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 Kelly 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 ICR 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 

without 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 withdrawal, to determine the 

MEMORANDUM

10306 Eaton Place, Suite 340

Paul Shriner and Jan Matuszko, EPA

Blaine Snyder and Kelly Meadows

October 21, 2008

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 maximum limit and 

20 density samples (10 samples during spawning season twice 

It is our assumption that one impingement sample per week covers the entire 

10 samples during spawning season twice per year” 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 ICR 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 weekly 

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 ICR 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 impingement samples would be processed on site, 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 threshold value). Personnel involved with sampling, data compilation, 

and reporting would include:

 Biologist -- A biologist will perform weekly sampling events over the course of 

twelve months (52 total samples). For each sampling event the biologist will take 

one 24-hour composite sample. Approximately four hours would be spent (on 

average) taking each impingement sample, and an additional four hours (on 

average) analyzing the impinged organisms.

 Biological technician -- A biological technician would accompany the biologist 

on each site visit, spending four hours taking each impingement sample, and an 

additional four hours analyzing the impinged organisms.

 Project manager -- The manager may spend a total of eighty hours managing the 

impingement monitoring program and supervising the impingement sampling.

 Statistician -- A statistician spends approximately three days analyzing the 

impingement sampling results and preparing the data for reporting (i.e., simple 

tallies to show compliance with EPA’s maximum threshold value).

 Junior technical -- Junior technical staff take approximately three days to review 

the monitoring results from the impingement sampling and summarize the results.

 Clerical – Clerical staff supports data document preparation and distribution 

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 $59,173

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 $6,307
3

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 system), 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 composition 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 collected 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 

over two twenty-four hour periods 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 approximately two hours taking each entrainment 

sample, and an additional two hours to prepare the sample for delivery to the 

laboratory.

 Biological technician -- A biological technician accompanies the biologist on each 

site visit, spending two hours taking each entrainment sample, and an additional 

two hours 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 days analyzing 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 technical staff take approximately three days 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 $23,015
4

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