ECONOMIC
ANALYSIS
FOR
PROPOSED
WATER
QUALITY
STANDARDS
FOR
COASTAL
WATERS
June
2004
Prepared
for:

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

Science
Applications
International
Corporation
11251
Roger
Bacon
Drive
Reston,
VA
20190
EPA
Contract
No.
68­
C­
99­
252
SAIC
Project
Number
01­
0833­
04­
7714­
xxx
June
2004
i
Table
of
Contents
Executive
Summary
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ES­
1
1.
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
1
1.3
Scope
of
the
Analysis
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1­
2
1.4
Organization
of
the
Report
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1­
2
2.
Baseline
for
the
Analysis
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2­
1
2.1
Water
Quality
Standards
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2­
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2.2
Other
Regulations
and
Policies
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2­
6
2.2.1
Storm
Water
from
MS4s
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2­
6
2.2.2
CZARA
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2­
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2.2.3
CSOs
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2­
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2.2.4
SSOs
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2­
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2.2.5
TMDLs
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2­
8
2.3
Summary
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2­
9
3.
Description
of
the
Rule
and
Potentially
Affected
Facilities
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3­
1
3.1
Water
Quality
Criteria
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3­
1
3.2
Potentially
Affected
Facilities
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3­
2
4.
Method
for
Estimating
Costs
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4­
1
4.1
Selecting
a
Sample
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4­
1
4.2
Determining
Necessary
Controls
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4­
1
4.2.1
Estimating
Facilities
Needing
Controls
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4­
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4.2.2
Estimating
Most
Likely
Control
Scenario
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4­
3
4.3
Estimating
the
Cost
of
Controls
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4­
5
4.4
Total
Annual
Costs
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4­
7
5.
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.
References
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6­
1
Appendices
Appendix
A.
Facility
Analyses
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A­
1
Appendix
B.
Total
Annual
Cost
Calculations
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B­
1
Appendix
C.
Potential
Sample
Analysis
Costs
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C­
1
Appendix
D.
Energy
Use
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D­
1
June
2004
ii
List
of
Exhibits
Exhibit
ES­
1.
Proposed
Bacteria
Criteria
for
Coastal
Recreation
Waters
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ES­
1
Exhibit
ES­
2.
Estimated
Universe
of
Potentially
Affected
Facilities
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ES­
2
Exhibit
ES­
3.
Potential
Costs
Attributable
to
the
Proposed
Rule
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ES­
3
Exhibit
2­
1.
Status
of
State
and
Territory
Water
Quality
Standards
for
Beaches
in
States
with
Coastal
Waters
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2­
1
Exhibit
3­
1.
Proposed
Bacteria
Criteria
for
Coastal
Recreation
Waters:
Fresh
Waters
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3­
1
Exhibit
3­
2.
Proposed
Bacteria
Criteria
for
Coastal
Recreation
Waters:
Marine
Waters
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3­
2
Exhibit
3­
3.
Estimated
Universe
of
Potentially
Affected
Facilities
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3­
3
Exhibit
4­
1.
Summary
of
Sample
Facilities
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4­
1
Exhibit
4­
2.
Facilities
Currently
in
Compliance
with
EPA's
1986
Bacteria
Criteria
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4­
3
Exhibit
4­
3.
Process
Modification
Cost
Components
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4­
7
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
1
June
2004
iii
List
of
Acronyms
BEACH
Act
Beaches
Environmental
Assessment
and
Coastal
Health
Act
CSO
Combined
sewer
overflow
CT
Contact
time
cu.
yd.
Cubic
yard
CWA
Clean
Water
Act
CZARA
Coastal
Zone
Act
Reauthorization
Amendments
DRBC
Delaware
River
Basin
Commission
EO
Executive
Order
EPA
Environmental
Protection
Agency
FC
Fecal
coliform
FS
Fecal
streptococcus
mgd
Million
gallons
per
day
MS4
Municipal
separate
storm
sewer
system
NPDES
National
pollutant
discharge
elimination
system
O&
M
Operation
and
maintenance
PCS
Permit
compliance
system
POTW
Publicly
owned
treatment
work
RB4
Los
Angeles
Regional
Board
SIC
Standard
industrial
classification
sq.
ft.
Square
feet
SSM
Single
sample
maximum
SSO
Sanitary
sewer
overflow
TMDL
Total
maximum
daily
load
WQS
Water
quality
standards
June
2004
Executive
Summary
ES­
1
Executive
Summary
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
proposing
water
quality
standards
(
WQS)
applicable
to
coastal
recreational
waters
in
28
States
and
Territories.
This
report
presents
EPA's
analysis
of
potential
costs
associated
with
the
proposed
rule.

The
Beaches
Environmental
Assessment
and
Coastal
Health
Act
(
BEACH
Act)
was
signed
into
law
on
October
10,
2000.
The
BEACH
Act
adds
Section
303(
i)
to
the
CWA,
and
requires
that
jurisdictions
that
are
authorized
by
EPA
to
adopt
water
quality
standards,
and
that
have
coastal
recreational
waters,
adopt
and
submit
to
the
Administrator
water
quality
criteria
and
standards
for
coastal
recreational
waters
for
pathogen
indicators
for
which
the
Administrator
has
published
criteria
under
Section
304(
a).
The
BEACH
Act
defines
coastal
recreation
water
to
include
the
Great
Lakes
and
marine
coastal
waters,
including
coastal
estuaries
that
are
designated
by
States
and
Territories
under
CWA
Section
303(
c)
for
swimming,
bathing,
surfing,
or
similar
water
contact
activities.
The
Act
also
requires
the
Administrator
to
promptly
propose
regulations
for
these
States
and
Territories
if
they
fail
to
adopt
the
applicable
criteria
by
April
10,
2004.

EPA
is
proposing
water
quality
criteria
for
bacteria
for
coastal
recreation
waters
in
specific
States
and
Territories
that
have
not
yet
met
their
obligations
under
section
303(
i)(
1)(
A)
of
the
CWA.
Exhibit
ES­
1
shows
the
proposed
criteria
for
fresh
and
marine
waters.

Exhibit
ES­
1.
Proposed
Bacteria
Criteria
for
Coastal
Recreation
Waters
Indicator
Geometric
Mean
Single
Sample
Maximum
(
per
100
mL)
a
Designated
Bathing
Beach
Moderate
Use
Light
Use
Infrequent
Use
Fresh
Waters:
E.
coli
126/
100
mLb
235c
298c
409c
575c
Marine
Waters:
Enterococci
35/
100
mLd
104e
158e
276e
501e
a.
As
an
alternative
to
the
single
sample
maximums
(
SSMs),
States
may
use
a
site­
specific
log
standard
deviation
to
calculate
a
SSM
for
individual
coastal
recreation
waters,
but
must
use
at
least
30
samples
to
do
so.
b.
This
value
represents
use
of
analytical
methods
1106.1
or
1600
or
any
equivalent
viable
method.
c.
Calculated
using
the
following:
single
sample
maximum
=
geometric
mean
*
10^(
confidence
level
factor
*
log
standard
deviation),
where
the
confidence
level
factor
is:
75%:
0.68;
82%:
0.94;
90%:
1.28;
95%:
1.65.
The
log
standard
deviation
from
EPA's
epidemiological
studies
is
0.4.
d.
This
value
represents
use
of
analytical
methods
1103.1,
1603,
or
1604
or
any
equivalent
viable
method.
e.
Calculated
using
the
following:
single
sample
maximum
=
geometric
mean
*
10^(
confidence
level
factor
*
log
standard
deviation),
where
the
confidence
level
factor
is:
75%:
0.68;
82%:
0.94;
90%:
1.28;
95%:
1.65.
The
log
standard
deviation
from
EPA's
epidemiological
studies
is
0.7.

Method
EPA
identified
850
potentially
affected
facilities
using
its
permit
compliance
system
(
PCS)
database.
In
doing
so,
EPA
assumed
that
only
wastewater
treatment
plants
or
facilities
with
June
2004
Executive
Summary
ES­
2
similar
effluent
characteristics
(
i.
e.,
facilities
having
the
potential
to
discharge
bacteria)
would
potentially
be
affected
by
the
proposed
rule.
Therefore,
EPA
was
only
able
to
include
facilities
for
which
standard
industrial
classification
(
SIC)
code
information
is
provided
in
PCS
(
in
order
to
determine
effluent
makeup).
EPA
also
assumed
that
only
facilities
located
in
States
included
in
the
proposed
rule
that
discharge
within
two
miles
of
coastal
waters
or
the
Great
Lakes
may
be
affected
by
the
proposed
rule.
EPA
identified
these
facilities
by
relating
facility
information
(
latitudes
and
longitudes)
to
the
potentially
affected
waters
using
GIS
software.
For
those
facilities
for
which
latitude/
longitude
data
are
not
in
PCS,
EPA
was
only
able
to
include
facilities
for
which
the
receiving
water
body
name
(
e.
g.,
Pacific
Ocean,
Lake
Erie,
Chesapeake
Bay)
indicates
a
coastal
water.
Exhibit
ES­
2
summarizes
the
universe
of
these
facilities.

Exhibit
ES­
2.
Estimated
Universe
of
Potentially
Affected
Facilities1
Category
Number
of
Facilities
Total
Major3
Minor2
Municipal
Other4
Coastal
298
283
108
689
Great
Lakes
64
76
21
161
Total
362
359
129
850
Source:
U.
S.
EPA
(
2003a).
1.
Facilities
from
States
included
in
the
proposed
rule
that
discharge
within
two
miles
of
coastal
waters
or
the
Great
Lakes.
2.
By
definition,
minor
facilities
discharge
less
than
1
million
gallons
per
day
(
mgd),
and
do
not
discharge
toxics
in
toxic
amounts.
3.
No
major
industrial
facilities
are
affected
by
the
proposed
rule.
However,
6
facilities
(
SIC
codes
9711
and
9999)
are
included
as
municipal
facilities
because
their
names
indicate
that
they
are
POTWs.
4.
Includes
the
following
SICs:
eating
places
(
5812),
drinking
places
(
5813),
operators
of
nonresidential
buildings
(
6512),
operators
of
apartment
buildings
(
6513),
operators
of
dwellings
other
than
apartment
buildings
(
6514),
operators
of
residential
mobile
home
sites
(
6515),
hotels
and
motels
(
7011),
recreational
vehicle
parks
and
campsites
(
7033),
organization
hotels
and
lodging
houses
(
7041),
physical
fitness
facilities
(
7991),
amusement
and
recreation
services
(
7999),
skilled
nursing
care
facilities
(
8051),
general
medical
and
surgical
hospitals
(
8062),
elementary
and
secondary
schools
(
8211),
colleges,
universities,
and
professional
schools
(
8221),
civic,
social,
and
fraternal
associations
(
8641),
private
households
(
8811).
Also
includes
the
following
SICs
if
the
facility
name
suggests
that
they
may
discharge
sanitary
waste:
operative
builders
(
1531),
sanitary
services,
not
elsewhere
classified
(
4959),
real
estate
agents
and
managers
(
6531),
business
associations
(
8611),
religious
organizations
(
8661),
services
not
elsewhere
classified
(
8999),
air
and
water
resource
and
solid
waste
management
(
9511),
national
security
(
9711),
nonclassifiable
establishments
(
9999).

EPA
evaluated
a
sample
of
facilities
for
potential
cost
impacts
associated
with
the
proposed
rule.
EPA
evaluated
the
15
major
municipal
facilities
with
design
flows
greater
than
120
mgd,
thus
ensuring
that
the
facilities
with
potential
for
the
largest
costs
would
be
evaluated.
For
the
remaining
facilities,
EPA
evaluated
a
sample
of
facilities
to
represent
discharger
type
and
category.

PCS
does
not
contain
E.
coli
or
enterococci
effluent
data
for
any
of
the
sample
facilities.
Therefore,
to
evaluate
potential
costs
associated
with
the
E.
coli
criteria,
EPA
assumed
that
100%
June
2004
Executive
Summary
ES­
3
of
the
fecal
coliform
measured
is
E.
coli
because
E.
coli
is
a
type
of
fecal
coliform.
EPA
estimated
that
facilities
with
average
monthly
effluent
levels,
based
on
the
last
3
years
of
data,
exceeding
a
geometric
mean
of
126
fecal
coliform/
100
mL
(
the
proposed
geometric
mean
E.
coli
criterion),
and
maximum
daily
levels
exceeding
235
fecal
colonies/
100
mL
(
the
proposed
single
sample
maximum
E.
coli
criterion),
would
need
treatment
controls
to
meet
potential
permit
limits
based
on
the
proposed
criteria.

In
comparison,
enterococci
are
fecal
bacteria
in
the
fecal
streptococcus
group,
and
the
relationship
to
fecal
coliform
bacteria
is
uncertain.
Therefore,
for
coastal
facilities,
EPA
used
data
and
information
in
the
literature
regarding
the
ratio
of
fecal
coliform
to
enterococci
in
untreated
sewage,
and
the
inactivation
of
both
of
these
bacteria
at
minimum
disinfection
levels,
to
identify
the
concentrations
of
fecal
coliform
that
may
indicate
a
need
for
controls.
Again,
EPA
compared
fecal
coliform
levels
over
the
last
three
years
to
both
the
proposed
geometric
mean
and
SSM
enterococci
criteria
values.

Experiences
from
facilities
currently
meeting
the
proposed
E.
coli
and
enterococci
criteria,
as
well
as
the
current
fecal
coliform
criteria,
suggest
that
chlorination
processes
can
be
upgraded
or
adjusted
to
produce
the
levels
of
bacteria
necessary
for
compliance
with
the
proposed
rule.
Therefore,
EPA
estimated
that
optimization
of
existing
disinfection
processes
would
enable
the
sample
facilities
to
comply
with
the
proposed
rule.
Process
optimization
usually
involves
process
analysis
and
process
modifications,
and
EPA's
cost
estimates
include
both
capital
and
operating
and
maintenance
costs.

Results
Based
on
the
potential
costs
for
the
15
facilities
with
flows
greater
than
120
mgd,
and
extrapolating
costs
for
a
sample
of
60
facilities
to
the
remaining
835
facilities
potentially
affected
by
the
proposed
rule,
EPA
estimated
a
total
annual
cost
of
approximately
$
22
million
($
15
million
for
coastal
facilities,
and
$
7
million
for
Great
Lakes
facilities).
Exhibit
ES­
3
provides
a
summary
of
the
costs.

Exhibit
ES­
3.
Potential
Costs
Attributable
to
the
Proposed
Rule
(
millions
of
$
2004)
1
Category
Annual
Costs
($/
yr)
2
Major
POTWs
>
120
mgd
Major
POTWs
<
120
mgd
Minor
POTWs
Minor
Others
Total
Coastal
Facilities
$
9,100,000
$
4,400,000
$
740,000
$
280,000
$
14,600,000
Great
Lakes
Facilities
$
3,200,000
$
3,800,000
$
280,000
$
60,000
$
7,300,000
Total
$
12,300,000
$
8,200,000
$
1,000,000
$
340,000
$
21,900,000
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.
June
2004
Executive
Summary
ES­
4
Note,
however,
that
the
estimated
cost
is
based
on
assumptions
regarding
how
States
and
Territorial
will
implement
the
proposed
standards
that
may
overstate
the
actual
cost
impacts.
States
have
flexibility
in
implementing
water
quality
standards.
For
example,
facilities
in
some
States
that
have
already
adopted
consistent
criteria
have
both
average
and
maximum
limits
for
E.
coli
and
enterococci,
and
facilities
in
other
States
have
only
average
limits
or
no
limits
at
all.
Also,
all
potentially
affected
facilities
may
not
discharge
to
designated
bathing
beaches,
thus,
less
stringent
SSM
values
may
apply
to
the
waters.
Many
of
the
uncertainties
associated
with
the
analysis
are
associated
with
a
lack
of
data
available
for
the
analysis.
EPA
made
a
number
of
assumptions
regarding
the
relationship
between
fecal
coliform
and
E.
coli
and
enterococci,
the
disinfection
processes
of
the
sample
facilities,
and
facility
responses
to
potential
revised
permit
conditions.
June
2004
1.
Introduction
1­
1
1.
Introduction
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
proposing
water
quality
standards
(
WQS)
applicable
to
coastal
recreational
waters
in
28
States
and
Territories.
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
incur
as
a
result
of
the
proposed
rule
through
changes
to
their
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
limits.

1.1
Background
The
Clean
Water
Act
(
CWA)
directs
States,
with
oversight
by
EPA,
to
adopt
WQS
to
protect
the
public
health
and
welfare,
enhance
the
quality
of
water,
and
serve
the
purposes
of
the
CWA.
Under
Section
303,
States'
water
quality
standards
must
include
at
a
minimum:
(
1)
designated
uses
for
all
water
bodies
within
their
jurisdictions,
(
2)
water
quality
criteria
sufficient
to
protect
the
most
sensitive
of
the
uses,
and
(
3)
an
antidegradation
policy
consistent
with
the
regulations
at
40
CFR
131.12.
States
are
also
required
to
hold
public
hearings
once
every
three
years
for
the
purpose
of
reviewing
applicable
water
quality
standards
and,
as
appropriate,
modifying
and
adopting
standards.
The
results
of
this
triennial
review
must
be
submitted
to
EPA,
and
EPA
must
approve
or
disapprove
any
new
or
revised
standards.
Section
303(
c)
also
directs
the
EPA
Administrator
to
promulgate
WQS
to
supersede
State
standards
that
have
been
disapproved
or
in
cases
where
the
Administrator
determines
that
a
new
or
revised
standard
is
needed
to
meet
the
CWA's
requirements.

The
Beaches
Environmental
Assessment
and
Coastal
Health
Act
(
BEACH
Act)
was
signed
into
law
on
October
10,
2000.
The
BEACH
Act
adds
Section
303(
i)
to
the
CWA,
and
requires
that
jurisdictions
that
are
authorized
by
EPA
to
adopt
water
quality
standards,
and
that
have
coastal
recreational
waters,
adopt
and
submit
to
the
Administrator
water
quality
criteria
and
standards
for
coastal
recreational
waters
for
pathogen
indicators
for
which
the
Administrator
has
published
criteria
under
Section
304(
a).
The
BEACH
Act
defines
coastal
recreation
water
to
include
the
Great
Lakes
and
marine
coastal
waters,
including
coastal
estuaries
that
are
designated
by
States
and
Territories
under
CWA
Section
303(
c)
for
swimming,
bathing,
surfing,
or
similar
water
contact
activities.
The
Act
also
requires
the
Administrator
to
promptly
propose
regulations
for
these
States
and
Territories
if
they
fail
to
adopt
the
applicable
criteria
by
April
10,
2004.

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
1
Agricultural
and
other
nonpoint
source
discharges,
as
well
as
point
source
discharges
due
to
wet
weather
events,
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.

June
2004
1.
Introduction
1­
2
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
(
i.
e.,
point
sources).
EPA
addresses
discharges
of
bacteria
from
municipal
separate
storm
sewer
systems
(
MS4s),
combined
sewer
overflows
(
CSOs),
and
sanitary
sewer
overflows
(
SSOs)
to
coastal
waters
in
existing
and
anticipated
regulations
and
policies,
and
has
tallied
potential
control
costs
as
part
of
analyses
for
these
actions.
Therefore,
to
avoid
double
counting,
EPA
did
not
estimate
such
costs
for
this
rule.
EPA
does
not
have
data
to
suggest
that
the
proposed
rule
would
result
in
increased
requirements
for
total
maximum
daily
loads
(
TMDLs).
Finally,
EPA
did
not
evaluate
the
potential
for
costs
to
other
nonpoint
sources
(
e.
g.,
agricultural)
that
it
does
not
have
direct
authority
to
regulate.
1
1.4
Organization
of
the
Report
This
report
is
organized
as
follows.
Section
2
outlines
the
baseline
for
the
analysis,
including
the
status
of
current
State
bacteria
criteria,
and
other
related
regulations
and
policies.
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.
Appendix
A
provides
detailed
information
on
the
sample
facilities.
Appendix
B
explains
the
estimation
of
total
costs.
Appendix
C
provides
information
on
the
estimation
of
monitoring
costs,
and
Appendix
D
shows
the
calculation
of
potential
energy
costs
associated
with
the
proposed
rule.
June
2004
2.
Baseline
for
the
Analysis
2­
1
2.
Baseline
for
the
Analysis
This
section
describes
the
baseline
conditions
relevant
to
evaluating
the
potential
cost
impact
of
the
proposed
rule.
To
estimate
incremental
costs,
EPA
evaluated
point
source
dischargers
to
affected
coastal
waters.
Thus,
this
section
describes
EPA's
evaluation
of
bacteria
standards
in
jurisdictions
that
it
has
authorized
to
adopt
water
quality
standards,
and
other
existing
regulations
and
policies
affecting
sources
of
E.
coli
and
enterococci
to
coastal
waters.

