UPDATED INFORMATION COLLECTION COSTS FOR SECTION 316( b) PHASE II NOTICE OF DATA AVAILABILITY ( NODA)

January 31, 2003 1 I. Information Collection Requirement Cost Analysis Since proposal, EPA has made several corrections and revisions to its burden and cost estimates for implementing the information collection requirements of the Section 316( b) Phase II rule, based on comments received and additional analysis. The following corrections and revisions have been made since proposal:

° EPA corrected the hourly rates for the statistician and biological technician labor categories, which were inadvertently transposed at proposal. ° EPA has increased the burdens associated with impingement and entrainment monitoring associated with the Impingement Monitoring and Entrainment Characterization Study. ° EPA has revised the pilot study costs to assume that only facilities which are projected to install new technologies will perform pilot studies, and to be proportional to the projected capital costs for installing these new technologies to comply with the rule.

The following sections present the rationale and results of EPA's estimation of burden and costs for implementing the information collection requirements of the Section 316( b) Phase II rule.

A. Respondent Labor Categories This section describes the facility burden estimates for information collection activities associated with the NPDES permit application as well as information collection activities that will occur on an annual basis after the permit is issued. These information collection activities can be separated into monitoring, conducting analyses, developing reports, and maintaining records. Information collection would require in scope facilities to devote time ( i. e., as measured by staff hours) and resources ( e. g., copies of documents and report mailings) to produce the necessary NPDES permit applications, implementation plans, and yearly status reports.

EPA expects that facility employees, including managers, engineers, engineering technicians, statisticians, biologists, biological technicians, draftsmen, and clerical staff, will devote time toward gathering, preparing, and submitting the various documents. To develop representative profiles of each employee's relative contribution, EPA assumed burden estimates that reflect the staffing and expertise typically found in manufacturing facilities and power generating plants. In doing this, EPA considered the time and qualifications necessary to complete a variety of tasks: reviewing instructions, planning responses, researching data sources, gathering and analyzing data, typing or writing the information requested, reviewing results, conferring with permitting authorities and expert consultants, and sending documents.

EPA anticipates that facilities will use contracted services to perform many of their required sampling and analysis tasks. The contracted staff are likely to include project managers, biologists, statisticians, and biological technicians. The work done by these contracted 2 employees will be done on site on a regular basis. Therefore, the hourly burdens associated with their work are included in the overall burden estimates for each facility.

For each activity burden assumption, EPA selected time estimates to reflect the expected effort necessary to carry out these activities under normal conditions and reasonable labor efficiency rates. EPA assumed that the majority of the actual work performed by facility staff, such as researching, collecting, and analyzing data, as well as writing the documents, will be carried out by junior technical staff. Burdens associated with managerial and senior engineering staff include time for actions such as occasional or seasonal visits to supervise sampling efforts, as well as periodic review of lab results and documentation. EPA assumed that the facilities will employ a drafter to perform computer aided drafting ( CAD) operations. For contracted employees, EPA assumed that the majority of the work would be carried out by the biologists and the biological technicians.

Labor burdens are often described in terms of days or weeks. For the purpose of the NODA, the term day refers to eight total hours worked by one or more employees within a given labor category. Likewise, a week refers to when one or more employees work a total 40 hours. The labor costs to the respondent facilities can be estimated by multiplying the time spent in each labor category by an appropriately loaded hourly wage rate. All base wage rates for facility labor categories were derived from the Bureau of Labor Statistics Occupational Outlook Handbook 2002 2003. These reported labor rates were based upon data from the year 2000, and required adjustment for inflation. An inflation factor of 3.9%, derived from the BLS Employment Cost Index ( BLS, 2001), was used to adjust the Occupational Outlook Handbook labor rates to reflect labor rates for June of 2001.

A compensatory loading factor of 35% was used to account for any paid leave, supplemental pay, insurance, retirement and savings, and required and nonrequired benefits received by employees ( BLS, 2001b). EPA assumed an additional loading factor of 15% to account for general overhead costs directly attributable to facility employees performing work in support of the permit process. Expenses for contracted employees typically include higher overhead costs, as well as fee to ensure profit for the contracting company. EPA assumes that the overhead for the contracted employees will be 50% and the fee will be 8%.

To represent the base labor rate for facility management, EPA used the average national salary for an engineering manager of $ 84,070 per year. This figure was divided by 2,080 hours to derive the hourly managerial wage rate of approximately $ 40 per hour. After adjusting this rate for inflation, compensation and overhead, the rate is approximately $ 67 per hour. The median annual salary of $ 40,020 for an engineering technician was used to represent the base labor rate for junior technical staff. After determining the hourly wage rate and adjusting for inflation and other factors, this labor rate was approximately $ 32 per hour. The median annual salary for a drafter performing CAD work was reported to be $ 17 per hour, and after adjusting and loading the rate it is approximately $ 28. The reported average annual salary for clerical workers was $ 21,130, and the fully adjusted and loaded hourly rate is $ 18 per hour. 3 To represent the base labor rate for a contracted manager of monitoring work done onsite EPA used the average national salary for a natural sciences manager of $ 75,880 per year, with a fully loaded rate of $ 85 per hour. The median annual salary for a statistician was $ 51,990 per year, with an adjusted hourly rate of approximately $ 57 per hour. Biologists and biological technicians had an average hourly pay of $ 24 and $ 15, and a fully loaded rate of $ 55 and $ 35, respectively.

B. Permit Application Reporting Labor Burden and Costs Permit application activities refer to the development and submittal of the required elements of the application for reissuance of the NPDES permit. This involves gathering, analyzing, and characterizing information and then submitting this information to the Director for review. For the purpose of the NODA, the labor burden and costs for these permit application activities are grouped into either reporting or monitoring requirements. These permitting requirements also have corresponding capital and O& M costs associated with them.

As part of the permit application process, Phase II existing facilities will gather source water physical data, cooling water intake structure data and cooling water system data. This information is analyzed and summarized in reports which are delivered to the director to demonstrate compliance with the permit requirements. Information gathered by the facility for a report can also be used as a starting point for other required studies, or to help the facility determine how it will comply with permit requirements. As a result, many of the studies will be done in a manner so that information from one can be used as a basis for another.

Reporting activities typically have incidental record keeping burdens associated with them. These burden estimates typically cover the time spent printing, copying, filing paper documents, and making back up copies of electronic files. EPA expects that much of this work is done by clerical staff. However, EPA assumes that approximately 3% of the time non clerical employees spend performing rule related activities can be attributed to record keeping as well.

Rule related reporting activities will also result in incidental costs to facilities for specific items not covered by general overhead. These costs, often referred to as Other Direct Costs ( ODCs), are for office supplies, occasional field work supplies, and shipping and handling fees. EPA assumes for the proposed rule that typical ODCs are between $ 1 and $ 2 per total hours spent on an activity, but could be as much as $ 3 to $ 4 per hour worked when the activity requires some field work. ODCs incurred by the company contracted to do the monitoring work are not considered because they are factored into the rates charged for the contracted work.

Because record keeping and ODC costs for reporting activities are relatively small in comparison to other facility costs, detailed breakouts showing record keeping burdens and costs for each activity are not included in the NODA, but can be found in Appendix A of the ICR Supporting Statement. 4 1. Start Up Activities All facilities will incur a start up burden associated with reading the published regulations, sample permits, and any guidance materials associated with the rule; determining the required staff and resources necessary to successfully complete the application process, and meet all annual monitoring and reporting requirements; and training staff to perform tasks that they would not be required to conduct if the rule were not implemented. These start up activities are assumed to be performed by facility management and junior technical staff.

Start Up Activities  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 6 18 $ 403 $ 1,208 Junior Technical $ 31.90 7.3 22 $ 234 $ 702 Clerical $ 18.20 1.0 3 $ 18 $ 55 2. Permit Application Activities Phase II existing facilities are required to gather permit application information as specified by 40 CFR 122.21( r) so that the Director can evaluate the potential impact to the water body in which the intake structure is located. The information collected under 40 CFR 122.21( r) includes source water physical data, cooling water intake structure data, source water baseline biological characterization data, and a Phase II existing facility cooling water system description.

a.) Source Water Physical Data EPA anticipates that much of the data required to characterize the water body and the cooling water intake structure has already been gathered by the facility, and that much of the actual facility burden is from deriving the requested information from this data. To derive the source water physical data, EPA assumes that junior technical staff will work with a CAD operator to develop a description of the physical configuration of the source water body where the CWIS is located, including areal dimensions, depths, salinity and temperature regimes. The CAD operator will produce scaled drawings showing the physical configuration of the source water body and prepare locational maps of the water body. The junior technical staff will use this information and available data to produce a report characterizing and documenting the hydrological and geomorphological features of the source water body. Depending on the extent of existing information it may be necessary for some facilities to conduct physical studies to determine the intake's area of influence within the water body. EPA assumes these studies are likely to consist of releasing dyes in the vicinity of CWIS and observing how the dye behaves 5 when the CWIS is operating. Such studies are routinely done when a facility is determining an appropriate site for a CWIS.

Source Water Physical Data  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 0.7 2 $ 45 $ 134 Junior Technical $ 31.90 5.3 16 $ 170 $ 510 CAD Operator $ 28.10 13.3 40 $ 375 $ 1,124 b.) Cooling Water Intake Structure Characterization Cooling water intake structure data will be used to develop a report on the operation of the intake structure. EPA assumes that a CAD operator will spend a day assisting junior technical staff in preparing a narrative description of the configuration of the CWIS and its location within the waterbody and in the water column, including measurements of the latitude and longitude of the CWIS. In addition, junior technical staff will spend one week developing a narrative that describes the operation of the CWIS, including design flows, daily hours of operation, number of days of the year in operation, and seasonal changes, if applicable. Management will spend two days reviewing and revising this characterization. Junior technical staff will also spend one week developing a narrative characterizing the facility's cooling water system, which includes a flow distribution and water balance diagram for the facility depicting all sources of water to the facility, recirculating flows, and discharges. Management will spend two days reviewing and revising this characterization.

CWIS Characterization  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 11.7 35 $ 783 $ 2,349 Junior Technical $ 31.90 28.7 86 $ 914 $ 2,743 CAD Operator $ 28.10 3.0 9 $ 84 $ 253 6 c.) Permit Application Engineering Calculations EPA anticipates that the junior technical staff will spend four days performing engineering calculations for the source water body and CWIS documents. Management will spend a day reviewing and revising these calculations.

Permit Application Engineering Calculations  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 2.7 8 $ 179 $ 536 Junior Technical $ 31.90 10.7 32 $ 340 $ 1,021 3. Source Water Baseline Biological Characterization Data Facilities will also collect Source Water Baseline Biological Characterization Data to evaluate the condition of the biological community prior to each permit application. The level of effort needed to collect the Source Water Baseline Biological Characterization Data may vary considerably from one facility to another, depending on the availability of existing background information and the characteristics of the water body in which the CWIS will be located. EPA assumes that for most facilities there is sufficient existing data for facilities to develop a baseline characterization of the contributing water body's biological community. Junior technical staff are anticipated to spend two weeks gathering existing data, and documenting data that are not available along with efforts made to identify sources of data. The facility manager spends one week overseeing this work and reviewing the results. The junior technical staff then spends an additional week and a half analyzing and summarizing the available data, and a CAD operator spends half a week assisting with the development of maps and diagrams. The manager spends four days reviewing and revising the results.

Source Water Baseline Biological Characterization Data  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 24.0 72 $ 1,610 $ 4,831 Junior Technical $ 31.90 46.7 140 $ 1,489 $ 4,466 CAD Operator $ 28.10 6.7 20 $ 187 $ 562 Clerical $ 18.20 4.0 12 $ 73 $ 218 7 4. Proposal for Collection of Information for Comprehensive Demonstration Study Facilities choosing to install new technologies rather than reducing flows to levels commensurate with wet cooling towers are required to gather and submit additional information in the form of a Comprehensive Demonstration Study to confirm that the technology( ies), operational measures and restoration measures proposed and/ or implemented at the intake meet the applicable performance standards.

a.) Description of Historical Studies That Will Be Used for Comprehensive Demonstration Study As a first step in the Comprehensive Demonstration Study, the facility must develop and submit a proposal for the collection of information to support the Study. EPA assumes that junior technical staff will spend one week developing a list and description of any historical studies characterizing impingement and entrainment and/ or the physical and biological conditions in the vicinity of the intakes and their relevancy to the Comprehensive Demonstration Study. The facility management will spend half a week reviewing the collected information to determine the extent to which existing data are representative of current conditions, are sufficient to develop a scientifically valid estimate of impingement and entrainment, and were collected using appropriate quality assurance/ quality control procedures.

