Tetra Tech, Inc.

10306 Eaton Place, Suite 340 Fairfax, VA 22030 phone 703
- 385
- 6000 fax 703
- 385
- 6007 TO : Paul Shriner, EPA FROM : Blaine Snyder, Hen DATE: December 7 , 2010 SUBJECT: Estimated costs for conducting entrainment monitoring Introduction Tetra Tech was tasked with developing an estimate for memo provides multiple examples support of 316(b) as a way to provide perspective on entrainment sampling costs supports the use of a cost estimate of approximately $490,000 per facility per year reasonable on a national scale, but site exact study

design, the site location, sampling , and other assumptions. Examples Example 1 Tetra Tech (and one subcontractor) conducted entrainment sampling at “small in 2002 in support of Phase III Rule development. River estuary , which represents relativel y local travel peak of the spawning/nursery season. one week (4 days) during each of the two sampling events. every 3 hours over the 24

- hour period. the total cost of the project was just over $600K. impingement and entrainment sampling and design (and we used an experienced subcontractor), the sampling was local, and the total costs are 2002 dollars. Example 2 We reviewed the costs provided in 

### MEMORANDUM

Paul Shriner, EPA Blaine Snyder, Hen ry

L atimer and Kell y Meadows , 2010 Estimated costs for conducting entrainment monitoring

Tetra Tech was tasked with developing an estimate for entrainment monitoring cost

multiple examples of monitoring cost estimate s developed by Tetra Tech in provide perspective on entrainment sampling costs supports the use of a cost estimate of approximately $490,000 per facility per year reasonable on a national scale, but site

- specific costs can vary signi ficantl y depending on the exact study

design, the site location, the experience/expertise of the staff conducting the , and other assumptions.

Tetra Tech (and one subcontractor) conducted entrainment sampling at “small facilities” for EPA in 2002 in support of Phase III Rule development. We sampled at 6 facilities in the Delaware

, which represents relativel y local travel

. Each facility was visited twice during the peak of the spawning/nursery season. We collected both entrainment and nearfield samples for one week (4 days) during each of the two sampling events. Each day consisted of sampling hour period. Our total number of samples was approximately 700, and the project was just over $600K. Keep in mind that we’re “experienced” in impingement and entrainment sampling and design (and we used an experienced subcontractor), the sampling was local, and the total costs are 2002 dollars.

costs provided in the Phase II NODA (2003) and the ICR Cost Analy sis entrainment monitoring cost s . This developed by

Tetra Tech in provide perspective on entrainment sampling costs and ultimately supports the use of a cost estimate of approximately $490,000 per facility per year

. This cost is ficantl y depending on the of the staff conducting the

facilities” for EPA We sampled at 6 facilities in the Delaware Each facility

was visited twice during the collected both entrainment and nearfield samples for

Each day consisted of sampling Our total number of samples was approximately 700, and Keep in mind that we’re “experienced” in impingement and entrainment sampling and design (and we used an experienced subcontractor),

the Phase II NODA (2003) and the ICR Cost Analy sis andattempted to extract only entrainment sampling, laboratory , analy sis, and reporting costs. It appears that the sampling scheme proposed at the time was 3 years of sampling, 26 weeks each, with 5 samples per week, for a total of 390 entrainment samples per facility. It is not straightforward to extract the costs from the expansive spreadsheets, but it appears that the total annual cost per facility would be approximately $100K (or $3 00K for 3 years of sampling). This represents on

- site entrainment sampling, using experienced personnel, and a 2003 dollar value. Example 3 We generated cost estimates for EPA in November 2009 based on entrainment study assumptions discussed at that ti me: 100 sampling events per ye ar; sampling once per week for 10 months; sampling daily

for the other 2 months; collecting 24

- hour composite samples; and sampling at an y/ all waterbody types (excluding marine). We added the assumptions that all samples were truly

entrainment samples, collected on

- site at the facility (e.g., behind the screens) and did not include any nearfield samples, boat samples, and the like. Therefore, equipment costs (e.g., boats, nets, etc.) were not included as part of other direct costs. Three scenarios were considered, including: a) use of a non

- local consultant (i.e., requiring travel to the sampling site); b) use of a local consultant; and c) “in

- house” sampling (i.e., consultants would train facility employees to do the work, resulting in labor costs that are near zero). Consideration of the three scenarios resulted in total costs of approximately $490K, $320K, and $100K per ye ar , respectivel y, in 2009 dollars. (See Attachment A.) Discussion As noted above , several of the cos t estimates presented here were derived on a national scale using very

broad assumptions and may not be representative of site

- specific costs for some facilities

. Given the complexity of sampling, the lack of on

- site or in

- house experience, and the high l evel of expertise involved in conducting scientifically valid studies , we believe th at most entrainment studies would be conducted b y non - local consultants, resulting in the highest cost scenario presented in Example 3 above. As a result, it is logical an d appropriate to use those costs as the basis for estimating overall rule costs. One common thread in all of these examples, despite differences in numbers of samples, locations, etc., is that the absolute minimum dollar amount needed for an entrainment s ampling exercise is $100K. However, these minimum costs can be considerabl y higher at some facilities due to high organism abundances, sampling access challenges, etc., and costs could easily climb to $500K, depending on the sampling scenario (even with number of samples remaining equal). Further, costs would be expected to be higher for facilities with multiple generating units and/or cooling water intake structures. Accordingl y, it is clear that these lower estimates are not appropriate to consider in a national scale estimate ; they may represent the true costs for some facilities, but are not likely to be representative of costs on a wider scale.