2.1
Water
Quality
Standards
EPA
researched
the
bacteria
criteria
in
States
and
Territories
that
have
EPA
authorization
to
adopt
water
quality
standards
and
jurisdiction
over
coastal
recreation
waters.
Exhibit
2­
1
summarizes
the
status
of
compliance
with
the
BEACH
Act
in
these
jurisdictions
(
jurisdictions
that
do
not
have
fully
consistent
criteria
are
included
in
the
proposed
rule).

Exhibit
2­
1.
Status
of
State
and
Territory
Water
Quality
Standards
for
Beaches
in
States
with
Coastal
Waters
Jurisdiction
Consistent
Criteria?
Comments
Alabama
No
As
of
April
20,
2004,
the
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria,
but
not
yet
submitted
them
to
EPA
for
review.

Alaska
No
The
State
notified
EPA
of
its
intention
to
adopt
criteria
consistent
with
EPA's
1986
bacteria
criteria,
and
anticipates
taking
public
comments
in
Summer
2004,
and
adopting
the
criteria
into
its
water
quality
standards
by
December
2004.

American
Somoa
Yes
On
November
16,
1999,
the
Territory
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria
and
EPA
approved
these
on
May
2,
2001.
The
criteria
are
for
enterococci
with
a
geometric
mean
of
35/
100
mL
and
a
single
sample
maximum
value
of
104/
100
mL
for
Pago
Pago
Harbor,
Fagatele
Bay,
and
Pala
Lagoon;
the
criteria
have
a
geometric
mean
of
35/
100
mL
and
a
single
sample
maximum
value
of
124/
100
mL
for
open
coastal
waters;
the
criteria
have
a
geometric
mean
of
35/
100
mL
and
a
single
sample
maximum
value
of
276/
100
mL
for
those
ocean
waters
beyond
the
600­
foot
depth
contour
seaward.

California
No
The
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria
for
some
but
not
all
coastal
recreation
waters.
The
Los
Angeles
Regional
Board
(
RB4)
adopted
these
standards
on
July
18,
2002
and
EPA
approved
them
on
September
25,
2002.
The
RB4
standard
is
for
enterococci,
and
has
a
geometric
mean
of
35/
100
mL
and
an
SSM
of
104/
100
mL.
The
other
Regional
Boards
with
coastal
recreation
waters
have
not
adopted
criteria
as
protective
of
human
health
as
EPA's
1986
criteria.
Exhibit
2­
1.
Status
of
State
and
Territory
Water
Quality
Standards
for
Beaches
in
States
with
Coastal
Waters
Jurisdiction
Consistent
Criteria?
Comments
June
2004
2.
Baseline
for
the
Analysis
2­
2
Commonwealth
of
Northern
Marianas
Islands
No
The
Commonwealth
adopted
a
geometric
mean
criterion
for
enterococci,
and
initiated
the
rulemaking
process
to
adopt
SSM
values.
The
Commonwealth
published
the
amendment
to
the
standards
in
April
2004,
and
anticipates
adopting
it
before
September
2004.

Connecticut
Yes
On
June
18,
2002,
the
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria,
and
EPA
approved
the
criteria.
The
State's
criteria
are
for
enterococci
with
a
geometric
mean
of
35/
100
mL,
and
an
SSM
of
104/
100
mL
for
waters
designated
for
swimming.

Delaware
No
The
State
adopted
enterococci
criteria
on
July
15,
1999,
and
EPA
approved
the
criteria
on
December
2,
1999.
The
standards
have
criteria
for
enterococci
with
a
geometric
mean
of
10/
100
mL
but
no
SSM.
Delaware
is
in
the
process
of
adopting
and
submitting
to
EPA
revised
standards
for
bacteria.

Florida
No
The
State
initiated
internal
discussions,
and
plans
to
initiate
adoption
of
EPA's
criteria
this
year.

Georgia
No
The
State
has
not
adopted
criteria
consistent
with
EPA's
criteria,
nor
initiated
any
regulatory
process
to
come
into
compliance
with
the
BEACH
Act.

Guam
Yes
On
June
18,
2002,
the
Territory
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria,
and
EPA
approved
these
on
July
24,
2002.
The
criteria
are
for
enterococci
and
have
a
geometric
mean
of
35/
100
mL
for
all
marine
waters.
The
SSM
is
104/
100
mL
for
whole
body
contact
recreation
waters
and
is
276/
100
mL
for
limited
body
contact
recreation.
EPA
considers
these
criteria
to
be
as
protective
of
human
health
as
EPA's
1986
criteria.

Hawaii
No
The
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria
for
some
but
not
all
coastal
recreation
waters.
The
State
adopted
a
geometric
mean
criterion
of
7
for
enterococcus
in
nonestuarine
marine
recreational
waters
within
300
meters
of
the
shoreline,
and
is
in
the
process
of
adopting
a
SSM
criterion
for
these
waters
and
consistent
criteria
for
estuaries.
The
State
has
no
numeric
criteria
protecting
waters
beyond
300
meters
from
shore,
although
these
waters
are
designated
for
recreation.

Illinois
No
The
State
informed
EPA
that
it
will
initiate
rulemaking
to
adopt
revised
standards
for
bacteria
by
September
30,
2004.
Exhibit
2­
1.
Status
of
State
and
Territory
Water
Quality
Standards
for
Beaches
in
States
with
Coastal
Waters
Jurisdiction
Consistent
Criteria?
Comments
June
2004
2.
Baseline
for
the
Analysis
2­
3
Indiana
Yes
The
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria,
and
EPA
approved
these
on
May
7,
1990.
The
criteria
are
for
E.
coli,
and
include
a
geometric
mean
of
125/
100
mL
and
an
SSM
of
235/
100
mL.

Louisiana
No
The
State
has
not
adopted
criteria
consistent
with
EPA's
1986
criteria,
nor
initiated
any
regulatory
process
to
be
in
compliance
with
the
BEACH
Act.

Maine
No
The
State
adopted
criteria
for
coastal
recreation
waters,
and
EPA
approved
these
criteria
on
July
16,
1986.
The
criteria
are
for
enterococci,
and
include
a
geometric
mean
of
8/
100
mL
and
a
single
sample
maximum
of
54/
100
mL
in
the
State's
waters
classified
as
"
SB."
Additionally,
the
criteria
include
a
geometric
mean
of
14/
100
mL
and
an
SSM
of
94/
100
mL
for
the
State's
waters
classified
as
"
SC."
However,
the
criteria
apply
only
to
enterococcus
of
human
origin,
and
EPA
does
not
believe
that
the
criteria
are
as
protective
of
human
health
as
EPA's
1986
bacteria
criteria
in
cases
where
the
enterococcus
bacteria
are
of
nonhuman
origin.

Maryland
No
The
State
initiated
the
rulemaking
process,
and
expects
to
adopt
EPA's
1986
bacteria
criteria.

Massachusetts
No
The
State
initiated
the
rulemaking
process,
and
expects
to
adopt
criteria
consistent
with
EPA's
1986
bacteria
criteria
by
December
31,
2004.

Michigan
Yes
On
May
20,
1994,
the
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria,
and
EPA
approved
these
criteria
on
August
11,
1994.
The
criteria
are
for
E.
coli
with
a
geometric
mean
of
130/
100
mL
and
an
SSM
value
of
300/
100
mL
for
total
body
contact
recreation,
and
an
SSM
of
1000/
100
mL
for
partial
body
contact
recreation.

Minnesota
No
The
State
initiated
the
rulemaking
process,
and
expects
to
adopt
EPA's
bacteria
criteria
by
July
2005.

Mississippi
No
The
State
initiated
internal
discussions,
and
expects
to
adopt
a
geometric
mean
criterion
by
August
2004.
The
State
will
be
conducting
beach
user
studies
in
the
summer
of
2004
to
determine
the
appropriate
single
sample
maximum
based
on
usage
of
certain
areas,
and
will
adopt
said
single
sample
criteria
by
August
2005.

New
Hampshire
Yes
On
July
2,
1991,
the
State
adopted
EPA's
1986
bacteria
criteria,
and
EPA
approved
these
on
August
31,
1991.
The
standards
include
enterococci
and
have
a
geometric
mean
of
35/
100
mL
and
an
SSM
value
of
104/
100
mL
for
all
coastal
recreation
waters.
Exhibit
2­
1.
Status
of
State
and
Territory
Water
Quality
Standards
for
Beaches
in
States
with
Coastal
Waters
Jurisdiction
Consistent
Criteria?
Comments
June
2004
2.
Baseline
for
the
Analysis
2­
4
New
Jersey
No
The
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria
for
all
coastal
recreation
waters
except
for
those
waters
of
the
Delaware
Estuary.
These
waters
are
classified
for
primary
contact
recreation
by
the
Delaware
River
Basin
Commission
(
DRBC),
include
enterococci,
and
have
a
geometric
mean
criterion
of
35/
100
mL,
but
not
an
SSM.
In
order
for
the
waters
of
the
Delaware
Estuary
to
be
in
full
compliance
with
the
criteria
and
standards
requirements
of
the
BEACH
Act,
the
SSM
maximum
criteria
must
also
be
included
in
the
DRBC
water
quality
standards.

New
York
No
The
State
has
not
initiated
any
regulatory
process
to
be
in
compliance
with
the
BEACH
Act.

North
Carolina
No
The
State
has
not
initiated
any
regulatory
process
to
be
in
compliance
with
the
BEACH
Act.

Ohio
No
The
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria
for
all
waters
in
Lake
Erie.
The
standards
for
E.
coli
include
a
geometric
mean
of
126/
100
mL
and
an
SSM
of
235/
100
mL
for
designated
bathing
waters,
and
a
geometric
mean
of
126/
100
mL
and
an
SSM
of
298/
100
mL
for
designated
primary
contact
waters.
However,
the
water
quality
standards
include
criteria
for
fecal
coliform
and
E.
coli,
and
specify
that
compliance
with
the
criteria
can
be
demonstrated
by
attainment
of
either
criterion.
The
State
uses
E.
coli
for
beach
monitoring,
but
limits
fecal
coliforms
in
the
NPDES
permits
it
issues.
EPA
interprets
the
intent
of
section
303(
i)
to
require
that
criteria
as
protective
of
human
health
as
EPA's
1986
criteria
be
used
for
permitting.
Also,
the
standards
include
E.
coli
values
that,
although
identical
to
EPA's
SSM
values
for
the
75%
and
82%
confidence
levels,
are
not
used
as
SSMs
but
as
values
not
to
be
exceeded
in
more
than
10%
of
samples
taken
during
any
30
day
period.

Oregon
No
The
State
has
not
initiated
any
regulatory
process
to
be
in
compliance
with
the
BEACH
Act.

Pennsylvania
No
The
State
initiated
a
modification
to
its
Department
of
Health
regulations
relating
to
the
bacteriological
monitoring
of
its
primary
recreation
Great
Lake
waters,
but
has
not
yet
submitted
any
revision
of
its
standards
to
EPA.
Exhibit
2­
1.
Status
of
State
and
Territory
Water
Quality
Standards
for
Beaches
in
States
with
Coastal
Waters
Jurisdiction
Consistent
Criteria?
Comments
June
2004
2.
Baseline
for
the
Analysis
2­
5
Puerto
Rico
No
The
Commonwealth
of
Puerto
Rico's
water
quality
criteria
for
recreational
waters
applies
to
those
Class
SB
(
coastal)
waters
which
are
intensely
used
for
primary
contact
recreation,
like
special
bathing
zones
(
beaches)
and
the
Class
SC
waters
for
which
EPA
recently
completed
rulemaking
to
establish
a
designated
use
and
applicable
water
quality
criteria
(
including
the
1986
criteria
for
enterococci)
to
protect
primary
contact
recreation.
The
remaining
Class
SB
waters,
which
are
not
designated
bathing
beaches,
are
not
consistent
with
the
1986
criteria.
The
Commonwealth
informed
EPA
of
its
intent
to
adopt
criteria
consistent
with
EPA's
1986
criteria
for
the
remaining
Class
SB
waters,
but
has
not
yet
submitted
any
revision
of
its
standards.
(
The
proposed
rule
only
applies
to
these
remaining
Class
SB
waters.)

Rhode
Island
No
The
State
informed
EPA
of
its
intent
to
adopt
criteria
consistent
with
EPA's
1986
bacteria
criteria
by
the
end
of
2004,
but
has
not
submitted
a
revision
of
its
standards.

South
Carolina
No
The
State
has
initiated
the
rulemaking
process,
and
expects
to
adopt
EPA's
criteria
by
July
2004.

Texas
No
The
State
adopted
criteria
consistent
with
EPA's
1986
bacteria
criteria
for
all
coastal
recreation
waters
except
for
those
that
overlap
with
shellfish
harvesting
waters.
For
these
shellfishing
waters,
the
State's
water
quality
standards
specify
only
fecal
coliform
criteria.
(
The
rule
only
applies
to
designated
"
oyster"
waters.)

Virginia
Yes
On
February
12,
2004,
the
State
adopted
EPA's
1986
bacteria
criteria,
and
EPA
approved
these
criteria
on
November
8,
2002.
The
criteria
are
for
enterococci
with
a
geometric
mean
of
35/
100
mL
for
all
coastal
waters,
and
an
SSM
value
of
104/
100
mL.

Virgin
Islands
No
The
Territory
initiated
the
rulemaking
process,
and
expects
to
adopt
EPA's
criteria
by
September
30,
2004.

Washington
No
On
May
11,
2004,
the
State
wrote
EPA
to
claim
that
their
data
show
that
where
the
geometric
mean
of
fecal
coliform
concentrations
are
at
or
below
14
counts/
100
mL,
the
corresponding
geometric
mean
of
enterococci
bacteria
are
at
or
below
EPA's
1986
marine
criterion
of
35
counts/
100
mL.
EPA
is
reviewing
these
data.

Wisconsin
No
The
State
initiated
the
rulemaking
process,
and
intends
to
adopt
EPA's
bacteria
criteria
by
winter
2005­
2006.

SSM
=
single
sample
maximum.
June
2004
2.
Baseline
for
the
Analysis
2­
6
June
2004
2.
Baseline
for
the
Analysis
2­
7
2.2
Other
Regulations
and
Policies
Several
national
regulations
and
policies
target
discharges
that
may
contain
bacteria,
including
fecal
coliform
(
FC),
E.
coli,
and
enterococci.

2.2.1
Storm
Water
from
MS4s
Storm
water
discharges
of
pathogens
from
MS4s
are
covered
under
the
Phase
I
and
Phase
II
storm
water
rules.
The
Phase
I
rule
covers
large
and
medium­
size
MS4s
[
Clean
Water
Act
Section
402(
p)
sources],
and
the
Phase
II
rule
covers
small
(
systems
serving
less
than
100,000
people)
MS4s.
For
example,
the
Phase
II
rule
requires
small
MS4s
to
be
covered
under
a
NPDES
permit,
under
which
they
must
develop
and
implement
a
storm
water
management
program
designed
to
reduce
the
discharge
of
pollutants
to
the
maximum
extent
practicable
to
protect
water
quality.
EPA
accounted
for
the
costs
of
minimum
measures
to
reduce
pathogens
(
e.
g.,
illicit
discharge
detection
and
elimination)
in
its
economic
analysis
of
the
Phase
II
rule,
as
well
as
estimated
the
benefits
associated
with
the
anticipated
pollutant
loading
reductions
(
e.
g.,
human
health
risk
reductions
associated
with
swimming
in
marine
waters).

The
measures
contained
in
the
Phase
I
and
Phase
II
rules
address
pathogens
(
and
other
pollutants)
contained
in
storm
water
discharged
to
coastal
waters.
Because
the
measures
are
designed
to
reduce
all
pollutants
found
in
storm
water,
changing
the
water
quality
standard
for
coastal
waters
from
a
standard
for
FC
to
E.
coli
or
enterococci
would
not
affect
the
controls
needed
for
MS4s.
That
is,
there
is
no
data
to
indicate
that
MS4s
would
require
additional
controls
beyond
those
required
by
the
storm
water
rules
to
meet
revised
water
quality
standards
for
coastal
waters
based
on
E.
coli
or
enterococci.

2.2.2
CZARA
The
Coastal
Zone
Act
Reauthorization
Amendments
(
CZARA)
call
for
the
development
and
implementation
of
State
coastal
nonpoint
pollution
programs,
in
conformance
with
EPA
guidance
on
the
best
economically
achievable
measures
to
protect
coastal
waters
from
nonpoint
source
pollution.
EPA's
guidance
addresses
urban
storm
water
runoff
(
including
septics),
and
EPA
accounted
for
potential
costs
of
these
measures
in
it's
economic
analysis
of
this
guidance
(
U.
S.
EPA,
1992).

2.2.3
CSOs
Discharges
of
pathogens
from
CSOs
are
covered
under
EPA's
CSO
Control
Policy.
The
CSO
Control
Policy
contains
provisions
for
developing
site­
specific
NPDES
permits
for
combined
sewer
systems
that
overflow
due
to
wet
weather
events,
and
establishes
nine
minimum
technology­
based
controls.
Permittees
can
either
demonstrate
that
their
control
plans
are
adequate
to
meet
water
quality
standards,
or
implement
minimum
treatment
(
e.
g.,
primary
clarification
of
at
least
85%
of
the
collected
combined
sewage
flows)
that
is
presumed
to
meet
June
2004
2.
Baseline
for
the
Analysis
2­
8
water
quality
standards,
unless
data
indicate
otherwise.
EPA
accounted
for
the
potential
costs
of
these
controls
in
its
report
to
Congress
(
U.
S.
EPA,
2001a).

States
that
do
not
yet
have
appropriate
water
quality
standards
for
coastal
recreation
waters
(
i.
e.,
based
on
E.
coli
or
enterococci),
have
standards
for
FC.
Changing
the
standard
to
include
criteria
for
E.
coli
or
enterococci
would
not
affect
the
controls
needed
for
these
systems.
That
is,
there
is
no
data
to
indicate
that
CSOs
would
need
controls
beyond
those
required
by
the
CSO
Control
Policy
to
meet
water
quality
standards
for
E.
coli
or
enterococci.
For
example,
EPA
identified
nine
minimum
controls
(
proper
operation
and
regular
maintenance
programs
for
the
sewer
system
and
CSO
outfalls,
maximum
use
of
the
collection
system
for
storage,
review
and
modification
of
pretreatment
requirements
to
ensure
that
CSO
impacts
are
minimized,
maximization
of
flow
to
the
POTW
for
treatment,
elimination
of
CSOs
during
dry
weather,
control
of
solid
and
floatable
materials
in
CSOs,
pollution
prevention
programs
to
reduce
containments
in
CSOs,
public
notification
to
ensure
that
the
public
receives
adequate
notification
of
CSO
occurrences
and
impacts,
and
monitoring
to
effectively
characterize
CSO
impacts
and
the
efficacy
of
controls)
to
reduce
CSOs
and
their
effects
on
receiving
water
quality
(
U.
S.
EPA,
1995).
These
controls
that
reduce
FC
present
in
CSO
discharges
also
reduce
E.
coli
and
enterococci
that
may
be
present
in
these
discharges.