Description of Historical Studies That Will Be Used for Comprehensive Demonstration Study  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 6.7 20 $ 447 $ 1,342 Junior Technical $ 31.90 13.3 40 $ 425 $ 1,276 Clerical $ 18.20 0.7 2 $ 12 $ 36 b.) Description of Proposed and/ or Implemented Technologies Junior technical staff are assumed to spend half a week developing a description of the proposed and/ or implemented technologies, operational measures and restoration measures to be evaluated in the Comprehensive Demonstration Study. Facility management spend one day reviewing and revising this description. 8 Description of Proposed and/ or Implemented Technologies  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 2.7 8 $ 179 $ 536 Junior Technical $ 31.90 6.7 20 $ 213 $ 638 c.) Source Water Sampling Plan Although some facilities are likely to have sufficient available information to forego an extensive monitoring study, EPA assumes that all facilities performing a Comprehensive Demonstration Study will perform an Impingement Mortality and Entrainment Characterization Study involving three years of monitoring. Therefore, these facilities will need to develop and submit a source water sampling plan that: documents all methods and quality assurance procedures for sampling and data analysis, as well as describes the study area ( including the area of influence of the cooling water intake structure and at least 100 meters beyond). EPA assumes that the junior technical staff will spend twenty hours reviewing source water and CWIS data, as well as information gathered for the Source Water Baseline Biological Characterization. They will then spend another twenty hours using this information to write a draft of the source water sampling plan. A CAD operator will spend one day assisting the junior technical staff in this effort. The facility manager will spend four days supervising this effort, reviewing the draft, and consulting with the manager of the contracted firm that will perform the monitoring. The contracted manager will spend one day reviewing the draft and providing feedback. The junior technical staff will then take twenty hours to revise the sampling plan and the facility manager will spend one day reviewing and revising the final sampling plan.

Source Water Sampling Plan  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 13.3 40 $ 895 $ 2,684 Junior Technical $ 31.90 20.0 60 $ 638 $ 1,914 CAD Operator $ 28.10 2.7 8 $ 75 $ 225 Contracted Manager $ 85.30 2.7 8 $ 227 $ 682 Clerical $ 18.20 1.3 4 $ 24 $ 73 9 5. Source Water Body Flow Information As part of the Comprehensive Demonstration Study, facilities with intakes located on freshwater rivers/ streams must submit source water body flow information. This information is used to determine the impact of the CWIS on the natural flow of the source water and is an important factor in determining the appropriate technologies. Similarly, facilities with intakes on freshwater lakes or reservoirs need to determine the extent to which the CWIS disrupts the thermal stratification of the water body. EPA anticipates that most facilities will have ready access to existing flow and thermal stratification information. However, EPA assumes that some facilities will need to take flow or thermal stratification measurements immediately around the intake. Junior technical staff are expected to take four days to gather existing information and take measurements for freshwater river and stream flows, and one week for lakes and reservoirs. Junior technical staff will spend an additional four days performing engineering calculations and developing a report. Facility management will spend one day reviewing and revising stream/ river information, and take one and a half days for lake/ reservoir information.

Freshwater Stream/ River Flow Information  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 2.7 8 $ 179 $ 536 Junior Technical $ 31.90 21.3 64 $ 681 $ 2,042 Lake/ Reservoir Thermal Stratification Information  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 4 12 $ 268 $ 805 Junior Technical $ 31.90 24.0 72 $ 766 $ 2,297 6. Design and Construction Technology Plan If the facility chooses to use design and construction technologies or operational measures in whole or in part to meet the requirements of § 125.94, the facility must also submit a Design and Construction Technology Plan as part of the Comprehensive Demonstration Study. EPA assumes that a CAD operator will spend one day delineating the hydraulic zone of influence, and that junior technical staff will spend five hours assisting them, and management 10 will spend two hours reviewing work. Junior technical staff will then spend one and a half days performing engineering calculations to determine anticipated impingement rates, and an additional two days developing narrative descriptions of the design and operation of all design and construction technologies or operational measures ( existing and proposed), used to meet the requirements to reduce impingement mortality. Management will spend a day reviewing the calculations and three hours reviewing the write up. Those facilities that also must address entrainment will spend approximately the same amount of time performing engineering calculations and developing a narrative description. Finally junior technical staff will spend one week documenting that these chosen technologies reflects BTA at the facility's site.

Design and Construction Technology Plan ( Impingement Only)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 4.3 13 $ 291 $ 872 Junior Technical $ 31.90 24.3 73 $ 776 $ 2,329 CAD Operator $ 28.10 2.7 8 $ 75 $ 225 Clerical $ 18.20 2.0 6 $ 36 $ 109 Design and Construction Technology Plan ( Impingement & Entrainment)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 8.0 24 $ 537 $ 1,610 Junior Technical $ 31.90 33.7 101 $ 1,074 $ 3,222 CAD Operator $ 28.10 2.7 8 $ 75 $ 225 Clerical $ 18.20 2.0 6 $ 36 $ 109 7. Verification Monitoring Plan As part of the Comprehensive Demonstration Study, facilities must include a plan to conduct, at a minimum, two years of monitoring to verify the full scale performance of the proposed or implemented technologies, operational measures, or restoration measures. EPA assumes that the junior technical staff will spend a week and a half writing a plan that describes 11 the frequency and duration of monitoring, the locations to be monitored, the basis for determining the locations, and the information that will be included in the final report. A CAD operator will spend a day assisting the junior technical staff with the drawings and diagrams contained in the plan. The facility management will spend a week overseeing the writing of the plan and reviewing and revising the various drafts of the plan before it is finalized.

Verification Monitoring Plan  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 13.3 40 $ 895 $ 2,684 Junior Technical $ 31.90 20.0 60 $ 638 $ 1,914 CAD Operator $ 28.10 2.7 8 $ 75 $ 225 8. Information to Support Site Specific Determination of BTA If a facility requests a site specific evaluation of BTA, it will first need to demonstrate to the Director that it meets one of two cost criteria. The first criteria requires the facility to demonstrate that its cost of compliance with the applicable performance standards specified would be significantly greater than those considered when the performance standards were established. The second criteria requires a facility to demonstrate that its costs would be significantly greater than benefits of complying with the performance standards at the facility's site.

a.) Comprehensive Cost Evaluation Study EPA assumes that for a facility to demonstrate to the Director that its actual implementation costs will be higher than those suggested by the performance standard, the facility will need to provide the Director with detailed information about the site, along with engineering calculations and cost estimates used to justify this conclusion. Much of the sitespecific information will have been gathered during the initial permit application process and the source water baseline biological characterization. Likewise, many of the initial engineering calculations will have been performed for the Design and Construction Technology Plan. Therefore, the main effort for the Comprehensive Cost Evaluation Study will be for the facility to justify the cost estimates it claims that it will incur to install and operate the BTA prescribed in the performance standards. EPA assumes that the junior technical staff will spend a week developing cost estimates and developing an initial draft of the study. The facility manager will spend two days overseeing the work done by the junior staff and revising the initial draft. The junior technical staff will then spend approximately half a week making the revisions and 12 finalizing the report. The management will then spend half a day reviewing the final draft and writing the executive summary.

Comprehensive Cost Evaluation Study  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 6.7 20 $ 447 $ 1,342 Junior Technical $ 31.9 20.0 60 $ 638 $ 1,914 b.) Evaluate Detailed Mortality Data Facilities choosing to demonstrate that their costs would be significantly greater than the benefits of complying with the otherwise applicable requirements must use a comprehensive methodology to fully value the impacts of impingement mortality and entrainment at the site and the benefits achievable by compliance with the applicable requirements. To compare benefits to costs, the facility must have cost estimates. EPA assumes that the facility will use the cost information from Comprehensive Cost Evaluation for this purpose. To begin assessment of potential benefits, the facility will need estimates of impingement and entrainment reductions resulting from use of the proposed technology at the facility. EPA assumes that the facility will use the estimates of impingement and entrainment reductions from the Design and Construction Technology Plan for this purpose. The facility must then estimate the potential recreational and commercial value of these organisms over the same period of time that it would be paying for the proposed technology. This begins with a detailed evaluation of mortality data. EPA assumes that the junior technical staff will spend a week reviewing mortality data derived from the Impingement Mortality and Entrainment Characterization Study, and developing a list of species, their impacted life stages, and corresponding mortality and injury reduction estimates. The facility manager will spend half a day reviewing and revising this list.

Evaluate Detailed Mortality Data  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 1.3 4 $ 89 $ 268 Junior Technical $ 31.9 13.3 40 $ 425 $ 1,276 c.) Valuation of Monetized Benefits 13 After the detailed list of impacted species is developed, facility and contracted staff will work together to develop estimates of the commercial and recreation value of the impacted species and the other species which depend on them as a food source. EPA assumes the biologists contracted to do the Impingement Mortality and Entrainment Characterization Study will take the lead on developing the monetized benefit estimates, spending five weeks to develop a comprehensive valuation of the current impacts from impingement mortality and entrainment at the site and the benefits derived from reducing the impact to commercial and recreational species residing in the source water. The junior technical staff will spend three and a half weeks assisting the biologist and helping develop and revise the monetized benefit estimates. A statistician will spend a week helping with the development of present value estimates for the technology costs and the monetized benefits so that they can be compared. Facility management and the contracted manager will spend a week and a week and a half, respectively, reviewing and revising the work.

Perform Valuation of Monetized Benefits  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 13.3 40 $ 895 $ 2,684 Junior Technical $ 31.9 46.7 140 $ 1,489 $ 4,466 Contracted Manager $ 85.3 20.0 60 $ 1,706 $ 5,118 Biologist $ 55.4 66.7 200 $ 3,693 $ 11,080 Statistician $ 56.8 13.3 40 $ 757 $ 2,272 d.) Engineering Calculations for Site Specific BTA Both the Comprehensive Cost Evaluation and the Valuation of Monetized Benefits will require the junior technical staff to perform engineering calculations to support the facility's assertions. EPA assumes that the junior technical staff will spend approximately one week performing engineering calculations to support the case for site specific determination, and the facility management will spend about ten hours reviewing and revising these calculations.

Perform Engineering Calculations for Site Specific BTA  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 3.3 10 $ 224 $ 671 Junior Technical $ 31.9 13.3 40 $ 425 $ 1,276 14 9. Site Specific Technology Plan This plan is based on the Comprehensive Cost Evaluation Study, and the valuation of monetized benefits if one was performed by the facility. It describes the design and operation of all design and construction technologies, operational measures, and restoration measures selected, and provides information that demonstrates the effectiveness of the selected technologies or measures for reducing the impacts on the species of concern.

a.) Narrative Description of Technologies EPA assumes that the junior technical staff will spend half a week developing a narrative description of the technologies and measures selected by the facility. The facility manager will devote one day to reviewing and revising this description.

Narrative Description of Technologies  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 2.7 8 $ 179 $ 537 Junior Technical $ 31.9 6.7 20 $ 213 $ 638 b.) Document That Technologies are Optimal The facility must document the efficacy of the proposed and/ or implemented technologies or operational measures for reducing impingement mortality and entrainment of all life stages of fish and shellfish. EPA assumes that the junior technical staff spends one week documenting the efficacy of the technologies or measures based on the information used to support a site specific determination of BTA, and results from representative studies and/ or sitespecific pilot studies. Facility management spends one day reviewing and revising this document.

Document Technologies are Optimal  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.10 2.7 8 $ 179 $ 537 Junior Technical $ 31.90 13.3 40 $ 425 $ 1,276 Clerical $ 18.20 2.0 6 $ 36 $ 109 15 c.) Site Specific BTA Design Estimates and Engineering Calculations Both the narrative description and the documentation of efficacy for the proposed technology or measures will require engineering calculations, design estimates, and drawings. EPA assumes that the junior technical staff will spend a week and a half performing this engineering work. The facility management will spend three days reviewing and revising this work. In addition, the biologist will spend a day assisting the junior technical staff with the efficacy calculations, and the contracted manager will spend half a day reviewing the work.

Site Specific BTA Design Estimates and Engineering Calculations  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 8.0 24 $ 537 $ 1,610 Junior Technical $ 31.9 20.0 60 $ 638 $ 1,914 Contracted Manager $ 85.3 1.3 4 $ 114 $ 341 Biologist $ 55.4 2.7 8 $ 148 $ 443 C. Permit Application Monitoring Labor Burden and Costs Although no monitoring studies are specifically required under the proposed rule, facilities are required to provide the Director with a comprehensive set of data to demonstrate that their chosen method of compliance adequately addresses impingement and entrainment. As a result, EPA anticipates that many facilities will perform monitoring studies to obtain the necessary information to complete their permit application. EPA recognizes that there will be a range of potential durations and costs for monitoring studies performed by facilities as part of the permit application process.

1. Impingement Mortality and Entrainment Characterization Study On average, the study is expected to take three years for the facilities to perform. This estimate takes into account that some facilities will have access to existing data, which may allow them to reduce the duration of the monitoring period, while other facilities may require additional time due to the confounding effects of other factors such as very dry years or fish kills due to red tides. The Study is assumed to be performed prior to permit issuance. Facilities that become subject to the rule within the first three years are assumed to provide the Director with preliminary study results, and complete the monitoring after the permit has been issued, to avoid 16 delays in permit reissuance. The monitoring study consists of an extensive sampling effort performed primarily by contracted employees, and then the characterization of the data in the form of a study report that is produced by both facility and contracted employees.

a.) Sample Types To accurately characterize the effects of impingement and entrainment on the aquatic communities found in the source water, offshore monitoring must occur at the same time that monitoring for impingement and entrainment is occurring. As a result, EPA assumes that monitoring is performed simultaneously at the facility for impingement and entrainment, and offshore at the edge of the determined zone of influence. Since impingement more often impacts adult organisms, while entrainment affects juvenile organisms, offshore samples must be taken of both juvenile and adult organisms. Therefore, EPA assumes that four types of sampling will occur.

