
hours
x
$
15.79/
hour),
and
annualized
these
capital
costs
at
7%
over
20
years.

EPA
estimated
costs
for
process
modification
costs
for
each
facility
based
on
current
treatment
performance.
Modification
costs
may
include
additional
chlorine
and
chlorine
storage
facilities,
cleaning
contact
basins,
installing
of
baffles
to
assist
mixing
in
the
contact
basin,
and
increasing
contact
basin
volume
(
i.
e.,
increasing
contact
time).
Each
component
may
have
capital
or
operation
and
maintenance
(
O&
M)
costs.
Exhibit
4­
2
summarizes
the
type
of
costs
associated
with
each
component
and
the
source
of
the
cost
estimates.

Exhibit
4­
2.
Process
Modification
Cost
Components
Modification
Costs
Incurred
Unit
Costs
Source
Increase
chlorine
dose
Additional
chlorine
Additional
chlorine
storage
space
$
1,280/
cylinder
of
chlorine
$
51.47/
sq.
ft.
storage
U.
S.
EPA
(
2003b)

Increase
maintenance
Additional
6­
15
labor
hrs/
mgd
for
cleaning
basins
$
15.79/
hour
WERF
(
1995);
BLS
(
2002)
Exhibit
4­
2.
Process
Modification
Cost
Components
Modification
Costs
Incurred
Unit
Costs
Source
October
2003
4.0
Method
for
Estimating
Costs
4
 
4
Improve
mixing
Installation
of
baffles
in
chlorination
contact
basin
$
36.49/
sq.
ft.
of
baffle
U.
S.
EPA
(
2003b)

Increase
contact
time
Additional
contact
basins
$
339/
cu.
yd.
U.
S.
EPA
(
2003b)

sq.
ft.
=
square
foot
cu.
yd.
=
cubic
yard
4.4
Total
Annual
Costs
To
estimate
total
annual
costs,
EPA
extrapolated
the
results
for
each
type
and
category
of
sample
facility
to
all
facilities
in
the
universe.
To
do
this,
EPA
calculated
a
per­
facility
cost
by
dividing
the
total
costs
for
each
type
and
category
by
the
number
of
sample
facilities
in
that
group.
EPA
then
multiplied
the
per­
facility
cost
by
the
total
number
of
facilities.

4.5
Potential
Loading
Reductions
EPA
estimated
fecal
coliform
loading
reductions
as
the
difference
between
the
estimated
baseline
concentration
and
the
projected
limit.
EPA
estimated
loadings
in
number
of
colonies
per
year
by
multiplying
the
pollutant
concentration
(
in
colonies/
100
mL)
by
the
facility
effluent
flow
(
in
mgd),
a
conversion
factor
(
3.79
x
107),
and
365
days
per
year.
The
estimated
loading
reduction
is
based
on
the
difference
between
the
average
of
the
monthly
effluent
values
that
exceed
the
projected
limit
(
or
the
current
effluent
limit
if
the
facility
is
not
currently
in
compliance
with
their
current
limit)
and
the
projected
effluent
limit.
October
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
Total
Costs
EPA
estimated
that
the
total
annual
potential
cost
of
the
proposed
rule
is
approximately
$
2.7
million.
Exhibit
5­
1
provides
a
summary
of
the
number
of
potentially
affected
facilities,
and
the
estimated
costs
associated
with
the
proposed
rule.
Appendix
A
provides
detailed
analyses
for
each
of
the
sample
facilities.
Appendix
B
shows
the
extrapolation
of
costs
for
all
potentially
affected
dischargers.

Exhibit
5­
1.
Potential
Costs
Attributable
to
the
Proposed
Rule
(
millions
of
$
2003)
1
Category
Facilities
Evaluated
(
Total
Affected)
Total
Capital
Annual
O&
M
Total
Annual
Costs2
Major
Municipal
6
(
19)
$
2.5
$
2.4
$
2.6
Minor
Municipal
2
(
10)
$
0.5
$
0.1
$
0.1
Major
Military
1
(
1)
$
0.0
$
0.0
$
0.0
Minor
Military
1
(
2)
$
0.1
$
0.0
$
0.0
Total
10
(
32)
$
3.2
$
2.4
$
2.7
Note:
Detail
may
not
add
to
total
due
to
rounding.
1.
Costs
for
evaluated
facilities
extrapolated
to
all
potentially
affected
facilities.
2.
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.

EPA
estimated
that
the
total
annual
costs
would
result
in
pollutant
loading
reductions
of
1.86
x
1015
fecal
coliform
colonies.
Fecal
coliforms
are
bacteria
that,
when
present,
indicate
contamination
of
receiving
waters
by
mammalian
feces,
including
human
feces.
At
high
numbers
of
fecal
coliform
bacteria
per
volume
of
water,
there
is
a
high
probability
that
human
pathogens
(
disease­
causing
organisms)
are
also
present,
resulting
in
an
increased
risk
of
disease
following
contact.
Ingestion
of
high
concentrations
of
fecal
coliform
bacteria
can
also
lead
directly
to
human
illness.
The
reductions
in
the
number
of
fecal
coliform
bacteria
as
a
result
of
the
proposed
rule
will
therefore
reduce
the
risk
of
human
disease
from
discharge
of
waste
from
wastewater
treatment
facilities.

5.2
Limitations
of
the
Analysis
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
2.
October
2003
5.0
Results
5
 
2
Exhibit
5­
2.
Limitations
of
the
Analysis
Limitation/
Assumption
Potential
Impact
on
Costs
Comment
EPA
did
not
have
specific
information
on
the
chlorination
process
(
e.
g.,
chlorine
dose,
volume
of
contact
basin,
frequency
of
maintenance)
at
the
sample
facilities.

