Tetra Tech, Inc.

10306 Eaton Place, Suite 340 Fairfax, VA 22030 phone 703
- 385
- 6000 fax 703
- 385
- 6007 TO : Paul Shriner and Jan Matuszko, EPA FROM : Blaine Snyder and Kell y Meadows DATE: October 21, 20 SUBJECT: Cost Estimates for EPA requested that Tetra Tech develop costs for compliance sampling for a regulatory option under consideration. The assumptions for the sampling plan included impingement samples used to show compliance with a monthly max entrainment sampling for 20 density samples (10 samples during spawning season twice per year). Approach It is our assumption that one impingement sample per months and that “ 10 samples during spawning seas two entrainment sampling events costing, the labor categories and rates presented in the Phase 2 NODA I CR were used as a starting point. A 20% inflation mark rates. Estimates presented here assume that either on collection or that qualified contractors are available locally (i.e., travel costs considered here). Also assumed here is that impingement and entrainment samples would require taxonomic identification; therefore, estimates include biologists in the field and laboratory. If EPA’s approach requires only enumeration with out identification, labor costs would be reduced below those presented here (e.g., technicians could be used for sampling and laboratory costs would be eliminated). Attachment A for more information. Impingement Sampling and Reporting Impingement monitoring involves collecting data on aquatic organisms trapped on the outer part of an intake structure or against screening devices during periods of cooling water withdr awal, to determine the 

### MEMORANDUM

10306 Eaton Place, Suite 340

Paul Shriner and Jan Matuszko, EPA Blaine Snyder and Kell y Meadows October 21, 20 08 Cost Estimates for Compliance Monitoring EPA requested that Tetra Tech develop costs for compliance sampling for a regulatory option under consideration. The assumptions for the sampling plan included

samples used to show compliance with a monthly max imum limit and 20 density

samples (10 samples during spawning season twice

It is our assumption that one impingement sample per week c over s the entire

10 samples during spawning seas on twice per ye ar ” means that two entrainment sampling events would occur per year (scheduled during the spawn). For he labor categories and rates presented in the Phase 2 NODA I CR were used as a starting point. A 20% inflation mark

- up was applied, since the ICR used 2001 labor Estimates presented here assume that either on

- site staff are available for sample collection or that qualified contractors are available locally (i.e., travel costs considered here). Also assumed here is that impingement and entrainment samples would require taxonomic identification; therefore, estimates include the services of biologists in the field and laboratory. If EPA’s approach requires only enumeration out identification, labor costs would be reduced below those presented here (e.g., technicians could be used for sampling and laboratory costs would be eliminated). Attachment A for more information.

and Reporting monitoring involves collecting data on aquatic organisms trapped on the outer part of an intake structure or against screening devices during periods of cooling

awal, to determine the abundance and composition of impinged organisms.

1 EPA requested that Tetra Tech develop costs for compliance sampling for a regulatory option under consideration. The assumptions for the sampling plan included weekl y m limit and 20 density

samples (10 samples during spawning season twice

s the entire period of 12 ” means that only (scheduled during the spawn). For he labor categories and rates presented in the Phase 2 NODA I CR were used as applied, since the ICR used 2001 labor site staff are available for sample collection or that qualified contractors are available locally (i.e., travel costs are not considered here). Also assumed here is that impingement and entrainment samples the services of biologists in the field and laboratory. If EPA’s approach requires only enumeration out identification, labor costs would be reduced below those presented here (e.g., technicians could be used for sampling and laboratory costs would be eliminated). See

monitoring involves collecting data on aquatic organisms trapped on the outer part of an intake structure or against screening devices during periods of cooling of impinged organisms.2

Since impi ngement samples would be processed on si te, there is no need for laboratory personnel or services . Reporting would involve a simple accounting of monthly impingement for the year (i.e., numbers and composition of organisms compared to EPA’s maximum thresh old value). Personnel involved with sampling, data compilation, and reporting would include:

 Biologist

-- A biologist wi ll perform weekly sampling events over the course of twelve months (52 total samples) . For each sampling event the biologist will tak e one 24

