1,400
                                                                             -
                                      Yes
                                      N/A
Nitrates

                                                                          19.2

                                                                        10,000
                                      N/A
                                      No

As shown above, ammonia has reasonable potential. Exhibit A-50 summarizes the average monthly and maximum daily effluent limitations that were calculated as part of the RPA for the Devils Lake WWTF.
Exhibit A-50: Summary of Calculated Limits for Parameters with Reasonable Potential for City of Devils Lake WWTF (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Ammonia
                                      AL
                                                                          7,600
                                                                         25,000
                                                                          5,780
                                      No

Summary
Although the RPA indicates reasonable potential for ammonia, actual effluent sampling results meet the effluent limits derived from the economic analysis criteria. The facility may wish to optimize its system to ensure it continues to operate in a way that achieves compliance with the potential limits and should be able to do so at minimal cost. Therefore, EPA estimated no incremental compliance cost for this facility at this time.
MG Waldbaum Company (NE0113735)
The MG Waldbaum Company facility (MG Waldbaum; NPDES permit number NE0113735) is in Wakefield, Nebraska, and conducts dairy product production, poultry slaughtering and processing, and chicken egg production. The facility is owned by the Michael Foods Egg Products Company and discharges industrial wastewater into Logan Creek.
EPA could not locate permit documentation for this facility and based the analysis on discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
Outfall 001 is the effluent discharge from the iron filter and softener backwash water treatment system. The discharge is to Logan Creek. Outfall 003 discharges effluent from the extended aeration activated sludge system to Logan Creek through a diffuser. Effluent from the industrial lagoon treatment system may also be land applied. MG Waldbaum's permit includes effluent limits for TSS, BOD, ammonia nitrogen, hydrogen sulfide, and residual chlorine. Reported design flow for the facility in EPA's Enforcement and Compliance History Online (ECHO) is 0.70 MGD.
Reasonable Potential Analysis
EPA had sufficient data to conduct reasonable potential analyses for Outfall 003 for the parameters shown in Exhibit A-51.
Exhibit A-51: Summary of Available Effluent Data for MG Waldbaum (ug/L)
Parameter
Effluent Data[a]
Detection Limit

Samples
50[th] Percentile
Max

Bacteria (E. coli; cfu/100 mL)
                                                                              5
                                                                              -
                                                                            72

Ammonia
                                                                             63
                                                                           400
                                                                         7,600
                                                                            10
Cadmium
                                                                              4
                                                                         ND[b]
                                                                            ND
                                                                          0.05
Chlorine
                                                                             25
                                                                            10
                                                                            20
                                                                            10
Copper
                                                                              4
                                                                              -
                                                                            30
                                                                           0.5
Selenium
                                                                              4
                                                                          ND[b]
                                                                             ND
                                                                           0.6
Zinc
                                                                              4
                                                                              -
                                                                            20
                                                                          0.05
Notes:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
[b] Cadmium and selenium were not detected in the effluent.
Exhibit A-52 summarizes the RPA for all parameters with sufficient data. Information about allowed mixing in the permit was not available; as such, EPA assumed no dilution was available for any of the parameters analyzed.
Exhibit A-52: Summary of Reasonable Potential Analysis for the MG Waldbaum (ug/L)
Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Bacteria (E. coli; cfu/100 mL)[b]
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                      N/A
                                      No
Ammonia
                                                                         19,200
                                                                         19,200
                                                                              -
                                                                         11,000
                                                                          1,400
                                                                              -
                                      Yes
                                      N/A
Cadmium
                                                                            0.0
                                                                            0.0
                                                                              -
                                                                            1.8
                                                                           0.72
                                                                              -
                                      No
                                      N/A
Chlorine
                                                                             55
                                                                             55
                                                                              -
                                                                             19
                                                                             11
                                                                              -
                                      Yes
                                      N/A
Copper
                                                                            140
                                                                            140
                                                                             31
                                                                            4.4
                                                                            2.7
                                                                          1,300
                                      Yes
                                      No
Selenium
                                                                              0
                                                                              0
                                                                              0
                                                                              -
                                                                            1.5
                                                                            130
                                      No
                                      No
Zinc
                                                                             95
                                                                             95
                                                                             21
                                                                            120
                                                                            120
                                                                          2,600
                                      No
                                      No
Notes:
[a] No dilution was used for this analysis.
[b] For bacteria, the facility was assumed to have reasonable potential if the maximum effluent concentration (see above exhibit) exceeds 100 cfu/100 mL.
As shown above, ammonia, chlorine, and copper have reasonable potential. Exhibit A-53 summarizes the average monthly and maximum daily effluent limitations that were calculated as part of the RPA for the MG Waldbaum facility.
Exhibit A-53: Summary of Calculated Limits for Parameters with Reasonable Potential for MG Waldbaum (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Ammonia
                                      AL
                                                                          1,400
                                                                          5,400
                                                                          7,600
                                      Yes
Chlorine
                                      AL
                                                                            8.1
                                                                             19
                                                                             20
                                      Yes
Copper
                                      AL
                                                                            2.2
                                                                            4.4
                                                                             30
                                      Yes

Summary
DMR data reported from January 2016 to April 2021 indicate that the facility has met the proposed MDL (5.4 mg/L) and AML (1.4 mg/L) for ammonia in all but one month. The facility may wish to optimize its system to ensure it continues to operate in a way that achieves compliance with the potential limits and should be able to do so at minimal cost. Therefore, EPA estimated no incremental compliance cost to comply with effluent limits for ammonia derived from the economic analysis criteria.
The facility had 25 detected measurements of chlorine from January 2016 to April 2021. The average of these detected measurements was 8.4 ug/L and the data ranged from 0 to 20 ug/L. To meet the limits derived from the potential baseline WQS of 8.1 ug/L as an AML and 19 ug/L as an MDL, the facility will need to add dechlorination. EPA estimated the cost of an upgrade to add dechlorination to the treatment process.
Copper was measured four times between July 2016 and April 2021. The 4 measurements ranged from 10 to 30 ug/L and averaged 17.50 ug/L, which exceeds both the AML of 2.2 ug/L and the MDL of 4.4 ug/L. To comply with the proposed AML and MDL for copper, the facility could evaluate a P2 program paired with additional treatment using a process such as chemical precipitation or ion exchange. EPA estimated the incremental cost of these options for this facility.
Exhibit A-54 summarizes the estimated costs for the treatment options considered for additional removal of ammonia, chlorine, and copper.
Exhibit A-54: MG Waldbaum Estimated Incremental Costs (0.70 MGD)
Parameter
Control Option
Capital Cost
Other One-Time Cost
O&M Cost
Annual Cost (3%)[a]
Annual Cost (7%)[b]
Chlorine
Dechlorination
                                   $440,167
                                      $0
                                    $35,276
                                    $64,862
                                    $76,825
Copper
Chemical Precipitation
                                  $1,063,069
                                      $0
                                   $375,486
                                   $446,941
                                   $475,832

Small Facility P2 Program
                                      $0
                                    $16,557
                                      $0
                                    $9,934
                                    $9,934

                       Alternative Treatment for Copper

Ion Exchange
                                  $1,442,194
                                      $0
                                   $140,413
                                   $237,351
                                   $276,546

Small Facility P2 Program
                                      $0
                                    $16,557
                                      $0
                                    $9,934
                                    $9,934
TOTAL:
                            $1,503,236 - $1,882,361
                                    $16,557
                              $175,689 -$410,762
                             $312,147 - $521,737 -
                             $363,305 -$562,591 -
Notes:
[a] Capital costs annualized over 20 years at a 3% discount rate. Other one-time costs are not annualized.
[b] Capital costs annualized over 20 years at a 7% discount rate. Other one-time costs are not annualized.
Los Alamos County Department of Public Utilities WWTF (NM0020141)
Los Alamos County Department of Public Utilities WWTF (Los Alamos WWTF; NPDES permit number NM0020141) is located in Los Alamos, New Mexico. The facility discharges from one outfall (Outfall 001) into the receiving water Pueblo Canyon, which flows into Los Alamos Canyon, a tributary to the Rio Grande.
EPA developed this facility analysis based on the EPA-issued 2017 permit together with discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
Los Alamos WWTF has a facility design flow of 1.40 MGD. The permit includes effluent limitations for BOD, TSS, E. coli, total residual chlorine, thallium, aluminum, and pH. EPA does not have information about the treatment processes currently in use at the facility.
Reasonable Potential Analysis
EPA had sufficient data to conduct reasonable potential analyses for the parameters shown in Exhibit A-55.
Exhibit A-55: Summary of Available Effluent Data for Los Alamos WWTF (ug/L)
Parameter
Effluent Data[a]
Detection Limit

Samples
50[th] Percentile
Max

Bacteria (E. coli; cfu/100 mL)
                                                                             50
                                                                           15.6
                                                                         121[b]
                                                                              -
Aluminum
                                                                             15
                                                                             10
                                                                             60
                                                                              -
Notes:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
[b] While the daily maximum for this facility was measured as 121.06 cfu/100 mL, the maximum of monthly averages was 31 cfu/100 mL.
Exhibit A-56 summarizes the RPA for all parameters with sufficient data. EPA did not have information on whether mixing is authorized for this facility; as such, EPA did not use dilution for this analysis.
Exhibit A-56: Summary of Reasonable Potential Analysis for Los Alamos WWTF (ug/L)
Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Bacteria (E. coli; cfu/100 mL)[b]
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                      N/A
                                      Yes
Aluminum
                                                                            196
                                                                            196
                                                                              -
                                                                            750
                                                                             87
                                                                              -
                                      Yes
                                      N/A
Notes:
[a] No dilution was used for this analysis.
[b] For bacteria, the facility was assumed to have reasonable potential if the maximum effluent concentration (see above exhibit) exceeds 100 cfu/100 mL.
As shown above, both bacteria and aluminum have reasonable potential. Exhibit A-57 summarizes the effluent limitations that were calculated as part of the RPA for the Los Alamos WWTF.
Exhibit A-57: Summary of Calculated Limits for Parameters with Reasonable Potential for Los Alamos WWTF (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Bacteria (E. coli; cfu/100 mL)
                                      HH
                                                                           100.