EPA
assumed
that
facilities
are
currently
operating
at
minimum
treatment
levels
(
e.
g.,
5
mg/
L
for
secondary
treatment
plants,
60
minute
contact
time).

EPA
used
average
monthly
fecal
coliform
data
from
its
PCS
database
to
determine
compliance
with
current
and
projected
effluent
limits.

EPA
PCS
data
are
summarized.
EPA
would
have
preferred
to
use
the
actual
data
that
the
average
monthly
data
are
calculated
from
so
that
a
geometric
mean
instead
of
an
average
value
could
be
used
(
since
the
fecal
coliform
limit
is
specified
as
a
geometric
mean).

The
universe
of
potentially
affected
facilities
includes
facilities
that
discharge
two
miles
or
less
upstream
of
the
affected
waters.

Some
facilities
that
discharge
upstream
of
the
affected
water
bodies
may
not
contribute
to
an
instream
exceedance
of
fecal
coliform.

EPA
applied
the
proposed
fecal
coliform
criteria
end­
of­
pipe
(
i.
e.,
did
not
allow
dilution).

The
Commonwealth
may
have
information
that
shows
that
applying
the
criteria
end­
of­
pipe
would
not
be
necessary.

Key:
+
=
Costs
are
potentially
overstated
October
2003
6.0
References
6
 
1
6.0
References
Bureau
of
Labor
Statistics
(
BLS).
2002.
2001
Occupational
Employment
Survey
(
OES)
State
Occupational
Employment
and
Wage
Estimates,
Puerto
Rico.
Online
at
http://
www.
bls.
gov/
oes/
2001/
oes_
pr.
htm.

U.
S.
EPA.
2003a.
Permit
Compliance
System
(
PCS)
Database.
Accessed
August
22,
2003.
Online
at
http://
www.
epa.
gov/
enviro/
html/
pcs/
adhoc.
html.

U.
S.
EPA.
2003b.
Chlorine
Disinfection
Model
of
the
WBS­
Based
Cost
Models
for
Drinking
Water
Treatment
Technologies.
Final
Draft.

Water
Environment
Research
Foundation
(
WERF).
1995.
Comparison
of
UV
Irradiation
to
Chlorination:
Guidance
for
Achieving
Optimal
UV
Performance.
Project
91­
WWD­
1.
Appendix
A:
Facility
Analyses
Bayamon
Regional
Wastewater
Treatment
Plant
Boquerón
Wastewater
Treatment
Plant
Carolina
Regional
Wastewater
Treatment
Plant
Fort
Allen
Training
Annex
Guanica
Wastewater
Treatment
Plant
Guayama
Regional
Wastewater
Treatment
Plant
Humacao
Regional
Sewage
Treatment
Plant
Puerto
Nuevo
Regional
Wastewater
Treatment
Plant
U.
S.
Naval
Station
­
Roosevelt
Roads
Vega
Baja
Wastewater
Treatment
Plant
October
2003
Appendix
A.
Facility
Analyses
A
 
1
Bayamon
Regional
Wastewater
Treatment
Plant
Facility
Description
The
Bayamon
Regional
Wastewater
Treatment
Plant
(
NPDES
No.
PR0023728)
is
located
in
Cataño,
Puerto
Rico.
The
facility,
which
began
operation
in
1983,
is
owned
by
the
Puerto
Rico
Aqueduct
and
Sewer
Authority
and
operated
by
the
Compañía
de
Aguas
de
Puerto
Rico.
The
facility
treats
wastewater
from
Bayamon
Cataño
and
parts
of
Guaynabo,
Rio
Piedras,
Toa
Alta,
and
Toa
Baja.
EPA
classifies
the
discharge
as
a
major
discharge.
The
facility
has
a
design
flow
of
30
mgd
and
discharges
about
7,364
feet
from
the
shore
into
the
Atlantic
Ocean.

Treatment
Processes
Information
provided
by
EPA
Region
2
indicates
that
current
treatment
processes
consist
of
mechanical
bar
screening
and
grit
removal,
primary
clarification
with
chemical
addition,
and
chlorination.
Sludge
is
removed
from
sedimentation
tanks
and
macerated
by
grinders
before
being
sent
to
sludge
thickeners.
Thickened
sludge
is
pumped
to
a
tanker
truck
for
offsite
disposal.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
1
summarizes
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
January
2000
through
June
2003.
Exhibit
A­
2
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliforms
does
not
allow
for
dilution.

Exhibit
A­
1.
Effluent
Data
Summary,
Bayamon
RWWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
38
27
5
695
42
2
2,0002
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
January
2000
to
June
2003.
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
2.
Compliance
Summary,
Bayamon
RWWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
42
2,000
None
200
2
out
of
38
Exhibit
A­
2.
Compliance
Summary,
Bayamon
RWWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
October
2003
Appendix
A.
Facility
Analyses
A
 
2
1.
Represents
the
average
of
the
average
monthly
values
from
January
2000
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
Less
than
20%
of
values
exceed
400
colonies/
100
mL.

Controls
Needed
The
facility
is
in
compliance
with
the
current
effluent
limit
for
fecal
coliform.
Only
two
observation
are
greater
than
the
projected
effluent
limit
(
values
of
285
and
695
colonies/
100
mL
in
June
2000
and
June
2003,
respectively),
and
the
average
of
the
average
monthly
values
is
well
below
the
projected
limit.
Therefore,
EPA
assumed
that
the
facility
would
most
likely
be
in
compliance
with
the
proposed
rule
because
of
the
infrequency
of
small
exceedances
of
the
projected
limit.
October
2003
Appendix
A.
Facility
Analyses
A
 
3
Boquerón
Wastewater
Treatment
Plant
Facility
Description
The
Boquerón
Wastewater
Treatment
Plant
(
NPDES
No.
PR0023442)
is
located
in
San
Juan,
Puerto
Rico.
The
facility
treats
sanitary
wastewater
and
serves
the
communities
of
Boquerón
and
Villa
Taína.
EPA
classifies
the
discharge
as
a
minor
discharge.
The
facility
discharges
an
average
of
0.25
mgd
to
Boqueròn
Bay.

