ECONOMIC ANALYSIS OF THE PROPOSED WATER QUALITY STANDARDS RULE FOR THE STATE OF ALABAMA November 2001 Prepared for U. S. Environmental Protection Agency Office of Water Office of Science and Technology Ariel Rios Building 1200 Pennsylvania Avenue, NW Washington, D. C. 20460 Prepared by Science Applications International Corporation 11251 Roger Bacon Drive Reston, Virginia 20190 EPA Contract No. 68 C 99 252 SAIC Project No. 06 6193 04 2805 xxx Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama iii Table of Contents 1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.2 Scope of the Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Organization of Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2. Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.1 Facility Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.2 Water Quality Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3. Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1 Use Attainability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.2 Estimating Revised Effluent Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.3 Determining Necessary Pollution Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3.4 Estimating the Cost of Pollution Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.5 Estimating Pollutant Loading Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4. Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.1 Estimated Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.1.1 Five Mile Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 4.1.2 Opossum Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4.1.3 Pepperell Branch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 4.1.4 Shirtee Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 4.1.5 Valley Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.1.6 Village Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 4.2 Pollutant Loading Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 4.3 Limitations of the Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 5. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Appendices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Appendix A. Facility Effluent Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Appendix B. Instream Water Quality Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Appendix C. Use Attainability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Appendix D. Ammonia Toxicity Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 Appendix E. Dissolved Oxygen Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 Appendix F. Facility Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 Appendix G. Nonpoint Source Control Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama iv List of Exhibits Exhibit 1 1. Comparison of Criteria Applicable to A& I, LWF, and F& W Standards . . . . . . . . 3 Exhibit 2 1. Facilities Potentially Affected by the Use Upgrades . . . . . . . . . . . . . . . . . . . . . . . . 6 Exhibit 3 1. Estimated Treatment Process Optimization Costs . . . . . . . . . . . . . . . . . . . . . . . . 10 Exhibit 4 1. Estimated Annual Costs to Achieve Use Classifications . . . . . . . . . . . . . . . . . . . 13 Exhibit 4 2. Estimated Annual Nonpoint Source Control Costs . . . . . . . . . . . . . . . . . . . . . . . . 15 Exhibit 4 3. Estimated Annual Point Source Costs and Pollutant Load Reductions for an A& I Use Classification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Exhibit 4 4. Estimated Annual Point Source Costs and Pollutant Load Reductions for an LWF Use Classification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Exhibit 4 5. Estimated Annual Point Source Costs and Pollutant Load Reductions for a F& W Use Classification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Exhibit 4 6. Biases and Uncertainties in the Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Exhibit A 1. Facility Effluent Data Considered in Cost Analyses . . . . . . . . . . . . . . . . . . . . . . . 24 Exhibit B 1. Stream Data Considered in Cost Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Exhibit B 2. Five Mile Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Exhibit B 3. Shirtee Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Exhibit B 4. Valley Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Exhibit B 5. Village Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Exhibit C 1. Toxic Pollutant Concentrations and Criteria Exceedances at Station FM1 . . . . . 38 Exhibit C 2. Five Mile Creek, Station FM1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Exhibit C 3. Toxic Pollutant Concentrations and Criteria Exceedances at Station FM2 . . . . . 39 Exhibit C 4. Five Mile Creek, Station FM2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 Exhibit C 5. Pepperell Branch, Station WPP 35 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 Exhibit C 6. Pepperell Branch, Station WPP 36 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 Exhibit C 7. Pepperell Branch, Station WPP 37 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 Exhibit C 8. Pepperell Branch, Station WPP 39 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 Exhibit C 9. Pepperell Branch, Station WPP 39A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 Exhibit C 10. Pepperell Branch, Station WPP 40 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 Exhibit C 11. Pepperell Branch, Station WPP 41 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Exhibit C 12. Shirtee Creek, Station SHIRTEE03 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 Exhibit C 13. Toxic Pollutant Concentrations and Criteria Exceedances at Station VAL 1 . . . 47 Exhibit C 14. Toxic Pollutant Concentrations and Criteria Exceedances at Station VAL 2 . . . 48 Exhibit C 15. Toxic Pollutant Concentrations and Criteria Exceedances at Station VAL 3 . . . 49 Exhibit C 16. Toxic Pollutant Concentrations and Criteria Exceedances at Station VI1 . . . . . . 51 Exhibit C 17. Village Creek, Station VILLAGECREEK02 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 Exhibit C 18. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 1 . . . . 52 Exhibit C 19. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 2 . . . . 53 Exhibit C 20. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 3 . . . . 54 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama v Exhibit C 21. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 4 . . . . 55 Exhibit D 1. Summary of WLA Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 Exhibit E 1. Current Permit Limits and Discharge Condition at Opossum Creek . . . . . . . . . . 60 Exhibit E 2. Summary of Key Model Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 Exhibit F 1. Compliance Summary, ABC Coke . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 Exhibit F 2. Projected Effluent Limits, ABC Coke . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 Exhibit F 3. Required Effluent Reductions, ABC Coke . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 Exhibit F 4. Annual Cost of Required Effluent Reductions, ABC Coke . . . . . . . . . . . . . . . . . 65 Exhibit F 5. Compliance Summary, ACIPCO . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 Exhibit F 6. Projected Effluent Limits, ACIPCO . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 Exhibit F 7. Required Effluent Reductions, ACIPCO . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 Exhibit F 8. Annual Cost of Required Effluent Reductions, ACIPCO . . . . . . . . . . . . . . . . . . . 68 Exhibit F 9. Compliance Summary, Ashland Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 Exhibit F 10. Compliance Summary, Avondale Mills   Eva Jane Plant . . . . . . . . . . . . . . . . . . 70 Exhibit F 11. Compliance Summary, Earl Ham WWTP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 Exhibit F 12. Annual Cost of Required Effluent Reductions, Earl Ham WWTP . . . . . . . . . . . . 73 Exhibit F 13. Compliance Summary, Five Mile Creek WWTP . . . . . . . . . . . . . . . . . . . . . . . . . 74 Exhibit F 14. Annual Cost of Required Effluent Reductions, Five Mile Creek WWTP . . . . . . 75 Exhibit F 15. Compliance Summary, Honeywell International . . . . . . . . . . . . . . . . . . . . . . . . . 76 Exhibit F 16. Projected Effluent Limits, Honeywell International . . . . . . . . . . . . . . . . . . . . . . . 77 Exhibit F 17. Required Effluent Reductions, Honeywell International . . . . . . . . . . . . . . . . . . . 77 Exhibit F 18. Annual Cost of Required Effluent Reductions, Honeywell International . . . . . . . 78 Exhibit F 19. Compliance Summary, Koppers Ind.   Woodward Coke Plant . . . . . . . . . . . . . . 79 Exhibit F 20. Projected Effluent Limits, Koppers Ind.   Woodward Coke Plant . . . . . . . . . . . . 80 Exhibit F 21. Required Effluent Reductions, Koppers Ind.   Woodward Coke Plant . . . . . . . . 80 Exhibit F 22. Annual Cost of Required Effluent Reductions, Koppers Ind.   Woodward Coke Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 Exhibit F 23. Compliance Summary, Koppers Ind.   Woodward Tar Plant . . . . . . . . . . . . . . . . 81 Exhibit F 24. Projected Effluent Limits, Koppers Ind.   Woodward Tar Plant . . . . . . . . . . . . . 82 Exhibit F 25. Compliance Summary, Sloss Industries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 Exhibit F 26. Projected Effluent Limits, Sloss Industries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 Exhibit F 27. Required Effluent Reductions, Sloss Industries . . . . . . . . . . . . . . . . . . . . . . . . . . 86 Exhibit F 28. Annual Cost of Required Effluent Reductions, Sloss Industries . . . . . . . . . . . . . 87 Exhibit F 29. Compliance Summary, SMI Steel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 Exhibit F 30. Schematic Diagram of Process Wastewater and Storm Water Outfalls, USX   Fairfield Works . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 Exhibit F 31. Compliance Summary, USX   Fairfield Works . . . . . . . . . . . . . . . . . . . . . . . . . . 90 Exhibit F 32. Projected Effluent Limits, USX   Fairfield Works . . . . . . . . . . . . . . . . . . . . . . . . 90 Exhibit F 33. Required Effluent Reductions, USX   Fairfield Works . . . . . . . . . . . . . . . . . . . . 91 Exhibit F 34. Annual Cost of Required Effluent Reductions, USX   Fairfield Works . . . . . . . 91 Exhibit F 35. Compliance Summary, Valley Creek WWTP . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92 Exhibit F 36. Projected Effluent Limits, Valley Creek WWTP . . . . . . . . . . . . . . . . . . . . . . . . . 93 Exhibit F 37. Required Effluent Reductions, Valley Creek WWTP . . . . . . . . . . . . . . . . . . . . . . 93 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama vi Exhibit F 38. Annual Cost of Required Effluent Reductions, Valley Creek WWTP . . . . . . . . . 94 Exhibit F 39. Compliance Summary, Village Creek WWTP . . . . . . . . . . . . . . . . . . . . . . . . . . . 95 Exhibit F 40. Projected Effluent Limits, Village Creek WWTP . . . . . . . . . . . . . . . . . . . . . . . . . 96 Exhibit F 41. Required Effluent Reductions, Village Creek WWTP . . . . . . . . . . . . . . . . . . . . . 96 Exhibit F 42. Annual Cost of Required Effluent Reductions, Village Creek WWTP . . . . . . . . 97 Exhibit F 43. Compliance Summary, Westwood Stevens   Opelika Finishing Plant . . . . . . . . 99 Exhibit G 1. Cost of Nonpoint Source Controls, Five Mile Creek . . . . . . . . . . . . . . . . . . . . . 100 Exhibit G 2. Cost of Nonpoint Source Controls, Valley Creek . . . . . . . . . . . . . . . . . . . . . . . . 100 Exhibit G 3. Cost of Nonpoint Source Controls, Village Creek . . . . . . . . . . . . . . . . . . . . . . . 101 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 1 1. Introduction The United States Environmental Protection Agency ( EPA, or the Agency) is proposing to upgrade Five Mile Creek, Opossum Creek, Pepperell Branch ( of Soughahatchee Creek), Shirtee Creek, Valley Creek, and Village Creek in Alabama to a higher designated use. The Alabama Department of Environmental Management ( ADEM) currently designates these creeks for Agricultural and Industrial ( A& I) use. Potential future uses include Fish and Wildlife ( F& W), Limited Warmwater Fishery ( LWF), and variants on LWF.

This report provides analysis of the potential costs and pollutant loading reductions associated with upgrading the designated uses of these creeks.

1.1 Background Section 303 ( U. S. C. 1313) of the CWA directs States, with oversight by EPA, to adopt water quality standards to protect the public health and welfare, enhance the quality of water, and serve the purposes of the CWA. Under Section 303, States are required to develop water quality standards for waters of the United States within their boundaries. Section 303( c) provides that water quality standards shall include the designated use or uses for the water and criteria necessary to protect those uses. States are required to review their water quality standards at least once every 3 years and, if appropriate, revise or adopt new standards. The results of this triennial review must be submitted to EPA and EPA must approve or disapprove any new or revised standards. Section 303( c) also authorizes the EPA Administrator to promulgate water quality standards to supersede State standards that have been disapproved or when the Administrator determines that a new or revised standard is needed to meet the requirements of the CWA.

On October 14, 1986, the Regional Administrator of EPA Region 4 disapproved use designations adopted by ADEM for 49 stream segments because the State failed to justify lower use classifications in accordance with 40 CFR § 131.10( j). Although the State had previously submitted use attainability analyses for these stream segments, EPA found that the analyses did not adequately describe the basis for the lower use classifications nor did they provide adequate information to determine if such classifications are appropriate. Between 1986 and 1991, ADEM either upgraded the use designation to fish and wildlife ( F& W) or EPA approved an agricultural and industrial water supply ( A& I) use for 20 of these streams. On July 18, 1991, the EPA Regional Administrator for Region 4 disapproved 30 beneficial use designations adopted by ADEM, 29 of which were previously disapproved in 1986, plus the beneficial use designation for one additional stream segment which lacked a use attainability analysis ( UAA).

ADEM upgraded 13 of the 30 segments which were the subject of EPA's 1991 action to F& W. This left 17 stream segments for which EPA has disapproved State use designations. A State action on April 22, 1997 reduced the length of 7 of these remaining segments to reflect upgrades of a portion of these segments to F& W use. However, the remaining portions of these seven streams remain subject to EPA's disapproval. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 2 On September 18, 1996, the Legal Environmental Assistance Foundation ( LEAF) filed suit in District Court in Alabama against EPA for failure to propose water quality standards for 12 stream segments in Alabama designated as A& I which EPA had previously disapproved. EPA, the Department of Justice, and the plaintiffs entered into a consent decree covering 9 of the 12 streams. Under the terms and conditions of the consent decree, EPA was to propose Federal use designations in the Federal Register or withdraw the disapproval of the existing Alabama standards for these waters by February 28, 1998. Since the signing of the consent decree, ADEM has upgraded two of these nine streams to F& W. The proposed Alabama Water Quality Standards Rule published in the Federal Register on March 5, 1998 covered the remaining seven consent decree streams as well as two other streams still subject to EPA's outstanding disapproval.

EPA's current proposal covers the following six segments: Five Mile Creek, Opossum Creek, Pepperell Branch ( of Soughahatchee Creek), Shirtee Creek, Valley Creek, and Village Creek.

1.2 Scope of the Analysis To estimate the potential costs and pollutant loading reductions associated with upgrading the designated uses, EPA evaluated potential impacts on National Pollutant Discharge Elimination System ( NPDES) permitted facilities and nonpoint sources of pollutant loadings to seven segments in the six creeks. In doing so, EPA used data and information in publically available sources. ( The appendices to this report describe the available data in detail). Some modeling results were also provided by ADEM and facility process information by EPA's Region 4 office.

The analysis addresses the costs and pollutant loading reductions that would be required to attain Alabama water quality criteria associated with A& I, LWF, and F& W uses. These criteria are shown in Exhibit 3 1. As can be seen from the exhibit, there is little difference in pH and temperature criteria across uses. The criteria for dissolved oxygen ( DO) and toxic pollutants differ among the three standards with the A& I standard being the least restrictive. A& I requires a 3 mg/ L minimum concentration of DO, a level of toxic compounds that does not interfere with water use for agricultural irrigation or impair fish survival, and a geometric mean of 2,000 fecal coliform bacteria per 100 ml ( and a maximum of 4,000 per 100 ml). The narrative toxic criteria require that A& I waters meet Alabama's acute criteria for protection of aquatic life ( ensure fish survival) and Alabama's human health criteria for consumption of organisms only ( for agricultural irrigation use).