                                                                          31[a]
                                      No
Aluminum
                                      AL
                                                                             67
                                                                            150
                                                                           60.0
                                      No
Note:
[a] While the daily maximum for this facility was measured as 121.06 cfu/100 mL, the maximum of monthly averages was 31 cfu/100 mL.
Summary
Although the RPA indicates reasonable potential for bacteria and aluminum, actual effluent sampling results for these parameters meet effluent limits derived from the economic analysis criteria. The facility may wish to optimize its system to ensure it continues to operate within the potential limits and should be able to do so at minimal cost. Therefore, EPA estimated no compliance cost for this facility at this time.
Los Alamos National Laboratory (NM0028355)
The Los Alamos National Laboratory (Los Alamos Lab; NPDES permit number NM0028355) is located in Los Alamos, New Mexico. The facility has a combined design flow of 1.40 MGD (see discussion of outfalls below) with discharge to a receiving water named Pueblo Canyon, which flows into Los Alamos Canyon, which is tributary to the Rio Grande. The Los Alamos Lab's permit is issued to both the Department of Energy and a private LLC that manages the laboratory on behalf of the federal government.
EPA developed this facility analysis based on the EPA-issued 2019 permit and associated fact sheet together with discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
This facility is permitted to discharge industrial wastewater from multiple outfalls. Cooling water blowdown, roof runoff, and stormwater are also discharged through several outfalls.
Outfall 001 discharges cooling water from the power plant, treated and recycled sanitary wastewater, and treated cooling tower blowdown to a perennial reach of Sandia Canyon. It has a continuous discharge with a monthly average flow of 0.154 MGD and a daily maximum flow of 0.333 MGD. This Outfall has a whole effluent toxicity (WET) limit (Ceriodaphnia dubia) and effluent limits for copper, zinc, thallium, and PCBs.
Outfall 13S discharges treated sanitary wastewater to Canada del Buey, an ephemeral reach. The average treated flow rate is 0.229 MGD and the maximum daily flow is 0.418 MGD. This Outfall has effluent limitations for thallium and PCBs.
Outfalls 03A027, 03A048, 03A181, 03A199, and 03A022 discharge treated cooling water and blowdown from cooling towers to various ephemeral and perennial stream reaches. When discharges occur, they have average flow rates of up to 0.088 MGD and maximum daily flows of up to 0.169 MGD. These outfalls have limits for copper, zinc, thallium, chromium, aluminum, arsenic, and mercury.
Outfall 05A055 discharges treated wastewater from the High Explosives Wastewater Treatment Facility to an ephemeral tributary of Canon de Valle. Average flow is 0.0003 MGD and the daily maximum flow is 0.0021 MGD. Effluent is usually diverted to evaporators and there was no discharge from this outfall between October 2014 and September 2018. This Outfall entails effluent limitations for aluminum, copper, selenium, zinc, and lead.
Outfall 051 discharges treated radioactive liquid waste from the Radioactive Liquid Waste Treatment Facility. It has an average flow rate of 0.02 MGD and a maximum daily flow rate of 0.040, and it discharges approximately 4 days per week. There was one discharge between October 2014 and the time of permit issuance in February 2020. This Outfall has effluent limits for copper and thallium.
Reasonable Potential Analysis
EPA had sufficient data to conduct a reasonable potential analysis for the parameters shown in Exhibit A-58 for Outfall 001.
Exhibit A-58: Summary of Available Effluent Data for Los Alamos Lab, Outfall 001 (ug/L)
Parameter
Effluent Data[a]
Detection Limit

Samples
50[th] Percentile
Max

Bacteria (E. coli; cfu/100 mL)
                                                                             62
                                                                           2.0
                                                                       33.1[b]
                                                                              -
Aluminum
                                                                              5
                                                                             -
                                                                            20
                                                                              -
Copper
                                                                              5
                                                                             -
                                                                            10
                                                                            0.5
PCBs
                                                                              5
                                                                             -
                                                                         0.010
                                                                           0.03
Notes:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
[b] While the daily maximum for this facility was measured as 33.10 cfu/100 mL, the maximum of monthly averages was 15.54 cfu/100 mL.
Exhibit A-59 summarizes the RPA for Outfall 001 for all parameters with sufficient data. EPA did not have any information providing dilution factors for this facility and, therefore, assumed that no dilution was available when conducting this analysis.
Exhibit A-59: Summary of Reasonable Potential Analysis for Los Alamos Lab, Outfall 001 (ug/L)
Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Bacteria (E. coli; cfu/100 mL)
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                      N/A
                                      No
Aluminum
                                                                          83.8
                                                                          83.8
                                                                              -
                                                                           750
                                                                            87
                                                                              -
                                      No
                                      N/A
Copper
                                                                           26.1
                                                                           26.1
                                                                           5.81
                                                                           4.4
                                                                           2.7
                                                                      1,300.00
                                      Yes
                                      No
PCBs
                                                                              -
                                                                              -
                                                                          0.093
                                                                              -
                                                                              -
                                                                      0.000009
                                      N/A
                                      Yes
Note:
[a] Calculated assuming no dilution.
As shown above, copper and PCBs discharged from Los Alamos Lab Outfall 001 have reasonable potential. Exhibit A-60 summarizes the average monthly and maximum daily effluent limitations that were calculated as part of the RPA.
Exhibit A-60: Summary of Calculated Limits for Parameters with Reasonable Potential for Los Alamos National Laboratory, Outfall 001 (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Copper
                                      AL
                                                                            2.2
                                                                            4.4
                                                                            6.2
                                      Yes
PCBs
                                      HH
                                                                      0.0000090
                                                                       0.000018
                                                                          0.013
                                      Yes

Summary
Although the RPA indicates reasonable potential for copper, only one annual effluent sampling result for this parameter exceeded the proposed MDL. The current permit has copper limits at Outfall 001 of 8.7 ug/L as both an AML and MDL, which are less stringent than the limits derived from the economic analysis criteria. The facility may wish to optimize its system to ensure it is able to operate within the potential limits and should be able to do so at minimal cost. Therefore, EPA estimated no compliance cost for this facility.
DMR data indicated a single reported measurement of PCBs during annual monitoring at 0.01ug/L. Otherwise PCBs were reported as not detected. The one reported value exceeds the proposed effluent limits. The current permit requires reporting only for PCBs. EPA assumes that this requirement would be retained given that the facility is not a new source of PCBs and all reported values other than one were non-detects. Therefore, EPA estimated no compliance cost for this facility.
Phillips 66 Ponca City Refinery (OK0000256)
The Phillips 66 Co. Ponca City Refinery (Phillips 66; NPDES permit number OK0000256) processes light, medium, and heavy crude oil types, producing liquefied petroleum gas (LPG), anode-grade petroleum coke, aviation fuel, diesel fuel, and gasoline. The facility covers 2,500 acres in Ponca City, Oklahoma, and is owned and operated by the Phillips 66 Corporation.
EPA could not locate permit documentation for this facility and based the analysis on discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
EPA was unable to determine the existing facility treatment processes. EPA's ECHO reports an average facility flow of 5.32 MGD. The facility has effluent limits for ammonia nitrogen, sulfide, selenium, phenols, chromium, hexavalent chromium, TSS, TDS, BOD, pH, and COD.
Reasonable Potential Analysis
EPA had sufficient data to conduct reasonable potential analyses for the parameters shown in Exhibit A-61.
Exhibit A-61: Summary of Available Effluent Data for the Phillips 66 Ponca City Refinery (ug/L)
Parameter
Effluent Data[a]
Detection Limit

Samples
50[th] Percentile
Max

Ammonia
                                                                             52
                                                                          1,150
                                                                         16,000
                                                                             10
Chromium (VI)
                                                                             64
                                                                          ND[b]
                                                                             20
                                                                            0.3
Selenium
                                                                             64
                                                                           40.5
                                                                             85
                                                                            0.6
Notes:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
[b] The data included both detected and non-detected concentrations. The 50th percentile (median) value was reported as "not detected."
Exhibit A-62 summarizes the RPA for all parameters with sufficient data. EPA did not have information on whether mixing is authorized for this facility; as such, EPA did not assume any dilution for this analysis.
Exhibit A-62: Summary of Reasonable Potential Analysis for Phillips 66 (ug/L)
Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Ammonia
                                                                         44,100
                                                                         44,100

                                                                         11,000
                                                                          1,400
                                                                              -
                                      Yes
                                      N/A
Chromium (VI)
                                                                           73.3
                                                                           71.8
                                                                              -
                                                                             16
                                                                             11
                                                                              -
                                      Yes
                                      N/A
Selenium
                                                                              -
                                                                            107
                                                                           40.5
                                                                              -
                                                                            1.5
                                                                            130
                                      Yes
                                      No
Note:
[a] No dilution was used in this analysis.
As shown above, ammonia nitrogen, chromium (VI), and selenium have reasonable potential. Exhibit A-63 summarizes the average monthly and maximum daily effluent limitations that were calculated as part of the RPA for Phillips 66.
Exhibit A-63: Summary of Calculated Limits for Parameters with Reasonable Potential for Phillips 66 (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Ammonia
                                      AL
                                                                         1,400
                                                                         5,300
                                                                        16,000
                                      Yes
Chromium (VI)
                                      AL
                                                                           5.0
                                                                            16
                                                                            20
                                      Yes
Selenium
                                      AL
                                                                           1.5
                                                                           2.4
                                                                            85
                                      Yes