2.2.4
SSOs
EPA
also
proposed
(
but
withdrew)
a
rule
controlling
SSOs.
EPA
accounted
for
the
costs
to
control
SSOs
(
achieve
one
overflow
in
a
system
every
5
years)
in
its
report
to
Congress
(
U.
S.
EPA,
2000).

States
without
appropriate
water
quality
criteria
for
coastal
waters
(
i.
e.,
based
on
E.
coli
or
enterococci)
have
standards
for
FC,
yet,
annually,
EPA
estimates
that
there
are
at
least
40,000
SSOs.
Clearly,
water
quality
standards
do
not
stop
SSOs
from
happening,
and
it
is
not
EPA's
intent
to
stop
SSO
discharges
with
water
quality
standards
for
beaches
(
i.
e.,
States
will
not
remedy
SSO
problems
in
response
to
this
rule).
However,
EPA
anticipates
an
SSO
rule.
Therefore,
EPA
did
not
estimate
costs
and
benefits
associated
with
SSOs
here
to
avoid
double
counting.
Further,
EPA
does
not
anticipate
any
incremental
SSO
controls
or
costs
to
meet
water
quality
standards
for
E.
coli
or
enterococci,
compared
to
those
for
FC.
Controls
for
SSOs
include
sewer
system
cleaning
and
maintenance;
reducing
infiltration
and
inflow
through
system
rehabilitation
and
repairing
broken
or
leaking
service
lines;
enlarging
or
upgrading
sewer,
pump
station,
or
sewage
treatment
plant
capacity
and
reliability;
and
constructing
wet
weather
storage
and
treatment
facilities
to
treat
excess
flows.
These
controls
result
in
reducing
or
eliminating
SSOs,
and
therefore,
would
reduce
E.
coli
and
enterococci
as
well
as
FC.

2.2.5
TMDLs
On
State
1998
303(
d)
lists
(
i.
e.,
State
lists
of
their
impaired
waters),
pathogens
represent
12.8%
of
the
41,331
causes
of
impairment
on
21,851
waters
(
U.
S.
EPA,
2001b).
Under
Section
303(
d)
of
the
CWA,
States
must
establish
TMDLs
for
waters
impaired
by
a
pollutant.
EPA
accounted
June
2004
2.
Baseline
for
the
Analysis
2­
9
for
the
potential
costs
of
the
TMDL
program
in
its
report
to
Congress
(
U.
S.
EPA,
2001b).
There
is
no
data
to
indicate
that
changing
the
bacterial
indicator
for
coastal
recreation
waters
from
FC
to
E.
coli
and
enterococci
would
result
in
any
additional
waters
listed
as
impaired
by
pathogens,
or
in
additional
controls
on
sources
to
coastal
recreation
waters
already
listed
as
impaired
by
pathogens.

2.3
Summary
The
proposed
rule
would
promulgate
EPA's
1986
bacteria
criteria
for
coastal
recreation
waters
in
28
States
and
Territories
that
have
not
yet
fully
adopted
these
criteria.
States
and
EPA
regions
potentially
use
the
bacteria
criteria
in
establishing
effluent
limitations
for
point
sources,
identifying
impaired
waters,
and
establishing
waste
load
allocations
for
impaired
waters.
Thus,
in
estimating
the
incremental
costs
of
the
rule,
EPA
evaluated
potential
impacts
on
NPDES­
permitted
dischargers
of
bacteria.
However,
EPA
addresses
discharges
of
bacteria
from
MS4s,
CSOs,
and
SSOs
to
coastal
waters
in
existing
and
anticipated
regulations
and
policies,
and
has
tallied
potential
control
costs
as
part
of
analyses
for
these
actions.
Therefore,
to
avoid
double
counting,
EPA
did
not
estimate
such
costs
for
this
rule.
EPA
does
not
have
data
to
suggest
that
the
proposed
rule
would
result
in
increased
requirements
for
TMDLs.

In
addition,
discharges
from
nonpoint
sources
(
e.
g.,
storm
water
runoff)
and
point
sources
due
to
wet
weather
events
(
e.
g.,
CSOs
and
SSOs)
are
difficult
to
model
and
evaluate
with
respect
to
potential
costs
impacts
because
they
are
intermittent,
highly
variable,
and
occur
under
different
hydrologic
or
climatic
conditions
than
continuous
discharges
from
industrial
and
municipal
facilities,
which
EPA
evaluates
under
critical
low
flow
or
drought
conditions.
Also,
data
on
instream
and
discharge
levels
of
bacteria
after
States
have
implemented
controls
to
meet
current
water
quality
standards
based
on
FC
are
not
available.
Therefore,
trying
to
determine
which
sources
would
not
achieve
standards
based
on
E.
coli
or
enterococci
after
complying
with
existing
regulations
and
policies
may
not
be
possible,
or
would
be
extremely
time
and
resource
intensive.
Finally,
it
is
likely
that
any
controls
needed
to
meet
existing
standards
(
i.
e.,
based
on
FC)
would
also
remedy
any
water
quality
problems
indicated
by
standards
based
on
E.
coli
or
enterococci.
June
2004
3.
Description
of
the
Proposed
Rule
3­
1
3.
Description
of
the
Rule
and
Potentially
Affected
Facilities
This
section
describes
EPA's
proposed
rule,
and
the
facilities
that
discharge
to
affected
waters.
Depending
on
how
permitting
authorities
implement
the
criteria
contained
in
the
proposed
rule,
these
facilities
may
be
impacted
through
changes
to
their
effluent
limitations.

3.1
Water
Quality
Criteria
EPA
is
proposing
water
quality
criteria
for
bacteria
for
coastal
recreation
waters
in
specific
States
and
Territories
that
have
not
yet
met
their
obligations
under
section
303(
i)(
1)(
A)
of
the
CWA.
The
criteria
apply
to
coastal
and
Great
Lakes
waters
that
specific
States
and
Territories
have
designated
for
swimming,
bathing,
surfing,
or
similar
water
contact
activities,
and
vary
by
four
categories
of
use:

Designated
bathing
beaches:
Waters
that,
during
the
recreation
season,
are
heavily­
used
or
where
a
lifeguard
or
bathhouse
facilities
or
public
parking
are
present.
States
may
include
any
other
coastal
recreation
waters
in
this
category
even
if
the
waters
do
not
meet
these
criteria.

Moderate
use:
Waters
that
are
not
designated
bathing
beach
waters
but
on
average
have
at
least
50%
of
the
number
of
people
during
the
recreation
season
of
typical
designated
bathing
beach
waters
within
the
State.
States
may
also
include
light
use
or
infrequent
use
coastal
recreation
waters
in
this
category.

Light
use:
Waters
that
are
not
designated
bathing
beach
waters
but
on
average
have
between
25%
and
50%
of
the
number
of
people
during
the
recreation
season
of
typical
designated
bathing
beach
waters
within
the
State.
States
may
also
include
infrequent
use
coastal
recreation
waters
in
this
category.

Infrequent
use:
Waters
that
have
less
use
than
light
use
coastal
recreation
waters.

Exhibits
3­
1
and
3­
2
show
the
proposed
criteria.
As
an
alternative
to
the
SSMs,
States
may
use
a
site­
specific
log
standard
deviation
to
calculate
a
SSM
for
individual
coastal
recreation
waters,
but
must
use
at
least
30
samples
to
do
so.

Exhibit
3­
1.
Proposed
Bacteria
Criteria
for
Coastal
Recreation
Waters:
Fresh
Waters
Indicator
Geometric
Mean
Single
Sample
Maximum
(
per
100
mL)

Designated
Bathing
Beach
Moderate
Use
Light
Use
Infrequent
Use
E.
coli
126/
100
mLa
235b
298b
409b
575b
a.
This
value
represents
use
of
analytical
methods
1106.1
or
1600
or
any
equivalent
viable
method.
b.
Calculated
using
the
following:
single
sample
maximum
=
geometric
mean
*
10^(
confidence
level
factor
*
log
standard
Exhibit
3­
1.
Proposed
Bacteria
Criteria
for
Coastal
Recreation
Waters:
Fresh
Waters
Indicator
Geometric
Mean
Single
Sample
Maximum
(
per
100
mL)

Designated
Bathing
Beach
Moderate
Use
Light
Use
Infrequent
Use
2EPA
had
to
correct
several
erroneous
latitude/
longitudes.
For
example,
in
several
instances
the
latitude
and
longitudes
in
PCS
are
reversed,
indicating
that
one
Alabama
facility
is
located
in
Greenland.
Other
times,
the
negative
sign
is
assigned
to
the
latitude
instead
of
the
longitude.
Therefore,
EPA
corrected
the
numbers
to
locate
the
facility
in
the
correct
location.

3Note
that
this
may
have
resulted
in
some
inaccuracies
(
e.
g.,
PCS
indicates
that
the
Calistoga
WWTP
discharges
to
the
San
Pablo
Bay,
however,
the
facility's
permit
indicates
that
the
facility
discharges
to
the
Napa
River).

June
2004
3.
Description
of
the
Proposed
Rule
3­
2
deviation),
where
the
confidence
level
factor
is:
75%:
0.68;
82%:
0.94;
90%:
1.28;
95%:
1.65.
The
log
standard
deviation
from
EPA's
epidemiological
studies
is
0.4.

Exhibit
3­
2.
Proposed
Bacteria
Criteria
for
Coastal
Recreation
Waters:
Marine
Waters
Indicator
Geometric
Mean
Single
Sample
Maximum
(
per
100
mL)

Designated
Bathing
Beach
Moderate
Use
Light
Use
Infrequent
Use
Enterococci
35/
100
mLa
104b
158b
276b
501b
a.
This
value
represents
use
of
analytical
methods
1103.1,
1603,
or
1604
or
any
equivalent
viable
method.
b.
Calculated
using
the
following:
single
sample
maximum
=
geometric
mean
*
10^(
confidence
level
factor
*
log
standard
deviation),
where
the
confidence
level
factor
is:
75%:
0.68;
82%:
0.94;
90%:
1.28;
95%:
1.65.
The
log
standard
deviation
from
EPA's
epidemiological
studies
is
0.7.

3.2
Potentially
Affected
Facilities
The
proposed
criteria
may
impact
facilities
discharging
to
affected
waters.
EPA
identified
these
facilities
using
its
permit
compliance
system
(
PCS)
database.
In
doing
so,
EPA
assumed
that
only
wastewater
treatment
plants
or
facilities
with
similar
effluent
characteristics
(
i.
e.,
facilities
having
the
potential
to
discharge
bacteria)
would
potentially
be
affected
by
the
proposed
rule.
Therefore,
EPA
was
only
able
to
include
facilities
for
which
standard
industrial
classification
(
SIC)
code
information
is
provided
in
PCS
(
in
order
to
determine
effluent
makeup).
EPA
also
assumed
that
only
facilities
located
in
States
included
in
the
proposed
rule
that
discharge
within
two
miles
of
coastal
waters
or
the
Great
Lakes
may
be
affected
by
the
proposed
rule.
EPA
identified
these
facilities
by
relating
facility
information
(
latitudes
and
longitudes)
to
the
potentially
affected
waters
using
GIS
software.
2
For
those
facilities
for
which
latitude/
longitude
data
are
not
in
PCS,
EPA
was
only
able
to
include
facilities
for
which
the
receiving
water
body
name
(
e.
g.,
Pacific
Ocean,
Lake
Erie,
Chesapeake
Bay)
indicates
a
coastal
water.
3
Exhibit
3­
3
summarizes
the
universe
of
these
facilities.
June
2004
3.
Description
of
the
Proposed
Rule
3­
3
Exhibit
3­
3.
Estimated
Universe
of
Potentially
Affected
Facilities1
Category
Number
of
Facilities
Total
Major3
Minor2
Municipal
Other4
Coastal
298
283
108
689
Great
Lakes
64
76
21
161
Total
362
359
129
850
Source:
U.
S.
EPA
(
2003a).
1.
Facilities
from
States
included
in
the
proposed
rule
that
discharge
within
two
miles
of
coastal
waters
or
the
Great
Lakes.
2.
By
definition,
minor
facilities
discharge
less
than
1
million
gallons
per
day
(
mgd),
and
do
not
discharge
toxics
in
toxic
amounts.
3.
No
major
industrial
facilities
are
affected
by
the
proposed
rule.
However,
6
facilities
(
SIC
codes
9711
and
9999)
are
included
as
municipal
facilities
because
their
names
indicate
that
they
are
POTWs.
4.
Includes
the
following
SICs:
eating
places
(
5812),
drinking
places
(
5813),
operators
of
nonresidential
buildings
(
6512),
operators
of
apartment
buildings
(
6513),
operators
of
dwellings
other
than
apartment
buildings
(
6514),
operators
of
residential
mobile
home
sites
(
6515),
hotels
and
motels
(
7011),
recreational
vehicle
parks
and
campsites
(
7033),
organization
hotels
and
lodging
houses
(
7041),
physical
fitness
facilities
(
7991),
amusement
and
recreation
services
(
7999),
skilled
nursing
care
facilities
(
8051),
general
medical
and
surgical
hospitals
(
8062),
elementary
and
secondary
schools
(
8211),
colleges,
universities,
and
professional
schools
(
8221),
civic,
social,
and
fraternal
associations
(
8641),
private
households
(
8811).
Also
includes
the
following
SICs
if
the
facility
name
suggests
that
they
may
discharge
sanitary
waste:
operative
builders
(
1531),
sanitary
services,
not
elsewhere
classified
(
4959),
real
estate
agents
and
managers
(
6531),
business
associations
(
8611),
religious
organizations
(
8661),
services
not
elsewhere
classified
(
8999),
air
and
water
resource
and
solid
waste
management
(
9511),
national
security
(
9711),
nonclassifiable
establishments
(
9999).
June
2004
4.
Method
for
Estimating
Costs
4­
1
4.
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
Selecting
a
Sample
EPA
evaluated
the
15
major
municipal
facilities
with
design
flows
greater
than
120
mgd
to
ensure
that
the
facilities
with
potential
for
the
largest
costs
would
be
evaluated.
For
the
remaining
facilities,
EPA
evaluated
a
sample
of
60
to
represent
each
discharge
type
(
major,
minor)
and
category
(
POTW,
other).
Exhibit
4­
1
summarizes
these
sample
facilities.

Exhibit
4­
1.
Summary
of
Sample
Facilities
Category
Number
of
Facilities
Total
Flows
>
120
mgd
Major
Municipal
Minor
Municipal
Other
Coastal
12
38
4
4
58
Great
Lakes
3
8
3
3
17
Total
15
46
7
7
75
Source:
U.
S.
EPA
(
2003a).

4.2
Determining
Necessary
Controls
The
proposed
criteria
are
for
affected
waters,
and
permitting
authorities
have
flexibility
in
implementing
water
quality
standards.
Facilities
in
some
States
that
have
adopted
the
1986
criteria
have
effluent
limits
for
E.
coli
or
enterococci;
however,
facilities
in
other
States
with
the
criteria
do
not
have
limits.
To
be
conservative
(
i.
e.,
err
on
the
side
of
higher
costs),
EPA
assumed
that
facilities
would
have
to
meet
both
the
applicable
geometric
mean
and
SSM
(
upper
percentile
value).

4.2.1
Estimating
Facilities
Needing
Controls
PCS
does
not
contain
E.
coli
or
enterococci
effluent
data
for
any
of
the
sample
facilities;
only
FC
data
are
available.
Therefore,
EPA
based
its
estimates
of
potential
costs
on
assumptions
regarding
the
potential
relationships
between
E.
coli
and
enterococci
and
FC.

Great
Lakes
Facilities
Since
E.
coli
is
a
type
of
FC,
EPA
assumed
that
E.
coli
values
will
be
equal
to
or
less
than
the
FC
values.
Since
all
FC
are
not
necessarily
E.
coli,
this
assumption
will
produce
a
conservative
(
i.
e.,
erring
on
the
side
of
higher
costs)
estimate
of
potential
costs.
For
the
Great
Lakes
States,
EPA
4
Note
that
EPA
(
2003b)
states
that
the
intended
use
of
the
upper
percentile
values
for
E.
coli
and
enterococci
is
beach
monitoring,
and
not
NPDES
permitting.
However,
States
have
flexibility
in
implementing
water
quality
criteria.
Ultimate
implementation
of
maximum
effluent
limits
in
facility
permits
based
on
these
values
is
not
known,
and
will
likely
vary
by
State
and
waterbody.

5Geldreich
(
1978,
as
cited
in
Thomann
and
Mueller,
1987)
in
summarizing
bacteria
data
for
14
cities
in
the
United
States,
reported
a
mean
FC/
FS
ratio
of
5.1,
with
individual
cities
ranging
from
4.4
to
28.
In
a
separate
study,
Davis
(
1979,
as
cited
in
Thomann
and
Mueller,
1987)
analyzed
data
for
two
Houston
wastewater
treatment
plants
and
reported
a
mean
ratio
FC/
FS
of
12.8.

June
2004
4.
Method
for
Estimating
Costs
4­
2
estimated
that
facilities
may
need
treatment
controls
if
their
geometric
mean
FC
effluent
value
exceeds
126
colonies/
100
mL
(
the
E.
coli
geometric
mean
associated
with
a
risk
level
of
0.8%
of
swimmers
for
fresh
waters),
or
their
maximum
FC
effluent
value
exceeds
235
fecal
colonies/
100
mL
(
E.
coli
75th
percentile
value
associated
with
a
risk
level
of
0.8%
of
swimmers).
4
Coastal
Facilities
Enterococci
are
fecal
bacteria
that
belong
to
the
fecal
streptococcus
(
FS)
group.
Data
in
the
literature
indicate
that
the
ratio
of
FC
to
FS
(
FC/
FS)
in
untreated
sewage
ranges
from
about
4
to
28,
with
a
mean
of
5.1
(
i.
e.,
FC
levels
are
5.1
times
FS
levels).
5
With
respect
to
treatment
efficacy,
wastewater
characteristics
are
not
comparable
across
facilities:
the
literature
indicates
that
the
chlorine
dose
required
for
the
inactivation
of
bacteria
varies
significantly,
due
to
factors
such
as
the
presence
of
ammonia,
temperature,
pH,
type
of
chlorine
used,
and
the
life
history
of
microorganisms
(
WERF,
1995).
However,
EPA
does
not
have
influent
data
for
the
sample
facilities
to
determine
current
treatment
performance.
The
literature
indicates
that
at
chlorine
doses
of
4
mg/
L
[
i.
e.,
a
minimum
treatment
level
(
Metcalf
and
Eddy,
1991)]
and
8
mg/
L
(
which
represents
a
doubling
of
this
minimum
treatment
dose)
inactivation
of
FC
and
enterococci
would
be
much
greater
than
99.9%
(
U.
S.
EPA,
1996).
Therefore,
EPA
made
the
assumption
that
log
inactivations
for
FC
and
FS
at
these
doses
are
essentially
equal,
and
used
this
assumption
in
conjunction
with
the
most
conservative
(
i.
e.,
erring
on
the
side
of
overestimating
costs)
ratio
of
FC/
FS
to
estimate
the
FC
levels
at
which
facilities
would
need
treatment
to
comply
with
the
proposed
enterococci
criteria.