The LWF standard is more restrictive than the A& I standard in that DO should always be greater than 3 mg/ L between May and November, and at least 5 mg/ L during other months. Toxic compounds should not be present in amounts that do not cause acute or chronic toxicity, although effluent limits based on chronic aquatic life criteria will be less stringent compared to F& W limits ( see below). The fecal coliform standard of 1,000 bacteria per 100 ml ( geometric mean) and a maximum of 2,000 bacteria per 100 ml is about twice as stringent as the A& I criterion.

Finally, the F& W standard requires 5 mg/ L DO at all times unless natural conditions prevent this, in which case a 4 mg/ L criterion applies. Toxic compounds shall not be present in such amounts as to cause either acute or chronic toxicity. The difference in the chronic toxicity criterion Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 3 between LWF and F& W lies in the stream flows used to determine compliance. Under LWF criteria, the receiving water stream flow is specified as the 7Q2, the lowest daily average stream flow over a weekly period that is expected to occur every 2 years; under F& W criteria, the receiving water stream flow is specified as the 7Q10, a lower flow than the 7Q2, which results in more restrictive permit limits for aquatic life protection. The F& W criteria for fecal coliform require a geometric mean of 200 organisms per 100 ml between June and September and a geometric mean of 1,000 organisms per 100 ml during other months. At no time shall the maximum number of fecal coliform bacteria per 100 ml exceed 2,000.

Exhibit 1 1. Comparison of Criteria Applicable to A& I, LWF, and F& W Standards Parameter A& I LWF F& W pH 6   8.5 standard units ( SU) 6   8.5 SU 6   8.5 SU Temperature 5 ° Fahrenheit ( F) above ambient, < 90 ° F 5 ° F above ambient; does not block fish migration 5 ° F above ambient; does not block fish migration DO > 3 m g/ L at mid depth > 3 m g/ L at mid depth ( May   November) > 5 mg/ L at mid depth except under extreme conditions; > 4 mg/ L when other conditions favorable Color, odor, and organoleptic Will not render waters unsuitable for fish survival or downstream uses Not exhibit acute or chronic toxicity or interfere with downstream uses Not exhibit acute or chronic toxicity or unreasonably affect the aesthetic value of waters for any use Toxic pollutants Will not render waters unsuitable for irrigation of agricultural crops, fish survival, or downstream uses Will not exhibit acute or chronic toxicity by toxicity testing or application of numeric criteria; use 7Q2 flow for calculating limits for chronic criteria Will not exhibit acute or chronic toxicity by toxicity testing or application of numeric criteria; use 7Q10 flow for calculating limits for chronic criteria Fecal coliform bacteria Geometric mean < 2,000/ 100ml with a maximum < 4,000/ 100ml in five samples over a 30 day period, separated by 24 hours Geometric mean < 1,000/ 100ml with a maximum < 2,000/ 100ml in five samples over a 30 day period, separated by 24 hours Geometric mean < 1,000/ 100ml with a maximum < 2,000/ 100ml ( June   September, geometric mean of 200/ 100ml when use is water contact recreation) in five samples over a 30 day period, separated by 24 hours Source: Alabama State Regulations Chapter 335 6 10. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 4 1.3 Organization of Report This report provides the following sections documenting the cost and pollutant loading reduction analyses. Chapter 2 describes the data used in the analyses. Chapter 3 provides a detailed description of the methodologies. Chapter 4 provides results and discusses uncertainties in the analysis. Several appendices further document the data, modeling, and facility level analyses. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 5 2. Data In analyzing potential costs and pollutant loading reductions associated with the use upgrades, EPA used stream data, facility process and effluent data, and modeling results from a number of sources. These data are described in the sections below.

2.1 Facility Data Exhibit 2 1 lists the municipal and industrial facilities potentially affected by the use designation upgrades for Five Mile Creek, Opossum Creek, Pepperell Branch ( of Soughahatchee Creek), Shirtee Creek, Valley Creek, and Village Creek. EPA used three sources of data on these facilities in its analysis:

C NPDES permits, applications, fact sheets, and inspection reports C Discharge monitoring reports for the most recent 3 years available obtained from EPA's Permit Compliance System ( PCS) ( or EPA Region 4)

C Facility wastewater treatment process information provided by EPA Region 4.

Appendix A provides a listing of the monitoring data available for the analysis.

2.2 Water Quality Data Alabama water quality criteria associated with A& I, LWF, and F& W use differ with respect to both conventional and toxic pollutants. EPA evaluated available instream data for these pollutants from EPA's water quality storage and retrieval ( STORET Legacy) database ( http:// epa. gov/ storet) and 2000   2001 data provided by EPA Region IV for Valley and Village Creeks. EPA obtained flow data from the USGS National Water Information System ( http:// water. usgs. gov/ nwis).

Appendix B provides a detailed list of the STORET data available at each sampling station and maps locating STORET and USGS stations on Five Mile, Shirtee, Valley, and Village Creeks. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 6 Exhibit 2 1. Facilities Potentially Affected by the Use Upgrades Facility ( Capacity) NPDES Number Major Five Mile Creek ABC Coke ( 0.12 mgd) AL0003417 Yes Five Mile Creek WWTP ( 20 mgd) AL0026913 Yes Sloss Industries ( 3.2 mgd) AL0003247 Yes Opossum Creek Koppers   Coke ( 0.236 mgd) AL0000680 No Koppers   Tar ( 0.036 mgd) AL0003221 No USX Fairfield Works ( 11 mgd) AL0003646 Yes Pepperell Branch ( of Soughahatchee Creek)

Westpoint Stevens Opelika Finishing Plant ( 1.85 mgd) AL0002968 Yes Shirtee Creek Avondale Mills ( 2.0 mgd) AL0001627 Yes Earl Ham WWTP ( 2.4 mgd) AL0020001 Yes Valley Creek Valley Creek WWTP ( 85 mgd) AL0023655 Yes Village Creek American Cast Iron Pipe Company ( 0.55 mgd) AL0029378 No Ashland Chemical ( 0.025 mgd) AL0021695 Yes Honeywell International ( 0.06 mgd) AL0021695 Yes Miller Steam ( storm water only) AL0027146 Yes SMI Steel ( 7.3 mgd) AL0001554 Yes Village Creek WWTP ( 60 mgd) AL0023647 Yes Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 7 3. Methods This chapter describes the methods EPA used to estimate the potential costs and pollutant loading reductions associated with meeting the various designated uses. As a first step, EPA conducted screening level analyses of use attainability for each creek. UAAs can indicate circumstances that might prevent the use from being attained and help identify sources ( e. g., urban runoff) that need to be controlled. Next, EPA estimated the required effluent limits ( for point sources), control technologies, and costs that would be required under each use designation. These analyses are described below.

3.1 Use Attainability As described above, EPA evaluated use attainability using available data as a means determining the types of controls that would be required to meet a higher designated use. This analysis is described in detail in Appendix F.

3.2 Estimating Revised Effluent Limits With the designation of LWF or F& W use, more stringent criteria apply for fecal coliform bacteria, DO, and toxic pollutants. The greater stringency of receiving water criteria often requires more stringent effluent limits to be placed on facilities discharging to upgraded waters.

Conventional Pollutants EPA estimated revised effluent limits for conventional pollutants at permitted facilities when a segment was not currently attaining the receiving water criterion for the higher use designation and a facility had an existing effluent limit for the pollutant. However, EPA did not estimate new fecal coliform limits for POTWs. Instead, it assumed that disinfection process optimization would be necessary to attain the fecal coliform criterion for F& W in all stream segments where a geometric mean of 200 per100 ml is not now being attained during summer months. No additional controls appeared necessary to meet a LWF classification.

EPA ran a steady state Streeter Phelps model to predict oxygen concentrations based on stream and effluent characteristics for segments that might have difficulty meeting a F& W use. EPA used stream parameters in the model from similar analyses run by ADEM, using the 7Q10 stream flow, summer temperatures, and discharges of BOD, ammonia, and Kjeldahl nitrogen. If, based on these runs, the resulting DO levels would not comply with the use requirements, EPA reduced point source loads of BOD and ammonia at the facilities proportionately until the higher use criterion was attained in the receiving water. The effluent concentrations used in the simulation that obtained the higher use DO criterion became the revised effluent limits for each facility.

Toxic Pollutants Some facilities that now discharge toxic pollutants have only best available technology ( BAT) effluent limits for a range of toxic pollutants. Therefore, for each pollutant limited at each Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 8 facility, EPA calculated water quality based limits based on the A& I acute aquatic life and human health criteria. These effluent limits apply, but often have not been implemented, in facility permits. EPA then estimated effluent limits for all toxic pollutants based on the acute and chronic aquatic life criteria and the human health criterion ( for organisms only) that would apply under a F& W classification.

EPA estimated revised effluent limits only for those pollutants that had a reasonable potential to cause or contribute to an instream criterion exceedance. EPA determined reasonable potential by comparing the receiving water concentration that would result from discharge of the maximum effluent concentration at different receiving water flows with appropriate criteria ( Note that the receiving water concentration is a function of the mean background receiving water concentration, the effluent concentration, and relative effluent design flow and receiving water flows). For a F& W classification, EPA compared the receiving water concentration using a 1Q10 receiving water flow to the acute criterion, the receiving water concentration using a 7Q10 receiving water flow to the chronic criterion, and the receiving water concentration using average flow to the human health criterion. For LWF use, EPA substituted the 2Q10 for the 7Q10 for chronic criteria used in the F& W analysis. EPA determined that pollutants for which the maximum concentration would cause an exceedance of any one criterion had reasonable potential.

EPA calculated the revised effluent limits according to the two value steady state wasteload allocation procedure specified in the Technical Support Document for Water Quality based Toxics Control ( EPA 1991). As in determining reasonable potential, EPA determined wasteload allocations ( WLA) for a facility based on acute, chronic, and human health criteria using the facility design flow and the 1Q10, 7Q10 ( or 7Q2), and average receiving water flows, respectively, and the mean receiving water concentration.

EPA assumed coefficients of variation ( CVs) of 0.6 for the facilities and pollutants because available data did not contain individual effluent concentrations, but averages or maxima of concentrations observed over specified months. Using the assumed CVs, EPA determined the minimum long term average ( LTA) effluent concentration that would allow compliance with each criterion. The effluent limit then becomes the limit calculated from the most stringent LTA. If the human health criterion had the limiting LTA, EPA set the average monthly limit ( AML) to the human health WLA. Similarly, if the acute criterion had the limiting LTA, EPA set the AML to the acute LTA times 3.11. Finally, if the chronic criterion had the limiting LTA, EPA set the AML to the chronic LTA times 1.55. The multipliers are based on the assumed CV of 0.6. For limits based on the chronic criterion, EPA chose a 95th percentile probability basis and 4 samples per month to determine the multipliers. For limits based on the acute criterion, EPA chose a 99th percentile probability basis and one sample per month.

3.3 Determining Necessary Pollution Controls EPA determined the necessary controls on point sources to reduce effluent concentrations to the required level by first evaluating whether low cost control option would be feasible and then considering more costly controls if necessary. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 9 EPA considered the lowest cost option   adjustment of existing treatment ( process optimization)   to be feasible if literature indicated that the existing treatment process could achieve the revised effluent limit or when the additional pollutant reduction was relatively small ( e. g., 10% to 25% of current discharge levels).

Where it was not technically feasible to simply adjust existing operations, EPA selected the next most attractive control strategy: waste minimization/ pollution prevention controls. However, EPA developed costs for these controls only when the reviewing engineer considered them feasible for the treatment processes at a given facility. Decision considerations included the level of pollutant reduction achievable through waste minimization/ pollution prevention techniques, appropriateness of waste minimization/ pollution prevention for specific pollutants, and knowledge of the manufacturing processes generating the pollutant of concern. In general, NPDES permit files did not contain detailed information on treatment and manufacturing processes. EPA Region 4 provided some process information. EPA also used best professional judgment based on general knowledge of industrial and municipal operations.

If waste minimization/ pollution prevention alone would not be feasible to reduce pollutant levels to those needed to comply with projected effluent limits, EPA considered a combination of waste minimization/ pollution prevention, simple treatment, and/ or process optimization. If these relatively low cost controls could not achieve the projected effluent limits, EPA considered additional treatment.

Development of treatment cost estimates began with a review of the existing treatment systems at each facility. For determining the need for additional or supplemental treatment, sources of performance information included the EPA Office of Research and Development Risk Reduction Engineering Laboratory's RREL Treatability Database ( Version 4.0). EPA evaluated the pollutant removal capabilities of the existing treatment systems and/ or any proposed additional or supplemental systems using the following criteria: ( 1) the current effluent levels achieved by the facility and ( 2) the levels that are documented in the RREL Treatability Database. If this analysis showed that additional treatment was needed, EPA identified unit processes that would achieve compliance with the projected effluent limits using the same documentation.

EPA determined that controls on nonpoint sources would be required for all streams that do not currently meet instream criteria for A& I, LWF, or F& W uses. Evaluation of landuse data indicated that the source of pollutants of concern is likely the urban areas in the vicinity of the creeks. In the absence of detailed knowledge of the existing storm water management systems, EPA assumed that storm water detention systems would be retrofit in urban areas that drain to affected streams. Detention systems generally reduce metals, BOD, and fecal coliforms, the three pollutants that cause instream exceedances in the affected stream segments. Removal efficiencies can be as high as 80% for these pollutants, depending on the design of the system ( Rouge River National Wet Weather Demonstration Project Cost Estimating Guidelines, 2001). Land use data for the creeks requiring nonpoint source controls is provided in Appendix G. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 10 3.4 Estimating the Cost of Pollution Controls EPA estimated the cost of pollution controls for point and nonpoint sources using available estimates from the literature.

Treatment Process Optimization Costs Treatment process optimization refers to measures facilities can implement to modify or adjust the operating efficiency of their wastewater treatment process. Such measures usually involve engineering analysis of existing treatment processes to identify minor adjustments to enhance pollutant removal or reduce chemical additions ( e. g., chlorine) that can result in toxic byproducts, followed by implementation of such adjustments. The costs for treatment process optimization vary according to the specific type of treatment process used at a site. EPA estimated the costs of treatment process optimization for chlorination/ dechlorination as 10% of the total treatment process costs. For organic pollutant removal, optimization costs are based on Truax ( 1992).

Exhibit 3 1. Estimated Treatment Process Optimization Costs Treatment Process Facility Effluent Flow ( in MGD)

< 1 1   < 10 > 10 Chlorination/ Dechlorination1 not estimated $ 7,400 $ 24,000 Biological Treatment2 $ 125,000 $ 170,000 $ 233,000 Organic pollutant removal2 $ 60,000 $ 88,000 $ 135,000 1Estimated as 10% of total treatment process cost. 2Based on Truax ( 1992).