Summary
For ammonia, the limits derived from the economic analysis criteria are an AML of 1.4 mg/L and an MDL of 5.3 mg/L. DMR data suggest that the facility would have exceeded the proposed MDL three times during the monitoring period from January 2017 to April 2021 that included 52 measurements and that the facility would have had difficulty meeting the AML on multiple occasions, particularly over the past three years. A facility upgrade may be necessary, and EPA estimated the cost of adding an additional nitrification step to the treatment process.
Selenium was measured from January 2016 through April 2021. The 64 measurements ranged from 25 to 85 ug/L and the average was 43 ug/L. Selenium control is necessary to meet the AML of 1.5 ug/L and the MDL 2.4 ug/L derived from the potential baseline WQS. EPA estimated the costs of implementing a P2 program along with the costs to add a carbon adsorption unit to the existing treatment system.
Chromium VI was measured from August 2020 through April 2021. The 5 measurements ranged from 10 to 20 ug/L and the average was 18 ug/L. Chromium VI control is necessary to meet the AML of 5.0 ug/L and the MDL of 16 ug/L. GAC shows some effectiveness at removing chromium from wastewater streams, so the addition of the carbon adsorption for selenium removal should also result in reductions of chromium VI. Therefore, EPA did not estimate any additional incremental cost for treating chromium VI beyond the cost of a P2 program focused on chromium.
Exhibit A-64 summarizes the estimated costs to this facility of additional treatment to comply with effluent limits derived from the economic analysis criteria.
Exhibit A-64: Phillips 66 Ponca City Refinery Estimated Incremental Costs (5.32 MGD)
Parameter
Control Option
Capital Cost
Other One-Time Cost
O&M Cost
Annual Cost (3%)[a]
Annual Cost (7%)[b]
Ammonia
Nitrification
                                  $1,669,611
                                      $0
                                    $99,340
                                   $211,564
                                   $256,939
Chromium, Selenium
Adsorption
                                  $9,851,389
                                      $0
                                   $269,710
                                   $931,878
                                  $1,199,611

Medium Facility P2 Program
                                      $0
                                    $66,230
                                      $0
                                    $30,908
                                    $30,908
TOTAL:
                                 $11,521,000
                                   $66,230
                                   $369,050
                                  $1,174,350
                                  $1,487,458
Notes:
[a] Capital costs annualized over 20 years at a 3% discount rate. Other one-time costs are not annualized.
[b] Capital costs annualized over 20 years at a 7% discount rate. Other one-time costs are not annualized.
Kenyon Industries, Inc. (RI0000191)
Kenyon Industries, Incorporated (Kenyon Industries; NPDES permit number RI0000191) is a textile mill located in Kenyon, Rhode Island. Production activities at the facility include coating woven fabrics, finishing, printing, dyeing, and scouring. The mill discharges treated domestic and industrial effluent into the Pawcatuck River through an effluent diffuser.
EPA developed this facility analysis based on the 2010 permit and associated fact sheet issued by the Rhode Island Department of Environmental Management together with discharge monitoring reports from between 2016 and 2021. The 2010 permit had an expiration date of 2015; however, EPA was not able to locate an updated permit and assumed that the 2010 documents are still representative of the facility.
Effluent and Treatment Process
Kenyon Industries has a package sanitary wastewater treatment system to treat domestic and two aerated lagoons to treat industrial wastewater. The outlet from the second aeration lagoon (Outfall 001A) has a maximum flow rate of 0.55 MGD. The facility's permit includes effluent limitations at this outfall for BOD, COD, TSS, pH, sulfide, total chromium, copper, lead, cadmium, silver, total residual chlorine, fecal coliform, nickel, aluminum, zinc, phenols, and whole effluent toxicity.
Reasonable Potential Analysis
EPA had sufficient data to conduct reasonable potential analyses for the parameters shown in Exhibit A-65.
Exhibit A-65: Summary of Available Effluent Data for Kenyon Industries, Inc. (ug/L)
Parameter
Effluent Data[a]
Detection Limit

Samples
50[th] Percentile
Max

Aluminum
                                                                             21
                                                                           296
                                                                        33,400
                                                                             -
Ammonia
                                                                             64
                                                                        12,850
                                                                        59,100
                                                                            10
Cadmium
                                                                             64
                                                                             -
                                                                          0.05
                                                                          0.05
Chlorine
                                                                             64
                                                                            40
                                                                           320
                                                                            10
Chromium (III)
                                                                             64
                                                                           154
                                                                           345

Copper
                                                                             64
                                                                         171.5
                                                                           254
                                                                           0.5
Lead
                                                                             64
                                                                           1.0
                                                                           8.0
                                                                           0.6
Nickel
                                                                             21
                                                                           6.0
                                                                            60
                                                                           0.5
Nitrates
                                                                             64
                                                                        31,550
                                                                        74,300
                                                                             2
Phenol
                                                                             64
                                                                          69.5
                                                                           191
                                                                          0.14
Silver
                                                                             64
                                                                             -
                                                                      0.050[b]
                                                                           0.1
Zinc
                                                                             21
                                                                          38.0
                                                                           115
                                                                          0.05
Notes:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
[b] This value is below the DL and is based on the assumption used in this analysis that measurements reported as "<" or "not quantified" are one-half of the DL.
Exhibit A-66 summarizes the RPA for all parameters with sufficient data. The fact sheet for the existing permit authorizes mixing zones for this facility, which EPA used in the RPA. Ambient data were not available for the receiving water, so EPA assumed background concentrations were equal to half the DL unless that value was above the applicable criteria.
Exhibit A-66: Summary of Reasonable Potential Analysis for Kenyon Industries, Inc. (ug/L)
 Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Aluminum
                                                                          9,705
                                                                          9,705
                                                                              -
                                                                            750
                                                                             87
                                                                              -
                                      Yes
                                      N/A
Ammonia
                                                                          4,247
                                                                          4,247
                                                                              -
                                                                         11,000
                                                                          1,400
                                                                              -
                                      Yes
                                      N/A
Cadmium
                                                                        0.00816
                                                                       0.00786
                                                                              -
                                                                            1.8
                                                                           0.72
                                                                              -
                                      No
                                      N/A
Chlorine
                                                                           25.6
                                                                           25.6
                                                                              -
                                                                             19
                                                                             11
                                                                              -
                                      Yes
                                      N/A
Chromium (III)
                                                                           5.77
                                                                           15.7
                                                                              -
                                                                            570
                                                                             74
                                                                              -
                                      No
                                      N/A
Copper
                                                                           12.6
                                                                           12.6
                                                                           1.90
                                                                            4.4
                                                                            2.7
                                                                          1,300
                                      Yes
                                      No
Lead
                                                                           0.52
                                                                           0.52

                                                                             65
                                                                            2.5
                                                                              -
                                      No
                                      N/A
Nickel
                                                                           11.6
                                                                           11.5
                                                                           0.43
                                                                            470
                                                                             52
                                                                            180
                                      No
                                      No
Nitrates
                                                                              -
                                                                              -
                                                                            305
                                                                              -
                                                                              -
                                                                         10,000
                                      N/A
                                      No
Phenol
                                                                              -
                                                                              -
                                                                           2.21
                                                                              -
                                                                              -
                                                                          4,000
                                      N/A
                                      No
Silver
                                                                         0.0086
                                                                              -
                                                                              -
                                                                            3.2
                                                                              -
                                                                              -
                                      No
                                      N/A
Zinc
                                                                           8.85
                                                                           8.92
                                                                           1.20
                                                                            120
                                                                            120
                                                                          2,600
                                      No
                                      No
Note:
[a] Dilution factors for acute and chronic criteria (25.5), carcinogenic human healthy (103.7), and non-carcinogenic human health (32.4) were devised for this analysis.
As shown above, aluminum, ammonia, chlorine, and copper have reasonable. Exhibit A-67 summarizes the effluent limitations that were calculated as part of the RPA for Kenyon Industries.
Exhibit A-67: Summary of Calculated Limits for Parameters with Reasonable Potential for Kenyon Industries, Inc. (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Aluminum
                                      AL
                                                                          1,200
                                                                          3,700
                                                                         33,400
                                      Yes
Ammonia
                                      AL
                                                                         32,000
                                                                        104,000
                                                                         59,100
                                      Yes
Chlorine
                                      AL
                                                                            190
                                                                            480
                                                                            320
                                      Yes
Copper
                                      AL
                                                                             57
                                                                             82
                                                                            254
                                      Yes

Summary
Aluminum was measured from July 2016 through March 2021. The 21 measurements ranged from 87 to 33,400 ug/L and averaged 3,409 ug/L, which exceeds the AML of 1,200 ug/L and the maximum daily limit of 3,700 ug/L. Additional treatment may be necessary in order to comply with effluent limits derived from the economic analysis criteria. The facility can actively remove aluminum with a process such as chemical precipitation or ion exchange. EPA estimated the incremental cost to this facility of adding chemical precipitation or ion exchange to the existing treatment system and implementing a P2 program to reduce effluent concentrations of aluminum.
The effluent limits for ammonia derived from the potential baseline WQS are an AML of 32 mg/L and MDL of 104 mg/L. DMR data suggest that the facility meets the proposed AML about 54% of the time during the monitoring period from January 2016 to April 2021 that included 64 measurements. The facility currently meets the proposed MDL all the time, but a facility upgrade may be necessary to ensure compliance with the AML. EPA estimated the cost of a facility upgrade to include an additional nitrification step in the treatment process.
Copper was measured from July 2016 through April 2021. The 64 measurements ranged from 0.18 to 254 ug/L and averaged 168 ug/L, which exceeds the AML of 57 ug/L and MDL of 82 ug/L. To meet these effluent limits derived from the economic analysis criteria additional treatment may be necessary. The facility can evaluate P2 activities and active removal with a process such as chemical precipitation or ion exchange. EPA did not estimate additional incremental cost to the facility of adding chemical precipitation or ion exchange beyond the cost for these treatment processes for removal of aluminum. EPA did estimate the incremental cost of implementing an additional P2 program to reduce effluent concentrations of copper.
The facility had 64 detected measurements of chlorine from January 2016 to April 2021. The average of these detected measurements was 57.5 ug/L and the data ranged from 0.04 to 320 ug/L. No measurements exceeded the MDL derived from the economic analysis criteria, and only a single measurement exceeded the AML. Therefore, EPA did not estimate additional costs for treatment to meet chlorine limits at this facility.
Exhibit A-68 summarizes the estimated incremental costs for this facility.
Exhibit A-68: Kenyon Industries Estimated Incremental Costs (0.55 MGD)
Parameter
Control Option
Capital Cost
Other One-Time Cost
O&M Cost
Annual Cost (3%)[a]
Annual Cost (7%)[b]
Ammonia
Nitrification
                                   $512,843
                                      $0
                                    $45,800
                                    $80,271
                                    $94,209
Aluminum, Copper
Chemical Precipitation
                                  $1,269,157
                                      $0
                                   $350,130
                                   $435,437
                                   $469,929

Small Facility P2 Program
                                      $0
                                    $33,114
                                      $0
                                    $19,868
                                    $19,868