Treatment
Processes
The
facility's
2000
permit
renewal
application
indicates
that
current
treatment
processes
consist
of
aeration,
sedimentation,
clarification,
and
chlorination.
Sludge
is
aerobically
digested
and
stabilized
in
drying
beds.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
3
summarizes
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
January
2000
through
June
2003.
Exhibit
A­
4
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliforms
does
not
allow
for
dilution.

Exhibit
A­
3.
Effluent
Data
Summary,
Boquerón
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
41
39
2
24,895
2,056
2
2002
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
January
2000
to
June
2003
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.

Exhibit
A­
4.
Compliance
Summary,
Boquerón
WWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Fecal
Coliform
(
colonies/
100
mL)
2,056
200
27
out
of
41
200
1.
Represents
the
average
of
the
average
monthly
values
from
January
2000
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.

Controls
Needed
October
2003
Appendix
A.
Facility
Analyses
A
 
4
The
facility
is
not
in
compliance
with
its
current
permit
limit
for
fecal
coliforms,
which
is
identical
to
the
projected
effluent
limit
under
the
proposed
rule.
Therefore,
once
in
compliance
with
the
current
permit
limit,
the
facility
would
also
be
in
compliance
with
the
projected
effluent
limit
and,
would
not
incur
costs
associated
with
EPA's
proposed
rule.
October
2003
Appendix
A.
Facility
Analyses
A
 
5
Carolina
Regional
Wastewater
Treatment
Plant
Facility
Description
The
Carolina
Regional
Wastewater
Treatment
Plant
(
NPDES
No.
PR0023752)
is
located
in
Barrio
Torrecilla
Baja
at
Loíza,
Puerto
Rico.
The
facility
is
owned
by
the
Puerto
Rico
Aqueduct
and
Sewer
Authority
and
operated
by
the
Compañía
de
Aguas
de
Puerto
Rico.
The
facility
treats
wastewater
from
the
municipalities
of
Carolina,
Loíza,
Canóvanas,
Trujillo
Alto,
and
Río
Grande.
EPA
classifies
the
discharge
as
a
major
discharge.
The
facility
discharges
an
average
of
45
mgd
about
6,200
feet
from
shore
into
the
Atlantic
Ocean.

Treatment
Processes
Information
provided
by
EPA
Region
2
indicates
that
current
treatment
processes
consist
of
mechanical
bar
screening,
grit
removal,
primary
clarification
with
chemical
addition,
and
chlorination.
Sludge
is
removed
from
the
clarifiers
by
telescopic
valves
and
macerated
and
pumped
to
holding
tanks.
The
sludge
is
then
dewatered
by
a
belt
filter
press.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
5
summarizes
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
January
2000
through
June
2003.
Exhibit
A­
6
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliform
does
not
allow
for
dilution.

Exhibit
A­
5.
Effluent
Data
Summary,
Carolina
RWWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
37
35
2
245
20
2
2,0002
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
January
2000
to
June
2003.
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
6.
Compliance
Summary,
Carolina
RWWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
20
2,000
None
200
1
out
of
37
Exhibit
A­
6.
Compliance
Summary,
Carolina
RWWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
October
2003
Appendix
A.
Facility
Analyses
A
 
6
1.
Represents
the
average
of
the
average
monthly
values
from
January
2000
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
Less
than
20%
of
the
values
exceed
400
colonies/
100
mL.

Controls
Needed
Exhibit
A­
6
indicates
that
the
facility
is
in
compliance
with
the
current
fecal
coliform
limit.
Only
one
observation
(
value
of
245
colonies/
100
mL)
is
greater
than
the
projected
effluent
limit.
Therefore,
the
facility
most
likely
would
not
incur
costs
associated
with
the
proposed
rule.
October
2003
Appendix
A.
Facility
Analyses
A
 
7
Fort
Allen
Training
Annex
Facility
Description
The
Fort
Allen
Training
Annex
(
NPDES
No.
PR0020044)
is
located
in
Juana
Diaz,
Puerto
Rico.
The
facility
is
an
army
training
facility
operated
by
the
Puerto
Rico
National
Guard
for
training
reserve
soldiers.
The
facility
provides
treatment
of
domestic
sanitary
wastewater
and
discharges
a
maximum
of
0.17
mgd
to
the
La
Colectora
Channel,
a
tributary
to
the
Caribbean
Sea.
EPA
classifies
the
discharger
as
a
minor
discharge.

Treatment
Processes
A
facility's
2000
permit
renewal
application
indicates
that
current
treatment
processes
consist
of
mechanical
bar
screens,
sedimentation,
clarification,
aeration,
and
chlorination.
Sludge
is
digested
and
dried
on
drying
beds.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
7
summarizes
the
maximum
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
March
2000
through
June
2003.
Exhibit
A­
8
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliform
does
not
allow
for
dilution.

Exhibit
A­
7.
Effluent
Data
Summary,
Fort
Allen
Training
Annex1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)
Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
22
20
2
6,683
577
2
2,0002
Source:
U.
S.
EPA
(
2003a).
1.
Maximum
monthly
values
from
March
2000
to
June
2003.
2.
Represents
an
average
monthly
limit.
The
facility's
current
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
8.
Compliance
Summary,
Fort
Allen
Training
Annex
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
765
2,000
2
out
of
22
200
5
out
of
22
1.
Represents
the
average
of
the
maximum
monthly
values
from
March
2000
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
maximum
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies.
100
mL)
based
on
maximum
monthly
values.
Less
than
20%
of
the
values
exceed
400
colonies/
100
mL.