Process analysis is a key factor in achieving optimum treatment efficiency. Process analysis is a time consuming investigation to determine performance limiting factors. Performance limiting factors include operator training, response to changes in wastewater quality, individual treatment unit design limits, maintenance activities, automation, process control testing, and administrative factors such as the number of trained staff to run a facility at all times. The cost of process analysis includes the cost of site visits, additional monitoring at selected sites, data collection, data analysis, and report preparation. Process analysis also includes post process modification treatment performance evaluation.

Process modifications include activities short of adding a new treatment technology units ( conventional or unconventional) to the treatment train. Process modifications may include one or more of the following: hydraulic regime modification, treatment train modification, chemical adjustment, operator training, installation of process control testing equipment, installation of automation equipment including necessary hardware and software. Several months of control system adjustment may be needed to achieve a desired level of process optimization due to anticipated problems ( e. g., pump rate synchronization with varied levels of treatment parameters such pH, temperature, etc.). Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 11 Waste Minimization/ Pollution Prevention Costs When EPA lacked information for developing alternative treatment or where existing effluent concentrations were close to projected effluent limits, it assumed that it would be more appropriate and technically efficient for a facility to use waste minimization or pollution prevention activities rather than provide additional or supplemental treatment units. EPA also assumed that a facility would incur costs to implement a waste minimization or pollution prevention practice that would be adequate to comply with the projected effluent limit. Waste minimization or pollution prevention practices could include the installation of equipment, best management practices, and production/ process changes at industrial facilities, and modifications to pretreatment requirements for POTWs.

The costs for implementing waste minimization/ pollution prevention controls are taken from EPA's cost analysis for the proposed Great Lakes Water Quality Guidance ( U. S. EPA, 1993). The unit waste minimization/ pollution prevention costs used for this analysis are for POTWs. The estimated total cost is $ 488,000, updated to year 2001 dollars using the Consumer Price Index.

The feasibility of waste minimization cannot be determined without process specific information. In general, however, relatively simple, inexpensive source controls, best management practices, and process changes have been shown to result in significant pollution reductions as well as savings in raw materials.

New/ Additional Treatment Systems EPA estimated capital costs for those facilities for which new/ additional treatment was needed. After EPA selected an appropriate treatment system, EPA extracted the costs from cost curves available in Treatability Manual, Volume IV: Cost Estimating ( U. S. EPA, 1980). Capital costs are total capital costs and include the cost of the equipment, design, and installation. EPA escalated costs to 2001 dollars using the Engineering News Record ( ENR) Construction Cost Index.

O& M costs are annual costs associated with operating and maintaining the equipment, treatment chemicals, and energy. EPA also derived these expenses from cost curves taken from U. S. EPA ( 1980). EPA escalated costs to 2001 dollars using the ENR Construction Cost Index. EPA assumed that residuals management and any required additional monitoring are included in the O& M costs. Generally, these costs are 1% or less of annualized costs.

Storm Water Runoff Controls EPA estimated the cost of storm water controls for facilities that had permit limits or reporting requirements for a pollutant in storm water on streams that exceeded instream aquatic life or human health criteria. EPA estimated costs based on a 300,000 ft3 storm water detention system that would remove a large percentage of the metal constituents that were exceeded in the receiving water. The cost of $ 227,300 was taken from the Rouge River Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 12 National Wet Weather Demonstration Project Cost Estimating Guidelines ( http:// www. wcdoe. org/ rougeriver/ pdfs/ stormwater/ sr10. pdf) and updated to 2001 dollars.

Nonpoint Sources Controls EPA estimated the cost of urban nonpoint source controls by acreage. For high density residential, commercial, industrial, and transportation land, EPA used a cost of $ 10,600 an acre ( or $ 1000/ acre annualized at 7% over 20 years). For low density residential land, EPA used a cost of $ 4,000 per acre ( or $ 377/ acre annualized at 7% over 20 years). The costs are averages ( updated to 2001 dollars using the Engineering News Record Construction Cost Index) of urban storm water retrofitting projects in Florida ( See Appendix G). EPA assumed that agriculture, forestry, and other undeveloped land uses contribute little to the metals impairments that occur in the creeks and did not estimate costs for these sources.

3.5 Estimating Pollutant Loading Reductions EPA calculated loading reductions by subtracting the estimated effluent loading ( the AML times the design flow and appropriate conversion factor) under the higher designated use from the estimated loading under the lower use. To calculate a current pollutant loading, EPA multiplied the maximum effluent concentration times the design flow and an appropriate conversion factor.

For toxic pollutants, EPA also calculated toxic weighted loading reductions by multiplying by toxicity weighting factors that standardize toxicity to the toxicity of copper ( U. S. EPA, 1988). Toxicity factors are derived primarily from EPA chronic freshwater aquatic criteria and toxicity values. However, EPA human health criteria also are used in cases in which EPA established a human health criterion for fish consumption. To calculate toxic pound equivalents for each pollutant, EPA multiplied the pollutant loading reduction for each facility by the appropriate toxic weight for that pollutant. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 13 4. Results This chapter provides a summary of the costs and pollutant loading reductions required for the six creeks to meet the different uses. More detailed stream and facility level results are provided in Appendix F.

4.1 Estimated Costs Exhibit 4 1 provides a summary of the estimated costs for each creek. As shown in the exhibit, the largest cost is associated with meeting the baseline use designation ( A& I). Costs to meet the baseline use reflect controls needed for point and nonpoint sources. Nonpoint source costs reflect municipal runoff controls ( see Appendix G). However, Jefferson County, in which Five Mile, Valley, and Village Creeks are located, is under a 1995 Consent Agreement with U. S. EPA to eliminate sanitary sewer overflows and frequent bypasses of the treatment facilities. Eliminating overflows and treatment bypasses may reduce or eliminate the need for the nonpoint source control costs shown. Incremental costs to meet a LWF use reflect controls needed for point sources to reduce loadings of toxic pollutants. Incremental costs to meet a F& W reflect controls needed for point sources to reduce conventional pollutants.

Exhibit 4 1. Estimated Annual Costs to Achieve Use Classifications1 ( Millions of Year 2001 Dollars)

Creek A& I2 LWF5 F& W6 Point Sources3 Nonpoint Sources4 Total Five Mile Creek 3.82 5.96 9.8 0 0.07 Opossum Creek 2.46 0 2.46 0.26 0.13 Pepperell Branch7 0 0 0 0 0.00 Shirtee Creek 0 0 0 0 0.07 Valley Creek 0.05 10.8 10.8 0 0.10 Village Creek 0.68 12.9 13.6 0 0.05 Total 7.01 29.6 36.7 0.26 0.42 1Reflects capital costs annualized at 7% over 20 years plus annual O& M costs. 2The creeks are currently designated for A& I use and thus this is the baseline for the rule. Costs attributable to meeting A& I use result from facilities not meeting their current permit limits or having permit limits that do not reflect A& I criteria. 3Costs reflect controls for industrial and municipal point sources to reduce toxic pollutants. 4Costs reflect municipal runoff controls ( see Appendix G). However, Jefferson County, in which Five Mile, Valley, and Village Creeks are located, is under a 1995 Consent Agreement with U. S. EPA to eliminate sanitary sewer overflows and frequent bypasses of the treatment facilities. Eliminating overflows and treatment bypasses may reduce or eliminate the need for the nonpoint source control costs shown. 5Costs reflect controls for industrial and municipal point sources to reduce toxic pollutants. 6Costs reflect controls for industrial and municipal point sources to reduce conventional pollutants. 7Controls ( and hence costs) may be required at the Westpoint Stevens facility on Pepperell Branch ( see Appendix F). Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 14 4.1.1 Five Mile Creek Analysis of available data indicate that both point and nonpoint sources would be necessary to meet designated uses along Five Mile Creek. However, most of the costs reflect a need for further controls to meet the baseline ( A& I) use.

Conventional Pollutants Fecal coliform numbers in Five Mile Creek exceed the geometric mean criterion of 200 per100 ml for a F& W use. The likely source of fecal coliforms is the Five Mile Creek WWTP. This facility does not have a limit for fecal coliforms and there are no effluent data for this pollutant. However, optimization of the existing chlorination process at the facility would likely reduce fecal coliform in the effluent to levels that would meet the F& W criterion.

Analysis of instream data on DO and facility discharges on Five Mile Creek indicates that no additional controls would be needed to meet a F& W criterion.

Toxic Pollutants Analysis of effluent monitoring data indicates that two industries on Five Mile Creek ( ABC Coke and Sloss Industries) that require additional controls to meet A& I acute aquatic life or human health criteria for PAHs, cyanide, ammonia, and metals ( See Appendix D for details of the ammonia analysis). Both facilities would comply with projected effluent limits with the addition of chemical oxidation. Sloss Industries would also require additional chemical precipitation to control discharges of metals and a detention basin to treat storm water for zinc. The addition of these controls to meet an A& I use would also allow both facilities to meet effluent limits based on either a LWF or F& W standard.

Instream data indicate that Five Mile Creek exceeds the human health criterion for mercury and mercury is commonly found in WWTP effluents. The Five Mile Creek WWTP would achieve the highest quality effluent for mercury with a waste minimization program that would reduce inputs to the plant at the source. This program is necessary to meet the A& I human health criterion for mercury. Development of a program would also ensure compliance with criteria required by LWF and F& W classifications.

Nonpoint Sources As shown in Exhibit 4 2, the instream concentrations of copper, mercury, lead, and zinc in Five Mile Creek exceed relevant acute, chronic, or human health criteria. Potential sources of these metals include combined sewer overflows and urban runoff. Jefferson County is under a 1995 Consent Agreement to reduce combined sewer overflows, but unsewered areas could also be contributing to instream exceedances of these pollutants. There is no basis for estimating resulting concentrations once combined sewer overflows are eliminated. To ensure that the different uses are met instream, the existing storm water management system in the area might need to be retrofit with storm water controls. Nonpoint source controls for Five Mile Creek may or may not be part of Phase I storm water program activities for the City of Birmingham. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 15 Exhibit 4 2. Estimated Annual Nonpoint Source Control Costs1 ( Millions of Year 2001 Dollars)

Creek Pollutants Requiring Controls A& I Cost LWF/ F& W Cost Five Mile Creek A& I2: copper, zinc, mercury LWF/ F& W3: lead 5.96 0 Opossum Creek None 0 0 Pepperell Branch No data 0 0 Shirtee Creek No data 0 0 Valley Creek A& I2: zinc, mercury F& W3: lead 10.8 0 Village Creek A& I2: zinc, mercury F& W3: lead 12.9 0 TOTAL 29.6 0 1Reflects capital costs annualized at 7% over 20 years. 2Pollutants which exceed the acute water quality criterion for more than 10% of all observations. 3Pollutants which exceed the chronic water quality criterion for more than 10% of all observations but do not exceed the acute criterion for more than 10% of all observations.

4.1.2 Opossum Creek Similar to Five Mile Creek, most of the costs for Opossum Creek reflect a need for further controls to meet the baseline ( A& I) use.

Conventional Pollutants There are no facilities that discharge fecal coliforms in Opossum Creek.

The current discharges of BOD, ammonia, and total Kjeldahl nitrogen from USX and the Koppers facilities will allow a 3 mg/ L A& I criterion as well as the 3/ 5 mg/ L LWF criterion to be met ( an ammonia discharge from Koppers Coke would be reduced to acceptable levels by controls for cyanide). USX would need to add activated sludge treatment to meet a year round 5 mg/ L F& W criterion. Appendix E provides details of the DO analysis for Opossum Creek.

Toxic Pollutants Analysis of discharge data indicate that Koppers Coke requires additional treatment to meet A& I cyanide criteria. With chemical oxidation at this facility, A& I criteria will be met instream. No additional controls would be necessary to meet either LWF or F& W criteria because the small additional reductions required ( less than 5% of the reductions required to meet A& I criteria) would be obtained with the treatment to achieve A& I criteria.

USX would need to reduce lead discharges to comply with criteria for both LWF and F& W uses. The addition of a chemical precipitation unit should allow discharges to be sufficiently reduced to meet projected effluent limits for lead. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 16 Nonpoint Sources Available data indicated that the revised effluent limits for point sources would allow the higher uses to be attained in Opossum Creek.

4.1.3 Pepperell Branch Analysis of available data indicate that there are no costs for this creek. However, as described below, data for the Westpoint Stevens facility are limited and prevent full analysis of this segment.

Conventional Pollutants No controls for fecal coliforms would be required on Pepperell Branch to achieve a F& W criterion.

Instream DO data indicate that oxygen levels are reduced near the Westpoint Stevens Opelika facility. Although there is insufficient information for a full assessment, the Westpoint Stevens Opelika facility may need additional controls to meet DO criteria for A& I, LWF, or F& W. Additional data are required to quantify the reductions needed and estimate controls and costs.

Toxic Pollutants There are no data that indicate that toxics would exceed appropriate criteria in Pepperell Branch. The Westpoint Stevens facility currently discharges at levels that comply with projected effluent limits for A& I, LWF, and F& W uses.

Nonpoint Sources There are no data on which to assess the need for nonpoint source controls for Pepperell Branch.

4.1.4 Shirtee Creek There are no costs associated with attaining A& I or LWF uses and only minimal costs to meet a F& W use on Shirtee Creek.

Conventional Pollutants Fecal coliform data indicate that the maximum allowable numbers of fecal coliform bacteria for a F& W use designation may be exceeded in Shirtee Creek. Process optimization of the chlorination/ dechlorination process at the Earl Ham WWTP should ensure that a F& W criterion will be met. A& I and LWF criteria for fecal coliforms are currently being attained.

Both Avondale Mills and the Earl Ham WWTP comply with a wasteload allocation that was developed in 1993 to determine loadings required to meet 5 mg/ L at all times. No additional controls are required. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 17 Toxic Pollutants Both Avondale Mills and Earl Ham WWTP appear to comply with projected effluent limits under a F& W use designation.

Nonpoint Sources There are no data with which to assess the need for nonpoint source controls for Shirtee Creek.

4.1.5 Valley Creek Costs for Valley Creek are primarily associated with meeting the baseline ( A& I) use. No additional costs are required to meet LWF and only minimal costs are associated with meeting F& W use.

Conventional Pollutants Analysis of discharges from the Valley Creek WWTP indicate that it marginally complies with a F& W criterion for fecal coliforms. Process optimization of chlorination should allow the criterion to be met instream.

Toxics Pollutants Valley Creek WWTP would not comply with projected effluent limits for hexavalent chromium and cyanide. The sources of these pollutants is likely indirect discharges from industrial facilities. Therefore, waste minimization programs for hexavalent chromium and cyanide at the Valley Creek WWTP should allow instream A& I criteria to be met. The reductions of these pollutants required to meet A& I use are large compared to the small additional reductions to meet projected effluents limits for LWF and F& W. The additional reductions will likely be met with the programs implemented to achieve A& I use.