                 Alternative Treatment for Aluminum and Copper

Ion Exchange
                                  $1,195,903
                                      $0
                                   $119,786
                                   $200,169
                                   $232,671

Small Facility P2 Program
                                      $0
                                    $33,114
                                      $0
                                    $19,868
                                    $19,868
TOTAL:
                            $1,708,746 -$1,782,000
                                    $33,114
                              $165,586 -$395,130
                              $300,308 -$535,576
                              $346,748 - $584,006
Notes:
[a] Capital costs annualized over 20 years at a 3% discount rate. Other one-time costs are not annualized.
[b] Capital costs annualized over 20 years at a 7% discount rate. Other one-time costs are not annualized.
Roberto R. Bustamante WWTF (TX0101605)
The Roberto R. Bustamante WWTF (Bustamante WWTF; NPDES permit number TX0101605) in El Paso, Texas, discharges treated domestic wastewater to either the Riverside intercepting drain or Riverside Canal of the Rio Grande River.
EPA could not locate permit documentation for this facility and based the analysis on discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
The Roberto R. Bustamante WWTF reported permitted flow capacity is 39 MGD. The facility employs extended aeration activated sludge processes, biological nitrification.
Reasonable Potential Analysis
EPA had sufficient data to conduct reasonable potential analyses for the parameters shown in Exhibit A-69.
Exhibit A-69: Summary of Available Effluent Data for Bustamante WWTF (ug/L)
Parameter
Effluent Data[a]
Detection Limit

Samples
50[th] Percentile
Max

Ammonia
                                                                             35
                                                                          3,340
                                                                          5,420
                                                                             10
Chlorine
                                                                             55
                                                                          3,250
                                                                          3,810
                                                                             10
Note:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
Exhibit A-70 summarizes the RPA for all parameters with sufficient data. Critical flow data were not available; therefore no dilution was assumed for the RPA.
Exhibit A-70: Summary of Reasonable Potential Analysis for Bustamante WWTF (ug/L)
Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Ammonia
                                                                          8,300
                                                                          8,300
                                                                          3,340
                                                                         11,000
                                                                          1,400
                                                                              -
                                      Yes
                                      N/A
Chlorine
                                                                          4,100
                                                                          4,100
                                                                          3,250
                                                                             19
                                                                             11
                                                                              -
                                      Yes
                                      N/A
Note:
[a] No dilution was used for this analysis.
As shown above, ammonia and chlorine have reasonable potential to exceed WQBELs derived from the economic analysis criteria. Exhibit A-71 summarizes the average monthly and maximum daily effluent limitations that were calculated as part of the RPA for the WWTF.
Exhibit A-71: Summary of Calculated Limits for Parameters with Reasonable Potential for Bustamante WWTF (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Ammonia
                                      AL
                                                                          1,400
                                                                          2,600
                                                                          5,420
                                      Yes
Chlorine
                                      AL
                                                                             11
                                                                             12
                                                                          3,810
                                      Yes

Summary
DMR data show that the facility reports an average effluent ammonia concentration of 3.4 mg/L, with concentrations ranging from 1.0 to 5.4 mg/L during the monitoring period from January 2016 to December 2018, which included 35 measurements. Effluent limits derived from the economic analysis criteria are an AML of 1.4 mg/L and an MDL of 2.6 mg/L A facility upgrade will likely be necessary to meet the more stringent limits. EPA estimated the cost of adding a nitrification step in the treatment process for this facility.
The facility also reported 55 detected measurements of chlorine from January 2016 to July 2020. The average of these detected measurements was 3,328 ug/L with concentrations ranging from 2,710 to 3,810 ug/L. All measurements exceeded the AML of 10 ug/L and the MDL of 12 ug/L derived from the economic analysis criteria. Therefore, EPA estimated the cost of additional de-chlorination treatment for this facility.
Exhibit A-72 summarizes the estimated incremental costs for this facility.
Exhibit A-72: Bustamante WWTF Estimated Incremental Costs (39 MGD)
Parameter
Control Option
Capital Cost
Other One-Time Cost
O&M Cost
Annual Cost (3%)[a]
Annual Cost (7%)[b]
Ammonia
Nitrification
                                  $4,682,717
                                      $0
                                   $302,910
                                   $617,662
                                   $744,925
Chlorine
Dechlorination
                                  $8,177,283
                                      $0
                                   $313,799
                                   $863,441
                                  $1,085,676
TOTAL:
                                  $12,860,000
                                      $0
                                   $616,709
                                  $1,481,103
                                  $1,830,601
Notes:
[a] Capital costs annualized over 20 years at a 3% discount rate. Other one-time costs are not annualized.
[b] Capital costs annualized over 20 years at a 7% discount rate. Other one-time costs are not annualized.
McKinley Paper Company (WA0002925)
McKinley Paper Company (McKinley Paper; NPDES permit number WA0002925) is one of two paper mills that McKinley USA -- a subsidiary of Bio Pappel International and the largest paper manufacturer for packaging, containing, wrapping, and newspapers in the country -- operates in the United States. The facility is located in Port Angeles, Washington. This plant produces 295 tons/day of telephone directory paper by way of thermo-mechanical pulping, de-inking pulping, and non-integrated semi-bleach kraft pulping systems. The facility discharges treated wastewater, filtered backwash, and stormwater into the Salish Sea's Strait of Juan de Fuca.
EPA developed this facility analysis based on the 2019 permit and associated fact sheet issued by Washington's Department of Ecology together with discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
The McKinley Paper Company's Washington plant has a facility design flow of 12 MGD. The permit includes effluent limitations for BOD, TSS, oil and grease, and pH.
Before discharging, McKinley treats its wastewater and stormwater on site via primary settling, secondary activated sludge treatment, and secondary clarification. Outfall 001 discharges secondary effluent into the Strait, while Outfall 002 discharges filter plant backwash to the same receiving water.
Reasonable Potential Analysis
Discharge monitoring reports did not include sufficient data for any parameters for EPA to conduct an RPA; therefore, EPA estimated no incremental compliance costs for this facility.
Domtar A.W., LLC WRC (WI0003620)
Domtar A.W., LLC WRC (Domtar WRC; NPDES permit number WI0003620) is a complex of paper, paper coating, and kraft pulp production facilities -- Nekoosa Mill and Nekoosa Coated Products, LLC -- in addition to the Wastewater Reclamation Center that treats process wastewaters from the production facilities and site landfill leachates. The Domtar WRC is located between Port Edwards and Nekoosa, while the two production facilities are located in Nekoosa city. Domtar WRC discharges treated wastewater through a Parshall flume for flow measurement, to the Wisconsin River via Outfall 002. The facility has a maximum annual average flow of 16.74 MGD and an actual average flow of 16.21 MGD.
EPA developed this facility analysis based on the 2018 permit and associated fact sheet issued by the Wisconsin Department of Natural Resources together with discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
Domtar WRC processes wastewaters that include all vacuum pump seal waters from Nekoosa mill, process wastewaters from Nekoosa Coated Products, ash-bark landfill leachate, and stormwater.
Treatment mechanisms include primary clarification, UNOX high purity oxygen activated sludge, and secondary treatment. For primary treatment, the WRC employs two lined lagoons that effect flow equalization, cooling, and partial BOD removal for primary clarifier effluent. The effluent then proceeds to the UNOX biological treatment system.
Reasonable Potential Analysis
EPA had sufficient data to conduct a reasonable potential analysis for chlorine, as shown in Exhibit A-73.
Exhibit A-73: Summary of Available Effluent Data for Domtar A.W., LLC WRC (ug/L)
Parameter
Effluent Data[a] (ug/L)
Detection Limit

Samples
50[th] Percentile
Max

Chlorine
                                                                             50
                                                                         ND[b]
                                                                             ND
                                                                            10
Notes:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
[b] Reported results for chlorine were all below the DL.
Exhibit A-74 summarizes the RPA for all parameters with sufficient data. There was no information on authorization of mixing zones, so EPA assumed no mixing zones for this analysis.
Exhibit A-74: Summary of Reasonable Potential Analysis for Domtar A.W., LLC WRC (ug/L)
Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Chlorine
                                                                            0.0
                                                                            0.0

                                                                             19
                                                                             11

                                      No
                                      N/A
Note:
[a] No dilution was used in this analysis.
As shown above, the facility does not have reasonable potential for chlorine; therefore, no additional effluent limitations were calculated as part of this analysis.
Summary
EPA estimated no incremental compliance costs for this facility.
City of Baraboo WWTP (WI0020605)
The City of Baraboo's WWTP (Baraboo WWTP; NPDES permit number WI0020605) is in Baraboo, Wisconsin, and discharges via Outfall 001 to the Baraboo River.
EPA developed this facility analysis based on the 2021 permit issued by the Wisconsin Department of Natural Resources together with discharge monitoring reports from between 2016 and 2021.
Effluent and Treatment Process
This facility has an annual average design flow of 2.53 MGD. The permit requires that Baraboo WWTP perform seasonal disinfection from May 1 through September 30 each year but does not provide any further information on POTW's treatment processes. The permit includes effluent limitations for BOD, TSS, pH, ammonia nitrogen, other nitrogen species, fecal coliform, bacteria (E. coli), phosphorus, mercury, and whole effluent toxicity.
Reasonable Potential Analysis
EPA had sufficient data to conduct reasonable potential analyses for the parameters shown in Exhibit A-75.
Exhibit A-75: Summary of Available Effluent Data for the Baraboo WWTP (ug/L)
Parameter
Effluent Data[a]
Detection Limit

Samples
50[th] Percentile
Max

Ammonia
                                                                             12
                                                                         11,750
                                                                         25,000
                                                                             10
Chloride
                                                                             12
                                                                        250,000
                                                                        300,000
                                                                              4
Note:
[a] For aquatic life economic analysis criteria, the reasonable potential analysis uses an estimate of the 99[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration. For human health criteria, the reasonable potential analysis uses either 1) the 50[th] percentile concentration from the existing effluent data set if the effluent data set includes 10 or more observations or 2) an estimate of the 50[th] percentile effluent concentration statistically projected from the maximum observed effluent concentration if the effluent data set includes fewer than 10 observations. Thus, this table does not include a 50[th] percentile calculated from the effluent data set when there are less than 10 observations.
Exhibit A-76 summarizes the RPA for all parameters with sufficient data. Critical flow data were not available, and no dilution factors were used in this analysis.
Exhibit A-76: Summary of Reasonable Potential Analysis for the Baraboo WWTP (ug/L)
Parameter
Conc at Edge of Mixing Zone[a]
Applicable Criteria
RP

Acute
Chronic
HH
Acute
Chronic
HH
AL
HH
Ammonia
                                                                        98,300
                                                                        98,300
                                                                        11,750
                                                                        11,000
                                                                         1,400
                                       -
                                      Yes
                                      N/A
Chloride
                                                                       351,300
                                                                       351,300
                                                                       250,000
                                                                       860,000
                                                                       230,000
                                       -
                                      Yes
                                      N/A
Note:
[a] No dilution was used for this analysis.
As shown above, there is reasonable potential for ammonia and chloride. Exhibit A-77 summarizes the average monthly and maximum daily effluent limitations that were calculated as part of the RPA for the Baraboo WWTP.
Exhibit A-77: Summary of Calculated Limits for Parameters with Reasonable Potential for the Baraboo WWTP (ug/L)
Parameter
Limiting Criterion
Limits
Max Conc
Exceeds Limit?