The
most
conservative
ratio
of
FC/
FS
in
raw
sewage
from
the
literature
is
about
4
[
Geldreich
(
1978,
as
cited
in
Thomann
and
Mueller,
1987)].
Assuming
that
log
inactivations
for
FC
and
FS
are
essentially
equal,
FC
levels
of
126
FC
per
100
mL
would
translate
to
enterococci
values
of
about
32
enterococci
per
100
mL
(
126
/
4
=
32,
which
is
less
than
the
health­
based
geometric
mean
criteria
for
enterococci
in
the
proposed
rule).
Therefore,
EPA
assumed
that
sample
facilities
treating
to
a
level
of
126
FC
per
100
mL
will
achieve
the
proposed
geometric
mean
criteria
of
35
enterococci
per
100
mL.
In
addition,
to
be
conservative
(
i.
e.,
err
on
the
side
of
overestimating
costs),
EPA
made
the
same
assumption
that
it
did
for
Great
Lakes
facilities
regarding
SSM
values.
That
is,
EPA
assumed
that
coastal
facilities
with
maximum
FC
effluent
values
exceeding
235
colonies
per
100
mL
would
need
treatment
controls
(
even
though
235
/
4
=
59,
which
is
more
stringent
than
the
SSM
value
of
104
in
the
proposed
rule).
6EPA
calculated
the
geometric
mean
from
all
the
average
monthly
values
in
PCS,
and
the
maximum
value
from
maximum
daily
values
in
PCS,
when
available.
In
most
cases,
sample
facilities
with
maximum
values
that
exceed
the
SSM
criteria
(
i.
e.,
235
colonies/
100
mL)
also
have
average
monthly
values
that
exceed
the
geometric
mean
criteria
(
i.
e.,
126
colonies/
100
mL).

June
2004
4.
Method
for
Estimating
Costs
4­
3
For
both
Great
Lakes
and
coastal
sample
facilities,
EPA
considered
the
relative
magnitude
of
the
maximum
daily
and
average
monthly
values,
the
pattern
of
occurrence
of
such
values
(
e.
g.,
when
maximum
values
occurred),
and
current
treatment
performance
characteristics
(
e.
g.,
compliance
with
current
permit).
6
If
effluent
data
indicate
that
the
facility
would
not
achieve
potential
effluent
limits
based
on
the
proposed
criteria,
EPA
first
evaluated
whether
the
facility
is
in
compliance
with
its
current
bacteria
limits.
If
not,
EPA
assumed
that
the
facility
would
incur
costs
for
controls
to
meet
baseline
requirements
(
i.
e.,
current
limits).
EPA
estimated
that
only
minor
additional
adjustments
to
the
baseline
controls
would
be
necessary
to
comply
with
the
revised
effluent
limits
based
on
the
proposed
criteria.
For
those
facilities
that
comply
with
their
current
permit
limits
but
may
not
comply
with
limits
based
on
the
proposed
criteria,
EPA
estimated
the
controls
that
would
be
necessary.

4.2.2
Estimating
Most
Likely
Control
Scenario
In
estimating
the
type
of
controls
that
may
be
necessary
for
compliance
with
the
proposed
rule,
EPA
identified
facilities
currently
meeting
the
proposed
E.
coli
limits
(
one
from
Maine
and
one
from
New
Hampshire),
and
two
facilities
currently
meeting
the
proposed
marine
enterococci
limits
(
both
from
Delaware).
Exhibit
4­
2
summarizes
the
effluent
data
for
each
facility
from
EPA's
PCS
database.

Exhibit
4­
2.
Facilities
Currently
in
Compliance
with
EPA's
1986
Bacteria
Criteria
NPDES
No.
Facility
Name
Type
Effluent
Data
(#/
100
mL)
a
Average
Maximum
E.
coli
ME0100072
Brewer
WPCF
Major
29.6
200
NH0100145
Lancaster
WWTP
Minor
<
10b
149
Enterococci
DE0020338
Kent
County
WWTP
Major
3.4
9.3
DE0020036
Harrington
STP
Minor
2.3
6.2
Source:
U.
S.
EPA
(
2003a).
a.
Represents
the
last
three
years
of
effluent
data.
b.
90%
of
observations
are
<
10
colonies/
100
mL
The
Maine
and
New
Hampshire
facilities
use
sodium
hypochlorite
for
disinfection.
In
1998,
Brewer
WPCF
upgraded
its
chlorination
contact
tanks
under
a
consent
agreement
with
the
Maine
June
2004
4.
Method
for
Estimating
Costs
4­
4
Department
of
Environmental
Protection
to
prevent
further
permit
violations
of
their
E.
coli
criteria.
The
facility
expanded
the
capacity
of
the
chlorine
contact
tank
to
treat
a
greater
storm
water
flow,
and
to
increase
the
contact
time
for
greater
disinfection
efficiency.
The
facility
also
reconstructed
baffles
within
the
tank
to
provide
for
better
mixing
during
disinfection.
Following
the
upgrade,
the
facility
consistently
meets
its
E.
coli
permit
limits
of
64
colonies/
100
mL
as
a
geometric
mean
(
personal
communication
with
Ken
Lockland,
Brewer
WPCF,
2004).
The
Lancaster
WWTP
is
a
minor
facility
that
operates
a
typical
chlorination
process
designed
for
a
chlorine
residual
of
0.5
mg/
L.
The
plant
did
not
have
to
add
any
treatment
controls
for
compliance
with
their
E.
coli
limits
of
126
colonies/
100
mL
as
a
geometric
mean
(
personal
communication
with
Lancaster
WWTP
operator,
2004).

Both
of
the
Delaware
facilities
use
chlorine
gas
in
their
disinfection
processes.
The
Kent
County
WWTP
chlorination
process
is
designed
for
a
residual
chlorine
concentration
of
1.0
­
2.0
mg/
L,
and
an
average
contact
time
of
20
to
25
minutes.
The
facility
also
conducts
bi­
hourly
sampling
to
ensure
proper
operation
of
the
disinfection
process
(
personal
communication
with
Ken
Gladen,
Kent
County
WWTP,
2004).
The
Harrington
STP
chlorination
process
is
designed
for
a
residual
chlorine
concentration
of
0.5
mg/
L,
and
an
average
contact
time
of
35
to
40
minutes
(
personal
communication
with
Harrington
STP
operator,
2004).
Neither
facility
implemented
treatment
controls
to
comply
with
their
enterococci
limits
of
33
colonies/
100
mL
as
a
geometric
mean.

These
experiences
suggest
that
chlorination
processes
can
be
upgraded
or
adjusted
to
produce
the
levels
of
bacteria
necessary
for
compliance
with
the
proposed
rule.
Therefore,
EPA
estimated
that
optimization
of
existing
disinfection
processes
would
enable
the
sample
facilities
to
comply
with
the
proposed
rule.
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
to
increase
or
improve
contact
time
efficiency),
increasing
contact
time
(
e.
g.,
adding
a
contact
basin),
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
biochemical
oxygen
demand,
total
suspended
solids,
and
flow).
June
2004
4.
Method
for
Estimating
Costs
4­
5
4.3
Estimating
the
Cost
of
Controls
EPA
estimated
the
cost
of
process
optimization
using
available
estimates
from
the
literature,
and
based
sample
facility
costs
on
the
potential
reductions
needed
at
each
facility.
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,
on
average,
facilities
are
operating
at
a
minimal
treatment
level
[
e.
g.,
4
mg/
L
chlorine
dose,
15
minute
average
contact
time,
poor
mixing,
cleaning
once
every
two
years
(
Metcalf
and
Eddy,
1991)].
EPA
also
assumed
that
process
modifications,
such
as
increasing
contact
time
and
chlorine
dose,
would
not
result
in
exceedances
for
other
pollutants.

EPA
estimated
process
analysis
costs
assuming
a
five
week
analysis
of
the
facility's
treatment
processes.
Therefore,
EPA
included
the
labor
and
benefits
costs
associated
with
five
full
time
weeks
of
monitoring
the
wastewater
at
different
stages
throughout
the
treatment
plant,
and
determining
the
process
modifications
necessary.
EPA
used
a
national
average
labor
rate
of
$
43
for
a
civil
engineer,
which
includes
employer
benefits
(
BLS,
2002).
Thus,
EPA
assumed
that
process
analysis
costs
of
$
8,600
would
be
incurred
(
200
hours
×
$
43/
hour),
and
annualized
these
capital
costs
at
7%
over
20
years.

EPA
estimated
costs
for
process
modification
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
time.
EPA
calculated
these
costs
for
the
sample
facilities
based
on
average
flows.

In
modifying
their
chlorination
process,
EPA
assumed
that
facilities
would
increase
their
chlorine
dose
to
8
mg/
L
(
Metcalf
and
Eddy,
1991).
To
calculate
the
additional
amount
of
chlorine
needed
in
pounds
per
year,
EPA
multiplied
the
difference
in
dose,
4
mg/
L
(
8
mg/
L­
4
mg/
L=
4
mg/
L),
by
the
average
flow
in
mgd,
number
of
days
in
a
year
(
365),
and
a
conversion
factor
(
8.34
to
convert
from
mg/
L
to
lbs/
million
gallons).
EPA
assumed
that
facilities
using
more
than
8,000
lbs/
year
of
chlorine
would
use
1­
ton
cylinders
of
chlorine,
and
facilities
using
less
than
8,000
lbs/
year
would
use
150­
lb
cylinders
of
chlorine.
EPA
also
included
storage
space
for
the
additional
chlorine
needed.
To
calculate
the
storage
area,
EPA
estimated
that
a
large
cylinder
would
have
an
area
of
150
square
feet,
and
a
small
cylinder
would
have
an
area
of
50
square
feet.
EPA
calculated
the
additional
number
of
cylinders
that
would
need
to
be
stored
in
a
given
time
period
(
e.
g.,
per
week,
per
month,
or
per
quarter),
and
multiplied
the
additional
number
of
cylinders
by
the
area
of
the
cylinder.

As
another
component
of
modifying
their
chlorination
process,
EPA
assumed
that
facilities
would
need
to
clean
their
contact
basins
twice
per
year,
instead
of
once
every
two
years.
Based
on
WERF
(
1995),
EPA
assumed
that
facilities
over
20
mgd
would
require
6
labor
hours
per
mgd,
and
facilities
less
than
or
equal
to
20
mgd
would
require
15
labor
hours
per
mgd.
However,
based
on
best
professional
judgement,
EPA
also
assumed
that
cleaning
would
not
take
more
than
400
7EPA
assumed
an
effluent
monitoring
frequency
of
once
a
week,
and
an
average
cost
of
$
50
per
sample
(
which
is
similar
to
the
cost
for
fecal
coliform
monitoring­­
see
Appendix
C),
which
results
in
an
annual
cost
of
$
2,600.

June
2004
4.
Method
for
Estimating
Costs
4­
6
Volume
CT
CT
Qavg
=
 
×
(
)
2
1
labor
hours
at
a
time
(
e.
g.,
4
employees
working
full
time
for
2.5
weeks).
Therefore,
EPA
included
the
labor
and
benefits
costs
associated
with
this
additional
maintenance.
EPA
used
a
national
average
labor
rate
of
about
$
29
for
a
water
and
liquid
waste
treatment
plant
and
system
operator,
which
includes
employer
benefits
(
BLS,
2002).

EPA
also
assumed
that
modifications
would
include
increasing
chlorine
contact
time
(
CT).
EPA
calculated
an
increase
in
CT
by
assuming
that
facilities
would
expand
the
size
of
their
contact
basin.
To
estimate
the
incremental
contact
basin
costs,
EPA
assumed
that
the
CT,
based
on
the
treating
the
average
flow,
would
increase
from
15
minutes
to
45
minutes
(
Metcalf
and
Eddy,
1991).
EPA
assumed
a
length
to
width
ratio
for
the
contact
basin
of
4,
a
depth
of
13
feet,
and
a
freeboard
of
3
feet.
Then,
EPA
used
the
following
equation
to
calculate
the
additional
basin
volume
necessary:

where,
CT
1
=
current
contact
time
(
15
min)
CT
2
=
projected
contact
time
(
45
min)
Q
avg
=
average
flow
(
ft3/
min).

Using
the
dimensions
of
the
basin
(
e.
g.,
width
to
length
ratio
of
4
feet
and
depth
of
13
feet),
EPA
calculated
the
additional
concrete
volume
need
for
the
basin,
assuming
a
wall
thickness
of
1
foot.

Finally,
EPA
assumed
that
modifications
to
facility
chlorination
processes
would
include
installing
baffles
to
improve
mixing
conditions.
To
estimate
the
cost
of
installing
baffles
in
the
contact
basin,
EPA
assumed
that
baffles
would
be
spaced
about
every
4
feet.
EPA
used
the
dimensions
of
the
basin
after
the
increase
in
contact
time,
minus
a
freeboard
of
3
feet,
to
calculate
the
surface
area
of
the
baffles.
For
example,
a
contact
basin
that
is
about
100
feet
wide
by
400
feet
long
and
13
feet
deep
would
need
about
24
baffles
[(
100/
4)­
1=
24].
The
surface
area
of
one
baffle
is
3,970
square
feet
[(
400­
3)
×
(
13­
3)
=
3,970].

The
estimated
process
modification
costs
include
both
capital
and
operation
and
maintenance
(
O&
M)
costs.
Exhibit
4­
3
summarizes
the
type
of
costs
associated
with
each
component,
and
the
source
of
the
cost
estimates.
Also,
to
be
conservative
(
i.
e.,
err
on
the
side
of
overestimating
costs),
EPA
included
incremental
effluent
monitoring
costs
for
E.
coli
(
Great
Lakes
facilities)
or
enterococci
(
coastal
facilities),
although
these
costs
may
actually
just
replace
previous
fecal
coliform
effluent
monitoring
costs.
7
June
2004
4.
Method
for
Estimating
Costs
4­
7
Exhibit
4­
3.
Process
Modification
Cost
Components
Modification
Capital
($
2004)
1
O&
M
($
2004)
1
Source
Increase
chlorine
dose
Additional
chlorine
storage
space:
$/
sq.
ft.
=
Area­
0.110548
×
$
132.16
Additional
chlorine:
$
1,300/
1­
ton
cylinder
$
300/
150­
lb
cylinder
AACE
(
2002);
Kuehne
Chemical
(
2002);
Roberts
Oxygen
(
2002)

Increase
maintenance
NA
Additional
labor
to
clean
basins:
$
29/
hour
BLS
(
2002)

Improve
mixing
Installation
of
baffles
in
chlorination
contact
basin:
$
38/
sq.
ft.
of
baffle
NA
Environetics
Inc
(
2003)

Increase
contact
time
Additional
contact
basins:
$
350/
cu.
yd.
of
concrete
NA
RS
Means
(
1998)

sq.
ft.
=
square
foot
cu.
yd.
=
cubic
yard
1.
Costs
escalated
to
2003
dollars
using
the
Engineering
New
Record
Construction
Cost
Index
and
the
Employment
Cost
Index.

4.4
Total
Annual
Costs
To
estimate
total
annual
costs,
EPA
summed
the
potential
costs
for
the
15
major
facilities
with
design
flows
greater
than
120
mgd.
For
facilities
with
flows
less
than
120
mgd,
EPA
extrapolated
the
results
for
the
sample
facilities.
To
extrapolate,
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.
June
2004
5.
Results
5­
1
5.
Results
This
section
presents
the
results
of
the
analysis,
and
describes
the
limitations
and
uncertainties
associated
with
these
results.

5.1
Total
Costs
Based
on
the
potential
costs
for
the
15
facilities
with
flows
greater
than
120
mgd,
and
extrapolating
costs
for
a
sample
of
60
facilities
to
the
remaining
835
facilities
potentially
affected
by
the
proposed
rule,
EPA
estimated
a
total
annual
cost
of
approximately
$
22
million
($
15
million
for
coastal
facilities,
and
$
7
million
for
Great
Lakes
facilities).
Exhibit
5­
1
provides
a
summary
of
the
costs.
Appendix
A
provides
additional
information
for
the
sample
facilities.
Appendix
B
provides
additional
detail
related
to
extrapolating
the
sample
facility
costs.

Exhibit
5­
1.
Potential
Costs
Attributable
to
the
Proposed
Rule
(
millions
of
$
2004)
1
Category
Annual
Costs
($/
yr)
2
Major
POTWs
>
120
mgd
Major
POTWs
<
120
mgd
Minor
POTWs
Minor
Others
Total
Coastal
Facilities
$
9,100,000
$
4,400,000
$
740,000
$
280,000
$
14,600,000
Great
Lakes
Facilities
$
3,200,000
$
3,800,000
$
280,000
$
60,000
$
7,300,000
Total
$
12,300,000
$
8,200,000
$
1,000,000
$
340,000
$
21,900,000
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.

5.2.
Limitations
of
the
Analysis
EPA's
estimate
is
subject
to
a
number
of
limitations
associated
with
uncertainties
regarding
how
States
and
Territories
will
implement
the
proposed
criteria,
facility
responses
to
potential
revised
permit
conditions,
and
the
data
available
for
the
analysis.
These
uncertainties
are
described
in
Exhibit
5­
2.
June
2004
5.
Results
5­
2
Exhibit
5­
2.
Limitations
of
the
Analysis
Limitation/
Assumption
Potential
Impact
on
Costs
Comment
EPA
estimated
costs
based
on
meeting
geometric
mean
E.
coli
and
enterococci
limits
of
126
colonies/
100
mL
and
35
colonies/
100
mL,
respectively,
and
maximum
mean
E.
coli
and
enterococci
limits
of
235
colonies/
100
mL
and
104
colonies/
100
mL,
respectively.

States
have
flexibility
in
implementing
standards,
and
the
actual
impact
on
facility
effluent
limits
is
unknown
(
e.
g.,
facilities
may
not
get
limits,
authorities
may
not
use
SSM
values
for
permitting).
Facilities
in
some
States
that
have
already
adopted
consistent
criteria
have
limits
for
E.
coli
and
enterococci,
while
facilities
in
other
States
do
not.
Also,
all
potentially
affected
facilities
may
not
discharge
to
bathing
beaches,
thus,
less
stringent
SSM
values
may
apply
to
the
waters.

EPA
used
effluent
FC
levels
as
a
surrogate
for
E.
coli
data,
and
assumed
that
100%
of
FCs
is
E.
coli.

The
ratio
of
FC
to
E.
coli
may
vary.

Costs
for
several
sample
facilities
are
based
on
exceedances
of
SSM
values,
and
not
geometric
means.

EPA
(
2000b)
states
that
the
intended
use
of
SSM
values
is
for
beach
monitoring,
and
not
permitting.
Facilities
may
not
need
to
implement
controls
if
they
are
already
in
compliance
with
the
geometric
mean
criteria.

EPA
did
not
have
specific
information
on
the
disinfection
process
(
e.
g.,
chlorine
dose,
volume
of
contact
basin,
frequency
of
maintenance)
at
the
sample
facilities.
Therefore,
EPA
used
"
one
size
fits
all"
estimates
for
process
optimization
costs.

Facilities
may
not
have
to
implement
all
of
the
modifications
EPA
estimated
costs
for
in
order
to
meet
limits
based
on
the
proposed
criteria.

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
E.
coli
or
enterococci.

The
universe
of
potentially
affected
facilities
includes
all
facilities
in
Puerto
Rico
and
Texas,
regardless
of
their
designated
use.

Coastal
recreation
waters
intensely
used
for
primary
contact
recreation
in
Puerto
Rico,
and
waters
not
designated
as
"
oyster
waters"
in
Texas
are
not
affected
by
the
proposed
rule.

PCS
does
not
contain
effluent
FC
data
or
limits
for
sample
facilities
in
Texas,
and
EPA
estimated
that
there
would
be
no
costs
incurred
by
these
facilities.
?
Data
may
or
may
not
indicate
that
controls
would
be
necessary,
but
there
is
presently
no
data
to
indicate
that
these
facilities
would
incur
compliance
costs.
Exhibit
5­
2.
Limitations
of
the
Analysis
Limitation/
Assumption
Potential
Impact
on
Costs
Comment
June
2004
5.
Results
5­
3
EPA
only
included
facilities
with
SIC
codes
in
PCS,
and
with
latitude
and
longitude
or
readily
identifiable
receiving
water
body
names
(
e.
g.,
Pacific
Ocean)
in
the
universe
of
potentially
affected
facilities.
?
Facilities
with
no
information
in
PCS
other
than
facility
name
and
NPDES
number,
or
inaccurate
latitude
and
longitude
data,
may
or
may
not
be
affected
by
the
proposed
rule.