Valley Creek exceeds the human health criterion for mercury. Although the Valley Creek WWTP is not know to discharge mercury, mercury is a common pollutant in POTW effluents. A waste minimization program for mercury would allow instream mercury criteria to be met. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 18 Nonpoint Sources Valley Creek exceeds A& I criteria for zinc and the lead and mercury LWF and F& W criteria ( Exhibit 4 2). Potential sources of these metals include combined sewer overflows and urban runoff. Jefferson County is under a 1995 Consent Agreement with U. S. EPA to reduce combined sewer overflows, but unsewered areas could also be contributing to instream exceedances of these pollutants. There is no basis for estimating resulting concentrations once combined sewer overflows are eliminated. To ensure that the different uses are met instream, the existing storm water management system in the area might need to be retrofit with storm water controls. Nonpoint source controls for Valley Creek may or may not be part of Phase I storm water activity for the City of Birmingham.

4.1.6 Village Creek Costs for Village Creek reflect controls on point and nonpoint sources to meet the baseline ( A& I) use.

Conventional Pollutants Instream data on fecal coliforms and DO below the discharges to Village Creek indicate that no additional controls would be needed to meet criteria for A& I, LWF, or F& W uses.

Toxic Pollutants American Cast Iron Pipe Company requires additional controls for copper and zinc to meet projected effluent limits based on A& I criteria and controls for lead to meet projected effluent limits based on LWF and F& W criteria. The addition of chemical precipitation should be adequate to control copper and zinc, and this treatment would incidentally remove lead to required levels to meet projected effluent limits for lead.

Village Creek WWTP requires controls to meet projected effluent limits based on A& I criteria for cyanide and hexavalent chromium. Since both are industrial pollutants, waste minimization programs would identify and reduce effluent concentrations to levels that would comply with projected limits. Because Village Creek exceeds the human health criterion for mercury and POTWs are a common source of mercury, a pollutant minimization program for mercury is also needed.

Nonpoint Sources Village Creek exceeds the A& I criteria for zinc and the LWF and F& W criteria for lead and mercury ( Exhibit 4 2). Potential sources of these metals include combined sewer overflows and urban runoff. Jefferson County is under a 1995 Consent Agreement with U. S. EPA to reduce combined sewer overflows, but unsewered areas could also be contributing to instream exceedances of these pollutants. There is no basis for estimating resulting concentrations once combined sewer overflows are eliminated. To ensure that the different uses are met instream, the existing storm water management system in the area might need to be retrofit with storm water Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 19 controls. Nonpoint source controls for Village Creek may or may not be part of Phase I storm water activity for the City of Birmingham.

4.2 Pollutant Loading Reductions Exhibits 4 3 through 4 5 present the estimated incremental pollutant loading reductions and annual costs associated with point source controls to meet the baseline use ( A& I), LWF, and F& W uses ( loading reductions and costs associated with nonpoint source controls are not included).

Exhibit 4 3. Estimated Annual Point Source Costs and Pollutant Load Reductions for an A& I Use Classification Segment Pollutant Reduction Cost Pounds Toxic Poundequivalents Total ( millions) Per Toxic Poundequivalent Five Mile Creek1 5,054 5,488 $ 3.79 $ 690.60 Opossum Creek 58,495 60,235 $ 2.46 $ 40.84 Pepperell Branch 0 0 $ 0 $ 0 Shirtee Creek 0 0 $ 0 $ 0 Valley Creek 4,330 153,715 $ 0.04 $ 0.26 Village Creek 1,574,159 1,768,574 $ 0.33 $ 0.19 Total 1,642,038 1,988,012 $ 6.62 $ 3.332 1Does not include reductions in ammonia at ABC Coke and Sloss because their current permit limit is more stringent than the projected A& I, LWF, and F& W limits ( costs reflect controls for other pollutants necessary to meet A& I and so are included). 2Represents sum of total costs divided by sum of toxic pound equivalents.

Exhibit 4 4. Estimated Annual Point Source Costs and Pollutant Load Reductions for an LWF Use Classification1 Segment Pollutant Reduction Cost Pounds Toxic Poundequivalents Total ( millions) Per Toxic Poundequivalent Five Mile Creek 0 0 $ 0 $ 0 Opossum Creek 1,013 1,823 $ 0.26 $ 142.59 Pepperell Branch 0 0 $ 0 $ 0 Shirtee Creek 0 0 $ 0 $ 0 Valley Creek 0 0 $ 0 $ 0 Village Creek 0 0 $ 0 $ 0 Total 1,013 1,823 $ 0.26 $ 142.59 1 Reductions and costs are additional to those to meet an A& I classification. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 20 Exhibit 4 5. Estimated Annual Point Source Costs and Pollutant Load Reductions for a F& W Use Classification1 Segment Pollutant Reduction Cost Pounds Toxic Poundequivalents Total ( millions) Per Toxic Poundequivalent Five Mile Creek 0 0 $ 0 $ 0 Opossum Creek 54,750 54,750 $ 0.13 $ 2.37 Pepperell Branch 0 0 $ 0 $ 0 Shirtee Creek 0 0 $ 0 $ 0 Valley Creek 0 0 $ 0 $ 0 Village Creek 0 0 $ 0 $ 0 Total 54,750 54,750 $ 0.13 $ 2.37 1 Reductions and costs are additional to those required to meet A& I and LWF classifications.

4.3 Limitations of the Analysis Exhibit 4 6 provides a summary of the limitations of the analysis. Data limitations are among the largest sources of uncertainty and may result in understating costs. However, EPA's method for calculating potential pollutant loading reductions required at permitted facilities ( i. e., comparing an average monthly effluent limit to a maximum effluent concentration) potentially overstates costs.

Exhibit 4 6. Biases and Uncertainties in the Analysis Assumption Potential Impact on Costs Comments Receiving water and effluent concentrations are limited and assumed to be zero if no data indicate otherwise. There are no data for organic pollutants in any of the streams and no data for metals in Pepperell Branch, Shirtee, and Opossum Creeks.   Receiving waters and effluents may contain low levels of pollutants that require facilities to install treatm ent to ensure instream criteria are met.

Required pollutant loading reductions are calculated by comparing the maximum effluent concentration to the average monthly limit. "+ Comparing maximum concentrations with average monthly limits overstates the required pollutant loading reductions.

POTWs will use waste minimization to reduce effluent concentrations rather than install treatm ent.   Additional treatment would cost considerably more than waste minimization programs at POTWs.

Treatment costs based on U. S. EPA ( 1980; 1993) and Truax ( 1992).

? Facilities may experience higher or lower actual treatment costs. In particular, use of U. S. EPA ( 1980) may result in overstated costs because of technological advances over the last 25 years. Use of engineering cost indices to update to current dollars can further magnify differences.

Capital costs annualized over 20 years. "+ The useful life of capital equipment is often more than 20 years so annual costs may be overstated.

Key: + = Costs are potentially overstated   = Costs are potentially understated ? = Affect on costs is unknown. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 21 5. References Alabama Department of Environmental Management ( ADEM). 1996. Waste Load Allocation for the USX WWTP Discharge to Opposum Creek near Fairfield. Montgomery, Alabama. August.

Alabama Department of Environmental Management ( ADEM). 2001. Waste Load Allocation for Valley Creek WWTP Assuming Fish and Wildlife Use Classification for Valley Creek. Montgomery, Alabama. February.

Alabama State Regulations. 2000. Chapter 335 6 10.

Applied Technology and Engineering, P. C. 1992. Shirtee Creek Wasteload Allocation Study. Prepared for Mr. Albert Chieves. Avondale Mills, Inc. Sylacauga, Alabama. January.

Livingston, Eric. 1999. A Review of Urban Stormwater Retrofitting in Florida. From: Comprehensive Stormwater & Aquatic Ecosystem Management, Proceedings of a Conference held in Auckland, New Zealand. February 22   26, 2999.

Rouge River National Wet Weather Demonstration Project Cost Estimating Guidelines. 2001. http:// www. wcdoe. org/ rougeriver/ pdfs/ stormwater/ sr10. pdf.

STORET Legacy. 2001. http:// epa. gov/ storet Truax, Dennis D. 1992. Optimization of Wastewater Treatment Plant Systems. Water Environment Research. 64( 4): 400   02.

U. S. EPA. 2001. Permit Compliance System.

U. S. EPA. 1999. 1999 Update of Ambient Water Quality Criteria for Ammonia. EPA 822 R 99 014. Washington, D. C. December.

U. S. EPA. 1993. Assessment of Compliance Costs Resulting from the Implementation of the Proposed Great Lakes Water Quality Guidance. Prepared by Science Applications International Corporation for U. S. EPA Office of Water, Office of Science and Technology.

U. S. EPA. 1991. Technical Support Document for Water Quality based Toxics Control. EPA/ 505/ 2 90 001. Washington, DC.

U. S. EPA. 1990. A Calibrated QUAL2E Model of Pepperell Branch and Sougahathee Creek, Volume II. Opelika, Alabama. September.

U. S. EPA. 1980. Treatability Manual Volume IV   Cost Estimating. EPA/ 600/ 8 80 042d. Washington, DC. July. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 22 U. S. EPA Office of Research and Development Risk Reduction Engineering Laboratory. RREL Treatability Database. Cincinnati, OH.

U. S. Geological Survey ( USGS). USGS National Water Information System. 2001. http:// water. usgs. gov. nwis. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 23 Appendices Appendix A. Facility Effluent Data Appendix B. Instream Water Quality Data Appendix C. Use Attainability Appendix D. Ammonia Toxicity Analysis Appendix E. Dissolved Oxygen Analysis Appendix F. Facility Analyses Appendix G. Nonpoint Source Control Costs Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 24 Appendix A. Facility Effluent Data Exhibit A 1. Facility Effluent Data Considered in Cost Analyses Facility Toxic Pollutants Evaluated Existing Perm it Limit? Conventional Pollutants Evaluated Existing Perm it Limit?

ABC Coke Benzene Benzo( a) pyrene Phenols Cyanide Yes Yes Yes No BOD DO Ammonia Kjeldahl Nitrogen Yes Yes Yes Yes American Cast Iron Pipe Company Copper Lead Zinc Phenols Yes Yes Yes Yes None N/ A Ashland Chemical BETX 1,1,2 Trichloroethane Dichloromethane Yes Yes Yes None N/ A Avondale Mills Copper Lead Phenols Zinc Yes Yes Yes Yes BOD DO Ammonia Kjeldahl Nitrogen Yes Yes Yes Yes Birmingham Steel None N/ A None N/ A Earl Ham WWTP Arsenic Cadmium Chromium Hexavalent Copper Lead Nickel Silver Cyanide Zinc No No No No No No No No No BOD DO Ammonia Yes Yes Yes Five Mile Creek WWTP None N/ A BOD DO Fecal Coliform Ammonia Kjeldahl Nitrogen Yes Yes No Yes Yes Koppers Industries  Woodward Tar Plant 1,1,1 Trichloroethane 1,1,2 Trichloroethane 1,1 Dichloroethane 1,1 Dichloroethylene 1,2,4 Trichlorobenzene 1,2 Dichlorobenzene 1,2 Dichloroethane 1,2 Dichloropropane 1,2 Trans Dichloroethylene 1,3 Dichloropropene 1,3 Dichlorobenzene 1,4 Dichlorobenzene 2,4 Dichlorophenol 2,4 Dimethlyphenol Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes BOD DO Ammonia Kjeldahl Nitrogen Yes Yes Yes Yes Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama Facility Toxic Pollutants Evaluated Existing Perm it Limit? Conventional Pollutants Evaluated Existing Perm it Limit?

25 2,4 Dinitrophenol 2,4 Dinitrotuluene 2,6 Dinitrotoluene 2 Chlorophenol 2 Nitrophenol 3,4 Benzofluoranthene 4,6 Dinitro O Cresol 4 Nitrophenol Acnepahthene Acenaphthylene Acrylonitirle Anthracene Benzene Benzo( a) anthracene Benzo( a) pyrene Benzo( k) fluoranthene Bis( 2 Ethlyhexyl) Phthalate Carbon Tetrachloride Chlorobenzene Chloroethane Chloroform Chromium ( as Cr) Chrysene Copper ( as Cu) Cyanide ( as Cn) Di n Butyl Phthalate Diethyl Phthalate Dimethyl Phthalate Ethylbenzene Fluoranthene Fluorene Hexachlorobenzene Hexachlorobutadiene Hexachloroethane Lead ( as Pb) Methyl Chloride Methylene Chloride Naphthalene Nickel, ( as Ni) Nitrobenzene Phenanthrene Phenol, Single Compound Pyrene Tetrachloroethylene Toluene Trichloroethyleen Vinyl Chloride Zinc ( as Zn) Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes No Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama Facility Toxic Pollutants Evaluated Existing Perm it Limit? Conventional Pollutants Evaluated Existing Perm it Limit?

26 Koppers Industries  Woodward Coke Plant Benzene Benzo( a) pyrene Phenols Cyanide Yes Yes Yes Yes BOD DO Ammonia Kjeldahl Nitrogen Yes Yes Yes Yes Sloss Industries 2,4 Dimethylphenol Benzo( a) anthracene Benzo( a) pyrene Benzo( b) fluoranthene Benzo( k) fluoranthene Chlorobenzene Chrysene Fluoranthene Flourene Pyrene Phenols Toluene Copper Cyanide Lead Nickel Zinc Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes BOD DO Ammonia Kjeldahl Nitrogen Yes Yes Yes Yes USX  Fairfield Works Benzene Benzo( a) pyrene Chromium Hexavalent Phenols Tetrachloroethylene Lead Zinc Cyanide No No Yes Yes Yes Yes Yes Yes BOD DO Ammonia Kjeldahl Nitrogen Yes Yes Yes Yes Valley Creek WWTP Chromium Hexavalent Cyanide No No BOD DO Fecal Coliform Ammonia Kjeldahl Nitrogen Yes Yes Yes Yes Yes Westpoint Stevens Opelika Finishing Plant Phenols Chromium Yes Yes BOD DO Ammonia Yes Yes Yes Honeywell International 1,1,2 Trichloroethane 1,1 Dichloroethane 1,1 Dichloroethylene 1,2 Dichlorobenzene 1,2 Dichloroethane 1,2 Dichloropropane 1,2 Trans Dichloroethylene 1,3 Dichloropropene 1,3 Dichlorobenzene 1,4 Dichlorobenzene 2,4 Dichlorophenol 2,4 Dimethlyphenol Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes BOD Ammonia Yes Yes Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama Facility Toxic Pollutants Evaluated Existing Perm it Limit? Conventional Pollutants Evaluated Existing Perm it Limit?