AML
MDL

Ammonia
                                      AL
                                                                          1,400
                                                                          4,200
                                                                         25,000
                                      Yes
Chloride
                                      AL
                                                                        220,000
                                                                        250,000
                                                                        300,000
                                      Yes

Summary
DMR data show that effluent ammonia concentrations average 12.5 mg/L and ranged from 0.33 to 25.0 mg/L during the monitoring period from January 2016 to December 2017 that included 12 measurements. The effluent limits derived from the economic analysis criteria are an AML of 1.4 mg/L and MDL of 4.2 mg/L. A facility upgrade may be necessary to meet these limits.
The facility reported 12 detected measurements of chloride from January 2017 to December 2017. The average of these detected measurements was 257 mg/L and the data ranged from 230 to 300 mg/L. Many of the measurements exceeded the AML of 223 mg/L, and the MDL of 253 mg/L derived from the economic analysis criteria, indicating that the facility may need additional treatment for removal of chlorides.
However, while the current permit includes seasonal effluent limits and monitoring requirements for ammonia, it does not include effluent limits or monitoring requirements for chloride. Furthermore, available DMR data for ammonia and chloride are available only for January 2016 through December 2017. Reverse osmosis, which would be required for chloride removal, is an expensive technology not widely used for wastewater treatment.
Based on these considerations, and as summarized in Exhibit A-78, EPA is estimating costs for this facility based on the cost of an additional nitrification step for ammonia removal to concentrations that would be required under the economic analysis criteria and either a P2 program or both a WQS variance and P2 program for chloride.
Exhibit A-78: City of Baraboo WWTP Estimated Incremental Costs (2.53 MGD)
Parameter
Control Option
Capital Cost
Other One-Time Cost
O&M Cost
Annual Cost (3%)[a]
Annual Cost (7%)[b]
Ammonia
Nitrification
                                   $988,000
                                      $0
                                    $66,210
                                   $132,619
                                   $159,470
Chloride
Small Facility P2 Program
                                      $0
                                    $16,557
                                      $0
                                    $9,934
                                    $9,934

                 Alternative Compliance Mechanism for Chloride

Small Facility P2 Program
                                      $0
                                    $16,557
                                      $0
                                    $9,934
                                    $9,934

Variance Feasibility Analysis
                                      $0
                                    $45,164
                                      $0
                                      $0
                                      $0

Variance Application
                                      $0
                                   $127,840
                                      $0
                                      $0
                                      $0
TOTAL:
                                   $988,000
                                   $189,561
                                    $66,210
                                   $142,553
                                   $169,404
Notes:
[a] Capital costs annualized over 20 years at a 3% discount rate. Other one-time costs are not annualized.
[b] Capital costs annualized over 20 years at a 7% discount rate. Other one-time costs are not annualized.
Source Control and Alternative Compliance Mechanism Supplemental Information and Costs
Source Control (P2 Program) Costs
As discussed in Section 4.4.2, controlling the source of pollutants entering a facility through a P2 program would likely be the next most cost-effective control option after process optimization. Some pollutants may also be present as a result of processes within a facility (e.g., contaminants from industrial processes for industrial dischargers). EPA reviewed requirements of P2 programs primarily for pollutants that triggered RP for sewerage systems, such as copper. It is expected that many facilities would at least attempt to limit influent concentrations or reduce pollutants used in their processes by exploring pollutant sources upstream through a P2 program.
Facilities seeking to limit their compliance costs are likely to implement P2 programs for the pollutants with effluent limits lower than what they are currently meeting, either as their main compliance mechanism, or in conjunction with another mechanism.
Copper is a pollutant that is prevalent and triggered RP for several facilities. A P2 program for copper for a POTW is likely to include: program development, sampling and analysis, workshops and other consultant work, advertising (i.e., public service announcements) and/or a website. Costs for these components were estimated as part of the economic analysis associated with EPA's copper and cadmium rule for the State of Oregon (EPA, 2016). EPA is estimating the cost of a P2 program for copper at a POTW and using this cost as an estimate for P2 programs and other programs to identify and reduce pollutants prior to treatment for all categories of facilities. This assumption may lead to overestimating costs for some facilities (e.g., industrial facilities that can more readily identify and eliminate the source of a pollutant in their effluent because of its control of processes and process inputs).
Because the current analysis includes tribal lands spread across multiple states, EPA updated costs from EPA's 2016 Economic Analysis for the Final Rule: Aquatic Life Criteria for Copper and Cadmium in Oregon to reflect national-scale labor rates and 2020 dollars (Bureau of Labor Statistics  -  BLS, 2020a; BLS, 2020b), as well as costs per sample based on a representative national average. Exhibit B-1 shows the estimated program costs (in 2020 dollars) at the national level for a copper P2 program for a small, medium and large facility. Costs for P2 programs for all pollutants were estimated based on experience with P2 programs for copper.
Exhibit B-1 Potential Initial and Annual Cost for P2 Program for Copper[a]
Facility Size
Initial Costs
Annual Costs
Small Facility (1-5 MGD)
$16,557
$9,934
Medium Facility (>5-20 MGD)
$33,115
$15,454
Large Facility (>20 MGD)
$49,672
$20,973
Note:
[a] Cost estimates are based on January 2015 to January 2020 inflation (BLS, 2021).
Alternative Compliance Mechanisms
WQS Variance
As noted in Section 4.4.4, dischargers are most likely to pursue a WQS variance based on economic infeasibility (40 CFR 131.10(g)(6)). Such an evaluation may require a comprehensive literature search and analysis of the data compiled from the search. The literature search may encompass general information identifying the treatment technologies capable of removing the pollutants of concern, background on the processes driving the removal or reduction of pollutants, and performance data showing the effluent levels demonstrated for WWTPs at pilot- and full-scale. Costs for these components were estimated as part of the economic analysis associated with EPA's copper and cadmium rule for the State of Oregon (EPA, 2016). Exhibit B-2 provides estimates of levels of effort that may be associated with technological feasibility analyses, based on EPA's recent cost estimates for Oregon (EPA, 2016). Because the current analysis includes tribal land spread across the entire country, EPA updated these costs to reflect national labor rates.
Exhibit B-2 Potential Level of Effort to Investigate Technological Feasibility for a Variance
Component
Hours
Cost[a]
Literature search
180
$25,405
Write up and evaluation of theory and performance data from search
100
$14,114
Evaluation of existing treatment performance
40
$5,645
Total
320
$45,164
Note:
[a] All cost estimates are based on a labor rate of $141/hr, reflecting the average wage for an environmental engineer in the USA in 2020 dollars (BLS, 2020b) and multiplied by a factor of 3.03 to account for overhead, benefits, and profit (PSMJ, 2007).
To evaluate the potential for control costs to cause "substantial and widespread economic and social impacts" (the regulatory language to be satisfied), dischargers are likely to follow EPA's Interim Economic Guidance for Water Quality Standards, which provides worksheets and instructions for public and private sector entities (EPA, 1995). Following this workbook, dischargers conduct a two-step analysis, first determining whether the control costs would have a substantial adverse financial impact and, if so, whether that impact would cause widespread adverse impacts on the surrounding community.
EPA based unit costs for WQS variances on estimates previously developed for the economic analysis associated with EPA's copper and cadmium rule for the State of Oregon (EPA, 2016). To account for a nationwide potential cost, EPA updated the Oregon costs to reflect national labor rates. Exhibit B-3 shows the cost for a variance under 40 CFR 131.10(g)(6) for economic and social impacts.
Exhibit B-3 Potential One-Time Cost to Apply for and Review WQS Variances for Economic and Social Impacts (40 CFR 131.10(g)(6))
Facility Size
Cost for Variance Preparation[a]
Small Facility (1-5 MGD)
                                   $127,840
Medium Facility (5-20 MGD)
                                   $255,680
Large Facility (>20 MGD)
                                   $383,520
Note:
[a] Based on a labor rate of $141/hr, reflecting the average wage for an environmental engineer in the USA in 2020 dollars (BLS, 2020b) and multiplied by a factor of 3.03 to account for overhead, benefits, and profit (PSMJ, 2007).
This analysis does not address costs associated with implementing controls necessary to meet the highest attainable condition, which may be intermediate between current performance and fully meeting the WQBEL associated with the proposed WQS.
EPA may require facilities to implement a P2 or source control program as part of the conditions for granting a variance. Thus, to be conservative (i.e., err on the side of overestimating costs), EPA assumed that facilities would need to implement a P2 program as part of a variance program.
 Dilution Credit
When applying for an RMZ, a specific study is required to estimate and document the level of mixing which is likely to be present in the receiving water under applicable critical conditions. A study of this type will typically require data collection and the mathematical modeling of the discharge and ambient receiving environment. In developing costs associated with developing a dilution special study, EPA estimated that an environmental engineer would spend approximately 320 hours to develop and interpret the model. EPA assumed the costs to obtain modeling software would be negligible, as EPA distributes software appropriate to this application (i.e., VisualPlumes) free of charge. Exhibit B-4 shows the costs for a dilution study.
Exhibit B-4 Potential Costs for a Dilution Study
Component
Hours
Cost
Dilution Study[a]
                                      320
                                    $45,120
      Note:
      [a] Based on a labor rate of $141/hr, reflecting the average wage for an environmental engineer in the USA in 2020 dollars (BLS, 2020b) and multiplied by a factor of 3.03 to account for overhead, benefits, and profit (PSMJ, 2007).