Impingement Mortality and Entrainment Characterization Study Sample Types Sample Type Location of Sample Impingement Sample At the intake structure.

Entrainment Sample In the facility.

Offshore Sample for Juvenile Organisms At the edge of the zone of influence.

Offshore Sample for Adult Organisms At the edge of the zone of influence.

To accurately characterize seasonal and annual fluctuations in aquatic communities impacted by the CWIS, EPA assumes sampling is performed at the facility on a biweekly basis over three years. To characterize daily fluctuations each time sampling occurs, five samples are taken over a twenty four hour period. As a result, there are assumed to be 390 samples taken over the three year period ( 3 years × 26 weeks × 5 samples = 390 samples), for each sample type.

b.) Implementing Offshore Sampling EPA believes that a sizable majority of the monitoring work will be carried out by the biologists and biological technicians. Over the course of the three year monitoring period, other employees will also spend time contributing to the use of the monitoring data. For example, a statistician is likely to spend five weeks over the course of the three years analyzing the monitoring data. This work is not likely to be distributed evenly between sample type or from month to month. However, for illustrative purposes EPA is providing estimates of employee burdens for each sample type.

For offshore freshwater sampling, EPA assumes that the labor burden is: 17 ° Biologist: A biologist spends approximately 4 hours conducting each offshore freshwater sampling event. ° Biological Technician: A biological technician accompanies the biologist on each site visit, spending approximately 4 hours conducting each offshore freshwater sampling event. ° Contracted Manager: Every two weeks the manager of the contracted firm spends on average of two hours managing the offshore sampling part of the project. ° Statistician: A statistician spends approximately four days each year analyzing the sampling results for statistical significance. ° Junior Technical: Facility junior technical staff spend approximately one hour every two weeks to review the monitoring data and summarize the results. ° Facility Manager: The facility manager will read over these offshore monitoring summaries. ° Clerical: Clerical staff spend approximately two days a year handling and delivering documents to the facility and contracted employees.

Implement Offshore Sampling, Freshwater  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 2.7 8 $ 179 $ 537 Junior Technical $ 31.9 26.0 78 $ 829 $ 2,488 Contracted Manager $ 85.3 53.3 160 $ 4,549 $ 13,648 Biologist $ 55.4 1,040.0 3120 $ 57,616 $ 172,848 Biological Technician $ 35.5 1,040.0 3120 $ 36,920 $ 110,760 Statistician $ 56.8 33.3 100 $ 1,893 $ 5,680 Clerical $ 18.2 16.7 50 $ 303 $ 910 Similar to freshwater offshore sampling, EPA expects that the same number of samples ( 780 offshore samples) and the same type of activities will occur at facilities with marine waters. However, EPA assumed that offshore sampling would require more effort at marine sites than at freshwater sites, due to the higher levels of biota typically present. Therefore, EPA estimates that the offshore marine sampling takes approximately 30% more time than offshore freshwater sampling. 18 Implement Offshore Sampling, Marine  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 3.3 10 $ 224 $ 671 Junior Technical $ 31.9 33.7 101 $ 1,074 $ 3,222 Contracted Manager $ 85.3 53.3 160 $ 4,549 $ 13,648 Biologist $ 55.4 1,352.0 4056 $ 74,901 $ 224,702 Biological Technician $ 35.5 1,352.0 4056 $ 47,996 $ 143,988 Statistician $ 56.8 33.3 100 $ 1,893 $ 5,680 Clerical $ 18.2 16.7 50 $ 303 $ 910 c.) Implement Impingement Sampling 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 taxa and abundance of impinged organisms. Over the three year period, EPA assumes that the freshwater impingement sampling labor burden is:

° Biologist: A biologist spends approximately two hours taking each freshwater impingement sample, and an additional two hours analyzing the impinged organisms. ° Biological Technician: A biological technician accompanies the biologist on each site visit, spending two hours taking each freshwater impingement sample, and an additional two hours analyzing the impinged organisms. ° Contracted Manager: Every two weeks the manager of the contracted firm spends on average of one hour managing the impingement sampling portion of the contract. ° Statistician: A statistician spends approximately two days each year analyzing the impingement sampling results for statistical significance. ° Junior Technical: Facility junior technical staff spend approximately two hours every three months to review the monitoring results from the impingement sampling and summarize the results. ° Facility Manager: Is assumed to review the impingement monitoring summaries. C Clerical: Clerical staff spends approximately one day over the course of a year handling and delivering documents to the facility and contracted employees. 19 Implement Freshwater Impingement Characterization Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 1.3 4 $ 89 $ 268 Junior Technical $ 31.9 8.0 24 $ 255 $ 766 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 520.0 1560 $ 28,808 $ 86,424 Biological Technician $ 35.5 520.0 1560 $ 18,460 $ 55,380 Statistician $ 56.8 16.7 50 $ 947 $ 2,840 Clerical $ 18.2 8.3 25 $ 152 $ 455 Impingement sampling at facilities with intakes in marine waters is expected to be performed in the same manner as freshwater impingement sampling. However, the sampling effort is expected to take 30% more time due to the greater abundance and diversity of organisms.

Implement Marine Impingement Characterization Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 1.3 4 $ 89 $ 268 Junior Technical $ 31.9 10.3 31 $ 330 $ 989 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 676.0 2028 $ 37,450 $ 112,351 Biological Technician $ 35.5 676.0 2028 $ 23,998 $ 71,994 Statistician $ 56.8 16.7 50 $ 947 $ 2,840 Clerical $ 18.2 8.3 25 $ 152 $ 455 d.) Implement Entrainment Sampling 20 Entrainment monitoring involves the collection of data on eggs, larvae, and plankton incorporated with cooling water flow ( entering and passing through a cooling water intake structure and into a cooling water system), to determine the taxa and abundance of entrained organisms. Over the three year period, EPA assumes that the entrainment freshwater sampling labor burden is:

C Biologist: A biologist spends on average two hours taking each entrainment sample and one hour preserving and preparing it for delivery to the laboratory. C Biological Technician: A biological technician accompanies the biologist on each site visit, taking approximately two hours for each entrainment sample and one hour helping to prepare the sample for shipping. ° Contracted Manager: Every two weeks the manager of the contracted firm spends on average one hour managing the entrainment sampling portion of the contract. ° Statistician: A statistician spends half a day every three months analyzing the entrainment sampling results for statistical significance. ° Junior Technical: Facility junior technical staff spend approximately two hours every three months to review the monitoring results from the entrainment sampling and summarize the results. ° Facility Manager: Is assumed to review these entrainment monitoring summaries. ° Clerical: Clerical staff spends approximately one day over the course of a year handling and delivering documents to the facility and contracted employees.

Implement Freshwater Entrainment Characterization Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 1.3 4 $ 89 $ 268 Junior Technical $ 31.9 8.0 24 $ 255 $ 766 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 390.0 1170 $ 21,606 $ 64,818 Biological Technician $ 35.5 390.0 1170 $ 13,845 $ 41,535 Statistician $ 56.8 16.7 50 $ 947 $ 2,840 Clerical $ 18.2 8.3 25 $ 152 $ 455 Entrainment sampling at facilities with intakes in marine waters is expected to be performed in the same manner as freshwater entrainment sampling. However, the sampling effort is expected to take 30% more time due to the greater abundance and diversity of organisms. 21 Implement Marine Entrainment Characterization Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 1.3 4 $ 89 $ 268 Junior Technical $ 31.9 10.3 31 $ 330 $ 989 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 507.0 1521 $ 28,088 $ 84,263 Biological Technician $ 35.5 507.0 1521 $ 17,999 $ 53,996 Statistician $ 56.8 16.7 50 $ 947 $ 2,840 Clerical $ 18.2 8.3 25 $ 152 $ 455 e.) Profile of Source Water Biota It was assumed that much of the work of profiling the source water biota is carried out by the contracted employees during the first year of the study, although updates to the profile are likely to be made as additional information becomes available over the remainder of the study period. The facility management and staff also take an active role in reviewing this work as this information forms the basis of the study results that are submitted to the Director. This information may also be used by the facility for other parts of the Comprehensive Demonstration Study. EPA assumes that the labor burden for profiling source water biota is:

C Facility Manager: The facility manager spends approximately four days reviewing the data and results of the biological profile. C Junior Technical: Facility junior technical staff spend approximately twenty hours assisting the facility manager with reviewing the data and results of the biological profile. C Contracted Manager: The contracted manager spends approximately four days reviewing lab results and documentation used for developing the biological profile. C Biologist: A biologist spends a week and a half identifying the species and characterizing the data based on lab results and statistical analysis. C Biological Technician: A biological technician spends twenty hours assisting the biologist with the review of lab results. C Clerical: Clerical staff spend approximately one day handling the documentation for the biological profile. 22 Profile Source Water Biota  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 10.7 32 $ 716 $ 2,147 Junior Technical $ 31.9 6.7 20 $ 213 $ 638 Contracted Manager $ 85.3 10.7 32 $ 910 $ 2,730 Biologist $ 55.4 20.0 60 $ 1,108 $ 3,324 Biological Technician $ 35.5 6.7 20 $ 237 $ 710 Clerical $ 18.2 2.7 8 $ 49 $ 146 f.) Identification of Critical Species:

The identification of critical species is based on the profiles of source water biota, the results of the statistical analysis, and a review of relevant information. Much of the identification is carried out by the contracted employees, although updates may be made to it as additional information becomes available. However, the facility manager takes a more active role in reviewing this work as this information will form the basis of the study results that he submits to the State. EPA assumes that the labor burden for identification of critical species is:

C Facility Manager: The facility manager spends approximately four days reviewing the data for the critical species identification and then determining the significance of these results to their overall compliance efforts. C Junior Technical: Facility junior technical staff spend approximately twenty hours assisting the facility manager with reviewing the data and results of the critical species identification. C Contracted Manager: The contracted manager spends approximately half a week assisting the biologist with the identification. C Biologist: A biologist spends a week identifying the critical species from the data and statistical analysis. C Clerical: Clerical staff spend approximately three hours handling the documentation for the critical species list. 23 Identification of Critical Species  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 10.7 32 $ 716 $ 2,147 Junior Technical $ 31.9 6.7 20 $ 213 $ 638 Contracted Manager $ 85.3 6.7 20 $ 569 $ 1,706 Biologist $ 55.4 13.3 40 $ 739 $ 2,216 Clerical $ 18.2 1.3 4 $ 24 $ 73 h.) Description of Additional Stresses It was assumed much of the description of additional stresses is carried out by the contracted employees, since they have the most direct knowledge of the waterbody, biological communities, and the monitoring data. This work is assumed to occur at the same time as the identification of critical species and to be approximately half of the Source Water Biota profile burden. EPA assumes that the labor burden for description of additional stresses is:

C Facility Manager: The facility manager spends approximately two days reviewing the data on additional stresses. C Junior Technical: Facility junior technical staff spend approximately ten hours assisting the facility manager with reviewing the data on additional stresses. C Contracted Manager: The contracted manager spends approximately two days reviewing lab results and documentation used for determining additional stresses. C Biologist: A biologist spends approximately thirty hours identifying and describing additional stresses. C Biological Technician: A biological technician spends ten hours assisting the biologist with the description of additional stresses. C Clerical: Clerical staff spend approximately one half a day handling the documentation for the description of additional stresses. 24 Description of Additional Stresses  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 5.3 16 $ 358 $ 1,074 Junior Technical $ 31.9 3.3 10 $ 106 $ 319 Contracted Manager $ 85.3 5.3 16 $ 455 $ 1,365 Biologist $ 55.4 10.0 30 $ 554 $ 1,662 Biological Technician $ 35.5 3.3 10 $ 118 $ 355 Clerical $ 18.2 1.3 4 $ 24 $ 73 i.) Write Study Based on Results and Submit for Review by the Director The study will be written towards the end of the third year primarily by the facility manager and junior staff. EPA assumes that the labor burden for writing the study is:

C Facility Manager: The facility manager spends two weeks outlining the report, writing critical sections, and reviewing the work done by the junior staff. C Junior Technical: Facility junior technical staff spend approximately four weeks drafting the bulk of the report and supporting materials. C Contracted Manager: The manager of the contracted firm spends approximately one day assisting the facility manager by providing expert opinion when needed and one day reviewing a draft of the study. C Biologist: A biologist spends one day assisting with providing expert opinion and reviewing study. C Statistician: A statistician also spends one day assisting with providing expert opinion and reviewing study. C Clerical: Clerical staff spends 8 hours assisting with preparing the report for submission. 25 Write Report for Impingement Mortality & Entrainment Characterization Study  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 26.7 80 $ 1,789 $ 5,368 Junior Technical $ 31.9 53.3 160 $ 1,701 $ 5,104 Contracted Manager $ 85.3 5.3 16 $ 455 $ 1,365 Biologist $ 55.4 2.7 8 $ 148 $ 443 Statistician $ 56.8 2.7 8 $ 151 $ 454 Clerical $ 18.2 2.7 8 $ 49 $ 146 j.) Recordkeeping Due to the necessity of the study for obtaining a permit, the facility staff and the contractor will spend time to ensure that both paper and electronic copies of all results, analyses, studies, and reviews are maintained. This record keeping is expected to be carried out through the course of the three year study, but the majority of it will likely occur during the last year when they study report is written and finalized. EPA assumes that the labor burden for this recordkeeping is:

C Facility Manager: The facility manager spends six hours maintaining records over the three years. C Junior Technical: Facility junior technical staff spend 12 hours maintaining records over three years. C Contracted Manager: The manager of the contracted firm spends six hours maintaining records over the three years. C Biologist: The biologist spends 12 hours maintaining records over the three years. C Clerical: Clerical staff spends three days maintaining study records over the three years. 26 Impingement Mortality & Entrainment Characterization Study Record Keeping  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 2.0 6 $ 134 $ 403 Junior Technical $ 31.9 4.0 12 $ 128 $ 383 Contracted Manager $ 85.3 2.0 6 $ 171 $ 512 Biologist $ 55.4 4.0 12 $ 222 $ 665 Statistician $ 56.8 1.0 3 $ 57 $ 170 Clerical $ 18.2 8.0 24 $ 146 $ 437 k.) Finalize Study Based on State Review EPA anticipates that the State will have questions and comments on the study that will require the facility staff to revise the study further. EPA assumes that the labor burden for revising the study is:

C Facility Manager: The facility manager spends two days reviewing the State's comments and questions and then crafting appropriate responses. C Junior Technical: Facility junior technical staff spend four days revising the study. C Clerical: Clerical staff spends one day resubmitting the study and maintaining records.

