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costs for additional treatment facilities, and will incur an estimated $ 0. 4 to $ 1. 3 billion dollars
per year more in increased operating costs. This corresponds to tens of billions of dollars in costs
passed down to approximately three quarters of the individual citizens and businesses in the State
of Florida. In addition, the treatment technologies needed to achieve these limits will potentially
use almost 5 percent of the total electric power generating capacity in the State of Florida and
contribute over 17. 4 million tons of carbon dioxide ( CO2) emissions per year.
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According to the Florida Department of Environmental Protection (FDEP), there are 0
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approximately 2, 100, permitted domestic wastewater facilities in the State with a total treatment
capacity of about 2. 4 billion gallons per day, approximately half of which discharge effluent to Z
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surface waters. FDEP reported in 2005 that approximately 64% of Florida' s population is served
by central sewer systems that feed these treatment facilities. Florida' s total population is in a
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excess of 18 million residents according to the US Census Bureau. Based on these figures, s
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approximately 12 m=illion citizens of Florida are served by permitted wastewater treatment Q
facilities that will be impacted by the proposed NNC.
Required facility upgrades to treat the 2. 4 billion gallons of wastewater per day to the new
standards would result in a cost of approximately $ 1. 6 to $ 3. 3 billion dollars per year over the
next 30 years in addition to current treatment costs. Considering the interest paid on bonds
required to fund these improvements, the State' s wastewater utilities are facing a $ 47. 6 to $ 98. 7
billion dollar price tag to meet the proposed nutrient criteria over the next 30 years. These figures
do not account for the corresponding increase in operating costs. We estimate that annual user
fees for customers served by the impacted facilities will increase by an average of $673 to $ 726
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per year in total. Table 1 summarizes the potential cost to Florida and the average individual
household.
This paper addresses the anticipated costs for Florida utilities to be in compliance with EPA -
promulgated numeric nutrient criteria; the treatment technologies available to achieve the
proposed criteria; and lastly, the additional $ 673 to $ 726 in yearly costs to customers should
these regulations be adopted.
Table 1 Summary of Estimated Project Costs and the Estimated Average Increase in
Annual Sewer Rates for the State of Florida to Implement Numeric Nutrient
Criteria.
Increase in
Annual Debt Annual yearly Sewer
Project Cost' Rate Increase
Service Operating
Costs3 per Customer
Florida Facilities
with NPDES 24540010009000 196000000 433, 000,000 673
Permits5
All Florida
5 50, 700, 000, 000 3, 300, 000, 000 1133090005000 726
Facilities
Notes:
1.
Project costs include estimated construction costs plus contingencies, administrative, legal, engineering and financing costs. Estimates also
assume all private facilities must be upgraded to provide advanced wastewater treatment, microfiltration, and reverse osmosis with concentrate
drying with landfill disposal. Assumes public facilities with deep wells will construct new deep wells for concentrate disposal. All other public
facilities assumed to construct facilities for concentrate drying.
2. Annual debt service based on 30 -year amortization schedule and 5% interest.
3. Assumes current flow is 50%
of design flow, and that this is representative of "actual" usage of the plant. Capital upgrades will be required for
the entire design flow, while operating costs are based on actual usage. O
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Average cost for public and private systems. Customer size estimated at 2. 1 persons per household based on US Census information.
5.
The range of project costs was based on two scenarios. The lower project cost assumes that only surface water dischargers ( e. g. assumed to be
plants with NPDES permits) would be required to comply with the proposed nutrient criteria. The higher project cost assumes that all Florida Z
plants will be required to comply with the proposed nutrient criteria. Z
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EXISTING AND PROPOSED NUTRIENT STANDARDS
Florida' s water reclamation plants already operate within a complex system of water quality
regulations that are among the most stringent in the world. Currently, the highest level of
treatment provided by Florida wastewater treatment plants is Advanced Wastewater Treatment
AWT). In Florida, the term " AWT" is often used to refer to wastewater treatment that produces
a reclaimed water achieving standards set out in section 403. 086( 4), Florida Statutes, i.e.
reclaimed water containing no more than 5 mg/ L of carbonaceous five -day biochemical oxygen
demand ( cBOD5), 5 mg /L total suspended solids ( TSS), 3 mg /L TN, and 1 mg /L TP.
According to the proposed consent decree between EPA and a coalition of environmental groups,
EPA is to propose NNC for fresh waters in Florida in January 2010 and marine waters by
January 2011. NNC proposed by FDEP in June 2008 would drop the TN limit from 3. 0 mg /L to
0. 82 — 1. 73 mg /L and TP limits from 1. 0 mg /L down to 0.069 —0.415 mg /L. Based on review
comments from EPA on the FDEP NNC, the actual values for EPA' s NNC are expected to be
lower than the NNC proposed by the FDEP. While these proposed changes might seem small,
the new NNC are at ( for TP) or below ( for TN) the concentrations achievable with proven
nutrient removal technologies now in full -scale use at municipal wastewater plants. Table 2
allows a comparison. of the current standards for secondary and AWT standards with the
proposed NNC standards.
The very low concentration criteria on TN and TP being proposed can be met, although at
significant cost, by adding additional treatment processes at the end of a Florida advanced
wastewater treatment ( AWT) plant. AWT as currently practiced will not provide consistent r
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compliance with the proposed NNC, and additional technologies must be employed. CL
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Table 2 Comparison of Maximum Pollutant Concentrations Allowed by Water Z
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Reclamation Standards
LiMitS2
Pollutant AWT Proposed Numeric c
Secondary Limits a
Limits3
Nutrient E
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cBOD5, mg /L 20 -30
