
                                  MEMORANDUM


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, 2008

SUBJECT:	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 weekly impingement samples used to show compliance with a monthly maximum limit and entrainment sampling for 20 density samples (10 samples during spawning season twice per year).

Approach

It is our assumption that one impingement sample per week covers the entire period of 12 months and that "10 samples during spawning season twice per year" means that only two entrainment sampling events would occur per year (scheduled during the spawn). For costing, the 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 rates.  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 are not 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 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).  See 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 abundance and composition of impinged organisms.  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


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

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