27 2,4 Dinitrophenol 2,4 Dinitrotoluene 2 Chlorophenol Acenaphthene Acenaphthylene Acrylonitrile Anthracene Benzene Benzo( a) anthracene Benzo( a) pyrene Benzo( k) fluoranthene Bis( 2 Ethylhexyl) phthalate Carbon Tetrachloride Chlorobenzene Chloroform Chrysene Di N Butylphthalate Diethylphthalate Demethylphthalate Ethylbenzene Fluoranthene Fluorene Hexachloroethane Methylene Chloride Nitrobenzene Phenols Pyrene Tetrachloroethylene Toluene Copper Cyanide Lead Nickel Zinc Trichloroethylene Vinyl Chloride Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes No No No Yes Yes SMI Steel Lead Zinc Yes Yes None N/ A Village Creek WWTP Hexavalent Chromium Cyanide No No BOD DO Fecal Coliform Ammonia Yes Yes Yes Yes Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 28 Appendix B. Instream Water Quality Data Exhibit B 1 summarizes the data available for assessing water quality and developing water quality based effluent limits. Some stations, however, contain only very old data ( earlier than 1980) and/ or have so few observations that the data are inconclusive. Exhibits B 2 through B 5 provide maps and station locations for four of the creeks.

Exhibit B 1. Stream Data Considered in Cost Analyses Station Conventional Pollutants Toxic Pollutants Five Mile Creek2 FIVEMILECREEK01 Ammonia, Water Temperature, BOD, Kjeldahl Nitrogen, DO Ammonia FIVEMILECREEK02 Ammonia Nitrogen, Water Temperature, BOD, DO, Kjeldahl Nitrogen Ammonia FMC 01 Ammonia, Kjeldahl Nitrogen, Water Temperature, Hardness, DO, BOD Ammonia FMC 02 Water Temperature, Ammonia, DO, Hardness, BOD, Kjeldahl Nitrogen Cyanide, Chromium, Recoverable Phenolics, Lead, Cadmium, Copper, Nickel, Zinc FMC 03 BOD, Kjeldahl Nitrogen, DO, Hardness, pH, Ammonia, Water Temperature Recoverable Phenolics 010359C Hardness ( calculated), Kjeldahl Nitrogen, DO, Water Temperature, Ammonia Nitrogen Zinc, Lead, Thallium, Cobalt, Manganese, Aluminum, Cadmium, Cyanide, Copper, Silver, Iron, Chromium, Nickel, Antimony, Mercury, Selenium, Arsenic FM1 BOD, Kjeldahl Nitrogen, DO, pH, Ammonia, Fecal Coliform, Water Temperature, Water Temperature, Hardness Phenols, Cyanide, Aluminum, Arsenic, Copper, Zinc, Mercury, Manganese, Lead, Cadmium, Chromium, Iron FMC 04 Ammonia, DO, Water Temperature, DO, Kjeldahl Nitrogen, Hardness, pH Copper, Cadmium, Chromium, Lead, Zinc, Cyanide, Nickel, Recoverable Phenolics 010359B Ammonia, Water Temperature, Kjeldahl Nitrogen, Hardness ( calculated), pH, DO Nickel, Beryllium, Chromium, Manganese, Lead, Mercury, Iron, Zinc, Copper, Thallium, Cyanide, Silver, Antimony, Selenium, Arsenic, Aluminum, Cadmium FMC 05 Kjeldahl Nitrogen, DO, Water Temperature, Hardness, BOD, pH, Ammonia FMC 06 Kjeldahl Nitrogen, Ammonia, Water Temperature, DO, BOD, pH Cadmium, Cyanide, Lead, Zinc, Nickel, Chromium, Copper, Recoverable Phenolics FMC 07 Ammonia, pH, Water Temperature, DO, BOD, Kjeldahl Nitrogen, DO, Hardness FM2 Water Temperature, DO, Kjeldahl Nitrogen, pH, Fecal Coliform, Ammonia, Hardness, BOD Lead, Zinc, Copper, Cadmium, Mercury, Cyanide, Phenols, Chromium, Arsenic 010359A Copper, Lead, Lindane, Nickel, Heptachlor, Chromium, Heptachlor Epoxide, Toxaphene, Cadmium, 4,4 DDD, PCB 1260, PCB 1254, Aldrin, PCB 1242, Dieldrin, Endrin, 4,4 DDE Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama Station Conventional Pollutants Toxic Pollutants 29 FMC 12 Ammonia, Water Temperature, Kjeldahl Nitrogen, pH, BOD, DO FMC 13 Ammonia, Kjeldahl Nitrogen, Water Temperature, DO, pH, Hardness Lead, Chromium, Cyanide, Cadmium, Nickel, Copper, Recoverable Phenolics FMC 14 ( Unnamed Tributary) Ammonia, Kjeldahl Nitrogen, Water Temperature, Hardness, pH, BOD, DO Lead, Cadmium, Chromium, Copper, Zinc, Nickel FMC 15 DO, Hardness, Ammonia, Kjeldahl Nitrogen, BOD, pH, Water Temperature Lead, Cadmium, Nickel, Copper, Chromium, Zinc FMC 16 Ammonia, Kjeldahl Nitrogen, Water Temperature, DO, Hardness, BOD Lead, Copper, Cyanide, Zinc, Chromium, Cadmium, Recoverable Phenolics, Nickel Opossum Creek 010359O Hardness, DO, pH, Water Tem perature Chromium, Copper, Cyanide, Lead, Nickel, Zinc 010359P Hardness, DO, pH, Water Tem perature Chromium, Copper, Cyanide, Lead, Nickel, Zinc 010359Q Hardness, DO, pH, Water Tem perature Chromium, Copper, Cyanide, Lead, Nickel, Zinc OC 1 DO, pH, Water Tem perature OC 3 DO, pH, Water Tem perature OC 4 DO, pH, Water Tem perature OPOSSUMCREEK01 Fecal Coliform, DO, pH, Water Temperature Pepperell Branch WPP35 DO, pH, Water Tem perature WPP36 DO, pH, Water Tem perature WPP37 DO, pH, Water Tem perature WPP39 DO, pH, Water Tem perature WPP40 DO, pH, Water Tem perature WPP41 DO, pH, Water Tem perature WPP39A DO, pH, Water Tem perature PEPPERELLBR01 DO, pH, Water Temperature, Ammonia, Kjeldahl Nitrogen PEPPERELLBR02 DO, pH, Water Temperature, Fecal Coliform, Ammonia, Kjeldahl Nitrogen PEPPERELLBR03 DO, pH, Water Temperature, Ammonia, Kjeldahl Nitrogen PEPPERELLBR04 DO, pH, Water Temperature, Ammonia, Kjeldahl Nitrogen PEPPERELLBR05 DO, pH, Water Temperature, Ammonia, Kjeldahl Nitrogen PEPPERELLBR06 DO, pH, Water Temperature, Ammonia, Kjeldahl Nitrogen Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama Station Conventional Pollutants Toxic Pollutants 30 Shirtee Creek SHIRT11 Water Temperature, pH, DO, Kjeldahl Nitrogen, BOD SHIRT12 Water Temperature, pH, DO, Kjeldahl Nitrogen, BOD SHIRTEE01 Water Temperature, pH, DO, Kjeldahl Nitrogen, Ammonia , BOD SHIRTEE02 Water Temperature, pH, DO, Kjeldahl Nitrogen, Ammonia, BOD SHIRTEE03 Water Temperature, pH, DO, Kjeldahl Nitrogen, Ammonia, Fecal Coliform, BOD SHIRTEECREEK012 Water Temperature, pH, DO, Kjeldahl Nitrogen, Ammonia SHIRTEECREEK02 Water Temperature, pH, DO, Kjeldahl Nitrogen, Ammonia, BOD SHIRTEECREEK03 Water Temperature, pH, DO Kjeldahl Nitrogen, BOD Valley Creek 010359J DO, Water Temperature 010359K DO, Water Temperature 010359L DO, Water Temperature 010359M DO, Water Temperature 010359N DO, Water Temperature 02462000 DO, Water Temperature VA1 Fecal Coliform, DO, Water Tem perature VALLEYCREEK02 DO, Water Temperature VC 10 DO, Water Temperature VC 11 DO, Water Temperature VC 5 Fecal Coliform, DO, Water Tem perature VC 6 DO, Water Temperature VC 7 DO, Water Temperature VC 8 DO, Water Temperature VC 9 DO, Water Temperature Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama Station Conventional Pollutants Toxic Pollutants 31 Village Creek3 2460500 Ammonia, DO, Fecal Coliform, Hardness, pH, Water Temperature Arsenic, Cadm ium, Chrom ium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Zinc VI1 Ammonia, DO, Fecal Coliform, Hardness, pH, Water Temperature Chromium, Copper, Cyanide, Lead, Mercury, Phenols, Zinc 010359E Ammonia, Water Temperature, pH, DO, hardness Antimony, Chloroform, Chrom ium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Zinc 010359F Ammonia, DO, hardness, pH, Water Temperature Antimony, Chromium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Zinc 010359G Ammonia, DO, hardness, pH, Water Temperature Antimony, Chromium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Zinc 010359H Ammonia, DO, hardness, pH, Water Temperature Antimony, Chromium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Zinc 010359I Ammonia, DO, hardness, pH, Water Temperature Antimony, Chromium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Zinc VILLAGECREEK01 Ammonia, DO, pH, Water Tem perature VILLAGECREEK02 Ammonia, DO, Fecal Coliform, pH, Water Temperature VILLAGECREEK03 Ammonia, DO, Fecal Coliform, pH, Water Temperature 1No data exist for stations 2457595, 245700, 010359D shown in Exhibit B 2 2The exact location of station SHIRTEECREEK01 is unknown and so it is not shown in Exhibit B 3. 3Stations 2458203, 2458300, and 2458375 shown in Exhibit B 5 only contain flow data. Note: Blank cells indicate that no data are available. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 32 Exhibit B 2. Five Mile Creek Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 33 Exhibit B 3. Shirtee Creek Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 34 Exhibit B 4. Valley Creek Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 35 Exhibit B 5. Village Creek Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 36 Appendix C. Use Attainability This appendix describes the methods EPA used to evaluate the attainability of different use classifications among the stream segments and the results of the evaluation.

C. 1 Methods C. 1.1 Conventional Pollutants EPA evaluated four conventional pollutants: fecal coliforms and those pollutants affecting DO levels in receiving waters [ DO, biochemical oxygen demand ( BOD), and ammonia].

Fecal Coliforms EPA downloaded all data on fecal coliform bacteria for the affected stream segments from the STORET Legacy system. In general, samples are too infrequent ( e. g., less than five per month) to evaluate compliance with Alabama water quality criteria. Therefore, EPA compared individual observations and geometric means with the criteria to evaluate current attainment of A& I, LWF, and F& W criteria. If a geometric mean between June and September exceeds 200 per100 ml, or a geometric mean in other months exceeded 1,000 per100 ml, F& W is not currently being attained. These data also provide some indication of whether point source and upstream nonpoint source controls could be used to achieve attainment.

Dissolved Oxygen EPA downloaded DO, BOD, and ammonia data from the STORET Legacy system. EPA assumed that only the most recent data ( since 1980) reflect current stream conditions, although the data series covered the period since the early 1970s for some stations on some segments. This assumption is justified because early data represent stream conditions prior to substantial improvements in pollution control technology and the closing of several facilities that had a negative impact on water quality in several segments. EPA compared DO concentrations to the 5 mg/ L minimum DO criterion for F& W. If the criterion is not currently being attained, then EPA determined if the criterion would be attained with control of point sources through modeling of instream concentrations with a steady state Streeter Phelps model. If, even with the control of point sources, an instream DO criterion would not be met, EPA concluded nonpoint source controls for BOD would be required.

C. 1.2 Toxic Pollutants EPA evaluated toxic pollutants by comparing instream concentrations of priority pollutants and ammonia with the most stringent of the acute aquatic life, chronic aquatic life, and human health criteria ( organisms only). If the instream data indicated compliance with the instream criteria ( based on the mean of the detected samples), EPA calculated revised effluent limits for point sources and assumed that nonpoint source controls would not be needed. However, if the instream data indicated consistent noncompliance with instream criteria ( based on mean of the Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 37 detected samples), and EPA could not attribute these exceedences to point source discharges, it assumed that nonpoint source controls would also be required.

C. 2 Results C. 2.1 Five Mile Creek Data are available for stations FM1 and FM2 for Five Mile Creek covering more than the last 20 years. EPA used only data since 1980 because earlier data do not represent current stream conditions. Station FM1, which is located above all point source discharges, has a mean DO of 8.7 ( 191 observations), and 2.6% of these observations are less than 5 mg/ L ( Exhibit C 1 and Exhibit C 2). Station FM2, which is located among several point source discharges, has a mean DO of 8.48 mg/ L and 1.4% of observations are less than 5 mg/ L( Exhibit C 3 and Exhibit C 4). Therefore, Five Mile Creek is attaining a 5 mg/ L F& W standard for DO.

Fecal coliform data are available for stations FM1 and FM2 for Five Mile Creek. At station FM1, which is upstream of all dischargers on this segment, 3.4% of the 88 observations from May 1989 to October 1998 exceed the F& W maximum criterion of 2,000 per 100 ml. The geometric mean for this station is 145 per 100 ml for all observations, well below the minimum 200 per 100 ml F& W criterion. At station FM2, which is below many dischargers, including the Jefferson County Five Mile Creek WWTP, 5.7% of the 87 observations from June 1989 to October 1998 exceed the F& W maximum criterion of 2,000 per 100 ml. The geometric mean for this station is 232 per 100 ml for all observations, but is well below the year round F& W geometric mean requirement of 1,000 per 100 ml. The geometric mean between June and September of 363 per 100 ml exceeds the F& W requirement for this period of 200 per 100 ml. Therefore, the stream segment is currently meeting the LWF standard, and a F& W standard could be attained with additional control of the wastewater treatment plant effluent.