Controls
Needed
October
2003
Appendix
A.
Facility
Analyses
A
 
8
Exhibit
A­
8
indicates
that
the
facility
may
not
be
in
compliance
with
the
current
effluent
limit
for
fecal
coliform.
However,
EPA
assumed
that
the
facility
would
not
need
to
install
treatment
controls
for
compliance
with
the
current
limit
because
the
facility's
discharge
monitoring
reports
(
DMRs)
indicate
that
one
of
the
exceedances
is
due
to
a
mechanical
malfunction
in
the
chlorination
system
and
low
pressure
at
the
potable
water
system,
and
the
other
exceedance
is
most
likely
the
result
of
poor
TSS
removal
due
to
scheduled
maintenance
and
clean
up.

The
facility
is
not
currently
in
compliance
with
the
projected
effluent
limit.
Based
on
maximum
monthly
values,
the
facility
would
exceed
the
projected
limit
about
23%
of
the
time.
Specific
information
on
the
chlorination
system
at
the
facility
such
as
chlorine
dose,
mixing
conditions,
and
contact
tank
volume
is
not
available,
however,
effluent
data
(
e.
g.,
TSS,
BOD,
and
flow
data)
do
not
indicate
that
other
treatment
processes
other
than
the
chlorination
system
are
contributing
to
the
increased
fecal
coliform
levels.
Therefore,
EPA
assumed
that
process
optimization
of
the
chlorination
system
would
enable
the
facility
to
comply
with
the
projected
effluent
limit.

Exhibit
A­
9
summarizes
the
estimated
control
costs
associated
with
reducing
fecal
coliform
to
the
required
levels.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances
(
through
monitoring
and
evaluation),
and
process
modifications
including
increasing
the
chlorine
dose
from
10
mg/
L
to
20
mg/
L,
improving
mixing
conditions
through
the
addition
of
baffles,
increasing
contact
time
from
60
minutes
to
90
minutes
(
additional
contact
basin
volume),
and
increasing
the
frequency
of
maintenance
and
cleaning
of
the
contact
basins
to
prevent
bacteria
build
up
from
once
every
2
years
to
twice
a
year.

Exhibit
A­
9.
Summary
of
Compliance
Costs,
Fort
Allen
Training
Annex
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
7,579
­
$
715
Process
Modifications:
Increase
Chlorine
Dose
Improve
Mixing
Increase
Contact
Time
Increase
Maintenance
$
45,873
$
2,020
$
4,7460
­
$
3,840
­
­
$
121
$
8,170
$
191
$
448
$
121
Total
$
60,218
$
3,961
$
9,645
Sources:
U.
S.
EPA
(
2003b);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs
October
2003
Appendix
A.
Facility
Analyses
A
 
9
Guanica
Wastewater
Treatment
Plant
Facility
Description
The
Guanica
Wastewater
Treatment
Plant
(
NPDES
No.
PR0020486)
is
located
in
Guanica,
Puerto
Rico.
The
facility
is
owned
by
the
Puerto
Rico
Aqueduct
and
Sewer
Authority
and
operated
and
maintained
under
contract
by
Ondeo
de
Puerto
Rico.
The
facility
treats
domestic
wastewater
from
the
town
of
Guanica.
EPA
classifies
the
discharge
as
a
minor
discharge.
The
facility
has
a
design
flow
of
0.8
mgd
and
discharges
to
Guanica
Bay.

Treatment
Processes
Information
provided
by
EPA
Region
2
indicates
that
current
treatment
processes
consist
of
preliminary
screening
and
grit
removal,
aeration,
aerobic
digestion,
clarification,
and
chlorination.
Sludge
is
discharged
to
sludge
drying
beds
or
a
mobile
belt
filter
press
for
dewatering.
Dried
sludge
is
disposed
of
in
a
landfill.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
10
summarizes
the
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
July
2000
through
June
2003.
Exhibit
A­
11
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliforms
does
not
allow
for
dilution.

Exhibit
A­
10.
Effluent
Data
Summary,
Guanica
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
36
34
2
2,382
120
2
2,0002
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
July
2000
to
June
2003.
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
11.
Compliance
Summary,
Guanica
WWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
120
2,000
1
out
of
36
200
4
out
of
36
Exhibit
A­
11.
Compliance
Summary,
Guanica
WWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
October
2003
Appendix
A.
Facility
Analyses
A
 
10
1.
Represents
the
average
of
the
average
monthly
values
from
July
200
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
the
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
Less
than
20%
of
values
exceed
400
colonies/
100
mL.

Controls
Needed
Exhibit
A­
11
indicates
that
the
facility
is
most
likely
in
compliance
with
its
current
effluent
limit
(
the
only
exceedance
occurred
in
July
2001).
However,
the
facility
would
not
be
in
compliance
with
its
projected
fecal
coliform
limit.
The
facility's
current
chlorination
process
is
operated
by
an
automatic
flow
controller
that
adjusts
the
amount
of
chlorine
input
into
the
contact
chambers
according
to
changes
in
effluent
flow.
The
effluent
flow
is
measured
at
the
chlorine
contact
chamber
outlet.
The
facility
would
most
likely
need
to
increase
the
dose
of
chlorine
associated
with
varying
effluent
flow
for
compliance
with
the
projected
effluent
limit.
Exhibit
A­
12
summarizes
the
control
costs
necessary
to
reduce
fecal
coliform
to
the
required
levels.
Costs
include
process
analysis
to
determine
the
necessary
dose
and
increasing
the
chlorine
dose
from
5
mg/
L
to
15
mg/
L
(
plus
the
additional
storage
space).