- hour composite sample . Approximately four hours would be spent (on average) taking each impingement sample, and an additional four hours (on average) anal yz ing the impinged organisms.
 Biological technician

-- A b iological technician would accompa ny the biologis t on each site visit, spending four hours taking each impingement sample, and an additional four hours analy zing the impinged organisms.
 Project manager

-- The manager may spend a total of eighty

hours managing the impingement monitoring pro gram and supervising the impingement sampling.
 Statistician

-- A statistici an spends approximately three day s anal yz ing the impingement sampling resu lts and preparing the data for reporting (i.e., simple tallies to show compliance with EPA’s maximum thresh old value)

.  Junior technical

-- Junior technical staff take approximately three day s to review the monitoring results from the impingement sampling and summarize the results.
 Clerical

– Clerical staff supports data document preparation and dis tribution during the monitoring program duration

. Impingement Sampling Labor Category Rate Hours Total Biologist $66.5 416 $27,664 Biological technician $42.6 416 $17,722 Project manager $102.4 80 $8,192 Statistician $68. 5 24 $1,644 Junior technical $38.3 24 $919 Clerical $21.8 24 $532 ODCs $2,500 Total $59,1 73 Impingement Reporting Labor Category Rate Hours Total Biologist $66.5 16 $1,064 Project manager $102.4 40 $4,096 Statistician $68.5 8 $548 Clerical $21.8 16 $349 ODCs $250 Total $6,30 73

Entrainment Sampling and Reporting Entrainment monitoring involves the collection of data on fish/shellfish eggs and larvae incorporated with cooling water flow (entering and passing through a cooling water intake structure and into a cooling water s ys tem ), to determine the abundance and composition of entrained organisms. Since entrained organisms are small, planktonic stages of fish and shellfish, sample processing would be conducted in the laboratory

. Reporting would involve a simple accounting of entrainment densities for the collection period (i.e., density and comp osition of organisms compared to an EPA threshold). A total of two sampling events would be scheduled during the peak of the spawning season at each facility, and 10 samples would be coll ected during each sampling event (for a total of 20 samples per year)

. Personnel involved with sampling, data compilation, and reporting would include:

 Biologist

-- A biologist will perform two sampling events over the course of the spawning period . For each sampling event the biologist will take five samples ove r two twenty- four hour period s to capture daylight and dark hours (i.e., 5 samples x 2 sampling days x 2 sampling events per spawning season = 20 total samples). The biologist spends approximate ly two hours taking each entrainment sample, and an additional two hour s to prepare the sample for delivery to the lab oratory

.  Biological technician

-- A biological technician accompanies the biologist on each site visit, spending two hours taking each entrainment sample, and an additional two hour s to prepare the sample for delivery to the lab.
 Project manager

-- The manager may spend a total of eighty

hours managing the entrainment monitoring program and supervising the entrainment sampling.
 Statistician

-- A statistician spends approximately three day s anal yz ing the entrainment sampling results and preparing the data for reporting (i.e., simple tallies to show compliance with EPA’s threshold value).
 Junior technical

-- Facility junior technic al staff take approximately three day s to review the monitoring results from the entrainment sampling and summarize the results.
 Clerical

-- Clerical staff supports data document preparation and distribution during the monitoring program duration. Entrainment Sampling Labor Category Rate Hours Total Biologist $66.5 80 $ 5,320 Biological technician $42.6 80 $ 3,408 Project manager $102.4 80 $ 8,192 Statistician $68.5 24 $ 1,644 Junior technical $38.3 24 $ 919 Clerical $21.8 24 $ 532 ODCs $3,000 Total $ 23,0154

Entrainment Laboratory Number of Samples Cost Per Sample Total 20 $350 $7,000 Entrainment Reporting Labor Category Rate Hours Total Biologist $66.5 16 $1,064 Project manager $102.4 40 $4,096 Statistician $68.5 8 $548 Clerical $21.8 16 $349 ODCs $250 Total $6,307