Two stations on File Mile Creek have data for toxic pollutants: FM1 and FM2. As indicated in Exhibits C 1 and C 3, Five Mile Creek waters exceed criteria for several toxic pollutants: arsenic, cadmium, copper, cyanide, lead, mercury, and zinc. Cyanide, mercury, and zinc exceed criteria in more than 10% of samples at both stations and copper exceeds criteria in more than 10% of samples at station FM1 ( the upstream station). The downstream station ( FM2) is near several facilities that discharge some of the pollutants with concentrations exceeding the criteria. However, even with control of these discharges, some pollutants ( such as mercury) may continue to exceed criteria because the facilities do not have limits for these pollutants. Additional controls on urban runoff will be necessary for Five Mile Creek to attain either LWF or F& W standards. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 38 Exhibit C 2. Five Mile Creek, Station FM1 Exhibit C 1. Toxic Pollutant Concentrations and Criteria Exceedances at Station FM1 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia, Unionized ( calculated) mg/ L 4 100.0 0.0019 0 0 a Ammonia, Unionzed mg/ L 4 100.0 0.0016 0 0 a Arsenic, Total µ g/ L 51 7.8 10 4 7.8 0.3 Cadmium, Total µ g/ L 56 1.8 5.0 1 1.8 2.04 Chromium, Total µ g/ L 65 10.8 25 0 0 382.5 Copper, Total µ g/ L 68 22.1 167 13 19.1 22.4 Cyanide, Total mg/ L 54 48.1 0.028 23 42.6 0.0052 Lead, Total µ g/ L 54 3.7 17 2 3.7 8.26 Mercury, Total µ g/ L 45 15.6 2.0 7 15.6 0.012 Phenols mg/ L 60 15.0 4.6 0 0 106 Zinc, Total µ g/ L 11 81.8 249 5 45.5 200 a   Criteria based on pH and temperature. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 39 Exhibit C 4. Five Mile Creek, Station FM2 Exhibit C 3. Toxic Pollutant Concentrations and Criteria Exceedances at Station FM2 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia, Unionized ( calculated) mg/ L 4 100.0 0.0012 0 0 a Ammonia, Unionzed mg/ L 4 100.0 0.00099 0 0 a Arsenic, Total µ g/ L 56 5.4 203 3 5.4 0.3 Cadmium, Total µ g/ L 60 0 0 2.04 Chromium, Total µ g/ L 64 4.7 9.7 0 0 382.5 Copper, Total µ g/ L 64 9.4 61 3 4.7 22.4 Cyanide, Total mg/ L 58 41.4 0.037 23 39.7 0.0052 Lead, Total µ g/ L 59 7.8 10 2 3.4 8.26 Mercury, Total µ g/ L 51 17.6 5.3 9 17.6 0.012 Phenols mg/ L 56 3.6 0.075 0 0 106 Zinc, Total µ g/ L 4 25.0 280 1 25.0 200 a   Criteria based on pH and tem perature Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 1The single point source may have already reduced discharges sufficiently to attain the standard.

40 C. 2.2 Opossum Creek Opossum Creek has six stations with DO data, but the number of observations is limited at each ( the station with the most observations has seven). With one exception, all of the data were taken between 1985 and 1989. The maximum average concentration for these stations is 7.3 mg/ L and the minimum average concentration is 1.3 mg/ L. At all stations, between 43% and 100% of observations are below 5 mg/ L. The most recent and only data point in the 1990s ( in 1998), is compliant with a 5 mg/ L criterion. A wasteload allocation study for Valley Creek conducted by ADEM ( 1996) indicates that although a 5 mg/ L criterion would be met in Valley Creek, it would not be met in Opossum Creek without substantial load reductions from the USX Fairfield Plant. To calculate the load reductions required at USX Fairfield to meet the F& W standards, EPA ran a steady state Streeter Phelps DO model based on the results from the ADEM Valley Creek model. Appendix E summarizes the methods and results of the analysis.

A single data point is available for Opossum Creek for fecal coliforms: 1,200 per 100 ml in August 1998. There are not sufficient data to determine compliance with any fecal coliform standard.

A single sample was taken at each of three stations on Opossum Creek for chromium, copper, cyanide, lead, nickel, and zinc. Chromium, copper, lead, and nickel were not detected at any station. Cyanide was detected at two of the three stations, and one value exceeds the acute criterion. Zinc samples all meet the criterion.

C. 2.3 Pepperell Branch There are several thousand DO observations of Pepperell Branch since 1980. Most of the observations ( 5,920 out of 6,944) and most of the stations ( 7 out of 10) indicate less than 5% of samples are less than 5 mg/ L. The remaining observations and remaining stations have 17.5, 33, and 40% of observations under 5 mg/ L, but the latter two values are for stations with 6 observations. Exhibits C 4 through C 11 summarize DO observations at the stations. Although the exact location of the stations on Pepperell Branch is uncertain, data indicate that sampling occurred three times a week at a number of stations downstream of the Westpoint Stevens facility. Only one of these stations indicates a relatively high number of values less than 5 mg/ L. Thus, with control of the single point source, 1 a 5 mg/ L standard is attainable in Pepperell Branch.

Fecal Coliform data are available for station PEPPERELLBR02. Of the six observations taken between June 1997 and October 1998, all were less than 2,000 per 100 ml. The geometric mean of all observations is 177 per 100 ml, and the geometric mean of all observations between June and September is 208 per 100 ml. Pepperell Branch essentially complies with a F& W standard at present.

No toxic data have been taken in Pepperell Branch. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 41 Exhibit C 5. Pepperell Branch, Station WPP 35 Exhibit C 6. Pepperell Branch, Station WPP 36 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 42 Exhibit C 7. Pepperell Branch, Station WPP 37 Exhibit C 8. Pepperell Branch, Station WPP 39 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 43 Exhibit C 9. Pepperell Branch, Station WPP 39A Exhibit C 10. Pepperell Branch, Station WPP 40 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 44 Exhibit C 11. Pepperell Branch, Station WPP 41 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 45 Exhibit C 12. Shirtee Creek, Station SHIRTEE03 C. 2.4 Shirtee Creek There are 7 stations on Shirtee Creek with limited data ( maximum 11 observations). Most of the samples were taken in the mid to late 1980s and were frequently less than 5 mg/ L. Data taken from 1997 and 1998, however, all were greater than 5 mg/ L, as shown in Exhibit C 12. In addition, a wasteload allocation study performed for Avondale Mills in 1993 indicated that a 5 mg/ L DO standard is attainable with control of point sources.

Fecal coliform data are available for station SHIRTEE03. Out of six observations taken between June 1997 and October 1998, 1 exceeded the F& W maximum criterion of 2,000 per 100 ml. The geometric mean of all observations is 205 per 100 ml and the geometric mean of observations between June and September is 393 per 100 ml. Except for the single exceedance of 2,000 per 100 ml, a LWF standard is currently being attained in Shirtee Creek. A F& W standard could be attained with further controls at the Earl Ham WWTP.

No toxic pollutant data have been taken in Shirtee Creek. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 46 C. 2.5 Valley Creek There are 15 stations on Valley Creek with DO data. The two stations with the largest number of observations, VA1 and 2462000, are several miles downstream of all discharges. Both of these stations indicate that F& W DO standards are currently being met for this part of this creek. In the area of the Valley Creek WWTP, there are several stations, but all but one of the stations has limited ( less than 10) observations, most of which are from the mid to late 1980s. DO observations for the station for which data exists is summarized in Exhibit C 13. All of these stations indicate that F& W DO criteria were not being met at that time. ADEM, however, has developed a Streeter Phelps model for Valley Creek ( ADEM, 2001) and the model output indicates that a 5 mg/ L DO level is attainable. Data from EPA Region IV, covering 2000 and part of 2001, indicate an LWF standard is achievable at all but the uppermost station ( above the Valley Creek WWTP).

Ninety fecal coliform samples were taken at station VA1 between February 1986 and October 1998. Six of these samples ( 6.7%) exceeds 2,000 per 100 ml. The overall geometric mean is 191 per 100 ml, with a geometric mean of 224 per 100 ml during the months between June and September. Four samples were taken at station VC5 between June 1997 and October 1998. The geometric mean of these samples is 586 per 100 ml. Eight fecal coliform samples were taken at each of three stations in 2000 and 2001. All of the samples at the upstream station ( above Valley Creek WWTP) exceed 1000 per 100 mL by a large margin. The geometric mean of the upstream station exceeds 10,000 per 100 mL. The two downstream stations exceed 1000 per 100 mL two or more times ( three times at the station below Valley WWTP), but have geometric means of 472 per 100 mL ( above Valley Creek WWTP) and 252 per 100 mL ( below Valley Creek WWTP). Therefore, the fecal coliforms are most likely attributable to nonpoint sources.

A limited number of samples have been taken for toxic pollutants in 2000 and 2001 at 3 stations ( Exhibits C 14   C 17). The chronic criteria for a variety of PAHs are exceeded on at least one occasion at the uppermost station ( above the Valley Creek WWTP). At the intermediate station, there is one exceedance each for copper, mercury, lead, and zinc. At the lowermost station, two PAHs have one exceedance in three samples and lead exceeds the chronic criterion in two out of six samples. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 47 Exhibit C 13. Toxic Pollutant Concentrations and Criteria Exceedances at Station VAL 1 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia dissolved mg/ L 10 100.0 0.218 0 0.0 1.23 Arsenic µ g/ L 6 50.0 2.45 0 0.0 190 Cadmium µ g/ L 6 66.7 0.140 0 0.0 1.58 Chromium µ g/ L 6 66.7 2.62 0 0.0 292 Copper µ g/ L 6 100.0 7.61 0 0.0 16.9 Lead µ g/ L 6 100.0 6.21 2 33.3 5.43 Mercury µ g/ L 6 0.0 N/ A 0 0.0 0.012 Nickel µ g/ L 6 50.0 2.02 0 0.0 225 Selenium µ g/ L 6 0.0 N/ A 0 0.0 5.0 Silver µ g/ L 6 50.0 1.14 0 0.0 8.36 Zinc µ g/ L 6 66.7 63.6 0 0.0 151 Acenaphthene µ g/ L 5 20.0 0.0218 0 0.0 579 Anthracene µ g/ L 5 60.0 0.0460 0 0.0 23,333 Benz( a) anthracene µ g/ L 5 20.0 0.189 1 20.0 0.067 Benzo( a) pyrene µ g/ L 5 40.0 0.124 1 20.0 0.067 Benzo( b) fluoranthene µ g/ L 5 40.0 0.283 1 20.0 0.067 Benzo( k) fluoranthe77ne µ g/ L 5 40.0 0.209 1 20.0 0.067 Chrysene µ g/ L 5 60.0 0.165 1 20.0 0.067 Dibenzanthracene µ g/ L 5 0.0 N/ A 0 0.0 0.067 Fluoranthene µ g/ L 5 80.0 0.233 0 0.0 81 Fluorene µ g/ L 5 40.0 0.0439 0 0.0 3,111 Indeno( 1,2,3 cd) pyrene µ g/ L 5 40.0 0.1388 1 20.0 0.067 Pyrene µ g/ L 5 80.0 0.197 0 0.0 2,333 Dieldrin µ g/ L 4 0.0 N/ A 0 0.0 0.0019 Lindane µ g/ L 4 0.0 N/ A 0 0.0 0.08 p, p' DDE µ g/ L 4 0.0 N/ A 0 0.0 0.00128 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 48 Exhibit C 14. Toxic Pollutant Concentrations and Criteria Exceedances at Station VAL 2 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia dissolved mg/ L 11 81.8 0.0740 0 0.0 0.401 Arsenic µ g/ L 6 83.3 3.10 0 0.0 190 Cadmium µ g/ L 6 16.7 0.233 0 0.0 1.85 Chromium µ g/ L 6 83.3 3.78 0 0.0 345 Copper µ g/ L 6 100.0 13.2 1 16.7 20.2 Lead µ g/ L 6 50.0 25.9 1 16.7 7.05 Mercury µ g/ L 6 16.7 N/ A 1 16.7 0.012 Nickel µ g/ L 6 16.7 1.70 0 0.0 268 Selenium µ g/ L 6 0.0 N/ A 0 0.0 5.0 Silver µ g/ L 6 16.7 0.210 0 0.0 11.9 Zinc µ g/ L 6 33.3 79.1 1 16.7 180 Acenaphthene µ g/ L 4 75.0 0.0202 0 0.0 579 Anthracene µ g/ L 4 50.0 0.0271 0 0.0 23,333 Benz( a) anthracene µ g/ L 4 0.0 N/ A 0 0.0 0.067 Benzo( a) pyrene µ g/ L 4 0.0 N/ A 0 0.0 0.067 Benzo( b) fluoranthene µ g/ L 4 0.0 N/ A 0 0.0 0.067 Benzo( k) fluoranthene µ g/ L 4 0.0 N/ A 0 0.0 0.067 Chrysene µ g/ L 4 25.0 0.0265 0 0.0 0.067 Dibenzanthracene µ g/ L 4 0.0 N/ A 0 0.0 0.067 Fluoranthene µ g/ L 4 100.0 0.0398 0 0.0 81 Fluorene µ g/ L 4 75.0 0.0178 0 0.0 3,111 Indeno( 1,2,3 cd) pyrene µ g/ L 4 0.0 N/ A 0 0.0 0.067 Pyrene µ g/ L 4 100.0 0.0389 0 0.0 2,333 Dieldrin µ g/ L 3 0.0 N/ A 0 0.0 0.0019 Lindane µ g/ L 3 0.0 N/ A 0 0.0 0.08 p, p' DDE µ g/ L 3 0.0 N/ A 0 0.0 0.00128 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 49 Exhibit C 15. Toxic Pollutant Concentrations and Criteria Exceedances at Station VAL 3 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia dissolved mg/ L 10 60.0 0.0392 0 0.0 0.544 Arsenic µ g/ L 6 66.7 2.47 0 0.0 190 Cadmium µ g/ L 6 33.3 0.147 0 0.0 1.64 Chromium µ g/ L 6 50.0 2.01 0 0.0 304 Copper µ g/ L 6 100.0 4.68 0 0.0 17.7 Lead µ g/ L 6 83.3 7.05 2 33.3 5.79 Mercury µ g/ L 6 0.0 N/ A 0 0.0 0.012 Nickel µ g/ L 6 16.7 1.70 0 0.0 235 Selenium µ g/ L 6 0.0 N/ A 0 0.0 5.0 Silver µ g/ L 6 16.7 0.210 0 0.0 9.12 Zinc µ g/ L 6 50.0 39.6 0 0.0 158 Acenaphthene µ g/ L 3 33.3 0.0260 0 0.0 579 Anthracene µ g/ L 3 33.3 0.0498 0 0.0 23,333 Benz( a) anthracene µ g/ L 3 33.3 0.0662 0 0.0 0.067 Benzo( a) pyrene µ g/ L 3 33.3 0.0600 0 0.0 0.067 Benzo( b) fluoranthene µ g/ L 3 33.3 0.105 1 33.3 0.067 Benzo( k) fluoranthene µ g/ L 3 33.3 0.0444 0 0.0 0.067 Chrysene µ g/ L 3 66.7 0.0433 1 33.3 0.067 Dibenzanthracene µ g/ L 3 0.0 N/ A 0 0.0 0.067 Fluoranthene µ g/ L 3 66.7 0.0915 0 0.0 81 Fluorene µ g/ L 3 33.3 0.0224 0 0.0 3,111 Indeno( 1,2,3 cd) pyrene µ g/ L 3 33.3 0.0512 0 0.0 0.067 Pyrene µ g/ L 3 66.7 0.0761 0 0.0 2,333 Dieldrin µ g/ L 3 0.0 N/ A 0 0.0 0.0019 Lindane µ g/ L 3 0.0 N/ A 0 0.0 0.08 p, p' DDE µ g/ L 3 0.0 N/ A 0 0.0 0.00128 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 50 C. 2.6 Village Creek There is one station that has a long data series for DO on Village Creek   station VI1. While data from this station indicate that a F& W standard is now being met ( only one value below 5 mg/ L has occurred in the last 10 years), this station is probably not representative of the creek as a whole because it is downstream of the lake. There are limited data upstream of the discharges, and data from VILLAGECREEK02 ( Exhibit C 15) indicate that 2 of 4 samples in 1988 were below 5 mg/ L ( 4.4 and 4.1 mg/ L). Both of the 1998 samples at this station exceed 5 mg/ L. In general, it appears that Village Creek could currently attain a F& W standard for DO, but the data are too limited for an accurate assessment in the area of the discharges. Data from EPA Region IV for 2000 and 2001 indicate a F& W standard is currently being met.