EPA
based
estimates
of
the
need
for
treatment
control
for
enterococci
on
effluent
FC
levels.
?
The
relationship
between
FC
and
enterococci
is
not
well
understood.
To
be
conservative
(
i.
e.,
err
on
the
side
of
higher
costs),
EPA
compared
FC
levels
to
the
E.
coli
SSM
value
of
235
colonies/
100
mL.
[
Based
on
the
ratio
of
FC/
FS
of
4,
treatment
to
this
level
may
exceed
levels
needed
to
achieve
the
proposed
criteria
(
235
/
4
=
59,
which
is
more
stringent
than
104)].

EPA
used
the
SSM
values
in
the
proposed
rule.
?
The
use
of
site­
specific
data
to
develop
SSM
values
may
result
in
more
or
less
stringent
criteria.

Key:
+
=
Costs
are
potentially
overstated
­
=
Costs
are
potentially
understated
?
=
Impact
of
costs
is
unknown
June
2004
6.
References
6­
1
6.
References
American
Association
of
Cost
Engineers
(
AACE).
2002.
International
Parametric
Cost
Estimating
Model
for
Buildings.
Online
at
http://
www.
aacei.
org/
technical/
costmodels/
BuildingModel.
shtml#
MODEL
Bureau
of
Labor
Statistics
(
BLS).
2004.
Table
5.
Wages
and
Salaries
(
not
seasonally
adjusted):
Employment
Cost
Index
for
wages
and
salaries,
civilian
and
State
and
local
government
workers,
by
industry
and
occupational
group.
Online
at
http://
www.
bls.
gov/
news.
release/
eci.
t05.
htm.

Bureau
of
Labor
Statistics
(
BLS).
2002.
2001
Occupational
Employment
Survey
(
OES)
National
Occupational
Employment
and
Wage
Estimates.
Online
at
http://
www.
bls.
gov/
oes/
2001/
oes_
nat.
htm.

Engineering
New
Record.
2004.
Construction
Cost
Index.
Online
at
http://
enr.
construction.
com/
features/
conEco/
costIndexes/
constIndexHist.
asp.

Environetics
Inc.
2003.
Personal
communication
with
Mark
Pannell,
May
2003.

Kuehne
Chemical
Company.
2002.
Personal
communication,
June
2002.

Metcalf
and
Eddy.
1991.
Wastewater
Engineering:
Treatment,
Disposal,
and
Reuse.
Tata
McGraw
Hill:
New
York,
1991.

Roberts
Oxygen.
2002.
Personal
communication,
June
2002.

RS
Means.
1998.
Heavy
Construction
Cost
Data,
12th
Annual
Edition.

Thomann,
R.
and
J.
Mueller.
1987.
Principles
of
Surface
Water
Quality
Modeling
and
Control.
Harper
and
Row,
Publishers:
New
York.

U.
S.
EPA.
2003a.
Permit
Compliance
System
(
PCS)
Database.
Accessed
November
13,
2003.

U.
S.
EPA.
2003b.
Implementation
Guidance
for
Ambient
Water
Quality
Criteria
for
Bacteria
­
May
2002
Draft.
EPA­
823­
B­
02­
003.

U.
S.
EPA.
2001a.
Report
to
Congress:
Implementation
and
Enforcement
of
the
Combined
Sewer
Overflow
Control
Policy.
EPA
833­
R­
01­
003.
Online
at
http://
cfpub.
epa.
gov/
npdes/
cso/
cpolicy_
report.
cfm?
program_
id=
5.
June
2004
6.
References
6­
2
U.
S.
EPA.
2001b.
The
National
Costs
of
the
Total
Maximum
Daily
Load
Program
(
Draft
Report).
EPA
841­
D­
01­
003.
Online
at
http://
www.
epa.
gov/
owow/
tmdl/
coststudy/
coststudy.
pdf.

U.
S.
EPA.
2000.
Clean
Watersheds
Needs
Survey
2000
Report
to
Congress:
Chapter
4,
Sanitary
Sewer
Overflows.
Online
at
http://
www.
epa.
gov/
owm/
mtb/
cwns/
2000rtc/
cwns2000­
chapter­
4.
pdf.

U.
S.
EPA.
1996.
Ultraviolet
Light
Disinfection
Technology
in
Drinking
Water
Application
­
An
Overview.
Office
of
Water.
EPA811­
R­
96­
002.
September.

U.
S.
EPA.
1995.
Combined
Sewer
Overflows,
Guidance
for
Nine
Minimum
Controls.
EPA
832­
B­
95­
003.

U.
S.
EPA.
1992.
Regulatory
Impact
Analysis:
Management
Measures
Guidance
for
Nonpoint
Source
Controls
in
Coastal
Watershed
Areas.
Nonpoint
Source
Control
Branch,
OWOW,
Office
of
Water.

Water
Environment
Research
Foundation
(
WERF).
1995.
Comparison
of
UV
Irradiation
to
Chlorination:
Guidance
for
Achieving
Optimal
UV
Performance.
Project
91­
WWD­
1.
Appendices
Appendix
A.
Facility
Analyses
Appendix
B.
Total
Annual
Costs
Calculations
Appendix
C.
Potential
Sample
Analysis
Costs
Appendix
D.
Energy
Use
List
of
Acronyms
AWTP
Advanced
wastewater
treatment
plant
EPA
Environmental
Protection
Agency
FC
Fecal
coliform
kWh
Kilowatt
hour
MWRA
Massachusetts
Water
Resources
Authority
NAS
Naval
Air
Station
NEORSD
Northeast
Ohio
Regional
Sewer
District
NPDES
National
pollutant
discharge
elimination
system
O&
M
Operations
and
maintenance
PCS
Permit
compliance
system
SD
Sanitation
district
SIC
Standard
industrial
classification
STP
Sewage
treatment
plant
WLSSD
Western
Lake
Superior
Sanitation
District
WPCP
Water
pollution
control
plant
WTP
Water
treatment
plant
WWTF
Wastewater
treatment
facility
WWTP
Wastewater
treatment
plant
Appendix
A.
Facility
Analyses
June
2004
Appendix
A.
Facility
Analyses
A­
1
Appendix
A.
Facility
Analyses
This
appendix
provides
the
analyses
for
the
sample
facilities.
EPA
determined
the
need
for
treatment
controls
based
on
fecal
coliform
(
FC)
data
for
each
sample
facility.
EPA
calculated
the
geometric
mean
using
average
monthly
FC
values,
and
the
maximum
value
from
the
maximum
of
the
maximum
daily
values
in
the
Permit
Compliance
System
(
PCS),
except
where
otherwise
noted.

EPA
based
estimated
costs
for
each
sample
facility
on
average
flow.
EPA
calculated
the
average
flow
from
effluent
data
in
PCS
as
the
average
of
all
available
observations
(
e.
g.,
average
of
monthly
average
and
daily
maximum
values).
June
2004
Appendix
A.
Facility
Analyses
A­
2
Facility
Analyses:
Flows
>
120
mgd
Facility
name:
Back
River
WWTP
NPDES
permit
number:
MD0021555
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
180
mgd
Average
Flow:
111
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
1
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
February
2001
through
February
2004.

Exhibit
A­
1.
Effluent
Data
Summary,
Back
River
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
37
37
0
52
10
200
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
February
2001
to
February
2004.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
criteria
for
enterococci.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
3
Facility
name:
Bird
Island
WWTP
NPDES
permit
number:
NY0028410
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
180
mgd
Average
Flow:
Not
Available
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
2
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
2.
Effluent
Data
Summary,
Bird
Island
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
74
74
0
549
71
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
July
2000
to
July
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
for
FC
twice
(
549
and
457
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
3
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
the
size
of
the
contact
basin,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
4
Exhibit
A­
3.
Summary
of
Compliance
Costs,
Bird
Island
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
1,750,000
$
170,100
$
5,290,000
$
0
$
0
$
1,426,100
$
0
$
17,400
$
165,200
$
1,442,000
$
499,300
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
7,218,000
$
1,446,000
$
2,128,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
5
Facility
name:
Bowery
Bay
WWTP
NPDES
permit
number:
NY0026158
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
150
mgd
Average
Flow:
105
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
4
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2001
through
July
2003.

Exhibit
A­
4.
Effluent
Data
Summary,
Bowery
Bay
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
50
50
0
397
22
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2001
to
June
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
is
most
likely
in
compliance
with
its
current
permit
limits.
Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
5
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.

Exhibit
A­
5.
Summary
of
Compliance
Costs,
Bowery
Bay
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Exhibit
A­
5.
Summary
of
Compliance
Costs,
Bowery
Bay
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
June
2004
Appendix
A.
Facility
Analyses
A­
6
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
1,068,000
$
111,200
$
3,010,000
$
0
$
0
$
832,000
$
0
$
17,400
$
100,800
$
842,500
$
284,100
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
4,197,000
$
852,000
$
1,248,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
7
Facility
name:
Frank
E.
Van
Lare
WWTP
NPDES
permit
number:
NY0028339
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
135
mgd
Average
Flow:
91.6
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
6
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
6.
Effluent
Data
Summary,
Van
Lare
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
74
71
3
430
75
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
July
2000
to
July
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
for
FC
once
(
430
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
7
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
8
Exhibit
A­
7.
Summary
of
Compliance
Costs,
Van
Lare
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
938,000
$
88,500
$
2,584,000
$
0
$
0
$
720,200
$
0
$
17,400
$
88,500
$
728,600
$
243,900
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
3,619,000
$
740,200
$
1,082,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
9
Facility
name:
Hunt's
Point
WPC
NPDES
permit
number:
NY0026191
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
200
mgd
Average
Flow:
107
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
8
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
March
2001
through
July
2003.

Exhibit
A­
8.
Effluent
Data
Summary,
Hunt's
Point
WPC1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
58
58
0
486
42
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
March
2001
to
June
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
March
2001
to
June
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
for
FC
twice
(
486
and
462
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
9
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
10
Exhibit
A­
9.
Summary
of
Compliance
Costs,
Hunt's
Point
WPC
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
1,085,000
$
104,400
$
3,093,000
$
0
$
0
$
847,600
$
0
$
17,400
$
102,400
$
857,500
$
292,000
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
4,291,000
$
867,600
$
1,273,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
11
Facility
name:
King
County
WWTP
NPDES
permit
number:
WA0029181
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
174.5
mgd
Average
Flow:
118
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
10
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
March
2000
through
March
2003.

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

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
70
70
0
583
11.7
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
March
2000
to
March
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
March
2000
to
March
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
for
FC
once
(
583
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
11
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
12
Exhibit
A­
11.
Summary
of
Compliance
Costs,
King
County
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
1,187,000
$
119,700
$
3,409,000
$
0
$
0
$
934,700
$
0
$
17,400
$
112,000
$
946,000
$
321,800
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
4,723,000
$
954,700
$
1,401,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
13
Facility
name:
Miami­
Virginia
Key
WTP
NPDES
permit
number:
FL0024805
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
121
mgd
Average
Flow:
123
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
12
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
February
2001
through
February
2004.

Exhibit
A­
12.
Effluent
Data
Summary,
Miami­
Virginia
Key
WTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
68
68
0
2,000
1.3
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
February
2001
to
Febraury
2004
2.
Represents
the
maximum
of
maximum
daily
values.
This
value
is
an
outlier
because
99%
of
the
remaining
values
are
less
than
100
colonies/
100
mL.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
maximum
FC
value
from
February
2001
to
February
2004
of
2,000
colonies/
100
mL
is
likely
not
representative
of
the
discharge;
this
value
is
an
outlier
because
about
99%
of
the
remaining
values
are
less
than
100
colonies/
100
mL.
Therefore,
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria,
and
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
14
Facility
name:
MWRA
­
Deer
Island
WWTP
NPDES
permit
number:
MA0103284
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
436
mgd
Average
Flow:
458
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
13
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
February
2001
through
February
2004
for
outfall
S01.

Exhibit
A­
13.
Effluent
Data
Summary,
Deer
Island
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
72
72
0
15,597
28
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
February
2001
to
Febraury
2004.
Note,
EPA
did
not
evaluate
the
facility's
7
CSO
outfalls
(
see
Section
2
regarding
CSOs
in
the
body
of
report).
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
discharges
its
effluent
into
the
Massachusetts
Bay
through
a
deep
rock
tunnel
that
extends
9.5
miles
from
the
shore
of
the
island.
The
initial
dilution
of
the
effluent
is
about
100
to
1.
The
effluent
is
discharged
through
a
diffuser,
consisting
of
more
than
50
pipes
that
rise
to
the
seabed
over
the
last
6,600
feet
of
the
tunnel's
length.
Each
pipe
connects
to
a
diffuser
cap
which
splits
the
flow
into
several
streams,
each
issuing
from
a
small
port.
There
are
more
than
400
diffuser
ports
to
disperse
the
effluent
at
a
depth
of
100
feet.

The
outfall
is
supposed
to
ensure
minimum
impacts
from
pollutants,
such
as
bacteria
and
nutrients.
To
ensure
that
the
discharge
does
not
result
in
adverse
impacts
on
water
quality,
the
facility's
NPDES
permit
requires
the
facility
to
follow
a
contingency
plan
whenever
exceedances
of
effluent
or
downstream
criteria
occur.
This
plan
sets
threshold
values
for
bacteria,
as
well
as
various
other
pollutants.
Currently,
both
public
beaches
and
shellfish
beds
are
tested
regularly
for
pathogen
contamination.
The
Metropolitan
District
Commission
tests
swimming
areas,
and
posts
swimming
areas
as
unsafe
when
FC
counts
are
above
200
colonies/
100
mL.
Shellfish
beds
are
"
restricted"
when
fecal
coliform
counts
are
above
14
colonies/
100
mL,
and
prohibited
at
counts
June
2004
Appendix
A.
Facility
Analyses
A­
15
above
88
colonies/
100
mL.
When
shellfish
harvesting
is
restricted,
only
specially
licensed
shellfishers
may
harvest,
and
shellfish
must
be
purified
at
the
State­
run
depuration
plant
before
being
sold.
In
addition,
shellfish
cannot
be
sold
if
their
fecal
coliform
contamination
exceeds
the
disinfection
capabilities
of
the
purification
plant
(
MWRA,
2004).

When
these
thresholds
are
exceeded,
a
process
begins
to
confirm
the
threshold
exceedance,
determine
the
causes
and
significance
of
the
exceedance,
and,
if
the
suggested
changes
are
attributable
to
the
effluent
outfall,
to
identify
a
response.
The
first
response
to
any
threshold
exceedance
is
to
determine
whether
plant
operation
can
be
altered
to
reduce
the
discharge
of
the
relevant
pollutant.
The
facility
may
have
to
develop
a
response
plan
which
includes
a
schedule
for
implementing
actions
such
as
additional
monitoring,
further
adjustments
in
plant
operations,
or
undertaking
an
engineering
feasibility
study.
Where
the
response
could
include
enhanced
treatment,
MWRA
has
identified
feasible
technologies
that
could
be
implemented.
For
bacteria,
enhanced
treatment
includes
improvements
or
changes
to
the
disinfection
process
(
MWRA,
2004).

EPA
believes
that
the
treatment
requirements
specified
in
the
contingency
plan
for
fecal
coliform
exceedances
would
also
apply
for
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
These
treatment
requirements
(
i.
e.,
improvements
or
changes
to
the
disinfection
process)
would
be
similar
to
the
process
optimization
costs
described
in
Section
4
in
the
body
of
the
report,
and
would
ensure
compliance
with
the
proposed
rule.
Therefore,
EPA
believes
that
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
16
Facility
name:
Newtown
Creek
WPC
NPDES
permit
number:
NY0026204
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
310
mgd
Average
Flow:
230
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
14
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2001
through
July
2003.

Exhibit
A­
14.
Effluent
Data
Summary,
Newtown
Creek
WPC1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
48
48
0
618
15
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2001
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
July
2001
to
July
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
for
FC
twice
(
618
and
535
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
15
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
17
Exhibit
A­
15.
Summary
of
Compliance
Costs,
Newtown
Creek
WPC
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
2,226,000
$
214,700
$
6,772,000
$
0
$
0
$
1,846,000
$
0
$
17,400
$
210,100
$
1,866,000
$
639,200
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
9,221,000
$
1,866,000
$
2,736,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
18
Facility
name:
NEORSD,
Easterly
WWTP
NPDES
permit
number:
OH0024643
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
155
mgd
Average
Flow:
201
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
16
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
October
2000
through
October
2003.

Exhibit
A­
16.
Effluent
Data
Summary,
Easterly
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
36
36
0
1,225
29.3
1,000
2,000
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
October
2000
to
October
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
maximum
FC
value
from
October
2000
to
October
2003
of
1,225
colonies/
100
mL
is
likely
not
representative
of
the
discharge;
this
value
is
an
outlier
because
all
of
the
remaining
values
are
less
than
236
colonies/
100
mL.
Therefore,
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria,
and
would
only
incur
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
19
Facility
name:
Orange
County
SD
NPDES
permit
number:
CA0110604
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
232
mgd
Average
Flow:
254
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
20
Facility
name:
Owl's
Head
WPC
NPDES
permit
number:
NY0026166
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
120
mgd
Average
Flow:
101
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
17
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
September
2001
through
August
2003.

Exhibit
A­
17.
Effluent
Data
Summary,
Owl's
Head
WPC1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
48
48
0
633
61
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
September
2001
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
September
2001
to
August
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
for
FC
once
(
633
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
18
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
21
Exhibit
A­
18.
Summary
of
Compliance
Costs,
Owl's
Head
WPC
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
1,029,000
$
104,400
$
3,010,000
$
0
$
0
$
799,500
$
0
$
17,400
$
97,100
$
809,400
$
284,100
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
4,152,000
$
819,500
$
1,211,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
22
Facility
name:
Point
Loma
WWTP
NPDES
permit
number:
CA0107409
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
240
mgd
Average
Flow:
190
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
23
Facility
name:
Southeast
WWTP,
San
Francisco
NPDES
permit
number:
CA0037664
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
150
mgd
Average
Flow:
104
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
19
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
September
2002
through
February
2004.

Exhibit
A­
19.
Effluent
Data
Summary,
Southeast
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
51
46
5
1,300
16.9
500
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
September
2002
to
February
2004.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
September
2002
to
February
2004,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC.
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
20
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
24
Exhibit
A­
20.
Summary
of
Compliance
Costs,
Southeast
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
1,068,000
$
104,400
$
3,010,000
$
0
$
0
$
832,000
$
0
$
17,400
$
100,800
$
841,900
$
284,100
$
17,400
Monitoring
$
0
$
2,600
$
2,600
Total
$
4,190,000
$
852,000
$
1,248,000
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
25
Facility
name:
Ward
Island
WPC
NPDES
permit
number:
NY0026131
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
250
mgd
Average
Flow:
182
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
21
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2001
through
July
2003.

Exhibit
A­
21.
Effluent
Data
Summary,
Ward
Island
WPC1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
50
50
0
106
13.4
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2001
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
26
Facility
Analyses:
Major
Facilities,
Flows
<
120
mgd
Facility
name:
Aransas
Pass
WWTP
NPDES
permit
number:
TX0025682
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
2
mgd
Average
Flow:
1.1
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
27
Facility
name:
Bay
City
Military
WWTP
NPDES
permit
number:
FL0167959
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
7
mgd
Average
Flow:
3.4
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
22
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2000
through
August
2003.

Exhibit
A­
22.
Effluent
Data
Summary,
Bay
City
Military
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
40
40
0
45
3.2
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2000
to
August
2003.
Note,
EPA
did
not
include
zero
values.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
28
Facility
name:
Bayamon
WWTP
NPDES
permit
number:
PR0023728
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
25
mgd
Average
Flow:
46
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
23
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
March
2001
through
March
2004.