References
BLS (Bureau of Labor Statistics). 2020a. May 2020 National Occupational Employment and Wage Estimates, United States. Water and Wastewater Treatment Plant and System Operators Wages (Occupation Code 51-8031). http://www.bls.gov/oes/current/oes_nat.htm.
BLS (Bureau of Labor Statistics). 2020b. May 2020 National Occupational Employment and Wage Estimates, United States. Environmental Engineer Wages (Occupation Code 17-2081). http://www.bls.gov/oes/current/oes_nat.htm.
BLS (Bureau of Labor Statistics). 2021. CPI Inflation Calculator. https://www.bls.gov/data/inflation_calculator.htm.
EPA (United States Environmental Protection Agency). 1995. The Great Lakes: An Environmental Atlas and Resource Book. Third Edition. EPA 905-B-95-001.
EPA (United States Environmental Protection Agency). 2016. Economic Analysis for the Proposed Rule: Aquatic Life Criteria for Copper and Cadmium in Oregon.
PSMJ (PSMJ Resources, Inc.). 2007. A/E Financial Performance Survey, 27th Edition: CEO Snapshot.

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Effluent Treatment Control and Costs
Based on the RPAs, analysis of monitoring data, and best professional judgement, described in detail in Appendix B, the pollutants that require further reduction are aluminum, ammonia, chloride. chlorine, chromium VI, copper, cyanide, manganese, nonylphenol, selenium, THMs, and zinc.
The first step for a treatment facility is to optimize the existing treatment process(es) with minor modifications. For ammonia removal, it is important to have adequate control of biochemical oxygen demand (BOD), alkalinity, air supply, and proper control of oxygen. For THM reduction, a THM precursor removal prior to disinfection, a different injection point for chlorine in the process, or a different type of disinfectant should be considered. After treatment optimization is completed and if further reduction is required, an effluent treatment may be considered. Effluent treatments evaluated for the purposes of this analysis include:
Treatment process optimization
Chemical precipitation
Ion exchange (IX)
GAC
Nitrification
Dechlorination
Reverse osmosis (RO)
Treatment Process Optimization
Treatment optimization costs (e.g., a few probes, addition of a carbon source or other chemicals) are typically minimal compared to effluent investments, and more importantly, are facility and treatment process-specific, and cannot be costed without an understanding of the specific facility. EPA assumed zero to minimal cost for most treatment process optimization actions.
Under process optimization, each unit process should be reviewed for target pollutant(s) removal, for example:
Dissolved oxygen and an oxidation-reduction or ammonia probe could be considered in the biological treatment for ammonia removal
A change in the application point for disinfectant or use of a different disinfectant could be considered in the process stream for THM reduction (Metcalf and Eddy, 2013; HACH, 2016).
Ammonia is removed when the ammonium ion (ammonia in water) is converted into nitrites and nitrates. These reactions require adequate amount of oxygen, alkalinity, and BOD. In the wastewater industry, biological processes are likely already equipped with dissolved oxygen, pH, and oxidation-reduction and/or ammonia probes to provide the information for process control and optimization of nitrification. To reduce ammonia concentrations, and comply with calculated WQBELs, some facilities may incur no cost or the minimal cost for a process analysis (similar to the one-time cost of a pollution prevention program).
Similarly, improving TDS removal will remove a portion of the THM precursors, which will reduce the formation of THMs during the disinfection (chlorination) process. A change of disinfectant application point(s) may also reduce the formation of THMs. Another option is to select a different disinfectant, such as a UV system, chlorine dioxide, and others. (Metcalf and Eddy, 2013). Addressing THMs is part of facility optimization, and EPA estimated no cost in addressing these pollutants.
Chemical Precipitation
Chemical precipitation is a common practice in wastewater treatment. Many metals can be removed from wastewater by the addition of chemical reagents that cause the metal to form a solid, which can be settled, filtered, or otherwise removed from the system prior to discharge (EPA, 2000a). The removal of metals (such as copper, aluminum, and zinc) can often be achieved by adding one or more compounds that create insoluble metal carbonates or hydroxides that are then physically removed from the water (EPA, 2000a). Typical additives include lime (calcium oxide), ferrous sulfate, and alum (EPA, 2000a). These precipitation processes are influenced by pH and sometimes dissolved oxygen, to be effective. The amount of chemical used in the precipitation process can vary depending on pH, alkalinity, the point of injection and mixing performed post injection (EPA, 2000a). Often a benchtop analysis is performed to optimize the amount and specific additive mixture needed to perform optimally for a given wastewater treatment system.
EPA (2000a) summarized the advantages and disadvantages of chemical precipitation:
Advantages
Chemical precipitation is a well-established technology with ready availability of
equipment and many chemicals.
Some treatment chemicals, especially lime, are very inexpensive.
Completely enclosed systems are often conveniently self-operating and low maintenance, requiring only replenishment of the chemicals used. Often times, a sophisticated operator is not needed.
Disadvantages
Competing reactions, varying levels of alkalinity and other factors typically make calculation of proper chemical dosages impossible. Therefore, frequent jar tests are necessary for confirmation of optimal treatment conditions. Overdosing can diminish the effectiveness of the treatment.
Chemical precipitation may require working with corrosive chemicals, increasing operator
safety concerns.
The addition of treatment chemicals, especially lime, may increase the volume of waste sludge up to 50 percent.
Large amounts of chemicals may need to be transported to the treatment location.
Polymers can be expensive.
A typical chemical precipitation system has an automatic chemical feed component that adds the chemical(s), monitors the process, and controls the amounts being added. The components may include storage tanks, feed tanks, metering pumps (or other type of conveyance), overflow containment basins, mixers, aging tanks, injection ports, injection controls, pipes and fittings, and valves (EPA, 2000a). The specific system components will vary according to the chemicals being used; whether they are wet, gaseous, or dry; how corrosive each chemical is, and the volumes required.
For aluminum, copper, and zinc control, mixtures of lime and ferrous sulfate may be used and for manganese removal, potassium permanganate may be used. For costing purposes, EPA assumed ferrous sulfate addition for chemical precipitation. In the costing analysis, for facilities where available information indicated that the treatment system currently has primary clarifiers, these clarifiers were specified as adaptable for the chemical precipitation/coagulation phase of the process. In the analysis, EPA made the conservative assumption that filtration would be added as a tertiary treatment process.
Nitrification
In some systems, the biological treatment process (oxidation ditch, activated sludge, lagoon, etc.) is not designed to sufficiently to remove ammonia to levels required in the ammonia criteria used as the basis for calculating WQBELs in the analysis. The first step for a facility with elevated ammonia levels should be an evaluation of the treatment processes that includes process modeling and optimization. When the modeling and optimization do not provide effluent levels of ammonia required to meet the criteria, additional process modifications are necessary to reduce the ammonia levels in the effluent.
Nitrification is the process of biologically converting ammonia to nitrite and then to nitrate using nitrifying bacteria. The process is aerobic, so sufficient oxygen in the treatment system is essential. Also, alkalinity is consumed in the nitrification process, so some systems may require alkalinity additions to the process water.
Nitrification processes in wastewater treatment can be achieved in fixed film reactors where a biofilm (containing nitrifying bacteria) is grown on some form of media in the process. For this analysis, several fixed film reactors were evaluated including trickling, rotating biological contactor (RBC), and moving bed biological reactor (MBBR). Nitrification can also be achieved in suspended growth processes where the bacterial film attaches to solids in the process water. Examples of suspended growth nitrification systems include oxidation ditches, sequencing batch reactors, and a variety of proprietary multi-stage reactors. Additional information on nitrification can be found in EPA fact sheets such as Trickling Filter Nitrification (EPA, 2000b). For costing purposes, EPA assumed the addition of a nitrifying trickling filter when an additional nitrification step was required.
Chlorination
Cyanide can be treated in wastewater with an alkaline oxidation process. This two-step process uses chlorine (using hypochlorite or chlorine gas) to oxidize cyanide to cyanate in an alkaline environment (which is achieved by adding a strong base, typically sodium hydroxide). Next cyanate is oxidized to carbon dioxide and nitrogen by adding more chlorine to the process water (Sensorex, 2021).
Control of the system pH is essential in the conversion of cyanide to cyanate, so the process typically uses pH and oxidation-reduction potential (REDOX or ORP) sensors to help control the reactions (Sensorex, 2021). Chlorine and sodium hydroxide are added and mixed in the first step. The system pH is maintained at 10-11.5 and the ORP is controlled at 250-400mV for optimal results (Sensorex, 2021). In the second phase, the system pH is reduced to 8.5-9 and ORP maintained at 300-600mV for optimal results (Sensorex, 2021).
Dechlorination
Dechlorination removes excess or residual chlorine from a waste stream prior to discharge. The most common dechlorination process uses sulfur dioxide. Other additives that can be used to dechlorinate water include carbon adsorption (see below), sodium metabisulfite, sodium bisulfite, and hydrogen peroxide (EPA, 2000c). Using sulfur dioxide requires equipment similar to the equipment used in systems that use chlorine gas for chlorination. Both chlorine gas and sulfur dioxide are dangerous and require numerous safety precautions to be in place. A typical dechlorination system has a chemical storage and delivery system, contact chambers, mixing, and sensors placed in the process water to ensure optimal results (EPA, 2000c). For costing purposes, EPA assumed that dechlorination would be accomplished using sodium sulfite (dry chemical) in a contact chamber.