Exhibit
A­
12.
Summary
of
Compliance
Costs,
Guanica
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
7,579
­
$
715
Process
Modifications:
Increase
Chlorine
Dose
$
91,747
$
15,360
$
24,021
Total
$
99,326
$
15,360
$
24,736
Sources:
U.
S.
EPA
(
2003b);
BLS
(
2002).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
October
2003
Appendix
A.
Facility
Analyses
A
 
11
Guayama
Regional
Wastewater
Treatment
Plant
Facility
Description
The
Guayama
Regional
Wastewater
Treatment
Plant
(
NPDES
No.
PR0025445)
is
located
in
Guayama,
Puerto
Rico.
The
facility
discharges
an
average
of
10
mgd
to
the
Caribbean
Sea.

Treatment
Processes
Information
provided
by
EPA
Region
2
indicates
that
current
treatment
processes
consist
of
screening
and
grit
removal,
primary
sedimentation,
biofiltration,
clarification,
and
chlorination.
Sludge
is
digested
and
sent
to
stabilization
ponds.
It
is
then
dried
in
drying
beds
and
hauled
to
a
sanitary
landfill.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
13
summarizes
the
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
April
2001
through
June
2003.
Exhibit
A­
14
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliforms
does
not
allow
for
dilution.

Exhibit
A­
13.
Effluent
Data
Summary,
Guayama
RWWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
26
23
3
24,739
2,001
2
2,0002
Source:
U.
S.
EPA
(
2003a)
1.
Average
monthly
values
from
April
2001
to
June
2003
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
14.
Compliance
Summary,
Guayama
RWWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
2,001
2,000
4
out
of
26
200
6
out
of
27
1.
Represents
the
average
of
the
average
monthly
values
from
April
2001
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
Less
than
20%
of
values
exceed
400
colonies/
100
mL.

Controls
Needed
October
2003
Appendix
A.
Facility
Analyses
A
 
12
Exhibit
A­
14
indicates
that
the
facility
is
not
in
compliance
with
its
current
permit
limit.
However,
all
of
the
exceedances
of
the
current
limit
occurred
in
2001,
and
the
facility
has
not
had
an
exceedance
of
its
current
limit
in
the
last
2
years.
Therefore,
is
likely
now
meeting
its
current
effluent
limit
for
fecal
coliform.

Since
December
2001
the
facility
has
exceeded
the
projected
limit
on
2
occasions
(
values
of
221
and
228
colonies/
100
mL
in
consecutive
months).
Therefore,
EPA
assumed
that
only
minor
process
optimization
(
e.
g.,
improvements
in
maintenance,
monitoring
of
chlorine
dose)
would
be
necessary
for
compliance
with
projected
limit.
EPA
assumed
that
such
measures
would
not
measurably
increase
operating
costs,
and
the
facility
would
not
incur
costs
associated
with
the
proposed
rule.
October
2003
Appendix
A.
Facility
Analyses
A
 
13
Humacao
Regional
Sewage
Treatment
Plant
Facility
Description
The
Humacao
Regional
Sewage
Treatment
Plant
(
NPDES
No.
PR0025399)
is
located
in
Rio
Abajo,
Puerto
Rico.
The
facility
is
owned
by
the
Puerto
Rico
Aqueduct
and
Sewer
Authority
and
is
operated
and
maintained
by
the
Professional
Services
Group.
The
facility
has
a
design
capacity
of
8.24
mgd
and
treats
sanitary
and
industrial
wastewater
from
Humacao,
Naguabo,
and
Las
Piedras.
EPA
classifies
the
discharge
as
a
major
discharge.
The
facility
discharges
to
the
Caribbean
Sea.

Treatment
Processes
Information
provided
by
EPA
Region
2
indicates
that
current
treatment
processes
consist
of
bar
screening,
grit
removal,
primary
sedimentation,
biofiltration,
final
clarification,
and
chlorination.
Sludge
is
gravity
thickened
or
anaerobically
digested,
dewatered
in
drying
beds
and
sent
to
an
onsite
landfill.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
15
summarizes
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
January
2000
through
June
2003.
Exhibit
A­
16
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliforms
does
not
allow
for
dilution.

Exhibit
A­
15.
Effluent
Data
Summary,
Humacao
RSTP1
Parameter
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)
Total
Detect
Nondetect
Maximum
Mean
Minimum
Average
Monthly
41
41
­
312
61
5.2
2,0002
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
January
2000
to
June
2003.
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
16.
Compliance
Summary,
Humacao
RSTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
61
2,000
None
200
2
out
of
41
1.
Represents
the
average
of
the
average
monthly
values
from
January
2000
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
Less
than
20%
of
the
values
exceed
400
colonies/
100
mL.
October
2003
Appendix
A.
Facility
Analyses
A
 
14
Controls
Needed
Exhibit
A­
16
indicates
that
the
facility
is
currently
in
compliance
with
its
current
effluent
limit,
but
may
not
be
in
compliance
with
the
projected
limit.
However,
both
exceedances
of
the
projected
limit
occurred
before
March
2001
(
values
of
280
and
312
colonies/
100
mL
in
April
2000
and
February
2001,
respectively).
Based
on
the
most
recent
effluent
conditions
(
i.
e.,
March
2001
to
June
2003),
the
facility
would
likely
be
in
compliance
with
the
projected
effluent
limit.
Therefore,
EPA
assumed
that
the
facility
would
not
incur
costs
associated
with
the
proposed
rule.
October
2003
Appendix
A.
Facility
Analyses
A
 
15
Puerto
Nuevo
Regional
Wastewater
Treatment
Plant
Facility
Description
The
Puerto
Nuevo
Regional
Wastewater
Treatment
Plant
(
NPDES
No.
PR0021555)
is
located
in
San
Juan,
Puerto
Rico.
The
facility
is
owned
by
the
Puerto
Rico
Aqueduct
and
Sewer
Authority
and
is
operated
by
the
Compañía
de
Aguas
de
Puerto
Rico.
The
facility
began
operation
in
1957
and
treats
wastewater
from
the
municipalities
of
San
Juan,
Trujillo
Alto,
and
portions
of
Bayamon,
Guayanbo,
and
Carolina.
EPA
classifies
the
discharge
as
a
major
discharge.
The
facility
has
an
average
hydraulic
loading
of
72
mgd
and
discharges
about
7,300
feet
from
the
shore
into
the
Atlantic
Ocean.