Impingement Mortality & Entrainment Characterization Final Report  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 5.3 16 $ 358 $ 1,074 Junior Technical $ 31.9 10.7 32 $ 340 $ 1,021 Clerical $ 18.2 2.7 8 $ 49 $ 146 27 l.) Impingement Mortality and Entrainment Characterization Study Other Direct Costs Facility ODCs for the Impingement Mortality and Characterization Study include supplies for periodic work at monitoring sites by facility employees, which may occasionally include boat rental. These ODCs are expected to vary for facilities depending on whether they are located adjacent to freshwater or marine waterbodies. EPA assumes that the ODCs for freshwater facilities over three years are $ 7,800. EPA anticipates that marine facilities would incur 67% more ODCs than freshwater facilities, so their three year ODCs are $ 13,000.

m.) Biological Study Laboratory Analysis EPA assumes that all offshore and entrainment samples, a total of 1,170 samples, will be analyzed by an outside laboratory. These laboratory analysis costs are considered O& M costs. For samples from facilities with intakes on freshwater, the laboratory analysis cost are expected to be $ 100 per sample. The laboratory analysis cost per marine sampling event was assumed to be 30% more expensive than for freshwater samples, due to both the greater abundance of biomass and higher diversity of the biota.

Impingement Mortality and Entrainment Characterization Study Laboratory Analysis  Summary O& M Cost Table Water body that the Sample was taken from Laboratory Cost per Sample Annual Cost Total Cost for ICR Period Freshwater Sample $ 100 $ 39,000 $ 117,000 Marine Sample $ 130 $ 50,700 $ 152,100 2. Pilot Study for New Impingement and Entrainment Technology As part of the Design and Construction Technology Plan, facilities must include a sitespecific evaluation of the technology( ies) and/ or operational measures. This site specific evaluation can be based on representative studies ( i. e., studies that have been conducted at cooling water intake structures located in the same waterbody type with similar biological characteristics) and/ or site specific technology prototype studies. EPA assumes for the sitespecific technology prototype studies, that the facilities will conduct an on site pilot study for the new technology or operational measure.

Pilot studies are the temporary installation and operation of a small scale version of the proposed technology. Facilities typically use pilot studies to determine how well a technology will work under the site specific conditions before carrying out a full scale installation of the technology. When determining the relative scope and duration of the pilot study, size of the pilot study equipment as compared to the full scale technology and the extent of the data that the 28 study will need to generate are considered. Facilities weigh how likely the performance of the pilot equipment will translate adequately to the full scale technology ( i. e. will the pilot study results be applicable to the actual proposed technology). The next decision facilities weigh is the cost of the pilot study against the financial risk of installing the actual technology without being tested on site. In other words, the greater the potential of financial risk associated with the proposed technology failing, the higher the expenses a facility is willing to spend on a pilot study to ensure that it will work properly.

In general, pilot study costs vary. The variables that affect pilot study costs are regulations, testing protocols, and testing duration. Pilot equipment is either rented or manufactured to suit specific site conditions. Generally, in either case, a typical ratio of total pilot study costs to the actual technology costs is less than one to ten for technologies that cost more than one million dollars. Therefore, EPA assumes that facilities will be willing to spend 10% of the technology installation cost on a pilot study to determine if the technology will function properly when installed and operated.

EPA assumes that a typical pilot study will involve the following activities: installing an intake pipe separate from the facility's actual cooling water system, but in the vicinity of the operating CWIS; deploying the proposed technology to feed in the separate intake pipe and pumping water through the intake so that impingement and entrainment levels can be observed under various pumping scenarios and seasonal conditions.

An important cost element in the Pilot Study is the cost of monitoring. EPA realizes that the amount of monitoring necessary will vary depending on the technology and the biological characteristics of the source water. However, EPA assumes that a typical monitoring effort would involve five samples being collected over a twenty four hour period, every two weeks for six months. Facilities will need to analyze the data, summarize the results, and use this information as the basis for their site specific evaluation. EPA estimates that the pilot study monitoring and reporting costs will typically range between $ 50,000 and $ 110,000 for a facility, depending on the source water type, and whether the facility will need to monitor for both impingement and entrainment or just impingement.

As part of the economic analysis for the proposed rule, EPA has developed technology cost estimates for those facilities that EPA anticipates will install new technologies. The installation costs for these technologies vary widely with the capital costs of the relatively inexpensive technologies being less than $ 500,000. EPA assumes that the financial risk to facilities installing relatively low cost technologies ( in comparison to a facility's overall cost of operation, revenues, or anticipated benefits) are not likely to warrant conducting a pilot study. In these cases, EPA believes that facilities with low cost technology options will forgo a pilot study and install the proposed technology based on existing performance information or manufacturers' guarantees to cover the cost of dismantling the equipment. The facility will then use the impingement and entrainment monitoring data from the Impingement Mortality and Entrainment Characterization Study to evaluate how well the technology performs. EPA assumes that when the capital cost for the proposed technology is less than $ 500,000, the facility will not 29 perform a pilot study. A pilot study may not be practical for some of the proposed technologies, such as widening the opening of the intake structure to reduce intake velocity. For those facilities anticipated to install technologies where a pilot study is impractical, EPA assumes, for the purpose of estimating the regulatory economic burden, that they will not perform pilot studies either.

To develop total pilot study cost estimates for facilities, EPA assumes that facilities will spend approximately 10% of the capital costs for installing the proposed technology on a cooling water intake. This cost covers the installation, operation, monitoring, and reporting costs associated with the pilot study. However, EPA assumes that the minimum cost to perform an acceptable pilot study would be $ 150,000. Therefore, if 10% of a facility's technology cost was below $ 150,000, the facility was automatically assigned a cost of $ 150,000.

For the Economic Analysis, total pilot study costs are reported on a per facility basis. For the ICR Analysis, average labor burdens and capital and O& M costs are reported.

a.) Implement Pilot Study Impingement Sampling All facilities performing pilot studies will conduct impingement monitoring. 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 taxa and abundance of impinged organisms. During the course of the pilot study, EPA assumes that the impingement freshwater sampling labor burden is:

° Biologist: A biologist will perform twelve sampling events over the course of six months. For each sampling event the biologist will take five samples over a twenty four hour period. The biologists spends approximately two hours taking each freshwater impingement sample, and an additional two hours analyzing the impinged organisms. ° Biological Technician: A biological technician accompanies the biologist on each site visit, spending two hours taking each freshwater impingement sample, and an additional two hours analyzing the impinged organisms. ° Contracted Manager: The contracted manager spends a total of eighty hours managing the impingement sampling portion of the contract and making occasional visits to the site to supervise the impingement sampling. ° Statistician: A statistician spends approximately one week analyzing the impingement sampling results for statistical significance. ° Junior Technical: Facility junior technical staff take approximately three days to review the monitoring results from the impingement sampling and summarize the results. ° Facility Manager: Is assumed to take two days observing the collection of data and reviewing the impingement monitoring summaries. 30 C Clerical: Clerical staff spends approximately two and a half days the course of the study handling and delivering documents to the facility and contracted employees.

Pilot Study Freshwater Impingement Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 5.3 16 $ 358 $ 1,074 Junior Technical $ 31.9 8.3 25 $ 266 $ 798 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 80.0 240 $ 4,432 $ 13,296 Biological Technician $ 35.5 80.0 240 $ 2,840 $ 8,520 Statistician $ 56.8 13.3 40 $ 757 $ 2,272 Clerical $ 18.2 6.7 20 $ 121 $ 364 Impingement sampling at facilities with intakes in marine waters is expected to be performed in the same manner as freshwater impingement sampling. However, the sampling effort is expected to take 30% more time due to the greater abundance and diversity of organisms.

Pilot Study Marine Impingement Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 5.3 16 $ 358 $ 1,074 Junior Technical $ 31.9 11.0 33 $ 351 $ 1,053 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 104.0 312 $ 5,762 $ 17,285 Biological Technician $ 35.5 104.0 312 $ 3,692 $ 11,076 Statistician $ 56.8 17.3 52 $ 985 $ 2,954 Clerical $ 18.2 8.7 26 $ 158 $ 473 31 b.) Implement Pilot Study Entrainment Sampling Facilities which are subject to the entrainment requirements will conduct entrainment monitoring as part of their pilot studies. Entrainment monitoring involves the collection of data on eggs, larvae, and other plankton incorporated with cooling water flow ( entering and passing through a cooling water intake structure and into a cooling water system), to determine the taxa and abundance of entrained organisms. During the course of the pilot study, EPA assumes that the entrainment freshwater sampling labor burden is:

° Biologist: A biologist will perform twelve sampling events over the course of six months. For each sampling event the biologist will take five samples over a twenty four hour period. The biologists spends approximately two hours taking each freshwater entrainment sample, and an additional hour to prepare the sample for delivery to the lab. ° Biological Technician: A biological technician accompanies the biologist on each site visit, spending two hours taking each freshwater entrainment sample, and an additional hour to prepare the sample for delivery to the lab. ° Contracted Manager: The contracted manager spends a total of eighty hours managing the entrainment sampling portion of the contract and making occasional visits to the site to supervise the entrainment sampling. ° Statistician: A statistician spends approximately one week analyzing the entrainment sampling results for statistical significance. ° Junior Technical: Facility junior technical staff take approximately three days to review the monitoring results from the entrainment sampling and summarize the results. ° Facility Manager: Is assumed to take two days observing the collection of data and reviewing the entrainment monitoring summaries. C Clerical: Clerical staff spends approximately two and a half days the course of the study handling and delivering documents to the facility and contracted employees.

Pilot Study Freshwater Entrainment Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 5.3 16 $ 358 $ 1,074 Junior Technical $ 31.9 8.3 25 $ 266 $ 798 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 60.0 180 $ 3,324 $ 9,972 Biological Technician $ 35.5 60.0 180 $ 2,130 $ 6,390 32 Statistician $ 56.8 13.3 40 $ 757 $ 2,272 Clerical $ 18.2 6.7 20 $ 121 $ 364 Entrainment sampling at facilities with intakes in marine waters is expected to be performed in the same manner as freshwater entrainment sampling. However, the sampling effort is expected to take 30% more time due to the greater abundance and diversity of organisms.

Pilot Study Marine Entrainment Sampling  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 5.3 16 $ 358 $ 1,074 Junior Technical $ 31.9 11.0 33 $ 351 $ 1,053 Contracted Manager $ 85.3 26.7 80 $ 2,275 $ 6,824 Biologist $ 55.4 78.0 234 $ 4,321 $ 12,964 Biological Technician $ 35.5 78.0 234 $ 2,769 $ 8,307 Statistician $ 56.8 17.3 52 $ 985 $ 2,954 Clerical $ 18.2 8.7 26 $ 158 $ 473 c.) Calculate Reduction in Impingement and Entrainment It was assumed that much of the work of calculating the reduction in impingement and entrainment is carried out by the facility staff. EPA assumes that the labor burden is:

C Facility Manager: The facility manager spends approximately two weeks reviewing results of the pilot study monitoring, comparing these results with the impingement and entrainment data being gathered for the Impingement Mortality and Entrainment Characterization Study, and reviewing the calculations made by the junior technical staff. C Junior Technical: Facility junior technical staff spend approximately two weeks assisting the facility manager with the analysis of the data and they will perform most of the actual reduction calculations. C Contracted Manager: The contracted manager spends approximately one day reviewing the data comparison and the subsequent reduction calculations. C Clerical: Clerical staff spend approximately one and a half days handling the documentation for the reduction calculations. 33 Calculate Reduction in Impingement and Entrainment  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 26.7 80 $ 1,789 $ 5,368 Junior Technical $ 31.9 26.7 80 $ 851 $ 2,552 Contracted Manager $ 85.3 2.7 8 $ 227 $ 682 Clerical $ 18.2 4.0 12 $ 73 $ 218 d.) Engineering Estimates of Technology Efficacy After the facility has used the pilot study data to develop estimates of impingement and entrainment reduction, the facility must then evaluate how well a full scale version of the technology will perform at the site. At this point, initial engineering design and cost estimates will be revised to reflect what has been learned about how the technology is likely to operate under the site specific conditions. EPA assumes that the labor burden for these engineering estimates is:

C Facility Manager: The facility manager spends approximately one week revising the engineering estimates and determining the efficacy of the proposed technology. C Junior Technical: Facility junior technical staff spend approximately four days assisting the facility manager with determining the efficacy of the proposed technology. C Clerical: Clerical staff spend approximately half a day handling the documentation for the engineering estimates.