Exhibit
A­
23.
Effluent
Data
Summary,
Bayamon
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
34
24
10
695
9.5
2,000
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
March
2001
to
March
2004.
Note,
EPA
did
not
include
zero
values.
2.
Represents
the
maximum
of
average
monthly
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
maximum
FC
value
from
March
2001
to
March
2004
of
695
colonies/
100
mL
is
likely
not
representative
of
the
discharge;
this
value
is
an
outlier
because
about
97%
of
the
remaining
values
are
less
than
100
colonies/
100
mL.
Therefore,
the
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria,
and
would
only
incur
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
29
Facility
name:
Benicia
WWTP
NPDES
permit
number:
CA0038091
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
3
mgd
Average
Flow:
3.4
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
for
FC.
However,
the
current
average
monthly
fecal
coliform
limit
is
200
colonies/
100
mL
and
the
maximum
limit
is
400
colonies/
100
mL.

Controls
Needed
Although
FC
data
are
not
available
for
this
facility,
the
majority
of
total
coliform
values
from
January
1998
to
December
1999
are
less
than
the
proposed
enterococci
criteria,
indicating
that
the
facility
is
most
likely
achieving
low
levels
of
bacteria.
Therefore,
EPA
assumed
that
the
facility
would
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria,
and
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
30
Facility
name:
Boca
Raton
WWTP
NPDES
permit
number:
FL0167959
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
20
mgd
Average
Flow:
12.8
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
24
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2000
through
August
2003.

Exhibit
A­
24.
Effluent
Data
Summary,
Boca
Raton
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
74
74
0
139
4.7
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2000
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
31
Facility
name:
Broadway
WWTP
NPDES
permit
number:
TX0047066
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
10
mgd
Average
Flow:
7.4
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
32
Facility
name:
Brookings
WWTP
NPDES
permit
number:
OR0020354
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
1.3
mgd
Average
Flow:
1.3
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
25
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
25.
Effluent
Data
Summary,
Brookings
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
74
74
0
98
4.8
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
33
Facility
name:
Burlingame
WWTP
NPDES
permit
number:
CA0037788
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
6
mgd
Average
Flow:
5.3
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
for
FC.
However,
the
current
average
monthly
fecal
coliform
limit
is
23
colonies/
100
mL
and
the
maximum
limit
is
240
colonies/
100
mL.

Controls
Needed
Although
FC
data
are
not
available
for
this
facility,
compliance
with
the
current
FC
effluent
limits
would
most
likely
ensure
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
The
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
34
Facility
name:
Cedar
Creek
WPCP
NPDES
permit
number:
NY0026859
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
76
mgd
Average
Flow:
56
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
26
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2001
through
July
2003.

Exhibit
A­
26.
Effluent
Data
Summary,
Cedar
Creek
WPCP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
50
50
0
38
3.8
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2001
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
35
Facility
name:
Ceiba
WWTP
NPDES
permit
number:
PR0020419
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
0.8
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
27
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
March
2001
through
March
2004.

Exhibit
A­
27.
Effluent
Data
Summary,
Ceiba
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
70
46
24
8,000
11.1
2,000
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
March
2001
to
March
2004.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
March
2001
to
March
2004,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC.
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
28
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
36
Exhibit
A­
28.
Summary
of
Compliance
Costs,
Ceiba
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
24,500
$
21,000
$
11,400
$
0
$
0
$
6,500
$
0
$
600
$
2,300
$
8,500
$
1,100
$
600
Monitoring
$
0
$
2,600
$
2,600
Total
$
65,500
$
9,700
$
15,900
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
37
Facility
name:
Clearwater
East
WWTP
NPDES
permit
number:
FL0021865
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
4.3
mgd
Average
Flow:
2.6
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
29
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
June
2000
through
December
2002.

Exhibit
A­
29.
Effluent
Data
Summary,
Clearwater
East
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
46
46
0
100
2.5
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
June
2000
to
December
2002.
Note,
EPA
did
not
include
zero
values.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
38
Facility
name:
Edmonds
WWTP
NPDES
permit
number:
WA0024058
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
10
mgd
Average
Flow:
6.4
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
30
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
March
2000
through
March
2003.

Exhibit
A­
30.
Effluent
Data
Summary,
Edmonds
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
74
74
0
480
14.9
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
March
2000
to
March
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
March
2000
to
March
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
for
FC
once
(
480
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
31
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
39
Exhibit
A­
31.
Summary
of
Compliance
Costs,
Edmonds
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
101,500
$
39,000
$
171,000
$
0
$
0
$
50,700
$
0
$
4,100
$
9,600
$
54,400
$
16,100
$
4,100
Monitoring
$
0
$
2,600
$
2,600
Total
$
320,100
$
57,400
$
87,600
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
40
Facility
name:
Erie
County
SD#
2
WWTP
NPDES
permit
number:
NY0022543
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
4.5
mgd
Average
Flow:
4.9
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
32
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
32.
Effluent
Data
Summary,
Erie
County
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
82
74
8
140
4.6
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
41
Facility
name:
Fairhaven
WWTP
NPDES
permit
number:
MA0100765
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
5
mgd
Average
Flow:
2.6
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
33
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2000
through
August
2003.

Exhibit
A­
33.
Effluent
Data
Summary,
Fairhaven
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
44
44
0
320
91
88
260
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2000
to
August
2003.
Note,
EPA
did
not
include
zero
value.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
August
2000
to
August
2003,
the
facility
exceeded
its
current
average
monthly
limit
for
FC
50%
of
the
time,
and
exceeded
its
maximum
daily
limit
for
FC
twice
(
280
and
320
colonies/
100
mL).
Therefore,
the
facility
is
most
likely
not
in
compliance
with
its
current
permit
limits.
EPA
assumed
that
the
facility
would
implement
process
optimization
consisting
of
a
process
analysis
study,
moving
the
chlorination
point
(
and
increasing
chlorine
dose),
increasing
maintenance
frequency,
and
improve
mixing
conditions.
Once
in
compliance
with
its
current
permit
limits,
the
facility
should
also
be
able
to
meet
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
However,
EPA
included
enterococci
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
42
Facility
name:
Fairhope
WWTP
NPDES
permit
number:
AL0020842
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
4
mgd
Average
Flow:
1.6
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
34
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2000
through
August
2003.

Exhibit
A­
34.
Effluent
Data
Summary,
Fairhope
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
74
74
0
962
19
100
1,000
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2000
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
August
2000
to
August
2003,
the
facility
did
not
exceed
its
current
average
monthly
or
maximum
daily
limit
for
FC.
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
35
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
43
Exhibit
A­
35.
Summary
of
Compliance
Costs,
Fairhope
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
38,500
$
21,000
$
30,400
$
0
$
0
$
13,000
$
0
$
1,200
$
3,600
$
15,000
$
2,900
$
1,200
Monitoring
$
0
$
2,600
$
2,600
Total
$
98,500
$
16,800
$
26,100
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
44
Facility
name:
Flagler
Beach
WWTP
NPDES
permit
number:
FL0026611
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
1
mgd
Average
Flow:
0.65
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
36
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
May
2000
through
May
2003.

Exhibit
A­
36.
Effluent
Data
Summary,
Flagler
Beach
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
37
37
0
250
4.9
200
800
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
May
2000
to
May
2003.
Note,
EPA
did
not
use
the
average
monthly
values.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
From
May
2000
to
May
2003,
the
facility
did
not
exceed
its
current
average
monthly
or
maximum
daily
limit
for
FC.
Therefore,
the
facility
is
most
likely
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
37
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Because
relatively
small
reduction
may
be
needed,
costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume
and
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L).
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
45
Exhibit
A­
37.
Summary
of
Compliance
Costs,
Flagler
Beach
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
$
21,000
$
18,000
$
0
$
15,900
$
2,000
$
17,600
Monitoring
$
0
$
2,600
$
2,600
Total
$
47,600
$
18,500
$
23,000
Sources:
AACE
(
2002);
Kuehne
Chemicals
(
2002);
Robert
Oxygen
(
2002);
RS
Means
(
1998);
BLS
(
2002).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
46
Facility
name:
Howard
F.
Curren
AWTP
NPDES
permit
number:
FL0020940
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
96
mgd
Average
Flow:
53
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
38
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
38.
Effluent
Data
Summary,
Howard
Curren
AWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
18
18
0
5
1.5
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
2.
Represents
the
maximum
of
average
monthly
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
47
Facility
name:
Homer
WWTP
NPDES
permit
number:
AK0021245
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
0.88
mgd
Average
Flow:
0.65
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
39
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2000
through
August
2003.

Exhibit
A­
39.
Effluent
Data
Summary,
Homer
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
74
72
2
6,200
54
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2000
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
August
2000
to
August
2003,
the
facility
exceeded
its
current
average
monthly
limit
for
FC
6
times,
and
exceeded
its
maximum
daily
limit
for
FC
3
times.
Therefore,
the
facility
is
most
likely
not
in
compliance
with
its
current
permit
limits,
and
would
have
to
implement
controls
to
reduce
current
levels.
EPA
assumed
that
the
facility
would
implement
process
optimization
consisting
of
a
process
analysis
study,
increasing
contact
time,
increasing
chlorine
dose,
and
increasing
maintenance
frequency.

Once
in
compliance
with
its
current
permit
limits,
only
minor
chlorination
optimization
would
be
necessary
for
compliance
with
the
proposed
enterococci
criteria.
EPA
estimated
that
the
facility
would
improve
its
mixing
conditions
through
the
addition
of
baffles
in
its
chlorination
contact
chamber.
EPA
also
included
enterococci
monitoring
costs.
Exhibit
A­
40
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
June
2004
Appendix
A.
Facility
Analyses
A­
48
Exhibit
A­
40.
Summary
of
Compliance
Costs,
Homer
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Improve
Mixing
$
11,400
$
0
$
1,100
Monitoring
$
0
$
2,600
$
2,600
Total
$
11,400
$
2,600
$
3,700
Sources:
Environetics
Inc.
(
2003).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
49
Facility
name:
Honouliuli
WWTP
NPDES
permit
number:
HI0020877
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
25
mgd
Average
Flow:
26.5
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
41
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
January
2001
through
January
2004.

Exhibit
A­
41.
Effluent
Data
Summary,
Honouliuli
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
36
36
0
12,259,609
6,706,461
None
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
January
2001
to
January
2004.
2.
Represents
the
maximum
of
average
monthly
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility's
treatment
train
provides
primary
treatment
to
the
entire
effluent,
and
secondary
treatment
to
about
13
mgd
of
the
effluent.
The
facility
discharges
about
1.7
miles
out
into
the
Pacific
Ocean
at
a
depth
of
200
feet
through
a
multiple
port
diffuser,
1,750
feet
long,
with
two
4
inch
ports
every
24
feet.
The
City
of
Honolulu
requires
extensive
monitoring
of
the
receiving
waters
to
ensure
the
discharge
is
not
having
a
significant
impact.
If
enterococci
levels
along
the
beach,
within
300
meters
of
the
shore,
exceed
the
State's
criteria
of
7
colonies/
100
mL,
the
facility
will
chlorinate
the
effluent
prior
to
discharge
(
Malama
o
Manoa,
2004).
Receiving
water
data
from
1998
from
the
City
of
Honolulu
indicate
that
enterococci
levels
are
well
below
the
proposed
enterococci
criteria.
Therefore,
EPA
believes
that
the
treatment
requirements
and
sampling
procedures
would
also
apply
for
potential
permit
limits
based
on
the
proposed
enterococci
criteria,
and
that
only
monitoring
costs
(
approximately
$
2,600
per
year)
would
be
incurred
by
this
facility.
June
2004
Appendix
A.
Facility
Analyses
A­
50
Facility
name:
Huron
Basin
STP
NPDES
permit
number:
OH0020125
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
1.6
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
42
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
October
2000
through
October
2003.

Exhibit
A­
42.
Effluent
Data
Summary,
Huron
Basin
STP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
37
37
0
6,800
59
1,000
2,000
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
October
2000
to
October
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
October
2000
to
October
2003,
the
facility
did
not
exceed
its
current
average
monthly,
and
only
exceeded
the
maximum
daily
limit
for
FC
once.
Therefore,
the
facility
is
most
likely
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
43
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
51
Exhibit
A­
43.
Summary
of
Compliance
Costs,
Huron
Basin
STP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
38,500
$
21,000
$
30,400
$
0
$
0
$
13,000
$
0
$
1,200
$
3,600
$
15,000
$
2,900
$
1,200
Monitoring
$
0
$
2,600
$
2,600
Total
$
98,500
$
16,800
$
26,100
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
52
Facility
name:
Kenosha
WWTP
NPDES
permit
number:
WI0028703
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
28
mgd
Average
Flow:
26.9
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
44
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
January
2001
through
January
2004.

Exhibit
A­
44.
Effluent
Data
Summary,
Kenosha
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
51
51
0
930
27
400
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
January
2001
to
January
2004.
2.
Represents
the
maximum
of
average
monthly
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
January
2001
to
January
2004,
the
facility
did
not
exceed
its
current
average
monthly
effluent
limit
for
FC.
Therefore,
the
facility
is
most
likely
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
45
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
53
Exhibit
A­
45.
Summary
of
Compliance
Costs,
Kenosha
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
322,000
$
30,200
$
752,400
$
0
$
0
$
213,200
$
0
$
7,000
$
30,400
$
216,000
$
71,000
$
7,000
Monitoring
$
0
$
2,600
$
2,600
Total
$
1,113,000
$
222,800
$
327,900
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
54
Facility
name:
Kodiak
WWTP
NPDES
permit
number:
AK0021555
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
3.7
mgd
Average
Flow:
2.5
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
46
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
February
2001
through
February
2004.

Exhibit
A­
46.
Effluent
Data
Summary,
Kodiak
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
74
74
0
184,000
8,400
200,000
500,000
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
February
2001
to
February
2004.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility's
current
permit
establishes
a
mixing
zone
for
FCs
that
is
400
meters
by
3,200
meters.
The
size
of
the
mixing
zone
is
based
on
a
FC
modeling
study
that
took
into
account
stream
conditions
and
the
size
of
the
effluent.
The
permit
only
requires
that
the
facility
chlorinate
its
effluent
when
downstream
FC
levels,
at
the
edge
of
the
mixing
zone,
exceed
current
standards.
The
facility
is
located
on
the
side
of
a
cliff,
and
no
primary
contact
recreation
occurs,
only
occasional
boating
through
the
channel
(
Plant
Operator,
Kodiak
WWTP,
personal
communication,
2004).
Therefore,
EPA
believes
that
the
current
mixing
zone
and
sampling
procedures
would
also
apply
for
potential
permit
limits
based
on
the
proposed
enterococci
criteria,
and
that
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
55
Facility
name:
Monterey
Regional
WWTP
NPDES
permit
number:
CA0048551
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
30
mgd
Average
Flow:
14.8
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
47
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
November
2002
through
July
2003.

Exhibit
A­
47.
Effluent
Data
Summary,
Monterey
Regional
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
11
11
0
100
5.3
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
November
2002
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
56
Facility
name:
Naples
WWTP
NPDES
permit
number:
FL0026271
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
10
mgd
Average
Flow:
1.9
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
48
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
48.
Effluent
Data
Summary,
Naples
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
10
9
1
52
4.9
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
Note
EPA
did
not
include
zero
values.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
57
Facility
name:
Naval
Air
Station
Pensacola
STP
NPDES
permit
number:
FL0002500
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
2.35
mgd
Average
Flow:
1.7
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
49
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2000
through
August
2003.

Exhibit
A­
49.
Effluent
Data
Summary,
NAS
Pensacola
STP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
31
30
1
59
8.6
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2000
to
August
2003.
Note,
EPA
did
not
include
zero
values.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
58
Facility
name:
Newport
WWTP
NPDES
permit
number:
RI0100293
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
11
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
50
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
September
2000
through
September
2003.

Exhibit
A­
50.
Effluent
Data
Summary,
Newport
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
74
74
0
16,000
95
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
September
2000
to
September
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
September
2000
to
September
2003,
the
facility
exceeded
its
current
average
monthly
limit
for
FC
3
times
(
227,
247,
and
1,232
colonies/
100
mL),
and
exceeded
its
maximum
daily
limit
for
FC
22%
of
the
time.
Therefore,
the
facility
is
most
likely
not
in
compliance
with
its
current
permit
limits,
and
would
have
to
implement
controls
to
reduce
current
levels.
EPA
assumed
that
the
facility
would
implement
process
optimization
consisting
of
a
process
analysis
study,
increasing
contact
time,
increasing
chlorine
dose,
and
increasing
maintenance
frequency.

Once
in
compliance
with
its
current
permit
limits,
only
minor
chlorination
optimization
would
be
necessary
for
compliance
with
the
proposed
enterococci
criteria.
EPA
estimated
that
the
facility
would
improve
its
mixing
conditions
through
the
addition
of
baffles
in
its
chlorination
contact
chamber.
EPA
also
included
enterococci
monitoring
costs.
Exhibit
A­
51
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
June
2004
Appendix
A.
Facility
Analyses
A­
59
Exhibit
A­
51.
Summary
of
Compliance
Costs,
Newport
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Improve
Mixing
$
273,600
$
0
$
25,800
Monitoring
$
0
$
2,600
$
2,600
Total
$
273,600
$
2,600
$
28,400
Sources:
Environetics
Inc.
(
2003).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
60
Facility
name:
Nueces
County
WWTP
NPDES
permit
number:
TX0091031
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
1
mgd
Average
Flow:
Not
Available
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.
Also,
flow
data
in
PCS
indicate
that
from
January
1998
to
January
2004
the
facility
did
not
discharge.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
61
Facility
name:
Ocean
City
WWTP
NPDES
permit
number:
MD0020044
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
14
mgd
Average
Flow:
5.4
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
52
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
February
2001
through
February
2004.

Exhibit
A­
52.
Effluent
Data
Summary,
Ocean
City
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
37
16
21
8
3.6
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
February
2001
to
February
2004.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
62
Facility
name:
Painesville
WWTP
NPDES
permit
number:
OH0026948
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
6
mgd
Average
Flow:
3.9
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
53
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
October
2000
through
October
2003.

Exhibit
A­
53.
Effluent
Data
Summary,
Painesville
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
38
38
0
854
5.3
1,000
2,000
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
October
2000
to
October
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
October
2000
to
October
2003,
the
facility
did
not
exceed
its
current
average
monthly
or
maximum
daily
effluent
limit
for
FC.
Therefore,
the
facility
is
most
likely
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
54
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
63
Exhibit
A­
54.
Summary
of
Compliance
Costs,
Painesville
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
70,000
$
55,800
$
79,800
$
0
$
0
$
31,200
$
0
$
2,600
$
6,600
$
36,500
$
7,500
$
2,600
Monitoring
$
0
$
2,600
$
2,600
Total
$
214,200
$
36,400
$
56,600
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
64
Facility
name:
Panama
City,
St
Andrew
WWTP
NPDES
permit
number:
MA0100765
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
5
mgd
Average
Flow:
2.6
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
55
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
June
2000
through
June
2003.

Exhibit
A­
55.
Effluent
Data
Summary,
St.
Andrew
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
38
38
0
890
7.7
14
43
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
June
2000
to
June
2003.
2.
Represents
the
maximum
of
average
monthly
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
June
2000
to
June
2003,
the
facility
exceeded
its
current
average
monthly
limit
for
FC
about
30%
of
the
time,
and
exceeded
its
maximum
daily
limit
for
FC
5
times.
Therefore,
the
facility
is
most
likely
not
in
compliance
with
its
current
permit
limits.
EPA
assumed
that
the
facility
would
implement
process
optimization
consisting
of
a
process
analysis
study,
increasing
contact
time,
increasing
chlorine
dose,
increasing
maintenance
frequency,
and
improve
mixing
conditions.
Once
in
compliance
with
its
current
permit
limits,
the
facility
should
also
be
able
to
meet
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
The
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
65
Facility
name:
Pascagoula
WWTP
NPDES
permit
number:
MS0020249
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
10
mgd
Average
Flow:
5.1
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
56
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2001
through
August
2003.