Fecal coliform data are available for station VI1 for the period from June to October 1998. Of the 96 samples taken, 2 ( 2.1%) exceed 2,000 per 100 ml. The geometric mean of all observations is 45 per 100 ml and the geometric mean of all observations between June and September is 39 per 100 ml. Village Creek now complies with a F& W fecal coliform standard at station VI1. Very limited data, one observation at station VILLAGECREEK02 and two observations at VILLAGECREEK03, however, indicate there may be relatively higher levels upstream of the dischargers ( 680 per 100 ml at VILLAGECREEK02 and 1,340 and 36 per 100 ml at VILLAGECREEK03). Data taken in 2000 and 2001 indicate high geometric means for fecal coliform at 2 stations near the headwaters ( 1585 and 1973 per 100 mL). However, fecal coliform numbers decrease downstream. Two miles upstream of the Village Creek WWTP the geometric mean is 321 per 100 mL and the only sample below the treatment plant has a value of 180 per 100 mL. These higher levels indicate that nonpoint source controls may be needed before a F& W use can be attained.

The longest series of toxic data for Village Creek is for station VI1 which is downstream of all dischargers, but also downstream of a lake that likely allows the settling of many of the toxic compounds evaluated. Data for most pollutants ( except zinc) cover the period from at least 1981 to 1996 or 1997. The zinc samples were taken in the 1970s and probably do not reflect current conditions. Exhibit C 17 indicates the mean toxic pollutant concentrations and criteria exceedances for this station. Arsenic, copper, cyanide, mercury, and zinc all exceed criteria for more than 10% of samples. Data from 2000 and 2001, shown in Exhibits C 19 through C 22, show similar patterns to the 1981   1997 data except that arsenic does not exceed the criterion and lead exceeds the criterion at least once at 3 of the 4 stations. At the uppermost station, PAH values exceed applicable criteria in two of the three observations. Similar exceedances are not observed at the three downstream stations. Even with control of point sources, nonpoint sources would also need to be controlled before LWF or F& W standards for toxic pollutants could be attained. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 51 Exhibit C 17. Village Creek, Station VILLAGECREEK02 Exhibit C 16. Toxic Pollutant Concentrations and Criteria Exceedances at Station VI1 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia, Unionized ( Calculated) mg/ L 4 100.0 0.072 0 0 a Ammonia, Unionized mg/ L 4 100.0 0.060 0 0 a Arsenic, Total µ g/ L 54 3.7 12 2 3.7 0.3 Cadmium, Total µ g/ L 59 0.0 0 0 1.46 Chromium, Total µ g/ L 67 6.0 29 0 0 269 Copper, Total µ g/ L 69 14.5 143 8 11.6 15.6 Cyanide, Total mg/ L 39 25.6 0.011 9 23.1 5.2 Lead, Total µ g/ L 59 3.4 11 2 3.4 4.79 Mercury, Total µ g/ L 49 14.3 5.0 7 14.3 0.012 Phenols mg/ L 58 1.7 0.010 0 0 106 Zinc, Total1 µ g/ L 11 81.8 264 5 45.5 139 1 Zinc data are for the 1970s only. a  Criteria based on pH and temperature.

Exhibit C 18. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 1 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 52 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia dissolved mg/ L 11 18.2 0.198 0 0.0 1.14 Arsenic µ g/ L 6 50.0 1.86 0 0.0 190 Cadmium µ g/ L 6 33.3 0.17 0 0.0 1.68 Chromium µ g/ L 6 50.0 2.16 0 0.0 312 Copper µ g/ L 6 33.3 6.02 0 0.0 18.2 Lead µ g/ L 6 33.3 15.0 2 33.3 6.03 Mercury µ g/ L 6 0.0 N/ A 0 0.0 0.012 Nickel µ g/ L 6 33.3 1.19 0 0.0 241 Selenium µ g/ L 6 0.0 N/ A 0 0.0 5.0 Silver µ g/ L 6 0.0 N/ A 0 0.0 9.63 Zinc µ g/ L 6 33.3 60.2 0 0.0 162 Acenaphthene µ g/ L 3 100.0 0.0177 0 0.0 579 Anthracene µ g/ L 3 66.7 0.0770 0 0.0 23,333 Benz( a) anthracene µ g/ L 3 66.7 0.468 2 66.7 0.067 Benzo( a) pyrene µ g/ L 3 66.7 0.671 2 66.7 0.067 Benzo( b) fluoranthene µ g/ L 3 66.7 0.931 2 66.7 0.067 Benzo( k) fluoranthene µ g/ L 3 66.7 0.501 2 66.7 0.067 Chrysene µ g/ L 3 66.7 0.796 2 66.7 0.067 Dibenzanthracene µ g/ L 3 66.7 0.251 2 66.7 0.067 Fluoranthene µ g/ L 3 100.0 0.897 0 0.0 81 Fluorene µ g/ L 3 100.0 0.0357 0 0.0 3,111 Indeno( 1,2,3 cd) pyrene µ g/ L 3 66.7 0.967 2 66.7 0.067 Pyrene µ g/ L 3 100.0 0.658 0 0.0 2,333 Dieldrin µ g/ L 4 25.0 0.005 1 25.0 0.0019 Lindane µ g/ L 4 0.0 N/ A 0 0.0 0.08 p, p' DDE µ g/ L 4 0.0 N/ A 0 0.0 0.00128 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 53 Exhibit C 19. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 2 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia dissolved mg/ L 7 71.4 0.106 0 0.0 0.988 Arsenic µ g/ L 4 75.0 4.03 0 0.0 190 Cadmium µ g/ L 4 100.0 2.53 3 75.0 1.73 Chromium µ g/ L 4 100.0 3.07 0 0.0 322 Copper µ g/ L 4 100.0 10.1 1 25.0 18.7 Lead µ g/ L 4 100.0 16.1 1 25.0 6.31 Mercury µ g/ L 4 0.0 N/ A 0 0.0 0.012 Nickel µ g/ L 4 100.0 1.77 0 0.0 249 Selenium µ g/ L 4 25.0 2.85 0 0.0 5 Silver µ g/ L 4 50.0 0.537 0 0.0 10.2 Zinc µ g/ L 4 100.0 272 2 50.0 167 Acenaphthene µ g/ L 2 50.0 0.140 0 0.0 579 Anthracene µ g/ L 2 0.0 N/ A 0 0.0 23,333 Benz( a) anthracene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Benzo( a) pyrene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Benzo( b) fluoranthene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Benzo( k) fluoranthene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Chrysene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Dibenzanthracene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Fluoranthene µ g/ L 2 100.0 0.145 0 0.0 81 Fluorene µ g/ L 2 50.0 0.131 0 0.0 3,111 Indeno( 1,2,3 cd) pyrene µ g/ L 2 50.0 0.0355 0 0.0 0.067 Pyrene µ g/ L 2 100.0 0.170 0 0.0 2,333 Dieldrin µ g/ L 2 0.0 N/ A 0 0.0 0.0019 Lindane µ g/ L 2 0.0 N/ A 0 0.0 0.08 p, p' DDE µ g/ L 2 0.0 N/ A 0 0.0 0.00128 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 54 Exhibit C 20. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 3 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia dissolved mg/ L 10 100.0 0.136 0 0.0 0.423 Arsenic µ g/ L 5 60.0 1.88 0 0.0 190 Cadmium µ g/ L 5 100.0 0.321 0 0.0 1.69 Chromium µ g/ L 5 40.0 0.988 0 0.0 314 Copper µ g/ L 5 100.0 8.02 0 0.0 18.3 Lead µ g/ L 5 100.0 2.07 0 0.0 6.09 Mercury µ g/ L 5 0.0 N/ A 0 0.0 0.012 Nickel µ g/ L 5 80.0 1.89 0 0.0 243 Selenium µ g/ L 5 0.0 N/ A 0 0.0 5.0 Silver µ g/ L 5 0.0 N/ A 0 0.0 9.77 Zinc µ g/ L 5 100.0 95.9 1 20.0 163 Acenaphthene µ g/ L 2 0.0 N/ A 0 0.0 579 Anthracene µ g/ L 2 0.0 N/ A 0 0.0 23,333 Benz( a) anthracene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Benzo( a) pyrene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Benzo( b) fluoranthene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Benzo( k) fluoranthene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Chrysene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Dibenzanthracene µ g/ L 2 0.0 N/ A 0 0.0 0.067 Fluoranthene µ g/ L 2 0.5 0.0537 0 0.0 81 Fluorene µ g/ L 2 0.5 0.0373 0 0.0 3,111 Indeno( 1,2,3 cd) pyrene µ g/ L 2 0.5 0.103 1 50.0 0.067 Pyrene µ g/ L 2 0.5 0.0446 0 0.0 2,333 Dieldrin µ g/ L 3 0.0 N/ A 0 0.0 0.0019 Lindane µ g/ L 3 0.0 N/ A 0 0.0 0.08 p, p' DDE µ g/ L 3 0.0 N/ A 0 0.0 0.00128 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 55 Exhibit C 21. Toxic Pollutant Concentrations and Criteria Exceedances at Station VIL 4 Pollutant Units Number of Samples Percent of Samples Detected Mean of Detected Values Number of Samples Exceeding Criteria Percent of Samples Exceeding Criteria Criteria Ammonia dissolved mg/ L 3 100.0 0.112 0 0.0 2.29 Arsenic ug/ L 2 100.0 2.35 0 0.0 190 Cadmium ug/ L 2 100.0 0.277 0 0.0 1.37 Chromium ug/ L 2 50.0 1.20 0 0.0 252 Copper ug/ L 2 100.0 6.61 0 0.0 14.5 Lead ug/ L 2 100.0 4.89 1 50.0 4.31 Mercury ug/ L 2 0.0 N/ A 0 0.0 0.012 Nickel ug/ L 2 100.0 2.20 0 0.0 193 Selenium ug/ L 2 0.0 N/ A 0 0.0 5.0 Silver ug/ L 2 0.0 N/ A 0 0.0 6.12 Zinc ug/ L 2 100.0 155 2 100.0 130 Acenaphthene ug/ L 1 100.0 0.0461 0 0.0 579 Anthracene ug/ L 1 0.0 N/ A 0 0.0 23,333 Benz( a) anthracene ug/ L 1 0.0 N/ A 0 0.0 0.067 Benzo( a) pyrene ug/ L 1 0.0 N/ A 0 0.0 0.067 Benzo( b) fluoranthene ug/ L 1 100.0 0.0404 0 0.0 0.067 Benzo( k) fluoranthene ug/ L 1 0.0 N/ A 0 0.0 0.067 Chrysene ug/ L 1 100.0 0.0284 0 0.0 0.067 Dibenzanthracene ug/ L 1 0.0 N/ A 0 0.0 0.067 Fluoranthene ug/ L 1 100.0 0.0731 0 0.0 81 Fluorene ug/ L 1 100.0 0.0262 0 0.0 3,111 Indeno( 1,2,3 cd) pyrene ug/ L 1 0.0 N/ A 0 0.0 0.067 Pyrene ug/ L 1 100.0 0.0442 0 0.0 2,333 Dieldrin ug/ L 16 0.0 N/ A 0 0.0 0.0019 Lindane ug/ L 0 0.0 N/ A 0 0.0 0.08 p, p' DDE ug/ L 0 0.0 N/ A 0 0.0 0.00128 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 56 Equation ( 2) Equation ( 1) Appendix D. Ammonia Toxicity Analysis This appendix describes the approach used to assess the ammonia toxicity compliance for all the facilities with an existing effluent limit for ammonia ( NH3 N). EPA evaluated the criteria for ammonia using the procedures described in the Guidelines for Deriving Numerical National Water Quality Criteria for the Protection of Aquatic Organisms and Their Uses ( U. S. EPA, 1999). The guidelines indicate that, except where an unusually sensitive species is important at a site, freshwater aquatic life should be protected if both of the following conditions are satisfied for the temperature and pH of the waterbody:

The 1 hour average concentration of total ammonia nitrogen ( in mg N/ L) does not exceed, more than once every 3 years on the average, the CMC ( acute criterion) calculated using the following equation when salmonid fish are absent:

The 30 day average concentration of total ammonia nitrogen ( in mg N/ L) does not exceed, more than once every 3 years on the average, the CCC ( chronic criterion) calculated using the following equations when fish early life stages are present:

D. 1 Description of Approach EPA evaluated data for all the facilities with an existing ammonia permit limit. First, EPA evaluated historic ambient data to identify any potential exceedances of the in stream ammonia criteria. Then, it developed waste load allocations ( WLAs) for the facilities. The two steps are described below.

D. 1.1 Analysis of Ambient Data   In Stream Criteria Exceedance EPA analyzed temperature, pH, and NH3 N ambient observations with the objective of identifying historic violations of the NH3 N criterion:

C Identify ambient monitoring stations with pH, temperature, and NH3 N observations C Use Equations 1 and 2 to compute the corresponding acute and chronic criteria using pH and temperature observations C Compare the corresponding criteria with the corresponding observed NH3 N to identify any historic ammonia violations. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 57 D. 1.2 Ammonia WLAs Following the in stream data analysis, EPA developed WLAs for the facilities. Because the ammonia criterion is a function of pH and temperature, EPA used critical temperature ( 28 ° C) and pH ( 8 SU) values based on in stream data in developing the NH3 limits ( Equation 3). The steps in the analysis are:

C Calculate the acute and chronic criteria using Equations 1 and 2 C Estimate the biologically based design flow; following U. S. EPA ( 1999), the 1Q10 flow is used for the acute criteria and the 30Q10 is used for the chronic criteria C Estimate the ambient NH3 N concentration for each segment C Calculate the NH3 N waste allocation based on the biologically based flow, the ammonia criterion, the discharge flows, and the ambient NH3 concentration:

WLA = [( Qdischarge + Design_ Flow)* criteria  Design_ Flow* Cambient]/ Qdischarge Equation ( 3)

where,

Qdischarge = facility discharge flow Criteria = acute or chronic criterion Design_ Flow = stream flow ( 1Q10 for acute and 30Q5 for chronic) Cambient = NH3 N in stream concentration in mg/ l C Use the more stringent of the two load allocations and compare it with the existing discharge observations to estimate level of reduction ( if any) needed to meet the ammonia stream criteria.