Engineering Estimates of Efficacy  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Total Hrs for ICR Period Annual Cost Total Cost for ICR Period Facility Manager $ 67.1 13.3 40 $ 895 $ 2,684 Junior Technical $ 31.9 10.7 32 $ 340 $ 1,021 Clerical $ 18.2 1.3 4 $ 24 $ 73 e.) Pilot Study Laboratory Analysis For facilities subject to entrainment reduction requirements, EPA assumes that all pilot study entrainment samples, a total of 60 samples, will be analyzed by an outside laboratory. 34 These laboratory analysis costs are considered O& M costs. For samples from facilities with intakes on freshwater, the laboratory analysis cost are expected to be $ 100 per sample. The laboratory analysis cost per marine sampling event was assumed to be 30% more expensive than for freshwater samples, due to both the greater abundance of biomass and higher diversity of the biota.

Pilot Study Entrainment Laboratory Analysis  Summary Cost Table Water body that the Sample was taken from Laboratory Cost per Sample Number of Entrainment Samples Total Cost for ICR Period Freshwater Sample $ 100 60 $ 6,000 Marine Sample $ 130 60 $ 7,800 f.) Pilot Study Capital and O& M Costs Pilot study costs were developed on a per facility basis using the approach described above. However, for the purpose of the ICR analysis, average monitoring and reporting costs, as well as average capital and O& M costs were estimated. To develop estimates of average capital and O& M costs, EPA developed four average total pilot study costs, based on a facility's source water type and whether or not the facility must address both impingement and entrainment or just impingement. The estimated average monitoring and reporting costs were then subtracted from these average total costs, to derive average installation and operation costs.

Average Pilot Study Costs Summary Table Facility Category Average Monitoring and Reporting Costs Average Installation and Operation Costs Average Total Costs Freshwater Pilot Study $ 84,156 $ 251,754 $ 335,910 Freshwater Pilot Study  Impingement Only $ 50,463 $ 198,206 $ 248,669 Marine Pilot Study $ 99,469 $ 422,926 $ 522,395 Marine Pilot Study  Impingement Only $ 58,037 $ 392,544 $ 450,581 35 D. Annual Monitoring Labor Burden and Costs All Phase II existing facilities would need to monitor both impingement and entrainment of the commercial, recreational and forage base fish and shellfish species and their life stages identified in either the Source Water Baseline Biological Characterization data or the Impingement Mortality and Entrainment Characterization Study. The monitoring methods used must be consistent with those used for the Source Water Baseline Biological Characterization data or the Impingement Mortality and Entrainment Characterization Study. The facility must follow the prescribed monitoring frequencies for at least two years after the initial permit issuance. After that time, the Director may approve a request for less frequent sampling in the remaining years of the permit term and when the permit is reissued, if supporting data show that less frequent monitoring would still allow for the detection of any seasonal and daily variations in the species and numbers of individuals that are impinged or entrained.

1. Biological Monitoring for Impingement 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 taxa and abundance of impinged organisms. The proposed rule requires facilities to monitor no less than once per month for impingement. So EPA assumes that facilities will have contracted employees take three samples for impingement, over a 24 hour period, twelve times a year, for a total of 36 impingement samples annually.

a.) Monthly Impingement Sample Collection As with the impingement samples taken for the Impingement Mortality and Entrainment Characterization Study, the collection of the samples is performed on site by the biologist and biological technician. For freshwater facilities the assumed labor burden is:

° Facility Manager: Is assumed to make four visits per year to observe sampling, spending approximately one half hour per visit. ° Contracted Manager: The contracted manager is expected to make four visits to oversee sampling per year each at one hour per sampling event. ° Biologist: The biologist is assumed to conduct 12 sampling events annually at one site with three samples being taken over a twenty four hour period. Each sample taking two hours to obtain. ° Biological Technician: The technician assists the biologist in conducting 12 sampling events annually at one site with three samples, each taking two hours to obtain. 36 Monthly Impingement Sample Collection ( Freshwater)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 2.0 $ 134 Contracted Manager $ 85.3 4.0 $ 341 Biologist $ 55.4 72.0 $ 3,989 Biological Technician $ 35.5 72.0 $ 2,556 Impingement sampling done at facilities with intakes on marine waters is assumed to require on average 30% more effort than sampling at freshwater facilities.

Monthly Impingement Sample Collection ( Marine)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 2.0 $ 134 Contracted Manager $ 85.3 5.0 $ 427 Biologist $ 55.4 94.0 $ 5,208 Biological Technician $ 35.5 94.0 $ 3,337 b.) Onsite Analysis of Impingement Samples As with the impingement sampling performed for the Impingement Mortality and Entrainment Characterization Study, the analysis of the impingement samples is performed onsite by the biologist and the biological technician. For freshwater facilities the burden for analyzing impingement samples is: ° Facility Manager: Is assumed to make four visits to observe impingement sample analysis per year, spending approximately one hour per visit. ° Contracted Manager: The contracted manager is expected to make four visits to oversee sampling analysis per year each at one hour per impingement sample analysis. ° Biologist: Each year, the biologist is assumed to conduct 12 on site sampling analysis for impingement, for three different samples, each taking two hours to analyze. ° Biological Technician: Each year, the technician assists the biologist in conducting 12 on site sampling analysis for impingement, for three different samples, each taking two hours to analyze.

Onsite Analysis of Impingement Samples ( Freshwater)  Summary Burden/ Cost Table 37 Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 4.0 $ 268 Contracted Manager $ 85.3 12.0 $ 1,024 Biologist $ 55.4 72.0 $ 3,989 Biological Technician $ 35.5 72.0 $ 2,556 Impingement sample analysis done at facilities with intakes on marine waters are assumed to require on average 30% more effort than sample analysis at freshwater facilities.

Onsite Analysis of Impingement Samples ( Marine)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 4.0 $ 268 Contracted Manager $ 85.3 16.0 $ 1,365 Biologist $ 55.4 94.0 $ 5,208 Biological Technician $ 35.5 94.0 $ 3,337 c.) Perform Statistical Analysis on Impingement Sample Data The annual impingement monitoring data will be analyzed for statistical significance. The results of the statistical analyses will be used for the yearly status report on 316( b) compliance. EPA assumes that the burden for the statistical analysis on impingement sample data is:

° Facility Manager: The facility manager spends one day per year reviewing lab results and statistical analysis. ° Junior Technical: The junior technical staff will spend one half day per year assisting the facility manager in reviewing the lab results and statistical analysis. ° Statistician: A statistician spends a day every quarter analyzing the sampling results for statistical significance. 38 Statistical Analysis on Annual Impingement Sample Data ( Freshwater)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 8 $ 537 Junior Technical $ 31.9 4 $ 128 Statistician $ 56.8 32 $ 1,818 Because of the higher volume of sampling data that is likely to be produced from impingement sampling at marine facilities, EPA assumes statisticians will spend 30% more time on statistical analysis of data from these facilities.

Statistical Analysis on Annual Impingement Sample Data ( Marine)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 8 $ 537 Junior Technical $ 31.9 4 $ 128 Statistician $ 56.8 42 $ 2,386 2. Biological Monitoring for Entrainment Entrainment monitoring involves the collection of data on eggs, larvae, and plankton incorporated with cooling water flow ( entering and passing through a cooling water intake structure and into a cooling water system), to determine the taxa and abundance of entrained organisms. The proposed rule suggests facilities would need to monitor no less than once every two weeks over a 24 hour period, while the CWIS is in operation and during the primary period of reproduction, larval recruitment and peak abundance, as determined by the Source Water Biological Characterization and the Impingement Mortality and Entrainment Characterization Study.

a.) Biweekly Entrainment Sample Collection EPA assumes that facilities will have contracted employees take three samples for entrainment, over a 24 hour period, 26 times a year, for a total of 78 entrainment samples 39 annually. This is a conservative estimate, considering that the critical periods in reproduction, larval recruitment, and peak abundance will not span an entire year. For freshwater facilities the assumed burden is:

° Facility Manager: Is assumed to make four visits to observe sampling per year, spending approximately one hour per visit. ° Contracted Manager: The contracted manager is expected to make four visits to oversee sampling per year, spending one hour per sample. ° Biologist: The biologist is assumed to conduct 26 sampling events annually at one site with three samples over a 24 hour period, each taking two hours to obtain. ° Biological Technician: The technician assists the biologist in conducting 26 sampling events annually at one site with three samples, each taking two hours to obtain.

Biweekly Entrainment Sample Collection ( Freshwater)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 4.0 $ 268 Contracted Manager $ 85.3 12.0 $ 1,024 Biologist $ 55.4 156.0 $ 8,642 Biological Technician $ 35.5 156.0 $ 5,538 Entrainment sampling done at facilities with intakes on marine waters is assumed to require on average 30% more effort than sampling at freshwater facilities.

Biweekly Entrainment Sample Collection ( Marine)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 4.0 $ 268 Contracted Manager $ 85.3 12.0 $ 1,024 Biologist $ 55.4 203.0 $ 11,246 Biological Technician $ 35.5 203.0 $ 7,207 b.) Handling and Preparation of Entrainment Samples EPA assumes that the entrainment samples will be preserved and prepared for being transported to an off site laboratory. For freshwater facilities, the assumed burden is: 40 ° Facility Manager: Is assumed to make four visits to oversee sampling analysis per year, spending approximately one hour per visit. ° Contracted Manager: The contracted manager is expected to make four visits to oversee sampling analysis per year. Spending one hour per sample preparation. ° Biologist: Every two weeks, the biologist is assumed to spend an hour preparing each of three entrainment samples for delivery to the lab. ° Biological Technician: Every two weeks, the biological technician is expected to spend three hours assisting the biologist is preparing entrainment samples for delivery to the lab.

Handling and Preparation of Entrainment Samples ( Freshwater)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 4.0 $ 268 Contracted Manager $ 85.3 12.0 $ 1,024 Biologist $ 55.4 78.0 $ 4,321 Biological Technician $ 35.5 78.0 $ 2,769 Entrainment sample preparation done at facilities with intakes on marine waters is assumed to require on average 30% more effort than sampling at freshwater facilities.

Handling and Preparation of Entrainment Samples ( Marine)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 4.0 $ 268 Contracted Manager $ 85.3 12.0 $ 1,024 Biologist $ 55.4 101.0 $ 5,595 Biological Technician $ 35.5 101.0 $ 3,586 41 c.) Perform Statistical Analysis on Entrainment Sample Data The annual entrainment monitoring data will be analyzed for statistical significance. The results of the statistical analyses will be used for the yearly status report on 316( b) compliance. EPA assumes that the burden for the statistical analysis will be somewhat greater than that for impingement, due to the additional need to characterize organisms in their various stages of development, and due to the inherent difficulty interpreting entrainment sample data. The assumed burden is:

° Facility Manager: The facility manager spends two days per year reviewing lab results and statistical analysis. ° Junior Technical: The junior technical staff will spend one half day per year assisting the facility manager in reviewing the lab results and statistical analysis. ° Statistician: A statistician spends two days every quarter analyzing the sampling results for statistical significance.

Statistical Analysis on Annual Entrainment Sample Data ( Freshwater)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 16 $ 1,074 Junior Technical $ 31.9 4 $ 128 Statistician $ 56.8 64 $ 3,635 Because of the higher volume of sampling data that is likely to be produced from entrainment sampling at marine facilities, EPA assumes statisticians will spend 30% more time analyzing data from these facilities.

Statistical Analysis on Annual Entrainment Sample Data ( Marine)  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 16 $ 1,074 Junior Technical $ 31.9 4 $ 128 Statistician $ 56.8 83 $ 4,714 42 d.) Annual Entrainment Study Laboratory Analysis EPA assumes that all annual entrainment samples, a total of 78 samples per year, will be analyzed by an outside laboratory. These laboratory analysis costs are considered O& M costs. For samples from facilities with intakes on freshwater, the laboratory analysis cost are expected to be $ 100 per sample. The laboratory analysis cost per marine sampling event was assumed to be 30% more expensive than for freshwater samples, due to both the greater abundance of biomass and higher diversity of the biota.

Annual Entrainment Monitoring Laboratory Analysis  Summary O& M Cost Table Water body that the Sample was taken from Laboratory Cost per Sample Number of Samples Total Cost for ICR Period Freshwater Sample $ 100 78 $ 7,800 Marine Sample $ 130 78 $ 10,140 E. Annual Reporting Labor Burden and Costs 1. Verification Study The verification study uses monitoring results to prove that the implemented technologies, operational measures, or restoration measures are performing as stated in the permit. The Study is assumed to be written and submitted in the beginning of the third year after permit issuance. Study data is derived from the biological monitoring that takes place during the first two years of the permit term. The Verification Study is not an annual, but a one time task. However, it is based on the results of the first two years of annual monitoring performed by the facility.