Exhibit
A­
56.
Effluent
Data
Summary,
Pascagoula
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
24
24
0
122
33
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2001
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
66
Facility
name:
Pawsley
WWTP
NPDES
permit
number:
SC0039951
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
1.6
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
57
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
57.
Effluent
Data
Summary,
Pawsley
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
74
68
6
232
1.8
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
Note
EPA
did
not
include
zero
values
in
PCS
as
observations.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
67
Facility
name:
Pismo
Beach
WWTP
NPDES
permit
number:
CA0048151
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
2
mgd
Average
Flow:
1.1
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
58
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
February
2000
through
May
2004.

Exhibit
A­
58.
Effluent
Data
Summary,
Pismo
Beach
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
12
12
0
>
1,600
135
100
200
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
February
2000
to
May
2004.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
February
2000
to
May
2004,
the
facility
exceeded
its
current
average
monthly
limit
for
FC
about
17%
of
the
time,
and
exceeded
its
maximum
daily
limit
for
FC
50%
of
the
time.
Therefore,
the
facility
is
most
likely
not
in
compliance
with
its
current
permit
limits.
EPA
assumed
that
the
facility
would
implement
process
optimization
consisting
of
a
process
analysis
study,
increasing
contact
time,
increasing
chlorine
dose,
increasing
maintenance
frequency,
and
improve
mixing
conditions.
Once
in
compliance
with
its
current
permit
limits,
the
facility
should
also
be
able
to
meet
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
The
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
68
Facility
name:
Port
Clinton
WWTP
NPDES
permit
number:
OH0052876
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
2
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
59
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
October
2000
through
October
2003.

Exhibit
A­
59.
Effluent
Data
Summary,
Port
Clinton
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
38
38
0
3,440
114
1,000
2,000
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
October
2000
to
October
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
October
2000
to
October
2003,
the
facility
did
not
exceed
its
current
average
monthly
effluent
limit
for
FC,
and
only
exceeded
the
maximum
daily
FC
limit
twice.
Therefore,
the
facility
is
most
likely
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
60
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
69
Exhibit
A­
60.
Summary
of
Compliance
Costs,
Port
Clinton
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
45,500
$
30,200
$
38,000
$
0
$
0
$
15,600
$
0
$
1,500
$
4,300
$
18,400
$
3,600
$
1,500
Monitoring
$
0
$
2,600
$
2,600
Total
$
122,300
$
19,700
$
31,200
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
70
Facility
name:
Port
Washington
WPCP
NPDES
permit
number:
NY0026778
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
4
mgd
Average
Flow:
2.8
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
61
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2001
through
July
2003.

Exhibit
A­
61.
Effluent
Data
Summary,
Port
Washington
WPCP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
48
38
10
500
8.4
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2001
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
July
2001
to
July
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
once
(
500
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
62
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
71
Exhibit
A­
62.
Summary
of
Compliance
Costs,
Port
Washington
WPCP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
56,000
$
11,400
$
68,400
$
0
$
0
$
23,400
$
0
$
2,000
$
5,300
$
24,500
$
6,500
$
2,000
Monitoring
$
0
$
2,600
$
2,600
Total
$
144,400
$
28,000
$
41,600
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
72
Facility
name:
San
Mateo
WPCP
NPDES
permit
number:
CA0037541
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
14
mgd
Average
Flow:
13
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
for
FC.
However,
the
current
average
monthly
fecal
coliform
limit
is
23
colonies/
100
mL
and
the
maximum
limit
is
240
colonies/
100
mL.

Controls
Needed
Although
FC
data
are
not
available
for
this
facility,
compliance
with
current
FC
effluent
limits
would
most
likely
ensure
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
73
Facility
name:
Seabrook
WWTP
NPDES
permit
number:
TX0022250
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
3
mgd
Average
Flow:
2.25
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
74
Facility
name:
Shelton
WWTP
NPDES
permit
number:
WA0023345
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
4.02
mgd
Average
Flow:
2.1
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
63
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
63.
Effluent
Data
Summary,
Shelton
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
68
62
6
50
1.1
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
75
Facility
name:
Slidell
WWTP
NPDES
permit
number:
LA0047180
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
6
mgd
Average
Flow:
5.3
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
64
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
November
2001
through
August
2003.

Exhibit
A­
64.
Effluent
Data
Summary,
Slidell
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
44
44
0
165
38
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
November
2001
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
76
Facility
name:
Silver
Creek
WWTP
NPDES
permit
number:
NY0022411
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
0.75
mgd
Average
Flow:
0.6
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
65
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2001
through
August
2003.

Exhibit
A­
65.
Effluent
Data
Summary,
Silver
Creek
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
50
50
0
80
9.0
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2001
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
77
Facility
name:
Sturgeon
Bay
Utilities
NPDES
permit
number:
WI0021113
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
3
mgd
Average
Flow:
1.6
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
66
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
October
2000
through
October
2003.

Exhibit
A­
66.
Effluent
Data
Summary,
Sturgeon
Bay
Utilities1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
38
38
0
960
55
400
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
October
2000
to
October
2003.
Note,
EPA
did
not
use
zero
values.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
October
2000
to
October
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC.
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
67
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
78
Exhibit
A­
67.
Summary
of
Compliance
Costs,
Sturgeon
Bay
Utilities
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
38,500
$
21,000
$
30,400
$
0
$
0
$
13,000
$
0
$
1,200
$
3,600
$
15,000
$
2,900
$
1,200
Monitoring
$
0
$
2,600
$
2,600
Total
$
98,500
$
16,800
$
26,100
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
79
Facility
name:
Suffolk
County
SD#
3
WWTP
NPDES
permit
number:
NY01048091
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
30
mgd
Average
Flow:
22
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
68
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
July
2000
through
July
2003.

Exhibit
A­
68.
Effluent
Data
Summary,
Suffolk
County
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
74
74
0
>
1,758
28
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
July
2000
to
July
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
maximum
FC
value
from
July
2000
to
July
2003
of
>
1,758
colonies/
100
mL
is
likely
not
representative
of
the
discharge;
this
value
is
an
outlier
because
about
95%
of
the
remaining
values
are
less
than
100
colonies/
100
mL.
Therefore,
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria,
and
would
only
incur
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
80
Facility
name:
Tacoma
WWTP
NPDES
permit
number:
WA0037087
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
28
mgd
Average
Flow:
23
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
69
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
March
2000
through
March
2003.

Exhibit
A­
69.
Effluent
Data
Summary,
Tacoma
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
76
76
0
381
40
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
March
2000
to
March
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
March
2000
to
March
2003,
the
facility
does
not
exceed
its
current
average
monthly
or
maximum
daily
limit
for
FC.
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
70
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
81
Exhibit
A­
70.
Summary
of
Compliance
Costs,
Tacoma
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
283,500
$
21,000
$
646,000
$
0
$
0
$
183,300
$
0
$
6,100
$
26,800
$
185,300
$
61,000
$
6,100
Monitoring
$
0
$
2,600
$
2,600
Total
$
959,100
$
192,000
$
282,500
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
82
Facility
name:
Washington
WWTP
NPDES
permit
number:
NC0020648
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
3.2
mgd
Average
Flow:
2.1
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
71
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
August
2000
through
August
2003.

Exhibit
A­
71.
Effluent
Data
Summary,
Washington
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
72
72
0
900
1.5
200
400
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
August
2000
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
August
2000
to
August
2003,
the
facility
did
not
exceed
its
current
average
monthly
limit
for
FC,
and
only
exceeded
its
maximum
daily
limit
once
(
900
colonies/
100
mL).
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Exhibit
A­
72
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
the
chlorine
dose
(
estimated
from
4
mg/
L
to
8
mg/
L),
improving
mixing
conditions
through
the
addition
of
baffles,
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.
EPA
also
included
enterococci
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
83
Exhibit
A­
72.
Summary
of
Compliance
Costs,
Washington
WWTP
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
Increase
Maintenance
$
63,000
$
11,400
$
68,400
$
0
$
0
$
24,700
$
0
$
2,000
$
5,900
$
25,800
$
6,500
$
2,000
Monitoring
$
0
$
2,600
$
2,600
Total
$
151,400
$
29,300
$
43,600
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
84
Facility
name:
West
Long
Beach
STP
NPDES
permit
number:
NY0023523
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
1.5
mgd
Average
Flow:
0.57
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
73
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
November
2000
through
August
2003.

Exhibit
A­
73.
Effluent
Data
Summary,
West
Long
Beach
STP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
68
13
55
33
2.8
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
November
2000
to
August
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
85
Facility
name:
Western
Lake
Superior
Sanitary
District
(
WLSSD)
NPDES
permit
number:
MN0049786
Major/
minor:
Major
Facility
Type:
Municipal
Design
Flow:
43.6
mgd
Average
Flow:
40
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
74
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
April
2001
through
February
2004.

Exhibit
A­
74.
Effluent
Data
Summary,
WLSSD1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
30
30
0
8,003
1,685
None
None
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
April
2001
to
February
2004.
2.
Represents
the
maximum
of
average
monthly
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
does
not
currently
have
effluent
limits
for
FC
that
apply
end­
of­
pipe.
In
the
early
1990s,
the
facility
was
using
between
25
mg/
L
to
30
mg/
L
of
chlorine,
and
was
still
not
able
to
meet
an
effluent
limit
of
200
colonies/
100
mL.
This
was
due
to
the
fact
that
over
half
of
the
facility's
influent
is
from
pulp
and
paper
mills
and
the
turbidity
and
color
of
the
influent
water
prevented
high
bacteria
inactivation
and
resulted
in
the
formation
of
high
levels
of
harmful
chlorinated
organics
(
Joe
Stepun,
WLSSD,
personal
communication,
April
2004).
Pulp
and
paper
processes
produce
wastes
that
are
highly
colored
and
contain
compounds
that
are
not
oxidized
during
their
pure
oxygen
activated
sludge
process.
These
compounds
react
with
chlorine
to
form
disinfection
byproducts
and
prevent
adequate
bacteria
inactivation
(
Joe
Stepun,
WLSSD,
personal
communication,
April
2004).
Therefore,
the
facility
applied
for,
and
was
granted,
a
variance
that
exempt
the
facility
from
chlorinating
due
to
the
high
levels
of
chlorinated
organics
in
their
effluent.

The
variance
requires
the
facility
to
monitor
for
FC
downstream
of
its
discharge,
at
the
edge
of
the
mixing
zone,
and
chlorinate
the
effluent
whenever
the
downstream
levels
exceed
a
geometric
June
2004
Appendix
A.
Facility
Analyses
A­
86
mean
of
200
colonies/
100
mL.
The
facility
currently
chlorinates
about
20
days
a
year
at
a
dose
of
about
15
mg/
L.
EPA
assumed
that
the
facility
would
most
likely
apply
for
another
variance
for
the
proposed
E.
coli
criteria
because
a
feasible
alternative
disinfection
method
has
not
yet
been
identified.
However,
EPA
estimated
that
the
facility
would
also
need
to
increase
the
frequency
of
chlorination
in
order
to
maintain
low
E.
coli
levels
at
the
edge
of
its
mixing
zone.
Exhibit
A­
75
summarizes
these
costs.
Costs
include
increasing
the
frequency
of
chlorination
from
20
times
per
year
to
40
times
per
year
(
about
twice
as
many).
Note,
the
facility
currently
uses
55­
ton
rail
cars
to
house
chlorine
and
only
replaces
the
rail
car
once
empty.
Therefore,
additional
storage
space
of
the
increase
in
chlorination
frequency
would
not
be
necessary.
EPA
also
included
E.
coli
monitoring
costs.

Exhibit
A­
75.
Summary
of
Compliance
Costs,
WLSSD
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Increase
chlorination
frequency
$
0
$
72,800
$
72,800
Monitoring
$
0
$
2,600
$
2,600
Total
$
0
$
75,400
$
75,400
Sources:
Kuehne
Chemicals
(
2002).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
87
Facility
Analyses
­
Minor
Facilities
Facility
name:
Brennan
Beach
Campground
NPDES
permit
number:
NY0216321
Major/
minor:
Minor
Facility
Type:
Other
Design
Flow:
0.032
mgd
Average
Flow:
0.023
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
76
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
October
2000
through
October
2003.

Exhibit
A­
76.
Effluent
Data
Summary,
Brennan
Beach
Campground1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
32
19
13
1,200
3.5
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
October
2000
to
October
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
maximum
daily
values.

Controls
Needed
The
maximum
FC
value
from
October
2000
to
October
2003
of
1,200
colonies/
100
mL
is
likely
not
representative
of
the
discharge;
this
value
is
an
outlier
because
about
95%
of
the
remaining
values
are
less
than
25
colonies/
100
mL.
Therefore,
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria,
and
would
only
incur
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
88
Facility
name:
Elysian
Beach
Resort
NPDES
permit
number:
VI0040321
Major/
minor:
Minor
Facility
Type:
Other
Design
Flow:
0.89
mgd
Average
Flow:
0.023
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
89
Facility
name:
Green
Cove
Condominiums
NPDES
permit
number:
OH0095575
Major/
minor:
Minor
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
0.04
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
77
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
June
2002
through
October
2003.

Exhibit
A­
77.
Effluent
Data
Summary,
Green
Cove1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)
Current
Limit
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Average
Maximum
Fecal
Coliform
18
18
0
5,000
118
1,000
2,000
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
June
2002
to
October
2003.
2.
Represents
the
maximum
of
maximum
daily
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
From
June
2002
to
October
2003,
the
facility
exceeded
its
current
average
monthly
and
maximum
daily
limits
for
FC
only
once.
Therefore,
EPA
assumed
that
the
facility
is
in
compliance
with
its
current
permit
limits.

Based
on
the
effluent
FC
levels,
EPA
estimated
that
the
facility
would
have
to
optimize
its
chlorination
process
for
compliance
with
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Exhibit
A­
78
summarizes
the
potential
control
costs
associated
with
the
proposed
rule.
Costs
include
process
analysis
to
determine
the
cause
of
the
exceedances,
and
process
modifications
including
increasing
contact
time
by
increasing
contact
basin
volume,
increasing
chlorine
dose,
and
improving
mixing
conditions
through
the
addition
of
baffles.
(
Note
that
costs
for
increasing
maintenance
frequency
are
essentially
zero
due
to
the
relatively
small
flow
of
the
facility.)
EPA
also
included
E.
coli
monitoring
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
90
Exhibit
A­
78.
Summary
of
Compliance
Costs,
Green
Cove
Cost
Component
Capital
Costs
O&
M
Costs
Total
Annual
Costs1
Process
Analysis
$
8,600
$
0
$
810
Process
Modifications:
Increase
Contact
Time
Increase
Chlorine
Dose
Improve
Mixing
$
3,500
$
11,400
$
1,100
$
0
$
900
$
0
$
330
$
2,000
$
100
Monitoring
$
0
$
2,600
$
2,600
Total
$
24,600
$
3,500
$
5,800
Sources:
AACE
(
2002);
Environetics
Inc.
(
2003);
Kuehne
Chemicals
(
2002);
Robert
Oxygen
(
2002);
RS
Means
(
1998);
BLS
(
2002);
WERF
(
1995).
1.
Capital
costs
annualized
at
7%
over
20
years
plus
O&
M
costs.
June
2004
Appendix
A.
Facility
Analyses
A­
91
Facility
name:
Henry
T.
Wing
School
NPDES
permit
number:
MA0101656
Major/
minor:
Minor
Facility
Type:
Other
Design
Flow:
0.015
mgd
Average
Flow:
0.003
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
for
FC.
However,
the
current
average
monthly
fecal
coliform
limit
is
14
colonies/
100
mL
and
the
maximum
limit
is
43
colonies/
100
mL.

Controls
Needed
Although
FC
data
are
not
available
for
this
facility,
compliance
with
current
FC
effluent
limits
would
most
likely
ensure
compliance
with
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
92
Facility
name:
Kaufer­
Hubert
Memorial
Park
WWTP
NPDES
permit
number:
TX0102857
Major/
minor:
Minor
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
0.006
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
93
Facility
name:
Kingsport,
St
Tammany
WWTP
NPDES
permit
number:
LA0049794
Major/
minor:
Minor
Facility
Type:
Municipal
Design
Flow:
0.89
mgd
Average
Flow:
Not
Available
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC
in
PCS.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
94
Facility
name:
Lakeland
College
NPDES
permit
number:
WI0029335
Major/
minor:
Minor
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
Not
Available
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
95
Facility
name:
Mitchel
Campus
WWTF
NPDES
permit
number:
TX0063231
Major/
minor:
Minor
Facility
Type:
Other
Design
Flow:
Not
Available
Average
Flow:
0.07
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
96
Facility
name:
University
of
California,
San
Diego
­
Oceanography
NPDES
permit
number:
CA0107239
Major/
minor:
Minor
Facility
Type:
Other
Design
Flow:
1
mgd
Average
Flow:
Not
Available
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
97
Facility
name:
Sodus
WWTP
NPDES
permit
number:
NY0021482
Major/
minor:
Minor
Facility
Type:
Municipal
Design
Flow:
0.2
mgd
Average
Flow:
0.34
mgd
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
98
Facility
name:
Somerset
County
WWTP
NPDES
permit
number:
MD0052256
Major/
minor:
Minor
Facility
Type:
Municipal
Design
Flow:
1
mgd
Average
Flow:
0.03
mgd
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
Exhibit
A­
79
summarizes
average
monthly
effluent
data
for
FC
from
EPA's
PCS
database
from
February
2001
through
February
2004.

Exhibit
A­
79.
Effluent
Data
Summary,
Somerset
County
WWTP1
Pollutant
Number
of
Observations
Summary
of
Detected
Values
(
colonies/
100
mL)

Total
Detect
Nondetect
Maximum2
Mean3
Fecal
Coliform
37
4
33
55
16.8
Source:
U.
S.
EPA
(
2003a).
1.
Data
from
February
2001
to
February
2004.
2.
Represents
the
maximum
of
average
monthly
values.
3.
Represents
the
geometric
mean
of
average
monthly
values.

Controls
Needed
The
facility
would
most
likely
be
in
compliance
with
potential
permit
limits
based
on
the
proposed
criteria
for
enterococci.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
99
Facility
name:
Taylor
Beach
Club
STP
NPDES
permit
number:
WA0037656
Major/
minor:
Minor
Facility
Type:
Municipal
Design
Flow:
Not
Available
Average
Flow:
Not
Available
Receiving
Water
Type:
Coastal
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC
in
PCS.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
enterococci
criteria.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
100
Facility
name:
Trizechahn
NPDES
permit
number:
IL0049239
Major/
minor:
Minor
Facility
Type:
Other
Design
Flow:
2.46
mgd
Average
Flow:
Not
Available
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
101
Facility
name:
Yacht
Port
Beach
Club
NPDES
permit
number:
OH0126489
Major/
minor:
Minor
Facility
Type:
Other
Design
Flow:
Not
Available
Average
Flow:
Not
Available
Receiving
Water
Type:
Great
Lakes
Summary
of
Effluent
Data
and
Limits
This
facility
does
not
have
effluent
data
or
limits
for
FC.

Controls
Needed
EPA
does
not
have
effluent
data
to
suggest
that
the
facility
would
have
reasonable
potential
to
exceed
potential
permit
limits
based
on
the
proposed
E.
coli
criteria.
Also,
the
facility
does
not
have
a
limit
for
bacteria
in
its
current
permit.
Therefore,
the
facility
likely
would
incur
only
monitoring
costs
(
approximately
$
2,600
per
year).
June
2004
Appendix
A.
Facility
Analyses
A­
102
References
American
Association
of
Cost
Engineers
(
AACE).
2002.
International
Parametric
Cost
Estimating
Model
for
Buildings.
Online
at
http://
www.
aacei.
org/
technical/
costmodels/
BuildingModel.
shtml#
MODEL
Bureau
of
Labor
Statistics
(
BLS).
2002.
2001
Occupational
Employment
Survey
(
OES)
National
Occupational
Employment
and
Wage
Estimates.
Online
at
http://
www.
bls.
gov/
oes/
2001/
oes_
nat.
htm.