Treatment
Processes
Information
provided
by
EPA
Region
2
indicates
that
current
treatment
processes
consist
of
mechanical
bar
screening,
grit
removal,
primary
clarification,
and
chlorination.
Sludge
is
dewatered
with
a
rotating
sludge
thickener
mechanism
and
pumped
to
a
tanker
truck
for
offsite
disposal.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
17
summarizes
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
January
2000
through
June
2003.
Exhibit
A­
18
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
for
fecal
coliforms
does
not
allow
for
dilution.

Exhibit
A­
17.
Effluent
Data
Summary,
Puerto
Nuevo
RWWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
38
34
4
35,512
1,078
2
2,0002
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
January
2000
to
June
2003.
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
18.
Compliance
Summary,
Puerto
Nuevo
RWWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
1,078
2,000
1
out
of
38
200
3
out
of
38
Exhibit
A­
18.
Compliance
Summary,
Puerto
Nuevo
RWWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
October
2003
Appendix
A.
Facility
Analyses
A
 
16
1.
Represents
the
average
of
the
average
monthly
values
from
January
200
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
Less
than
20%
of
the
values
exceed
400
colonies/
100
mL.

Controls
Needed
Exhibit
A­
18
indicates
that
the
facility
is
most
likely
in
compliance
with
its
current
effluent
limit
for
fecal
coliform.
(
Hard
copy
DMR
data
from
the
facility
indicate
that
the
single
exceedance
of
the
current
limit
was
the
result
of
an
insufficient
chlorine
dose.)
However,
the
facility
may
not
be
in
compliance
with
the
projected
effluent
limit.
The
facility's
DMR
data
indicate
that
two
of
the
three
exceedances
are
due
to
a
chlorine
demand
greater
than
the
supplied
chlorine
dose.
Therefore,
EPA
assumed
that
increasing
the
chlorine
dose
when
the
chlorine
demand
increases
would
enable
the
facility
to
comply
with
the
projected
limit.
Exhibit
A­
19
summarizes
the
control
costs
associated
with
reducing
fecal
coliforms
to
the
required
levels.
Costs
include
monitoring
of
the
influent
and
effluent
to
the
chlorine
contact
chambers
(
e.
g.,
process
analysis)
and
the
additional
chlorine
costs
to
increase
the
dose
from
10
mg/
L
to
15
mg/
L
(
plus
the
additional
storage
space).

Exhibit
A­
19.
Summary
of
Compliance
Costs,
Puerto
Nuevo
RWWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
7,579
­
$
715
Process
Modifications:
Increase
Chlorine
Dose
$
504,608
$
701,440
$
749,075
Total
$
512,187
$
701,440
$
749,790
Sources:
U.
S.
EPA
(
2003b);
BLS
(
2002).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
October
2003
Appendix
A.
Facility
Analyses
A
 
17
U.
S.
Naval
Station
Roosevelt
Roads
Facility
Description
The
U.
S.
Naval
Station
Roosevelt
Roads
(
NPDES
No.
PR0020010)
is
located
in
Ceiba,
Puerto
Rico.
The
U.
S.
Naval
Station
operates
and
maintains
facilities
for
naval
surface
and
air
operations
of
the
Atlantic
Fleet
through
use
of
its
airfield
and
ship
yards.
The
base
has
three
wastewater
treatment
plants
(
Forrestal,
Capehart,
and
Bundy)
that
treat
domestic,
commercial,
and
industrial
wastewater.
Outfall
001
(
Forrestal
WWTP)
has
an
average
flow
of
0.38
mgd
and
treats
wastewater
generated
in
the
Waterfront
Service
Area,
including
the
pesticide
and
pest
control
building,
the
engine
service
station,
the
pier,
torpedo,
vehicle,
and
aircraft
washrack
areas,
sandblasting
and
spray
painting
area,
batteries
handling
areas,
and
the
fire
fighting
training
area.
Outfall
001
is
discharged
to
the
Ensenda
Honda.
Outfall
002
(
Capehart
WWTP)
has
an
average
flow
of
0.14
mgd
and
treats
sanitary
wastewater
from
the
local
high
school
and
surrounding
Navy
housing
area.
Outfall
003
(
Bundy
WWTP)
has
an
average
flow
of
0.46
mgd
and
treats
sanitary
wastewater
as
well
as
wastewater
from
the
vehicle
maintenance
area.
Both
outfalls
002
and
003
discharge
to
the
Vieques
Passage.
EPA
classifies
the
facility
as
a
major
discharger.

Treatment
Processes
The
facility's
2002
permit
renewal
application
indicates
that
current
treatment
processes
for
outfall
001
consist
of
screening
and
grit
removal,
flow
equalization,
preaeration,
oil
recovery,
primary
clarification,
trickling
filtration,
secondary
clarification,
nitrification,
denitrification,
chlorination,
dechlorination,
and
cascading
aeration.
Current
treatment
processes
for
outfall
002
consist
of
grit
removal
and
washing,
comminutor,
aeration,
clarification,
nitrification,
denitrification,
chlorination,
dechlorination,
and
cascading
aeration.
Current
treatment
processes
for
outfall
003
consist
of
screening
and
grit
removal,
primary
clarification,
trickling
filtration,
secondary
clarification,
nitrification,
dentrification,
chlorination,
dechlorination,
and
cascading
aeration.
Sludge
from
each
outfall
is
aerobically
digested
and
dried
in
sludge
drying
beds.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
20
summarizes
average
monthly
effluent
fecal
coliform
data
from
EPA's
PCS
database
for
each
outfall
from
January
2000
through
June
2003.
Exhibit
A­
21
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limits
for
fecal
coliforms
do
not
allow
for
dilution.