EPA assumes that the facility manager spends approximately 9 hours comparing lab results and statistical analyses with the verification methods outlined in the Verification Monitoring Plan submitted with the facility's permit application. Then the manager spends two days drafting the report. The junior technical staff will spend 30 hours assisting the facility manager in reviewing the lab results and statistical analysis and drafting the report. The contracted manager and the biologist are each expected to take approximately two days to review various drafts of the study analyses and provide comments. The statistician spends about three days analyzing the sampling results from the previous two years to determine how they compare with the verification methods outlined in the Verification Monitoring Plan submitted with the facility application. 43 Verification Study  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 25 $ 1,677 Junior Technical $ 31.9 30 $ 957 Contracted Manager $ 85.3 15.0 $ 1,280 Biologist $ 55.4 15.0 $ 831 Statistician $ 56.8 25 $ 1,420 Clerical $ 18.2 1.0 $ 18 2. Yearly Status Report a.) Report on Inspection and Maintenance The facility management and junior technical staff each spend two days reviewing and summarizing the facility's internal inspection and maintenance records at the plant for the previous year.

Yearly Status Report on Inspection and Maintenance  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 16.0 $ 1,074 Junior Technical $ 31.9 16.0 $ 510 b.) Summary of Biological Monitoring Results The yearly status report provides evidence to the Director that the level of impingement and entrainment are being reduced to the levels specified in the permit. EPA assumes that the facility will spend several days reviewing the results of the monitoring data and the statistical analysis, to find evidence supporting its assertions. Facility management is expected to spend three days reviewing the data, consulting with the contracted employees about the significance of the data, and developing a summary of the findings. Junior technical staff are expected to spend four days assisting management with the review and characterization of the data. The contracted manager and biologist will each spend half a day conferring with facility staff over the 44 significance of the results. The statistician will also spend three days working with facility staff to determine the significance of the results.

Summary of Biological Monitoring Results for Yearly Status Report  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 24 $ 1,610 Junior Technical $ 31.9 32 $ 1,021 Contracted Manager $ 85.3 4.0 $ 341 Biologist $ 55.4 4.0 $ 222 Statistician $ 56.8 24 $ 1,363 c.) Compile and Submit Status Report EPA assumes that facility management will devote two weeks to outlining, drafting, and reviewing the yearly status report. Junior technical staff is expected to spend an equivalent amount of time assisting in this effort. Clerical staff will take two days to retrieve documents, distribute and track various drafts of the report, and prepare the final draft for submitting to the Director.

Drafting and Submitting the Yearly Status Report  Summary Burden/ Cost Table Labor Category Labor Rate Annual Hours Annual Cost Facility Manager $ 67.1 80 $ 5,368 Junior Technical $ 31.9 80 $ 2,552 Clerical $ 18.2 16.0 $ 291 SUPPORTING SPREADSHEETS FOR UPDATED INFORMATION COLLECTION COSTS FOR SECTION 316( b) PHASE II NOTICE OF DATA AVAILABILITY ( NODA)

31 Jan 03 Exhibit A. 1 Facility Cost and Burden Estimates for NPDES Permit Application Activities Exhibit A. 1a Start up Activities Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Read and Understand Rule 331 91 98 520 12 12 0 0 0 0 0 1 25 $ 1,206 13,000 $ 627,224 Mobilization/ Planning 331 91 98 520 4 8 0 0 0 0 0 1 13 $ 542 6,760 $ 281,736 Training 331 91 98 520 2 2 0 0 0 0 0 1 5 $ 216 2,600 $ 112,424 Totals 331 91 98 520 18 22 0 0 0 0 0 3 43 $ 1,964 $ 50 $ 2,014 22,360 $ 1,047,384 Exhibit A. 1b Permit Application Activities Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Statement of Intent to perform Comprehensive Demonstration Study 113 112 87 312 1 0 0 0 0 0 0 1 2 $ 85 624 $ 26,614 Source Water Physical Data 135 113 112 360 2 16 40 0 0 0 0 0 58 $ 1,769 20,880 $ 636,696 Configuration and Location of CWIS 135 113 112 360 2 5 8 0 0 0 0 0 15 $ 519 5,400 $ 186,660 Facility Water Balance Diagram 135 113 112 360 1 1 1 0 0 0 0 0 3 $ 127 1,080 $ 45,756 CWIS Operation Narrative 135 113 112 360 16 40 0 0 0 0 0 0 56 $ 2,350 20,160 $ 845,856 CWS Operation Narrative 135 113 112 360 16 40 0 0 0 0 0 0 56 $ 2,350 20,160 $ 845,856 Engineering Calculations 135 113 112 360 8 32 0 0 0 0 0 0 40 $ 1,558 14,400 $ 560,736 Submit Materials for Review by State 135 113 112 360 0 0 0 0 0 0 0 6 6 $ 109 2,160 $ 39,312 Recordkeeping 135 113 112 360 2 5 2 0 0 0 0 2 11 $ 386 3,960 $ 139,068 Totals 135 113 112 360 247 $ 9,252 $ 500 $ 9,752 88,824 $ 3,479,940 Water balance diagram is assumed to be taken from the facility design report. The hours reported here are for incorporation of the diagram( s) in the permit. Assumed Loaded Hourly Rate Level of Effort ( hrs)

Assumed Loaded Hourly Rate Level of Effort ( hrs) A Facilities ( Respondents) A Facilities ( Respondents)

ODCs lump sum* Burden Per Facility Burden Per Facility Labor Cost per Facility Total Initial Cost Labor Cost per Facility ODCs lump sum* Total Cost Per Facility Total Burden ( hrs.)

Total Burden ( hrs.) Total Cost Per Facility Total Initial Cost January31, 2003 Exisiting Facility Rule Information Collection Request A. 1 1 Exhibit A. 1c Source Water Baseline Biological Characterization Data Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Identify Available Data and Document Efforts 135 113 112 360 40 80 0 0 0 0 0 8 128 $ 5,382 46,080 $ 1,937,376 Compile and Analyze Existing Data 135 113 112 360 32 60 20 0 0 0 0 4 116 $ 4,696 41,760 $ 1,690,560 Submit Data for Review by State 135 113 112 360 0 0 0 0 0 0 0 8 8 $ 146 2,880 $ 52,416 Recordkeeping 135 113 112 360 3 5 1 0 0 0 0 6 15 $ 498 5,400 $ 179,316 Totals 135 113 112 360 267 $ 10,721 $ 750 $ 11,471 96,120 $ 4,129,668 OPTION 3 HIDE TABLE Flow Reduction Information Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Develop Narrative 23 13 16 52 8 16 0 0 0 0 0 0 24 $ 1,047 1,248 $ 54,454 Perform Engineering Calculations 23 13 16 52 4 12 0 0 0 0 0 0 16 $ 651 832 $ 33,862 Document Minimization of Make up and Blowdown 23 13 16 52 0 40 0 0 0 0 0 6 46 $ 1,385 2,392 $ 72,030 Submit Data and Analysis for Review 23 13 16 52 0 0 0 0 0 0 0 8 8 $ 146 416 $ 7,571 Recordkeeping 23 13 16 52 2 4 0 0 0 0 0 8 14 $ 407 728 $ 21,185 Totals 23 13 16 52 108 $ 3,637 $ 400 $ 4,037 5,616 $ 209,903 Exhibit A. 1d Proposal for Collection of Information for Comprehensive Demonstration Study Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Description of Historical Studies that will be Used 308 78 82 468 20 40 0 0 0 0 0 2 62 $ 2,654 29,016 $ 1,242,259 Description of Proposed and/ or Implemented Technologies 308 78 82 468 8 20 0 0 0 0 0 0 28 $ 1,175 13,104 $ 549,806 Develop Source Water Sampling Plan 308 78 82 468 40 60 8 8 0 0 0 4 120 $ 5,578 56,160 $ 2,610,504 Submit Data and Plans for Review 308 78 82 468 0 0 0 0 0 0 0 12 12 $ 218 5,616 $ 102,211 Revise Based on State Review 308 78 82 468 8 16 4 0 0 0 0 4 32 $ 1,232 14,976 $ 576,763 Recordkeeping 308 78 82 468 3 5 1 1 0 0 0 8 18 $ 620 8,424 $ 290,066 Totals 308 78 82 468 272 $ 11,478 $ 750 $ 12,228 127,296 $ 5,722,610 Assumed Loaded Hourly Rate Level of Effort ( hrs) Facilities ( Respondents)

A Facilities ( Respondents) ODCs lump sum* Total Cost Per Facility Assumed Loaded Hourly Rate Level of Effort ( hrs) Labor Cost per Facility Burden Per Facility Total Initial Cost Total Burden ( hrs.)

Total Burden ( hrs.)

A Burden Per Facility Labor Cost per Facility Total Cost Per Facility Total Initial Cost ODCs lump sum* Total Initial Cost Assumed Loaded Hourly Rate Facilities ( Respondents) Burden Per Facility Labor Cost per Facility ODCs lump sum*

A Level of Effort ( hrs) Total Cost Per Facility Total Burden ( hrs.)

January31, 2003 Exisiting Facility Rule Information Collection Request A. 1 2 Exhibit A. 1e Source Water Body Flow Information Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Gather Information to Characterize Flow ( FW River/ Stream) 64 47 63 174 0 32 0 0 0 0 0 0 32 $ 1,021 5,568 $ 177,619 Water Body Thermal Stratification Narrative ( Lake/ Reservoir) 28 23 17 68 4 40 0 0 0 0 0 0 44 $ 1,544 2,992 $ 105,019 Perform Engineering Calculations 92 70 80 242 8 32 0 0 0 0 0 0 40 $ 1,558 9,680 $ 376,939 Submit Data and Analysis for Review 92 70 80 242 0 0 0 0 0 0 0 16 16 $ 291 3,872 $ 70,470 Recordkeeping 92 70 80 242 1 3 0 0 0 0 0 8 12 $ 308 2,904 $ 74,633 Totals 92 70 80 242 103 $ 3,325 $ 200 $ 3,525 25,016 $ 853,081 Exhibit A. 1f Design and Construction Technology Plan Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Delineate Hydraulic Zone of Influence 112 100 96 308 2 5 8 0 0 0 0 0 15 $ 519 4,620 $ 159,698 Develop Narrative Description of Technologies ( Impingement) 112 100 96 308 8 16 0 0 0 0 0 0 24 $ 1,047 7,392 $ 322,538 Perform Engineering Calculations ( Impingement) 112 100 96 308 3 12 0 0 0 0 0 0 15 $ 584 4,620 $ 179,903 Develop Narrative Description of Technologies ( Entrainment) 54 55 46 155 8 16 0 0 0 0 0 0 24 $ 1,047 3,720 $ 162,316 Perform Engineering Calculations ( Entrainment) 54 55 46 155 3 12 0 0 0 0 0 0 15 $ 584 2,325 $ 90,536 Document that Technologies Are Optimal 112 100 96 308 0 40 0 0 0 0 0 6 46 $ 1,385 14,168 $ 426,642 Submit Data and Analysis for Review 112 100 96 308 0 0 0 0 0 0 0 6 6 $ 109 1,848 $ 33,634 Recordkeeping 112 100 96 308 1 4 0 0 0 0 0 6 11 $ 304 3,388 $ 93,601 Totals 112 100 96 308 137 $ 4,769 $ 400 $ 5,169 42,081 $ 1,592,066 Level of Effort ( hrs) Assumed Loaded Hourly Rate Level of Effort ( hrs)

Assumed Loaded Hourly Rate Facilities ( Respondents)

A A Burden Per Facility Facilities ( Respondents) Burden Per Facility Labor Cost per Facility Labor Cost per Facility Total Initial Cost Total Burden ( hrs.) Total Cost Per Facility ODCs lump sum*

Total Initial Cost ODCs lump sum* Total Cost Per Facility Total Burden ( hrs.)