Ion Exchange (IX)
Ion exchange technology has been designed to remove dissolved and ionic forms of pollutants from wastewater using resins selected specifically for their pollutant removal properties. The treatment system relies on adsorption and chemical bonding of ions through ion exchange, and works best when waste streams are pretreated to remove suspended and dissolved solids to enhance pollutant removal and eliminate competing ions (NDWC, 1997).
The ion exchange process consists of four operations: service, backwash, regeneration, and rinse. In the service step, the resin is contacted with the influent water. The resin is considered spent once it can no longer remove the desired amount of pollutant. Next, the backwash step is initiated to expand the bed and to remove fines that may be clogging the packed bed. The spent resin is regenerated using a concentrated solution of the original exchange ion, reversing the exchange process. Lastly, the rinse step removes excess regeneration solution before the column is brought back online for the next service cycle. Note that some sorbents cannot be regenerated, and once they are spent (i.e., there is no more capacity to adsorb copper, cyanide, and others), they are disposed of and replaced with fresh media. Advantages of ion exchange technology include:
A large variety of specific resins are available from manufacturers, tailored to removal of specific pollutants; and
Pollutants can be recovered from most resins upon regeneration (NDWC, 1997).
Use of ion exchange also has disadvantages:
Management and disposal of spent media or regenerated brine can be costly, due to high concentrations of the waste effluent;
Effluent quality may be highly variable (depending on sorbent loading);
To achieve low pollutant levels in wastewater, extensive pretreatment may be necessary; and
Ion exchange units are sensitive to the presence of competing ions (NDWC, 1997).
For copper, historically, the use of sorbent resins has been limited to strong acid cationic resins applied to industrial wastewater containing inorganic copper and calcium. The selectivity of copper is less than that for calcium. Certain cationic resins can also be used to remove copper because they have a high selectivity for copper. Another resin that can be used to remove copper is a chelating resin, such as amidoxime chelating resin which is designed for removal of cations of metals, such as copper and iron from water at relatively low pH. Also, a typical ion exchange system is often designed with lead and lag vessels. When the treatment system is properly designed and maintained, the expected copper removal can reach 95 percent (WesTech, 2016).
Granular Activated Carbon
GAC has been used successfully in advanced treatment of municipal and industrial wastewater for years. GAC is primarily used to adsorb refractory organics, such as 4,4'-DDT, alpha-BHC, dioxin, bis(2-ethylhexyl) phthalate, PCBs, THMs as well as residual amounts of inorganics such as nitrogen, sulfides, and heavy metals (Metcalf and Eddy, 2013). However, water-soluble compounds and small molecules are not adsorbed well (NAVFAC, 2008).
GAC adsorption occurs when pollutant molecules adhere to the internal walls of pores in carbon particles produced by thermal activation (EPA, 2000d). At municipal WWTPs, GAC is usually installed prior to disinfection, but after filtration (or some other type of pretreatment) that removes suspended solids in order to prevent fouling and maximize the time before breakthrough occurs (i.e., the point at which the pollutant is no longer absorbed).
Advantages of GAC include the following:
Proven, reliable technology for removing dissolved organics
Low space requirements
Easy to incorporate into existing systems (EPA, 2000d).
However, GAC is not without its disadvantages, including:
Under certain conditions, hydrogen sulfide may be generated from bacterial growth, creating odor and corrosion problems
Wet GAC is highly corrosive and abrasive
Requires pretreated wastewater with low suspended solids, and little variations in pH, temperature, and flow rate (EPA, 2000c)
Spent carbon may be a hazardous waste
Spent carbon must be regenerated or disposed of and the adsorbed pollutants must be destroyed, often by incineration (possibly re-releasing pollutants into the environment; organic pollutants are usually thermally degraded)
The presence of multiple pollutants can affect the process performance due to competitive adsorption of different classes of compounds; bench tests may be conducted to estimate carbon usage for mixtures
Some common chlorinated pollutants are weakly sorbed, resulting in low GAC capacity
Type and pore size of the carbon, as well as the operating temperature, must be carefully selected to optimize pollutant removal (NAVFAC, 2008).
EPA was not able to find any studies demonstrating GAC organics removal at WWTPs, although there are several plants throughout the country using GAC either to supplement secondary treatment or to enhance phosphorus removal. EPA's PCS database for these facilities contains no effluent data for toxic pollutants. GAC has been used for a number of groundwater cleanup operations. However, the removal rates vary based on the specific pollutant, quality of the source water, and operating parameters of the GAC unit (e.g., single versus dual stage).
Although GAC can remove low concentrations of certain metals, it has not been widely used for this purpose possibly due to the fact that spent carbon used for metals removal can be difficult to regenerate and may require treatment and/or disposal as a hazardous waste (EPA, 1991).
Use of this type of GAC for heavy metal removal at WWTPs discharging to surface waters has not been demonstrated on a full scale. The major disadvantage to this type of GAC it that it cannot be regenerated, so once its capacity is exhausted, it must be replaced with new media, which can be costly.
Reverse Osmosis (RO)
Theoretically, reverse osmosis (RO) can remove nearly all inorganic pollutants from water, (NDWC, 1997), as well as viruses and most organic pollutants, including some pesticides. The process removes pollutants from water using a semi-permeable membrane that permits only water molecules to pass through its pores. The contaminated water is subjected to high pressures that force pure water through the membrane, leaving pollutants behind in a brine solution (NDWC, 1997).
Properly operated RO units can achieve 96 percent removal of arsenic (III), arsenic (IV), barium, cadmium, chromium (III), chromium (VI), fluoride, lead, mercury, nitrite, selenium (IV), selenium (VI), and silver (NDWC, 1997). They will also likely achieve 95 percent removal of copper (WestTech, 2016). Multiple RO units operated in series, however, are capable of nondetectable or almost 100 percent removal rates (NDWC, 1997). RO has several advantages, including:
Removal of nearly all pollutant ions and most other dissolved pollutants
Relatively insensitive to flow and total dissolved solids levels
Also removes bacteria and particulates (NDWC, 1997).
However, despite these claims, there are no full scale performance data available from WWTPs discharging to surface waters that indicate that such removals are possible at these facilities on a consistent basis. This may be due to the fact that few, if any, facilities have been required to reduce toxic pollutants to such low levels through the use of end- of-pipe treatment. The use of RO for treating wastewater is limited, and therefore performance data are scarce.
Even if the necessary pollutant levels are achievable with RO, it is important to consider the potential disadvantages and limitations of this technology, including:
Capital and operating (including energy) costs are high, and the latter increase with decreasing desired effluent concentrations;
Management and disposal of residuals (brine and media) is potentially costly and problematic;
Expensive pretreatment may be required to maintain the high treatment efficiency levels needed to achieve extremely low levels of pollutants (e.g., carbon prefilter for the reduction of chlorine, which can damage some types of chlorine sensitive RO membranes, sediment pre-filter or microfiltration to ensure that fine suspended materials do not clog the membrane);
Membranes are prone to fouling (NDWC, 1997);
The technology may not be feasible for treatment of large flows; and
RO does not remove pollutants from the environment, rather transfers them to another medium (pollutants are concentrated in the reject discharge or brine).
The most limiting of these disadvantages, especially for larger systems, is the management and disposal of residuals. Most RO systems reject about 10% to 25% of influent water as a concentrated brine solution (EPA, 1996). This brine contains the pollutants removed from the wastewater and must be treated prior to disposal. The more feasible residual disposal options for WWTPs include:
Land disposal (e.g., evaporation pond, underground injection)
Treatment (e.g., brine concentrator, thermal evaporation) (Metcalf and Eddy, 2013).
The first option requires that the waste be classified as nonhazardous. Otherwise, the brine must be disposed of as a hazardous waste, which can be extremely costly, especially for larger volumes. The land disposal option also may require a large amount of land, and if evaporation ponds are the only land disposal option, precipitation rates cannot be greater than evaporation rates. The treatment through controlled evaporation is feasible, although operating and maintenance costs may be extremely high. This approach is usually only employed where no other alternatives are available (Metcalf and Eddy, 2013).
In addition, these disposal options do not guarantee that the pollutants in the residuals will not be re-released into the environment. The pollutant is simply transferred from the effluent to a residual brine that must be disposed of in some manner.
Because no WWTPs in the country have installed RO to remove toxics to very low levels for discharges to surface waters, there is no information on installed costs. Nor is information available from similar industrial applications. However, EPA contacted RO system manufacturers to obtain price quotes on RO system configurations set up to meet these low copper levels. Exhibit C-5 summarizes the assumptions used by the manufacturer to price an RO unit.
Exhibit C-5 Parameters Provided for Costing RO and Ion Exchange Systems for Wastewater
Component
Input Value
Hardness
                                   140 mg/L
Alkalinity
                                   140 mg/L
pH
                                      7.5
Temperature
                                    20° C