D. 2 Application to Alabama Facilities As shown in Exhibit D 1 and in the sections below, the ammonia WLA analyses indicates that three facilities need to control ammonia discharge: ABC Coke, Sloss Industries, and Koppers Coke.

D. 2.1 ABC Coke Ammonia WLA Discharge Flow = 0.12 MGD Effluent Limit Acute = 255 mg/ l NH3 N Effluent Limit Chronic = 28.4 mg/ l A total of 36 observations, consisting of average monthly concentrations, were reported between January 1998 and December 2000. The existing monthly average permit limit for ABC Coke is 25 lbs per day and is more stringent than the projected limit. Based on these recent data, covering a period of 3 years, the projected chronic effluent limit as well as the existing limit are exceeded 9 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 58 times ( 17%). Based on these observations, EPA estimated the necessary load reduction using the mean of all exceedances. EPA estimated the required reduction to be 27% and be attributable to the existing limit. No additional reduction is required to meet a F& W standard.

D. 2.2 Sloss Industries Ammonia WLA Discharge Flow = 3.22 MGD WLA Acute = 17.6 mg/ l NH3 N WLA Chronic = 1.89 mg/ l NH3 N A total of 28 observations were reported between January 1998 and December 2000. The observations consist of maximum monthly discharge concentrations. Based on these data, covering a period of 3 years, the projected chronic ammonia limit is exceeded eight times ( 29%). All of the 8 violations also exceed the existing permit limit of 1.86 mg/ L. Based on these observations, EPA estimated the load reduction to be 47%. This reduction is required to comply with existing effluent limits. No additional reduction would be required to meet F& W standards.

D. 2.3 Koppers Coke Ammonia Waste Load Allocation Discharge Flow = 0.22 MGD WLA Acute = 376 mg/ l NH3 N WLA Chronic = 34.8 mg/ l NH3 N A total of 20 observations were reported between January 1998 and December 2000. The observations consist of average monthly discharge concentrations. Based on these data, covering a period of 3 years, the projected ammonia limit is exceeded 5 times ( 25%). All of the 5 violations also exceed the existing permit limit of 35 mg/ L. Based on these excursions from the existing limit, EPA estimated the load reduction to be 46%. This reduction is required to comply with existing effluent limits as well as limits based on LWF and F& W criteria. Exhibit D 1. Analysis of WLA Analysis Facility Discharge cfs 1Q10 cfs 30Q10 cfs NH3 Ambient mg/ l WLA Acute mg/ l WLA Chronic mg/ l Final WLA mg/ l Compliance? Discharge data ABC Coke 0.188 5.8 8.3 0.4 255.45 28.41 28.41 No 17% of observations above limit Sloss Industries 5.05 5.85 8.4 0.5 17.57 1.89 1.89 No 29% of observations above limit Koppers Tar 0.07 15 21.5 0.3 1,745.75 222.29 222.29 Yes no observations above limit Koppers Coke 0.339 15.75 22 0.5 375.80 34.79 34.79 No 25% of observations above limit Valley Creek WWTP 133.45 15.3 27 0.044 9.37 1.22 1.22 Yes no observations above limit Village Creek 94.2 9.75 12.8 0.053 9.27 1.15 1.15 Yes no observations above limit Five Mile Creek WWTP 31.4 10.9 13.45 0.1 11.29 1.41 1.41 Yes no observations above limit Honeywell 0.054 1.1 1.5 0.053 178.59 27.89 27.89 Yes no observations above limit Earl Ham 3.8 5.6 8.1 0.015 20.78 3.16 3.16 Yes no observations above limit Avondale Mills 3.18 5.6 8.1 0.015 23.19 3.58 3.58 Yes no observations above limit USX 17.5 0.33 0.49 0.05 8.57 1.05 1.05 Yes 3% of observations above limit Westpoint Stevens 4.3 0.46 0.68 0.09 9.30 1.17 1.17 Yes 5% of observations above limit Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 59 Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 60 Appendix E. Dissolved Oxygen Analysis This appendix summarizes the results for the waste load allocation modeling runs EPA performed for Opossum Creek. EPA used the results from a previous waste load allocation study performed by ADEM ( 1996). ADEM used a calibrated and verified dissolved oxygen ( DO)/ BOD model to develop load allocations for the three dischargers to Opossum Creek ( Koppers Coke, Koppers Tar, and USX). Using the ADEM model parametrization, EPA reproduced the results with a Streeter Phelps DO model and then assessed:

C The attainment of a minimum DO standard of 3 mg/ l all year long ( A& I use)

C The attainment of a minimum DO standard of 3 mg/ l in summer and 5 mg/ l in winter ( LWF use)

C The attainment of a minimum DO standard of 5 mg/ l all year long ( F& W use).

E. 1 Facility Limits and Discharges Exhibit E 1 contains the current permit limits for the three dischargers and the reported concentrations and loading for BOD and ammonia taken from the EPA's PCS database. The limits presented in Exhibit E 1 are based on the results of ADEM's WLA to meet A& I use. Exhibit E 1 also presents the current concentrations, loading, and percent of total loading for each facility of the three dischargers. For example, Koppers Coke contributes 5.85% of the current total BOD loading to the creek. Similarly, they are responsible for 63.6 % of the current total ammonia nitrogen loading.

All facilities are currently discharging well below their permit limits ( except for Koppers Coke with respect to ammonia). EPA used current discharges to assess reductions needed to attain the three DO standards. The loads presented are derived from discharge data reported in EPA's PCS.

Exhibit E 1. Current Permit Limits and Discharge Condition at Opossum Creek1 Facility ( flow) BOD Concentration BOD Loading (% of Total) NH3 N Concentration NH3 N Loading (% of total) Limit Discharge Limit Discharge Limit Discharge Limit Discharge USX ( 11 mgd) 8 4.0 734 ( 88.7%) 367 ( 94.1%) 1 0.4 92.0 ( 55.1%) 37 ( 36.1%)

Koppers Tar ( 0.036 mgd) 15 1.1 4.5 ( 0.6%) 0.33 ( 0.085%) 20 1.4 6.0 ( 3.6%) 0.42 ( 0.41%)

Koppers Coke ( 0.236 mgd) 45 11.6 88.5 ( 10.7%) 22.8 ( 5.85%) 35 33.1 69.0 ( 41.3%) 65.2 ( 63.6%) 1Concentrations in mg/ L; Loadings in lbs/ day. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 61 E. 2 Modeling Results Exhibit E 2 contains the key model parameters used for the four model segments with the three dischargers. The model parameters are the same as those used in the ADEM ( 1996) model.

Exhibit E 2. Summary of Key Model Parameters Segment Length ( miles) Discharger Kd CBOD Decay Rate ( 1/ day) KNH3 ( NBOD Decay rate ( 1/ day) Ka Reaeration rate ( 1/ day) 7Q10 Stream Flow ( cfs) Average Stream Velocity ( ft/ sec)

1 0.47 USX 2.06 3.08 6.73 0.36 0.304 2 0.47 Koppers Tar 2.06 2.82 7.42 17.44 0.304 3 0.51 None 2.06 2.82 4.92 17.46 0.305 4 1.19 Koppers Coke 2.06 2.60 8.53 17.82 0.308 Source: ADEM ( 1996).

EPA's model predictions for the three potential use designations are as follows:

C Based on the existing discharge conditions, Opossum Creek meets the DO standard for A& I ( 3 mg/ l all year long)

C Based on the existing discharge conditions, Opossum Creek meets the LWF DO standard ( DO = 3 mg/ l from May through November and 5 mg/ l from December through April)

C LWF DO standards will be attained with the incidental removal of NH3 N loads from Koppers Coke associated with removal of cyanide C BOD discharge reduction of 40% to 50% of current loads is needed from USX to meet the F& W standard ( the addition of activated sludge treatment at USX should reduce BOD sufficiently to attain 5 mg/ l at all times of the year). Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 62 Appendix F. Facility Analyses This appendix provides the detailed engineering and cost analyses for each facility organized alphabetically by name. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 63 ABC Coke Description Alabama ByProducts Corporation ( ABC) is a producer of foundry coke, used in the production of metals. ABC Coke Division/ Drummond Company ( NPDES permit number AL0003417), located in Trussville, Alabama, is a 0.12 mgd facility that discharges to Five Mile Creek. The facility has two permitted outfalls, DSN001 and DSN002. In the facility's 2000 permit, limits for outfall DSN001 ( treated process wastewater and storm water runoff) are based either on the more stringent of Federal effluent guidelines [ 40 CFR 420.13( b) BAT / 40 CFR 420.12( b) BPT] or water quality requirements. Limits for outfall DSN002 ( storm water runoff from coal yard) are based on best professional judgment. Flows ( in cfs) in Five Mile Creek are as follows: average: 43.0, harmonic mean: 19.2, 1Q10: 5.76, 7Q10: 6.40, 7Q2: 6.53.

Existing Treatment Processes Information from U. S. EPA Region 4 indicates that the facility has a very advanced biological treatment operation that can achieve NH3 concentrations in the range of 1 to 2 mg/ l. ABC Coke is also installing a new biological treatment system and advanced secondary activated sludge with recycle soon. The Region also indicated that cyanide is a concern at the facility ( that it may need a hydrogen peroxide unit) and that facility has been planning for the use classification upgrade.

Summary of Effluent Data and Limits Exhibit F 1 summarizes the last 3 years ( approximately) of effluent monitoring for outfall DSN001 for pollutants with existing limits.

Exhibit F 1. Compliance Summary, ABC Coke Pollutant Number of Observations Effluent Concentrations1 ( µ g/ L unless noted) Existing Limit Comply with Existing Lim it? Total Detect Maximum Mean Ammonia nitrogen ( mg/ l) 36 36 55.3 15.3 25 No2 Benzene 24 0     150 Yes Benzo( a) pyrene 14 6 120 39.9 150 Yes Cyanide 3 3 6,095 3,131 400 No3 Phenols 60 59 220 83.3 170 Yes 1Detected values only (`   ` indicates not applicable). 2About 25% of the average reported concentrations exceed the existing average monthly limit for ammonia. 3One of three reported values complies with the effluent limit.

Naphthalene is also limited at outfall DSN001, but because there are no Alabama criteria for napthalene, there would be no change associated with a change in use. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 64 Exhibit F 2 summarizes projected effluent limits for the facility under different use classifications. Projected effluent limits for the current use ( A& I) only differ from current permit limits if data indicate that all applicable criteria are not reflected in the facility's permit. Only pollutants with reasonable potential and for which data indicates that a reduction in effluent concentrations is needed are shown.

Exhibit F 2. Projected Effluent Limits, ABC Coke ( all values in µ g/ l unless otherwise noted)

Pollutant MEC1 Current Lim it Projected Effluent Limit2 A& I LWF F& W Ammonia N ( mg/ l) 55.3 25 278 56 56 Benzo( a) pyrene 120 150 16 16 16 Cyanide 6,095 400 42 4.2 4.2 1Maximum effluent concentration. 2Projected A& I limit differs from current limit if data indicate all applicable criteria are not reflected in current permit.

Exhibit F 3. Required Effluent Reductions, ABC Coke ( pounds per year)

Pollutant Projected Pollutant Loading Reductions Current Permit1 A& I2 LWF F& W Ammonia N 11,0703 0 0 0 Benzo( a) pyrene 0 38 0 0 Cyanide 2,080 131 145 0 1Reductions needed to meed current limit indicate noncompliance. 2Reductions needed to m eet A& I differ from reductions needed to meet current limit if data indicate all applicable criteria are not reflected in current limit. 3For Ammonia N, the current permit is more stringent than projected A& I, LWF, and F& W limits Controls Needed Ammonia Nitrogen: ABC Coke does not meet its existing limit for ammonia. A 27% reduction would be required to meet the existing limit and will be met with the addition of chemical oxidation ( see below for benzo( a) pyrene).

Benzo( a) pyrene: ABC Coke is in compliance with its existing limit but not in compliance with the projected A& I limit. Consequently, pollution controls need to be installed to meet the A& I limit. Chemical oxidation will reduce benzo( a) pyrene to the projected A& I limit; the reduction will also be sufficient to meet projected LWF and F& W limits. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 65 Cyanide: ABC Coke is not in compliance with its existing limit or the projected A& I limit. Consequently, pollution controls need to be installed to meet the existing and A& I limit. Chemical oxidation that will be installed to remove ammonia and benzo( a) pyrene will incidentally reduce cyanide to levels required to meet a F& W standard as well.

Exhibit F 4. Annual Cost of Required Effluent Reductions, ABC Coke ( Millions of Year 2001dollars)

Control ( pollutant) Total Capital Annualized Capital1 O& M Total Annual Cost Chemical Oxidation 2.4 0.23 1.0 1.23 TOTAL 2.4 0.23 1.0 1.23 1Annualized at 7% over 20 years. Economic Analysis of the Proposed Water Quality Standards Rule for the State of Alabama 66 American Cast Iron Pipe Company Description American Cast Iron Pipe Co.( ACIPCO) ( NPDES permit number AL0029378) manufactures ductile iron pipe and fittings, fire hydrants, valves and pumps for fire trucks, centrifugally cast steel tubes, static castings and fabricated assemblies, electric resistance welded steel pipe, and spiral welded steel pipe. ACIPCO, a 0.55 MGD facility located in Birmingham, Alabama, discharges to Village Creek. The facility has eight permitted outfalls. In the facility's 1993 permit, limits for outfall DSN001 ( treated process wastewater and storm water) are based on Federal effluent guidelines [ 40 CFR 464]. Limits for outfalls DSN002   DSN008 ( storm water runoff from industrial activity) are based on Federal guidelines [ 40 CFR 464]. Flows ( in cfs) in Village Creek are as follows: average: 47.04, harmonic mean: 21, 1Q10: 6.3, 7Q10: 7, 7Q2: 7.14.

Existing Treatment Processes Information from U. S. EPA Region 4 indicates that the facility's wastewater is treated in lime settling ponds followed by a final pH adjustment.

Summary of Effluent Data and Limits Exhibit F 5 summarizes effluent monitoring from January 1, 2000 through February 28, 2001 for outfall DSN001 for pollutants with existing limits.

Exhibit F 5. Compliance Summary, ACIPCO Pollutant Number of Observations Effluent Concentrations1 ( µ g/ L unless noted) Existing Limit Comply with Existing Limit? Total Detect Maximum Mean Total Copper 14 14 654 327 1,330 Yes Total Lead 7 7 218 218 6,388 Yes Total Zinc 27 27 11,990 3,117 4,556 No2 Total Phenols 14 14 872 358 556 No 1Detected values only. 2The five m ost recent observations exceed the current limit.