January31, 2003 Exisiting Facility Rule Information Collection Request A. 1 3 Exhibit A. 1g Impingement Mortality & Entrainment Characterization Study Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Implement Offshore Freshwater Sampling 194 242 291 291 8 78 0 160 3120 100 3120 50 6636 $ 306,871 $ 7,800 1,606,516 $ 74,290,707 Impingement Monitoring Freshwater 194 242 291 291 4 24 0 80 1560 50 1560 25 3303 $ 152,957 799,627 $ 37,029,513 Entrainment Monitoring Freshwater 194 242 291 291 4 24 0 80 1170 50 1170 25 2523 $ 117,506 610,796 $ 28,447,145 Implement Offshore Marine Sampling 114 144 177 177 10 101 0 160 4056 100 4056 50 8533 $ 392,821 $ 13,000 1,236,048 $ 56,902,129 Impingement Monitoring Marine 114 144 177 177 4 31 0 80 2028 50 2028 25 4246 $ 195,722 615,054 $ 28,351,238 Entrainment Monitoring Marine 114 144 177 177 4 31 0 80 1521 50 1521 25 3232 $ 149,635 468,171 $ 21,675,407 Profile of Source Water Biota 308 78 82 468 32 20 0 32 60 0 20 8 172 $ 9,694 80,496 $ 4,536,979 Identification of Critical Species 308 78 82 468 32 20 0 20 40 0 0 3 115 $ 6,762 53,820 $ 3,164,522 Description of Additional Stresses 308 78 82 468 16 10 0 16 30 0 10 4 86 $ 4,847 40,248 $ 2,268,490 Write Study based on Results and Submit for Review by State 112 100 96 308 80 160 0 16 8 8 0 8 280 $ 12,880 86,240 $ 3,967,040 Recordkeeping 112 100 96 308 6 12 0 6 12 3 0 24 63 $ 2,569 19,404 $ 791,314 Finalize study based on State review 112 100 96 308 16 32 0 0 0 0 0 8 56 $ 2,240 17,248 $ 689,920 Totals 308 242 291 468 14,576 $ 677,159 $ 9,767 $ 686,925 5,633,667 $ 265,885,829 $ 21,303 $ 17,689 Exhibit A. 1h Pilot Study for New Impingement & Entrainment Technology Facility Manager Junior Technical CAD Operator Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Calculate Reduction in Impingement Mortality and Entrainment 54 44 37 135 80 80 8 0 0 0 0 12 180 $ 8,363 24,300 $ 1,129,032 Perform Engineering Estimates of Efficacy 54 44 37 135 40 32 0 0 0 0 0 4 76 $ 3,778 10,260 $ 509,976 Perform Impingement Monitoring ( Freshwater) 25 23 25 73 16 25 0 80 240 40 240 20 661 $ 33,147 48,253 $ 2,419,738 Perform Entrainment Monitoring ( Freshwater) 12 13 17 42 16 25 0 80 180 40 180 20 541 $ 27,693 22,722 $ 1,163,110 Perform Impingement Monitoring ( Marine) 29 21 12 62 16 33 0 80 312 52 312 26 831 $ 40,722 51,491 $ 2,524,761 Perform Entrainment Monitoring ( Marine) 25 17 11 53 16 33 0 80 234 52 234 26 675 $ 33,632 35,749 $ 1,782,483 Submit Data and Analysis for Review 54 44 37 135 8 10 0 8 6 4 0 16 52 $ 2,389 7,020 $ 322,515 Recordkeeping 54 44 37 135 4 8 0 4 8 2 0 20 46 $ 1,786 6,210 $ 241,056 Totals 54 44 37 135 1,526 $ 74,761 $ 1,000 $ 75,761 206,005 $ 10,227,671 Level of Effort ( hrs) Assumed Loaded Hourly Rate Assumed Loaded Hourly Rate Level of Effort ( hrs) A Facilities ( Respondents)

A Avg. Total Cost Per Facility over 3 yrs Total Burden ( hrs.) Total Initial Cost Facilities ( Respondents)

Burden Per Facility Labor Cost per Facility ODCs lump sum* Total Cost Per Facility Avg. Burden Per Facility over 3 yrs Avg. Labor Cost per Facility for 3 yrs lump sum ODCs for 3 yrs* Total Initial Cost ($) for ICR period Total Burden ( hrs.) for ICR period January31, 2003 Exisiting Facility Rule Information Collection Request A. 1 4 Exhibit A. 1i Information to Support Site Specific Determination of BTA Facility Junior CAD Contracted Biologist Statistician Biological Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Perform Comprehensive Cost Evaluation Study 54 55 46 155 20 60 0 0 0 0 0 0 80 $ 3,256 12,400 $ 504,680 Perform Valuation of Monetized Benefits 54 55 46 155 40 140 0 60 200 40 0 0 480 $ 25,620 74,400 $ 3,971,100 Evaluate Detailed Mortality Data 54 55 46 155 4 40 0 0 0 0 0 0 44 $ 1,544 6,820 $ 239,382 Perform Engineering Calculations 54 55 46 155 10 40 0 0 0 0 0 0 50 $ 1,947 7,750 $ 301,785 Submit Data and Analysis for Review 54 55 46 155 0 0 0 0 0 0 0 16 16 $ 291 2,480 $ 45,136 Recordkeeping 54 55 46 155 3 9 0 2 6 2 0 8 30 $ 1,251 4,650 $ 193,843 Totals 54 55 46 155 700 $ 33,909 $ 780 $ 34,689 108,500 $ 5,376,826 Exhibit A. 1j Site Specific Technology Plan Facility Junior CAD Contracted Biologist Statistician Biological Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Develop Narrative Description of Technologies 54 55 46 155 8 20 0 0 0 0 0 0 28 $ 1,175 4,340 $ 182,094 Document that Technologies Are Optimal 54 55 46 155 8 40 0 0 0 0 0 6 54 $ 1,922 8,370 $ 297,910 Develop Design Calculations, Drawings, & Estimates 54 55 46 155 8 20 0 0 0 0 0 0 28 $ 1,175 4,340 $ 182,094 Perform Engineering Calculations 54 55 46 155 16 40 0 4 8 0 0 0 68 $ 3,134 10,540 $ 485,770 Submit Data and Analysis for Review 54 55 46 155 0 0 0 0 0 0 0 6 6 $ 109 930 $ 16,926 Recordkeeping 54 55 46 155 2 4 0 1 1 0 0 6 14 $ 512 2,170 $ 79,314 Totals 54 55 46 155 198 $ 8,027 $ 370 $ 8,397 30,690 $ 1,301,458 Burden Per Facility Labor Cost per Facility ODCs lump sum* Total Cost Per Facility Assumed Loaded Hourly Rate Total Burden ( hrs.) Total Initial Cost Assumed Loaded Hourly Rate Level of Effort ( hrs) Level of Effort ( hrs)

Facilities ( Respondents)

A Facilities ( Respondents)

A Burden Per Facility Labor Cost per Facility ODCs lump sum* Total Burden ( hrs.) Total Cost Per Facility Total Initial Cost January31, 2003 Exisiting Facility Rule Information Collection Request A. 1 5 Exhibit A. 1k Verification Monitoring Plan Facility Junior CAD Contracted Biologist Statistician Biological Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 28 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D) Develop Verification Monitoring Plan 112 100 96 308 40 60 8 0 0 0 0 4 112 $ 4,896 34,496 $ 1,507,845 Submit Data and Plans for Review 112 100 96 308 0 0 0 0 0 0 0 2 2 $ 36 616 $ 11,211 Revise Based on State Review 112 100 96 308 2 4 1 0 0 0 0 1 8 $ 308 2,464 $ 94,895 Recordkeeping 112 100 96 308 1 1 1 1 0 0 0 2 6 $ 249 1,848 $ 76,630 Totals 112 100 96 308 128 $ 5,489 $ 400 $ 5,889 39,424 $ 1,813,781 Total Labor Burden, Labor Cost, and ODCs for All NPDES Application Activities Year 1 Year 2 Year 3 Total Totals 6,419,983 $ 301,430,314 Level of Effort ( hrs) Burden Per Facility Labor Cost per Facility ODCs lump sum* Total Burden ( hrs.) Total Initial Cost Assumed Loaded Hourly Rate Total Cost Per Facility Facilities ( Respondents) Facilities ( Respondents)

A Total Burden ( hrs.) Total Initial Cost January31, 2003 Exisiting Facility Rule Information Collection Request A. 1 6 Exhibit A. 1l Permitting Process Capital and O& M Costs Activity ODCs lump sum Cost ($) Purchase and Installation of Remote Monitoring Device 23 22 17 62 $ 50,000 $ 1,000 $ 3,162,000 Purchase, Installation & Operation of Pilot Study Technology Freshwater 12 13 17 42 $ 251,800 $ 10,575,600 Purchase, Installation & Operation of Pilot Study Technology Freshwater Impingement Only 13 10 8 31 $ 198,200 $ 6,144,200 Purchase, Installation & Operation of Pilot Study Technology Marine 25 17 11 53 $ 422,900 $ 22,413,700 Purchase, Installation & Operation of Pilot Study Technology Marine Impingement Only 4 4 1 9 $ 392,500 $ 3,532,500 Biological Study Laboratory Analysis ( Freshwater) 194 242 291 291 $ 28,353,000 Biological Study Laboratory Analysis ( Marine) 114 144 177 177 $ 22,054,500 Pilot Study Entrainment Laboratory Analysis ( Freshwater) 12 13 17 42 $ 252,000 Pilot Study Entrainment Laboratory Analysis ( Marine) 25 17 11 53 $ 413,400 $ 96,900,900 Total Burden and Costs for All NPDES Application Activities Totals 6,419,983 $ 398,331,214 * The ODC estimate was not estimated for each activity, but rather as a lump sum for each provision of the rule. Facilities ( Respondents)

Total Burden ( hrs.) Total Initial Cost $ 7,800 Activity Cost $ 6,000 $ 117,000 $ 152,100 January31, 2003 Exisiting Facility Rule Information Collection Request A. 1 7 Exhibit A. 2 Facility Cost and Burden Estimates for Annual Activities Exhibit A. 2a Biological Monitoring for Impingement ( Freshwater)

Facility Manager Junior Technical Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D)

Monthly Sample Collection 0 92 162 162 2 0 4 72 0 72 0 150 $ 7,020 38,100 $ 1,137,272 Onsite Analysis of Samples 0 92 162 162 4 0 12 72 0 72 0 160 $ 7,837 40,640 $ 1,269,562 Perform Statistical Analysis 0 92 162 162 8 4 0 0 32 0 0 44 $ 2,482 11,176 $ 402,084 Record Keeping 0 92 162 162 2 1 1 4 1 0 16 25 $ 821 6,350 $ 133,002 Totals 0 92 162 162 16 5 17 148 33 144 16 379 $ 18,160 $ 500 $ 18,660 96,266 $ 3,022,920 Exhibit A. 2b Biological Monitoring for Impingement ( Marine)

Facility Manager Junior Technical Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D)

Monthly Sample Collection 0 43 86 86 2 0 5 94 0 94 0 194 $ 9,086 25,078 $ 781,396 Onsite Analysis of Samples 0 43 86 86 4 0 16 94 0 94 0 207 $ 10,107 26,677 $ 869,230 Perform Statistical Analysis 0 43 86 86 8 4 0 0 42 0 0 54 $ 3,027 6,914 $ 260,346 Record Keeping 0 43 86 86 2 1 1 5 1 0 16 27 $ 930 3,457 $ 79,989 Totals 0 43 86 86 16 5 22 192 43 187 16 482 $ 23,151 $ 650 $ 23,801 62,126 $ 2,046,861 Exhibit A. 2c Biological Monitoring for Entrainment ( Freshwater)

Facility Manager Junior Technical Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D)

Biweekly Sample Collection 0 92 162 162 4 0 12 156 0 156 0 328 $ 15,472 83,312 $ 2,506,529 Handling and Preparation of Samples 0 92 162 162 4 0 12 78 0 78 0 172 $ 8,382 43,688 $ 1,357,916 Perform Statistical Analysis 0 92 162 162 16 4 0 0 64 0 0 84 $ 4,836 21,336 $ 783,497 Recordkeeping 0 92 162 162 2 1 1 8 2 0 16 30 $ 1,099 7,620 $ 178,103 Totals 0 92 162 162 26 5 25 242 66 234 16 614 $ 29,790 $ 500 $ 30,290 155,956 $ 4,907,045 Assumed Loaded Hourly Rate Level of Effort ( hrs)

Assumed Loaded Hourly Rate Level of Effort ( hrs) Burden ( hrs) Labor Cost ODCs lump sum* Total Costs Burden ( hrs.) Annual Cost Burden ( hrs.) Annual Cost Totals Per Facility for the ICR Approval Period Total for AllFacilities in the ICR Approval Period Total for AllFacilities in the ICR Approval Period Burden ( hrs) Labor Cost ODCs lump sum* Total Costs A Facilities ( Respondents)

A Facilities ( Respondents)

A Facilities ( Respondents) Totals Per Facility for the ICR Approval Period Total for AllFacilities in the ICR Approval Period Burden ( hrs.) ODCs lump sum* Total Costs Totals Per Facility for the ICR Approval Period Burden ( hrs) Annual Cost Assumed Loaded Hourly Rate Labor Cost Level of Effort ( hrs)

January 31, 003 Existing Facility Rule Information Collection Request A. 2 1 Exhibit A. 2d Biological Monitoring for Entrainment ( Marine)

Facility Manager Junior Technical Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D)

Biweekly Sample Collection 0 43 86 86 4 0 12 203 0 203 0 422 $ 19,745 54,438 $ 1,698,044 Handling and Preparation of Samples 0 43 86 86 4 0 12 101 0 101 0 218 $ 10,473 28,122 $ 900,669 Perform Statistical Analysis 0 43 86 86 16 4 0 0 83 0 0 103 $ 5,916 13,287 $ 508,742 Recordkeeping 0 43 86 86 2 1 1 10 3 0 16 33 $ 1,267 4,257 $ 108,962 Totals 0 43 86 86 26 5 25 314 86 304 16 776 $ 37,400 $ 650 $ 38,050 100,104 $ 3,272,317 Exhibit A. 2e Visual or Remote Inspections Facility Manager Junior Technical Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D)

Visually or Remotely Inspect All InstalledTechnologies 0 135 248 383 24 208 0 0 0 0 0 232 $ 8,246 88,856 $ 3,158,065 Recordkeeping 0 135 248 383 3 16 0 0 0 0 2 21 $ 748 8,043 $ 286,522 Totals 0 135 248 383 27 224 0 0 0 0 2 253 $ 8,994 $ 100 $ 9,094 96,899 $ 3,482,887 Exhibit A. 2f Yearly Status Report Activities Facility Manager Junior Technical Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D)

Report on Inspection and Maintenance 0 135 248 383 16 16 0 0 0 0 0 32 $ 1,584 12,256 $ 606,672 Detail Biological Monitoring Results 0 135 248 383 24 32 4 4 24 0 0 88 $ 4,557 33,704 $ 1,745,408 Compile and Submit Report 0 135 248 383 80 80 0 0 0 0 16 176 $ 8,211 67,408 $ 3,144,890 Recordkeeping 0 135 248 383 8 12 0 0 0 0 8 28 $ 1,065 10,724 $ 407,972 Totals 0 135 248 383 128 140 4 4 24 0 24 324 $ 15,418 $ 750 $ 16,168 124,092 $ 6,192,191 Annual Cost Facilities ( Respondents)

A Total for AllFacilities in the ICR Approval Period Totals Per Facility for the ICR Approval Period Burden ( hrs) Labor Cost ODCs lump sum* Annual Cost Total Costs Assumed Loaded Hourly Rate Level of Effort ( hrs) Burden ( hrs.) Annual Cost ODCs lump sum* Burden ( hrs) Labor Cost Total for AllFacilities in the ICR Approval Period Total for AllFacilities in the ICR Approval Period A Facilities ( Respondents) Assumed Loaded Hourly Rate Burden ( hrs)

Level of Effort ( hrs)

Totals Per Facility for the ICR Approval Period Labor Cost ODCs lump sum* Total Costs Facilities ( Respondents)

A Totals Per Facility for the ICR Approval Period Level of Effort ( hrs) Assumed Loaded Hourly Rate Burden ( hrs.) Burden ( hrs.)