Environetics
Inc.
2003.
Personal
communication
with
Mark
Pannell,
May
2003.

Honolulu
Department
of
Environmental
Services.
1998.
Honouliuli
WWTP
Outfall:
Enterococci
Geometric
Means
for
June
1998.
Online
at
http://
www.
co.
honolulu.
hi.
us/
env/
honosta.
gif.

Kuehne
Chemical
Company.
2002.
Personal
communication,
June
2002.

Malama
o
Manoa.
2004.
November
15th
BWS
Honouliuli
Water
Recycling
Facility
Tour.
Online
at
http://
www.
malamaomanoa.
org/
kuleana/
BWSHonouliuliSlides/.

Massachusetts
Water
Resources
Authority
(
MWRA).
2004.
The
Deer
Island
Sewage
Treatment
Plant.
Online
at
http://
www.
mwra.
state.
ma.
us/
03sewer/
html/
sewditp.
htm.

Roberts
Oxygen.
2002.
Personal
communication,
June
2002.

RS
Means.
1998.
Heavy
Construction
Cost
Data,
12th
Annual
Edition.

U.
S.
EPA.
2003.
Permit
Compliance
System
(
PCS)
Database.
Accessed
November
13,
2003.

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
June
2004
Appendix
B.
Total
Annual
Cost
Calculations
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
the
method
for
extrapolating
costs
to
the
total
number
of
potentially
affected
facilities
(
as
described
in
Section
4.1.5).

EPA
originally
identified
a
total
of
497
facilities
(
195
majors
and
302
minors)
likely
to
be
affected
by
the
proposed
bacteria
criteria.
Based
on
changes
to
the
proposed
rule,
EPA
identified
an
additional
307
facilities
(
150
majors
and
157
minors)
that
may
be
affected.
In
identifying
affected
dischargers,
EPA
was
only
able
to
include
facilities
for
which
SIC
codes
are
available
in
PCS
to
indicate
that
they
are
likely
to
discharge
bacteria
(
e.
g.,
wastewater
treatment
plants),
and
for
which
latitude/
longitude
data
are
available
in
PCS
to
determine
that
indicate
they
discharge
within
two
miles
of
affected
waters
(
unless
the
listed
receiving
water
body
name
indicates
a
coastal
water).

EPA
evaluated
a
sample
of
facilities
from
each
group,
and
extrapolated
the
costs
to
each
universe
separately.
Exhibits
B­
1
and
B­
2
summarize
the
total
capital,
O&
M,
and
annual
costs
for
sample
facilities
in
each
universe.

Exhibit
B­
1.
Potential
Sample
Facility
Costs,
Original
Universe
Facility
Name
Facility
Type
Category
Capital
Costs
O&
M
Costs
Annual
Costs1
Coastal
Bowery
Bay
WPC
Major
Municipal
>
120
$
4,197,000
$
852,000
$
1,248,000
Hunt's
Point
WPC
Major
Municipal
>
120
$
4,291,000
$
867,600
$
1,273,000
King
County
WWTP
Major
Municipal
>
120
$
4,723,000
$
954,700
$
1,401,000
Miami­
Virginia
Key
Major
Municipal
>
120
$
0
$
2,600
$
2,600
MWRA
­
Deer
Island
WTP
Major
Municipal
>
120
$
0
$
2,600
$
2,600
Newtown
Creek
WPC
Major
Municipal
>
120
$
9,221,000
$
1,866,000
$
2,736,000
Owls
Head
WPC
Major
Municipal
>
120
$
4,152,000
$
819,500
$
1,211,000
Ward
Island
WPC
Major
Municipal
>
120
$
0
$
2,600
$
2,600
Bay
City
Military
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Boca
Raton
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Brookings
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Cedar
Creek
WPCP
Major
Municipal
$
0
$
2,600
$
2,600
Clearwater
East
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Edmonds
WWTP
Major
Municipal
$
320,100
$
57,400
$
87,600
Fairhaven
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Exhibit
B­
1.
Potential
Sample
Facility
Costs,
Original
Universe
Facility
Name
Facility
Type
Category
Capital
Costs
O&
M
Costs
Annual
Costs1
June
2004
Appendix
B.
Total
Annual
Cost
Calculations
B­
2
Fairhope
WWTP
Major
Municipal
$
98,500
$
16,800
$
26,100
Flagler
Beach
WWTP
Major
Municipal
$
47,600
$
18,500
$
23,000
Homer
WWTP
Major
Municipal
$
11,400
$
2,600
$
3,700
Howard
F
Curren
AWTP
Major
Municipal
$
0
$
2,600
$
2,600
Kodiak
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Naples
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
NAS
Pensacola
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Newport
WWTF
Major
Municipal
$
273,600
$
2,600
$
28,400
Pascagoula
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Pawsley
WWTTO
Major
Municipal
$
0
$
2,600
$
2,600
Port
Washington
WPCP
Major
Municipal
$
144,400
$
28,000
$
41,600
Shelton
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Slidell
WTTP
Major
Municipal
$
0
$
2,600
$
2,600
St
Andrew
STP
Major
Municipal
$
0
$
2,600
$
2,600
Suffolk
County
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Tacoma
WWTP
Major
Municipal
$
959,100
$
192,000
$
282,500
West
Long
Beach
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
Washington
WWTP
Major
Municipal
$
151,400
$
29,300
$
43,600
Kingsport
WWTP
Minor
Municipal
$
0
$
2,600
$
2,600
Taylor
Beach
Club
STP
Minor
Municipal
$
0
$
2,600
$
2,600
Elsyian
Beach
Resort
Minor
Other
$
0
$
2,600
$
2,600
Henry
T.
Wing
School
Minor
Other
$
0
$
2,600
$
2,600
Great
Lakes
Bird
Island
WWTP
Major
Municipal
>
120
$
7,218,000
$
1,446,000
$
2,128,000
Frank
E.
Van
Lare
WWTP
Major
Municipal
>
120
$
3,619,000
$
740,200
$
1,082,000
Erie
County
SD
Major
Municipal
$
0
$
2,600
$
2,600
Silver
Creek
WWTP
Major
Municipal
$
0
$
2,600
$
2,600
WLSSD
Major
Municipal
$
0
$
75,400
$
75,400
Sodus
WWTP
Minor
Municipal
$
0
$
2,600
$
2,600
Brennan
Beach
Campground
Minor
Other
$
0
$
2,600
$
2,600
Exhibit
B­
1.
Potential
Sample
Facility
Costs,
Original
Universe
Facility
Name
Facility
Type
Category
Capital
Costs
O&
M
Costs
Annual
Costs1
June
2004
Appendix
B.
Total
Annual
Cost
Calculations
B­
3
Trizechahn
Minor
Other
$
0
$
2,600
$
2,600
1.
Capital
costs
annualized
at
7%
over
20
years
plus
annual
O&
M
costs.

Exhibit
B­
2.
Potential
Sample
Facility
Costs,
Second
Universe
Facility
Name
Facility
Type
Category
Capital
Costs
O&
M
Costs
Annual
Costs1
Coastal
Back
River
WWTP
Major
POTW
>
120
$
0
$
2,600
$
2,600
Orange
County
SD
Major
POTW
>
120
$
0
$
2,600
$
2,600
Point
Loma
WWTF
Major
POTW
>
120
$
0
$
2,600
$
2,600
Southeast
WPCP
Major
POTW
>
120
$
4,190,000
$
852,000
$
1,248,000
Aransas
Pass
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Bayamon
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Benicia
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Broadway
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Burlingame
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Ceiba
WWTP
Major
POTW
$
65,500
$
9,700
$
15,900
Honouliuli
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Monterey
Regional
WPCA
Major
POTW
$
0
$
2,600
$
2,600
Nueces
County
WCID
#
4
Major
POTW
$
0
$
2,600
$
2,600
Ocean
City
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Pismo
Beach
WWTP
Major
POTW
$
0
$
2,600
$
2,600
San
Mateo
WPCP
Major
POTW
$
0
$
2,600
$
2,600
Seabrook
WWTP
Major
POTW
$
0
$
2,600
$
2,600
Kaufer­
Hubert
Memorial
Park
WWTP
Minor
POTW
$
0
$
2,600
$
2,600
Somerset
County
SD
Minor
POTW
$
0
$
2,600
$
2,600
Mitchel
Campus
WWTF
Minor
Other
$
0
$
2,600
$
2,600
UC,
San
Diego
­
Oceanography
Minor
Other
$
0
$
2,600
$
2,600
Great
Lakes
NOERSD
­
Easterly
WWTP
Major
POTW
>
120
$
0
$
2,600
$
2,600
Exhibit
B­
2.
Potential
Sample
Facility
Costs,
Second
Universe
Facility
Name
Facility
Type
Category
Capital
Costs
O&
M
Costs
Annual
Costs1
June
2004
Appendix
B.
Total
Annual
Cost
Calculations
B­
4
City
of
Port
Clinton
WWTP
Major
POTW
$
122,300
$
19,700
$
31,200
Huron
Basin
STP
Major
POTW
$
98,500
$
16,800
$
26,100
Kenosha
WWTP
Major
POTW
$
1,113,000
$
222,800
$
327,900
Painesville
WWTP
Major
POTW
$
214,200
$
36,400
$
56,600
Sturgeon
Bay
Utilities
Major
POTW
$
98,500
$
16,800
$
26,100
Green
Cove
Condos
Minor
POTW
$
24,600
$
3,500
$
5,800
Lakeland
College
Minor
POTW
$
0
$
2,600
$
2,600
Yacht
Port
Beach
Condos
Minor
Other
$
0
$
2,600
$
2,600
1.
Capital
costs
annualized
at
7%
over
20
years
plus
annual
O&
M
costs.

Based
on
these
sample
facility
costs,
EPA
extrapolated
to
obtain
a
total
annual
cost
for
the
States
included
in
the
rule
(
except
Maine)
of
approximately
$
21
million,
which
includes
$
14
million
per
year
for
coastal
facilities,
and
$
7
million
per
year
for
Great
Lakes
facilities.
Exhibits
B­
3
and
B­
4
summarize
the
extrapolations.

Exhibit
B­
3.
Summary
of
Potential
Costs
to
Point
Sources
Associated
with
the
Proposed
Rule,
Original
Universe
Facility
Type
Annual
Sample
Facility
Costs
Number
in
Sample
Annual
Per
Facility
Cost
Total
Number
in
Universe
Total
Annual
Costs
Coastal
Select
POTW
(
flow
>
120
mgd)
$
7,877,000
8
NA
8
$
7,877,000
Major
POTW
(
flow
<
120
mgd)
$
580,700
25
$
23,200
156
$
3,619,000
Minor
POTW
$
5,200
2
$
2,600
183
$
475,800
Minor
Other
$
5,200
2
$
2,600
82
$
213,200
TOTAL
$
8,468,000
37
NA
429
$
12,185,000
Great
Lakes
Select
POTW
(
flow
>
120
mgd)
$
3,210,000
2
NA
2
$
3,210,000
Major
POTW
(
flow
<
120
mgd)
$
80,600
3
$
26,900
29
$
780,100
Minor
POTW
$
2,600
1
$
2,600
22
$
57,200
Minor
Other
$
5,200
2
$
2,600
15
$
39,000
TOTAL
$
3,298,000
8
NA
68
$
4,086,000
Note:
Detail
may
not
add
to
total
due
to
rounding.
June
2004
Appendix
B.
Total
Annual
Cost
Calculations
B­
5
Exhibit
B­
4.
Summary
of
Potential
Costs
to
Point
Sources
Associated
with
the
Proposed
Rule,
Second
Universe
Facility
Type
Annual
Sample
Facility
Costs
Number
in
Sample
Annual
Per
Facility
Cost
Total
Number
in
Universe
Total
Annual
Costs
Coastal
Select
POTW
(
flow
>
120
mgd)
$
1,255,000
4
NA
4
$
1,255,000
Major
POTW
(
flow
<
120
mgd)
$
47,100
13
$
3,600
113
$
406,800
Minor
POTW
$
5,200
2
$
2,600
77
$
200,200
Minor
Other
$
5,200
2
$
2,600
20
$
52,000
TOTAL
$
1,313,000
21
NA
214
$
1,914,000
Great
Lakes
Select
POTW
(
flow
>
120
mgd)
$
2,600
1
NA
1
$
2,600
Major
POTW
(
flow
<
120
mgd)
$
467,900
5
$
93,600
32
$
2,995,000
Minor
POTW
$
8,400
2
$
4,200
54
$
226,800
Minor
Other
$
2,600
1
$
2,600
6
$
15,600
TOTAL
$
481,500
9
NA
93
$
3,240,000
Note:
Detail
may
not
add
to
total
due
to
rounding.

With
the
addition
of
Maine
to
the
rule,
EPA
identified
an
additional
46
facilities
(
17
majors
and
29
minors)
that
may
be
affected.
By
extrapolating
the
estimated
costs
from
the
original
universe
(
since
the
per
facility
costs
for
the
original
universe
are
higher,
this
assumption
likely
errs
on
the
side
of
overestimating
costs),
EPA
estimated
that
the
cost
of
the
rule
for
point
source
dischargers
in
Maine
would
be
approximately
$
500,000.
Thus,
the
total
cost
of
the
rule
is
approximately
$
22
million,
including
$
14.6
million
for
coastal
facilities,
including
facilities
in
Maine,
and
$
7.3
million
for
Great
Lakes
facilities.
Exhibit
B­
5
summarizes
the
potential
costs
of
the
rule
to
facilities
in
Maine.

Exhibit
B­
5.
Extrapolation
of
Potential
Costs
to
Point
Source
Dischargers
in
Maine
Associated
with
the
Proposed
Rule
Facility
Type
Annual
Per
Facility
Cost
Number
of
Additional
Facilities
Total
Annual
Costs
Coastal
Select
POTW
(
flow
>
120
mgd)
NA
0
$
0
Major
POTW
(
flow
<
120
mgd)
$
23,200
17
$
394,400
Exhibit
B­
5.
Extrapolation
of
Potential
Costs
to
Point
Source
Dischargers
in
Maine
Associated
with
the
Proposed
Rule
Facility
Type
Annual
Per
Facility
Cost
Number
of
Additional
Facilities
Total
Annual
Costs
June
2004
Appendix
B.
Total
Annual
Cost
Calculations
B­
6
Minor
POTW
$
2,600
23
$
59,800
Minor
Other
$
2,600
6
$
15,600
TOTAL
NA
46
$
469,800
Note:
Detail
may
not
add
to
total
due
to
rounding.
Appendix
C.
Potential
Sample
Analysis
Costs
June
2004
Appendix
C.
Sample
Analysis
Costs
C­
1
Appendix
C.
Potential
Sample
Analysis
Costs
Exhibit
C­
1
provides
sample
analysis
costs
from
five
analytical
laboratories.
EPA
estimated
that
facilities
would
monitor
weekly
for
E.
coli
(
Great
Lakes
facilities)
or
enterococci
(
coastal
facilities),
at
an
average
cost
of
$
50
per
sample.
These
costs
are
similar
to
the
cost
of
analyzing
samples
for
fecal
coliform.

Exhibit
C­
1.
Sample
Monitoring
Costs
Laboratory
E.
coli
Enterococci
Fecal
Coliform
Source
Analytical
Services,
Inc.
$
50
NA
$
50
Analytical
Services,
Inc
(
2002)

Biological
Consulting
Services
NA
$
21
$
23*
Biological
Consulting
Services
(
2004)

BioVir
Laboratories,
Inc.
$
50
$
50
$
44*
BioVir
Laboratories
(
2004)

EMSL
Analytical,
Inc.
$
25
NA
$
25
EMSL
Analytical,
Inc.
(
2004)

UMPQUA
Research
Company
$
40
$
65
$
40
UMPQUA
Research
Company
(
2002)

*
Represent
an
average
cost.
June
2004
Appendix
C.
Sample
Analysis
Costs
C­
2
References
Analytical
Services,
Inc.
2004.
Price
List.
Email
from
Tom
Smith,
Sales
Manager.

Biological
Consulting
Services.
2004.
Bacterial
Detection
and
Enumeration.
Online
at
www.
microbioservices.
com/
bde.
htm.

BioVir
Laboratories,
Inc.
2004.
2004
Services.

EMSL
Analytical,
Inc.
2004.
Laboratory
Services
Pricing
Guide
2004.

UMPQUA
Research
Company.
2002.
Drinking
Water
and
Environmental
Analytical
Services,
Fee
Schedule.
Online
at
http://
chemlab.
cc/
price.
pdf.
Appendix
D.
Energy
Use
June
2004
Appendix
D.
Energy
Use
D­
1
Appendix
D.
Energy
Use
This
appendix
describes
EPA's
estimates
regarding
energy
use,
and
Executive
Order
13211.

EPA
estimated
that
facilities
needing
controls
to
comply
with
the
proposed
rule
would
optimize
their
chlorination
process.
Process
optimization
includes
process
analysis
and
process
modifications.
The
following
section
describes
the
potential
energy
use
associated
with
these
activities.

Process
Analysis
Process
analysis
involves
studying
the
chlorination
process.
EPA
estimates
that
there
is
no
incremental
increase
in
energy
use
associate
with
this
activity.

Process
Modifications
Process
modifications
include
the
following
components:

Increasing
chemical
(
chlorine)
dose:
Involves
allowing
more
chemical
to
flow
through
the
pipes
from
pressurized
vessels,
or
by
gravity
for
liquid
chlorine
applications.
EPA
estimates
that
there
is
no
incremental
increase
in
energy
use
associated
with
this
activity.

Increasing
maintenance:
Cleaning
contact
basins
requires
use
of
a
vacuum
and/
or
a
water
jet
to
remove
water
scum
and
sediment.
Running
the
vacuum
and/
or
jet
requires
power.
The
source
of
this
power
may
be
electric
(
for
stationary
equipment),
but
more
likely
will
be
diesel
or
gasoline
because
the
equipment
is
more
likely
to
be
mobile.
As
a
rough
estimate,
assuming
that
cleaning
equipment
requires
a
10
horsepower
source
(
each
horsepower
equals
750
Watts)
of
energy
for
10
hours
per
basin,
for
a
maximum
of
3
basins
for
large
facilities
(
less
energy
would
be
expended
for
small
facilities),
225,000
Watts,
or
225
kiloWatt
hours
(
kWh)
of
energy
is
needed.
EPA
assumed
that
cleaning
would
increase
by
1.5
times
(
from
once
every
two
years
to
twice
per
year)
per
year
per
facility.
Thus,
the
incremental
increase
in
energy
use
would
be
total
horsepower
required
is
337.5
kWh
per
facility.
Based
on
the
total
number
of
facilities
(
large
and
small)
requiring
process
optimization
to
comply
with
the
rule,
the
total
annual
increase
in
energy
use
is
approximately
140,000
kWh.
Compared
to
total
annual
energy
production
in
the
United
States
in
2002
(
3,858,452
million
kWh),
this
increase
is
negligible
(
0.000004%).

Improving
mixing:
Involves
adding
baffles
to
the
contact
basin.
EPA
estimates
that
there
is
no
incremental
increase
in
energy
use
associated
with
this
activity,
as
baffles
act
as
static
mixers
(
i.
e.,
baffles
are
stationary,
and
require
no
energy
to
run).
June
2004
Appendix
D.
Energy
Use
D­
2
Increasing
contact
time:
Involves
adding
incremental
contact
basin
capacity.
EPA
estimates
that
there
is
no
incremental
increase
in
energy
use
associate
with
adding
volume
to
existing
contact
basins
because
tanks
are
fixed
structures,
and
they
do
not
require
any
mechanical,
energy­
dependent
mixing
devices.