Exhibit
A­
20.
Effluent
Data
Summary,
U.
S.
Naval
Station
Roosevelt
Roads1
Outfall
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
001
(
Forrestal)
41
41
­
20
8.5
2
2,0002
002
(
Capehart)
39
39
­
45
8.3
2
2,0002
Exhibit
A­
20.
Effluent
Data
Summary,
U.
S.
Naval
Station
Roosevelt
Roads1
Outfall
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
October
2003
Appendix
A.
Facility
Analyses
A
 
18
003
(
Bundy)
35
35
­
20
8.2
2
2,0002
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
January
2000
to
June
2003.
2.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
21.
Compliance
Summary,
U.
S.
Naval
Station
Roosevelt
Roads
Outfall
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit2
Projected
Limit
Exceedances4
001
(
Forrestal
WWTP)
8.5
2,000
None
200
None
002
(
Capehart
WWTP)
8.3
2,000
None
200
None
003
(
Bundy
WWTP)
8.2
2,000
None
200
None
1.
Represents
the
average
of
the
average
monthly
values
from
January
2000
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
Less
than
20%
of
the
values
exceed
400
colonies/
100
mL.

Controls
Needed
Exhibit
A­
21
indicates
that
the
facility
is
currently
in
compliance
with
the
current
and
projected
effluent
limits
for
fecal
coliform.
Therefore,
the
facility
would
not
incur
costs
associated
with
the
proposed
rule.
October
2003
Appendix
A.
Facility
Analyses
A
 
19
Vega
Baja
Wastewater
Treatment
Plant
Facility
Description
The
Vega
Baja
Wastewater
Treatment
Plant
(
NPDES
No.
PR000021679)
is
located
in
Humacao,
Puerto
Rico.
The
facility
is
owned
by
the
Puerto
Rico
Aqueduct
and
Sewer
Authority
and
operated
and
maintained
by
Compañia
de
Aguqas
de
Puerto
Rico.
The
facility
began
operation
in
1971,
and
in
1988
a
package
activated
sludge
plant
was
added.
Both
facilities
are
currently
in
use.
The
facility
treats
domestic
wastewater
from
Vega
Baja,
and
discharges
an
average
of
2.2
mgd
to
Cabo
Caribe
Creek.
EPA
classifies
the
discharge
as
a
major
discharge.

Treatment
Processes
Information
provided
by
EPA
Region
2
indicates
that
current
treatment
processes
consist
of
communitors
and
grit
removal,
flow
splitting,
primary
clarification,
activated
sludge,
biofiltration,
final
sedimentation,
and
chlorination.
Sludge
is
anaerobically
digested
and
dried
in
drying
beds
or
a
belt
filter
press.

Summary
of
Effluent
Data
and
Limits
Exhibit
A­
22
summarizes
average
monthly
effluent
data
for
fecal
coliform
from
EPA's
PCS
database
from
January
2000
through
June
2003.
Exhibit
A­
23
compares
current
effluent
conditions
to
the
current
and
projected
effluent
limits
for
fecal
coliform
under
the
proposed
rule.
EPA
assumed
that
the
criteria
would
apply
end­
of­
pipe
because
the
current
effluent
limit
does
not
allow
for
dilution.

Exhibit
A­
22.
Effluent
Data
Summary,
Vega
Baja
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum
Mean
Minimum
Fecal
Coliform
41
38
3
397,423
40,9242
3
2,0003
Source:
U.
S.
EPA
(
2003a).
1.
Average
monthly
values
from
January
2000
to
June
2003.
2.
Average
is
underestimated
because
4
values
are
reported
as
greater
than
a
number
(
e.
g.,
>
160,000),
and
EPA
assumed
the
value
was
at
the
detection
limit
(
e.
g.,
160,000).
3.
Represents
an
average
monthly
limit.
The
permit
also
prohibits
more
than
20%
of
the
samples
from
exceeding
4,000
colonies/
100
mL.

Exhibit
A­
23.
Projected
Effluent
Limits,
Vega
Baja
WWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
Fecal
Coliform
(
colonies/
100
mL)
40,924
2,000
14
out
of
41
200
19
out
of
41
Exhibit
A­
23.
Projected
Effluent
Limits,
Vega
Baja
WWTP
Pollutant
Effluent
Value1
Current
Limit
Current
Limit
Exceedances2
Projected
Limit3
Projected
Limit
Exceedances4
October
2003
Appendix
A.
Facility
Analyses
A
 
20
1.
Represents
the
average
of
the
average
monthly
values
January
2000
to
June
2003.
2.
Violations
of
current
permit
limit
based
on
average
monthly
values.
3.
Represents
an
average
monthly
limit.
Under
the
proposed
rule,
the
limit
would
also
prohibit
more
than
20%
of
the
samples
from
exceeding
400
colonies/
100
mL.
4.
Violations
of
projected
limit
(
200
colonies/
100
mL)
based
on
average
monthly
values.
About
39%
of
values
also
exceed
400
colonies/
100
mL.