Scaling is a concern in RO operation; the scaling potential may limit the water recovery percentage of each RO unit. The less water that is recovered from each unit, the greater volume of residual brine that needs treatment and disposal, thus increasing capital and operating costs. If the concentration of barium or sulfate is higher than shown in the exhibit, or if silica is present, water recovery could be limited.
Certain RO membranes are intolerant of free chlorine, and most microfiltration membranes have limited chlorine tolerance. Thus, prior to microfiltration, the wastewater should be dechlorinated if chlorine is used in previous treatment units. Note that dechlorination may result in an increase in sulfate ions, which, as mentioned above, could contribute to the scaling potential of the RO membranes. Costs may be higher than shown to account for these factors.
For the Los Alamos National Laboratory in Arizona, EPA considered two options for brine management: evaporation ponds with land application and blending with the plant's biosolids and hauling away for off-site disposal. Cost estimates do not include land cost, which may be federally owned, or the hauling cost because biosolids are most likely already being hauled and the tipping charge is assumed to be on a contract basis. Both options provide a range of disposal costs. The cost of land application rate (Tetra Tech, 2012) was adjusted to 2017 dollars. For disposal with biosolids, the final pollutant concentration of the blend of biosolids and brine concentrate may limit disposal options.
Costing Discussion
For this economic analysis, EPA used CapdetWorks, which is a software tool for preliminary, planning-level design and cost estimation for WWTP construction project alternatives that is based on the CAPDET program originally developed by the U.S. Army Corps of Engineers (USACE). CapdetWorks designs user-specified unit processes based on influent characteristics and then estimates the capital and operation and maintenance (O&M) costs of the design.
Capital cost estimates in CapdetWorks depend on several factors, including equipment cost for treatment units, land cost, construction labor wages, and other direct and indirect construction costs. CapdetWorks allows the user to overwrite default values for the equipment cost indices, land cost, and construction labor rate used in the program. EPA used construction cost indices for 2020 provided in CapdetWorks and construction labor rates based on construction worker wages from the Bureau of Labor Statistics (BLS) for 2020.
O&M cost estimates in CapdetWorks consist of several components: operation, maintenance, material, chemicals, and energy. Operation costs are further divided by type of labor and include WWTP operator, administrative, and laboratory labor costs. Calculations in CapdetWorks assume that wages for administrative staff (e.g., plant managers, clerical staff) are, on average, the same as wages for WWTP operators. CapdetWorks allows the user to overwrite default values for labor rates and energy costs. EPA used labor rates based on BLS 2020 wage data and energy rates based on the 2020 national average electricity cost to commercial customers. WWTP operator, administrative, and laboratory labor make up the CapdetWorks estimate of operation costs while maintenance cost estimates in CapdetWorks consist solely of WWTP operator labor.
For this assessment EPA estimated costs of additional treatment units using CapdetWorks by evaluating incremental costs above the cost of a baseline treatment system. Baseline systems for each facility were defined in CapdetWorks as a simplified version of the facility's existing treatment system as described in available information from NPDES permits and fact sheets or other available facility descriptions.
 References
EPA (United States Environmental Protection Agency). 1991. Engineering Bulletin: Granular Activated Carbon Treatment. EPA/540/2-91/024.
EPA (United States Environmental Protection Agency). 2000a. Wastewater Technology Fact Sheet: Chemical Precipitation. EPA 832-F-00-018.
EPA (United States Environmental Protection Agency). 2000b. Wastewater Technology Fact Sheet: Trickling Filter Nitrification. EPA 832-F-00-015.
EPA (United States Environmental Protection Agency). 2000c. Wastewater Technology Fact Sheet: Dechlorination. EPA 832-F-00-022.
EPA (United States Environmental Protection Agency). 2000d. Arsenic Removal from Drinking Water by Ion Exchange and Activated Alumina Plants. EPA 600-R-00-088.
HACH (HACH Company). 2016. Personal Communication with HACH Sales Representative for DO, pH, Oxidation/Reduction, and Ammonia Probes.
Metcalf and Eddy. 2013. Wastewater Engineering: Treatment and Reuse. Fifth Edition. McGraw Hill, Boston, MA
NAVFAC (Naval Facilities Engineering Command). 2008. Environmental Restoration and BRAC: Granular Activated Carbon (GAC) Adsorption (Liquid Phase). https://portal.navfac.navy.mil/portal/page?_pageid=181,5782928&_dad=portal&_schema=PORTAL.
NDWC (National Drinking Water Clearinghouse). 1997. Tech Brief: Ion Exchange and Demineralization. https://wcwc.ca/wp-content/uploads/2021/01/NESC-Tech-Brief_Ion-Exchange-and-Demineralization.pdf?msclkid=26782e07b12b11ec81b8cf13d750e1b6.
Sensorex. 2021. What You Need to Know About Cyanide Wastewater Treatment. https://sensorex.com/blog/2016/04/26/cyanide-wastewater-treatment/
Tetra Tech (Tetra Tech, Inc.). 2012. Biosolid Management System Alternatives Study - Wastewater Documentation Updates. http://media.ktoo.org/2013/09/Biosolids_Report.pdf?msclkid=79256c83b12b11ec85c40a6c2fcbe5e0.
WesTech (WesTech Engineering). 2016. Personal communication with Jon Farrell and Lindsay Horsley. For pricing of Ion Exchange and RO systems
--------------------------------------------------------------------------------
Pollutant Impacts
Exhibit D-1 identifies the parameters with potential human health impairments in Indian reservation waters, the number of water bodies with potential impairment (as identified in Section 6.2), and a description of the contaminants' human health impacts and the cancer classification according to the Agency for Toxic Substances and Disease Registry (ATSDR).
Exhibit D-1 Parameters with Potential Human Health Criteria Impairments and Adverse Health Impacts[a]
Parameter
Potentially Impaired Waterbodies
Affected Organ Systems
Antimony
                                       1
Cardiovascular, respiratory
Barium
                                       1
Cardiovascular, gastrointestinal,
Copper
                                       1
Gastrointestinal, hematological, hepatic, respiratory, endocrine, ocular, neurological, reproductive
Dieldrin
                                       1
Developmental, endocrine, hepatic, immunological, neurological, cardiovascular, reproductive
E. coli
                                      68
Gastrointestinal
Enterococci
                                       3
Gastrointestinal
Manganese
                                      56
Cardiovascular, neurological, respiratory, hematological, reproductive
Methylmercury
                                       1
Developmental, neurological, renal
Nickel
                                       1
cardiovascular, dermal, immunological, respiratory, renal, reproductive, developmental, gastrointestinal, hepatic, renal
Nitrates
                                      18
Gastrointestinal, hematological, endocrine, dermal
pH
                                      54
Acidic conditions may cause other pollutants to dissolve, increasing exposure to and toxicity of metals, for example
Zinc
                                       1
Gastrointestinal, hematological, respiratory, ocular, homeostatic, immunological
Notes:
[a] Source: based on Agency for Toxic Substances and Disease Registry (ATSDR). Toxic Substances Portal.
Exhibit D-2 describes the potential environmental concerns associated with potential impairments, specifically related to aquatic species.
Exhibit D-2 Parameters with Potential Aquatic Life Impairments and Adverse Impacts to Aquatic Species[a]
Parameter
Potentially Impaired Waterbodies
Environmental Concern
Alkalinity
                                      114
Important for fish and other aquatic life in freshwater systems because it is a measure of the buffering capacity of the water, and since pH has a direct effect on organisms as well as an indirect effect on the toxicity of certain other pollutants in the water, this buffering capacity is important to water quality
Aluminum
                                      15
Elevated levels of aluminum can affect some species ability to regulate ions, like salts, and inhibit respiratory functions, like breathing. Aluminum can accumulate on the surface of a fish's gill, leading to respiratory dysfunction, and possibly death.
Ammonia
                                       2
Impairment of gill ionoregulation and/or respiratory dysfunction or polymerization of aluminum hydroxides on the gill surface during alkalinization of water passing over the gills
Arsenic
                                       2
Causes poisoning of the liver and kidney in fish
Cadmium
                                       3
Accumulates majorly in stomach, liver and gills in fish; at sub-lethal levels it can produce toxic effects on the hepatic, immunological and hematological functions of fish
Chloride
                                       1
Elevated levels observed in fish with liver and blood abnormalities
Chlorine
                                       3
Elevated concentrations are toxic to fish; at lower concentrations, it stresses fish by damaging their gills
Chromium (III)
                                       1
Destabilizes the ecosystem due to their toxic impact on biota and bioaccumulation in certain organisms. Also produces cytotoxicity and detrimental impact on behavior of fish such as hypertrophy and paraplegia at gill epithelium, uneven swimming and suspended feeding.
Copper
                                      14
Invertebrates with elevated levels require more energy to support their metabolism and therefore exhibit diminished growth. Several species of fish exposed to copper have exhibited damage to liver and muscle function, reproductive, developmental and metabolic functions
Iron
                                      22
Biota with elevated levels have exhibited sublethal effects including metabolic changes and abnormalities of the liver and kidneys, as well as disrupted reproductive and developmental functions
Lead
                                      11
Respiratory asphyxiation under extreme concentrations and the disruption of ionoregulatory homeostasis under more environmentally relevant concentrations
Methylmercury
                                       1
Biota with elevated levels have exhibited effects including metabolic changes and abnormalities of the liver and kidneys
Nickel
                                       1
Toxicity is associated with branchial lesions that cumulatively increase the diffusive distance across the gill epithelium, leading to impaired respiratory function
Oxygen, Dissolved
                                      60
Dissolved oxygen is used by almost all aquatic organisms for respiration, and, thus, is necessary for their survival. When insufficient amounts of dissolved oxygen available, fish and other aquatic organism cannot survive.
pH
                                      74
Acidic conditions may cause other pollutants to dissolve, increasing their fate and transport and increasing the potential for bioaccumulation in aquatic organisms.
Selenium
                                      24
Readily bioaccumulates; elevated concentrations have caused fish kills and numerous sublethal effects (e.g., increased metabolic rates, decreased growth rates, reproductive failure) to aquatic and terrestrial organisms. Short term exposure at high levels can cause damage to the peripheral nervous system. Long term exposure can result in damage to the kidney, liver, and nervous and circulatory systems.
Silver
                                       2
Two key enzymes of ion transport in the gills (Na+/K+-ATPase and carbonic anhydrase), and death results from ionoregulatory failure. Silver appears to be taken up by sodium and copper transport pathways in the gills, as well as by diffusion of neutral complexes. Silver accumulates preferentially in the liver, which serves as a scavenging organ.
Zinc
                                       2
Biota with elevated levels have exhibited sublethal effects such as requiring more energy to support their metabolism and therefore exhibiting diminished growth, and abnormalities of the liver and kidneys; accumulates in the gills of fish and disrupts developmental and hematological functions
Note:
[a] See Kumari et al. (2016); Elbeshti et al. (2018); Gautam et al. (2014); Aslam and Yousaf (2017); Ip et. al (2001); Mager (2011); Pyle and Couture (2011); Wilson (2011); Wood (2011)

 References
Aslam, S., and A. M. Yousafzai. 2017. Chromium toxicity in fish: A review article. Journal of Entomology and Zoology Studies 5(3):1483 - 1488.
Elbeshti R.T., N.M. Elderwish, K.M. Abdelali, and Y. Tastan. 2018. Effects of heavy metals on fish. Menba Journal of Fisheries Faculty 4(1):36 - 47.
Gautam, R.K., K.S. Sanjay, M. Suresh, and C.C. Mahesh. 2014. Contamination of Heavy Metals in Aquatic Media: Transport, Toxicity and Technologies for Remediation. Chapter 1 in Heavy Metals In Water: Presence, Removal and Safety, pp. 1 - 24. doi:10.1039/9781782620174-00001.
Ip, Y.K., S.F. Chew, and D.J. Randall. 2001. Ammonia toxicity, tolerance, and excretion. Fish Physiology 20:109 - 148.
Kumari, B., V. Kumar, A. Sinha, J. Ahsan, A. Ghosh, H. Wang, and G. De Boeck. 2016. Toxicology of arsenic in fish and aquatic systems. Environmental Chemistry Letters 14:1-22. doi:10.1007/s10311-016-0588-9.
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