Controls
Needed
Exhibit
A­
23
indicates
that
the
facility
is
not
in
compliance
with
its
current
effluent
limit.
Hard
copy
DMR
data
from
the
facility
indicates
that
fecal
coliform
exceedances
are
most
likely
the
result
of
exceedances
in
flow,
BOD,
and
TSS
concentrations.
In
several
cases,
the
exceedances
resulted
from
a
damaged
clarifier
in
the
biofiltration
plant.
EPA
assumed
the
facility
would
need
to
install
a
flow
equalization
tank
and
optimize
the
secondary
treatment
units
to
achieve
consistently
lower
BOD
and
TSS
levels
for
compliance
with
the
current
fecal
coliform
limits.
Once
in
compliance
with
the
current
limits,
additional
process
optimization
of
the
chlorination
system
would
enable
compliance
with
the
projected
fecal
coliform
limit.
Exhibit
A­
24
summarizes
the
control
costs
necessary
to
reduce
fecal
coliform
to
the
required
levels.
Costs
include
process
analysis,
and
process
modifications
including
increasing
the
chlorine
dose
from
5
mg/
L
to
15
mg/
L,
improving
mixing
conditions
through
the
addition
of
baffles,
increasing
contact
time
from
60
minutes
to
90
minutes,
and
increasing
the
frequency
of
maintenance
and
cleaning
of
the
contact
tanks
to
prevent
bacteria
build
up
from
once
every
2
years
to
twice
a
year.

Exhibit
A­
24.
Summary
of
Compliance
Costs,
Vega
Baja
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
7,579
­
$
715
Process
Modifications:
Increase
Chlorine
Dose
Improve
Mixing
Increase
Contact
Time
Increase
Maintenance
$
252,304
$
10,109
$
21,357
­
$
43,520
­
­
$
1,563
$
67,337
$
954
$
2,016
$
1,563
Total
$
291,349
$
45,083
$
72,587
Sources:
U.
S.
EPA
(
2003b);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
October
2003
Appendix
A.
Facility
Analyses
A
 
21
References
Bureau
of
Labor
Statistics
(
BLS).
2002.
2001
Occupational
Employment
Survey
(
OES)
State
Occupational
Employment
and
Wage
Estimates,
Puerto
Rico.
Online
at
http://
www.
bls.
gov/
oes/
2001/
oes_
pr.
htm.

U.
S.
EPA.
2003a.
Permit
Compliance
System
(
PCS)
Database.
Accessed
September
10,
2003.
Online
at
http://
www.
epa.
gov/
enviro/
html/
pcs/
adhoc.
html.

U.
S.
EPA.
2003b.
Chlorine
Disinfection
Model
of
the
WBS­
Based
Cost
Models
for
Drinking
Water
Treatment
Technologies.
Final
Draft.

Water
Environment
Research
Foundation
(
WERF).
1995.
Comparison
of
UV
Irradiation
to
Chlorination:
Guidance
for
Achieving
Optimal
UV
Performance.
Project
91­
WWD­
1.
Appendix
B
Total
Annual
Cost
Calculations
October
2003
Appendix
B.
B
 
1
Appendix
B.
Total
Annual
Cost
Calculations
This
appendix
provides
a
summary
of
the
estimated
costs
of
the
proposed
rule
to
the
sample
facilities,
and
an
explanation
of
the
extrapolation
of
costs
to
the
total
number
of
potentially
affected
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
Estimated
Costs
to
Sample
Facilities
NPDES
No.
Facility
Type
Category
Total
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
PR0023728
Bayamon
RWWTP
Major
Municipal
$
0
$
0
$
0
PR0023752
Carolina
WWTP
Major
Municipal
$
0
$
0
$
0
PR0025445
Guayama
RWWTP
Major
Municipal
$
0
$
0
$
0
PR0025399
Humacao
RSTP
Major
Municipal
$
0
$
0
$
0
PR0021555
Puerto
Nuevo
RWWTP
Major
Municipal
$
512,187
$
701,440
$
749,790
PR0021679
Vega
Baja
WWTP
Major
Municipal
$
291,349
$
45,083
$
72,587
PR0023442
Boquerón
WWTP
Minor
Municipal
$
0
$
0
$
0
PR0020486
Guanica
WWTP
Minor
Municipal
$
99,326
$
15,360
$
24,736
PR0020010
U.
S.
Naval
Station
­
Roosevelt
Roads
Major
Military
$
0
$
0
$
0
PR0020044
Fort
Allen
Training
Annex
Minor
Military
$
60,218
$
3,961
$
9,645
1.
Represents
capital
costs
annualized
at
7%
over
20
years,
plus
annual
O&
M
costs.

To
extrapolate
the
sample
facility
costs
to
the
universe
of
affected
facilities,
EPA
first
calculated
an
average
annual
cost
per
facility
for
major
municipals,
minor
municipals,
major
military,
and
minor
military
facilities.
EPA
then
multiplied
the
average
per
facility
cost
by
the
total
number
of
potentially
affected
facilities
in
each
discharge
category.
Exhibit
B­
2
summarizes
the
resulting
total
costs
associated
with
the
proposed
rule.

Exhibit
B­
2.
Potential
Costs
to
All
Facilities
Potentially
Affected
by
the
Proposed
Rule
Discharger
Category
Sample
Size
Number
in
Sample
with
Costs
Total
Annual
Cost
for
Sample
Facilities
Annual
Cost
per
Facility
Number
Potentially
Affected
Total
Annual
Cost
Major
Municipal
6
2
$
822,377
$
137,063
19
$
2,604,194
Minor
Municipal
2
1
$
24,736
$
12,368
10
$
123,680
Major
Military
1
0
$
0
$
0
1
$
0
Minor
Military
1
1
$
9,645
$
9,645
2
$
19,290
Total
10
4
$
856,758
NA
32
$
2,747,164
NA
=
not
applicable.
October
2003
Appendix
B.
B
 
2