Total Costs January 31, 003 Existing Facility Rule Information Collection Request A. 2 2 Exhibit A. 2g Verification Study Facility Manager Junior Technical Contracted Manager Biologist Statistician Biological Technician Clerical Year 1 Year 2 Year 3 Total $ 67 $ 32 $ 85 $ 55 $ 57 $ 36 $ 18 Activity B C D C+ D A* B A*( C+ D)

Perform Statistical Analysis 0 135 248 383 25 30 15 15 25 0 1 111 $ 6,183 42,513 $ 2,368,166 Submit Monitoring Results & Study Analysis 0 0 0 0 0 0 0 0 0 0 4 4 $ 73  $ 0 Record Keeping 0 135 248 383 1 2 0 0 0 0 4 7 $ 204 2,681 $ 78,017 Totals 0 135 248 383 26 32 15 15 25 0 9 122 $ 6,460 $ 500 $ 6,960 45,194 $ 2,637,683 Total Burden and Cost for All Annual Activities Year 1 Year 2 Year 3 Total Totals 680,637 $ 25,561,904 Exhibit A. 2h Facility Annual O& M Costs Activity ODCs lump sum* Cost ($)

Operation of Remote Monitoring Device 0 27 50 77 $ 50 $ 19,250 Identify & Enumerate Entrained Freshwater Biota 0 92 162 162 $ 500 $ 1,344,600 Identify & Enumerate Entrained Marine Biota 0 43 86 86 $ 500 $ 915,040 $ 1,050 $ 2,278,890 Total Cost for All NPDES Application Activities Total Cost ($) Totals $ 27,840,794 A Labor Cost ODCs lump sum* Total Costs Level of Effort ( hrs) Assumed Loaded Hourly Rate Totals Per Facility for the ICR Approval Period Facilities ( Respondents) Total for AllFacilities in the ICR Approval Period Burden ( hrs) Annual Cost Burden ( hrs.)

Total Annual Cost Total Burden ( hrs.)

$ 7,800 $ 10,140 Facilities ( Responses) Contracted Laboratory Analysis Cost Facilities ( Respondents)

Operation and Maintenance Costs $ 200 January 31, 003 Existing Facility Rule Information Collection Request A. 2 3 Exhibit A. 3 Director Burden and Cost Estimates for Activities Exhibit A. 3a Director Start up Activities Senior Technical Junior Technical Clerical $ 45 $ 29 $ 22 Activity A B C D C+ D A* B A*( C+ D) Read and Understand Rule 45 12 12 0 24 $ 877 1,080 $ 39,474 Mobilization/ Planning 45 24 16 0 40 $ 1,526 1,800 $ 68,652 Training 45 4 32 0 36 $ 1,093 1,620 $ 49,194 Totals 45 40 60 0 100 $ 3,496 $ 50 $ 3,546 4,500 $ 159,570 Exhibit A. 3b Director Permit Issuance Activities Senior Technical Junior Technical Clerical $ 45 $ 29 $ 22 Activity A B C D C+ D A* B A*( C+ D) Review Source Water Physical Data 360 2 6 0 8 $ 261 2,880 $ 93,816 Review CWIS Data 360 6 18 0 24 $ 782 8,640 $ 281,448 Review Source Water Baseline Biological Characterization Data 360 20 20 0 40 $ 1,462 14,400 $ 526,320 Review Proposal for Collection of Information for Comprehensive Demonstration Study 468 16 16 0 32 $ 1,170 14,976 $ 547,373 Review Source Water Body Flow Information 242 2 6 0 8 $ 261 1,936 $ 63,065 Review Design and Construction Technology Plan 308 24 8 0 32 $ 1,297 9,856 $ 399,414 Review Impingement Mortality & Entrainment Characterization Study 308 400 50 0 450 $ 19,230 138,600 $ 5,922,840 Review Pilot Study for New Impingement & Entrainment Technology 135 16 16 0 32 $ 1,170 4,320 $ 157,896 Review Restoration Measures 36 400 100 0 500 $ 20,660 18,000 $ 743,760 Review Information to Support Site Specific Determination of BTA 155 800 200 0 1,000 $ 41,320 155,000 $ 6,404,600 Determine Monitoring Frequency 360 2 6 0 8 $ 261 2,880 $ 93,816 Determine Record keeping and Reporting Frequency 360 2 6 0 8 $ 261 2,880 $ 93,816 Establish Requirements for Site Specific Technology 155 8 24 0 32 $ 1,042 4,960 $ 161,572 Considering Public Comments 360 16 16 0 32 $ 1,170 11,520 $ 421,056 Issuing Permit 360 1 6 1 8 $ 238 2,880 $ 85,680 Permit Record Keeping 360 1 1 2 4 $ 117 1,440 $ 42,084 Totals 468 1716 499 3 856 $ 34,368 $ 300 $ 34,668 395,168 $ 16,146,556 Directors ( Responses) Assumed Loaded Hourly Rate Level of Effort ( hrs) Burden Per Director Labor Cost per Director ODCs lump sum*

Total Burden ( hrs.) Total Initial Cost* Total Burden ( hrs.) Total Initial Cost Total Cost Per Director ODCs lump sum* Total Cost Per Permit Burden Per Permit Labor Cost per Permit Assumed Loaded Hourly Rate Level of Effort ( hrs) Directors ( Responses)

January 31, 2003 Existing Facility Rule Information Collection Request A. 3 1 Exhibit A. 3c Verification Study Review Senior Technical Junior Technical Clerical $ 45 $ 29 $ 22 Activity A B C D C+ D A* B A*( C+ D) Review of Verification Studies 0 2 4 0 6 $ 203 0 $ 0 Permit Modification Due to Unfavorable Results 0 4 10 0 14 $ 464 0 $ 0 Record Keeping 0 0 0 1 1 $ 22 0 $ 0 Totals 0 6 14 1 21 $ 689 $ 10 $ 699 0 $ 0 Exhibit A. 3d Alternative Regulatory Requirements Senior Technical Junior Technical Clerical $ 45 $ 29 $ 22 Activity A B C D C+ D A* B A*( C+ D) Document Alternative Regulatory Requirements 10 12 24 0 36 $ 1,220 360 $ 12,204 Document Environmental Conditions within Watershed 10 16 32 0 48 $ 1,627 480 $ 16,272 Include Supporting Historical Studies, Calculations, & Analyses 10 20 80 0 100 $ 3,178 1,000 $ 31,780 Submit Documentation 10 0 0 4 4 $ 88 40 $ 876 Record Keeping 10 1 2 1 4 $ 124 40 $ 1,236 Totals 10 49 138 5 192 $ 6,237 $ 100 $ 6,337 1,920 $ 63,368 Exhibit A. 3e Annual Director Activities Senior Technical Junior Technical Clerical $ 45 $ 29 $ 22 Activity A B C D C+ D A* B A*( C+ D) Review of Yearly Status Report 383 6 12 0 18 $ 610 6,894 $ 233,707 Compliance Tracking 383 4 12 0 16 $ 521 6,128 $ 199,620 Determination on Monitoring Frequency Reduction 383 4 8 0 12 $ 407 4,596 $ 155,804 Record Keeping 383 1 2 1 4 $ 124 1,532 $ 47,339 Totals 383 15 34 1 50 $ 1,662 $ 25 $ 1,687 19,150 $ 646,044 Total Burden ( hrs.) Total Annual Cost Burden Per Permit Labor Cost per Permit ODCs lump sum* Total Cost Per Permit Burden Per Permit Labor Cost per Permit Directors ( Responses) Assumed Loaded Hourly Rate Directors ( Responses) Assumed Loaded Hourly Rate Level of Effort ( hrs)

Directors ( Responses)

Level of Effort ( hrs) ODCs lump sum* Total Cost Per Permit Total Burden ( hrs.) Total Initial Cost Total Burden ( hrs.) Total Annual Cost Assumed Loaded Hourly Rate Level of Effort ( hrs) Burden Per Permit Labor Cost per Permit ODCs lump sum* Total Cost Per Permit January 31, 2003 Existing Facility Rule Information Collection Request A. 3 2 Total Burden and Cost for All Director Activities Totals 420,738 17,015,538 Total Burden ( hrs.) Total Initial Cost January 31, 2003 Existing Facility Rule Information Collection Request A. 3 3 Exhibit A. 4 Federal Burden and Cost Estimates for Activities Exhibit A. 4a Federal Permit Program Oversight Activities Senior Technical Junior Technical Clerical $ 45 $ 29 $ 22 Activity A B C D C+ D A* B A*( C+ D) Review Source Water Physical Data 360 1 3 0 4 $ 130 1,440 $ 46,908 Review CWIS Data 360 1 2 0 3 $ 102 1,080 $ 36,612 Review Source Water Baseline Biological Characterization Data 360 1 2 0 3 $ 102 1,080 $ 36,612 Review Proposal for Collection of Information for Comprehensive Demonstration Study 468 1 2 0 3 $ 102 1,404 $ 47,596 Review Source Water Body Flow Information 242 1 2 0 3 $ 102 726 $ 24,611 Review Design and Construction Technology Plan 308 1 3 0 4 $ 130 1,232 $ 40,132 Review Impingement Mortality & Entrainment Characterization Study 308 3 6 0 9 $ 305 2,772 $ 93,971 Review Pilot Study for New Impingement & Entrainment Technology 135 1 2 0 3 $ 102 405 $ 13,730 Review Restoration Measures 36 3 6 9 $ 305 324 $ 10,984 Review Information to Support Site Specific Determination of BTA 155 6 12 0 18 $ 610 2,790 $ 94,581 Review the Monitoring Frequency 360 1 2 0 3 $ 102 1,080 $ 36,612 Review Establish Requirements for Site Specific Technology 155 1 3 0 4 $ 130 620 $ 20,197 Permit Record Keeping 360 1 1 2 4 $ 117 1,440 $ 42,084 Totals 468 22 46 2 40 $ 1,331 $ 50 $ 1,381 16,393 $ 562,629 Level of Effort ( hrs) Total Burden ( hrs.) Total Initial Cost * ODCs lump sum* Total Cost per Permit Review Federal ( Responses) Burden per permit Review Labor Cost per Permit Review Assumed Loaded Hourly Rate January 31, 2003 Existing Facility Rule Information Collection Request A. 4 1 Exhibit A. 5 Respondents for the ICR Approval Period Year by Year by Activity Facilities Year 1 Year 2 Year 3 Sep. 2004  Aug. 2005 Sep. 2005  Aug. 2006 Sep. 2006  Aug. 2007 Annual Average Start up Activities 331 91 98 173 Permit Application Activities 135 113 112 120 Source Water Baseline Biological Characterization Data 135 113 112 120 Proposal for Collection of Information for Comprehensive Demonstration Study 308 78 82 156 FW River/ Stream Source Water Body Flow Information 64 47 63 58 FW Lake/ Reservoir Source Water Body Flow Information 28 23 17 23 Design and Construction Technology Plan ( Impingement Only) 58 45 50 51 Design and Construction Technology Plan ( Impingement & Entrainment) 54 55 46 52 Freshwater Monitoring for Impingement Mortality & Entrainment Characterization Study 194 242 291 242 Marine Monitoring for Impingement Mortality & Entrainment Characterization Study 114 144 177 145 Impingement Mortality & Entrainment Characterization Study Initial Analysis 308 78 82 156 Impingement Mortality & Entrainment Characterization Study Final Report 112 100 96 103 Pilot Study Impingement Monitoring Only ( Freshwater) 13 10 8 10 Pilot Study Impingement & Entrainment Monitoring ( Freshwater) 12 13 17 14 Pilot Study Impingement Monitoring Only ( Marine) 4 4 1 3 Pilot Study Impingement & Entrainment Monitoring ( Marine) 25 17 11 18 Information to Support Site Specific Determination of BTA 54 55 46 52 Site Specific Technology Plan 54 55 46 52 Verification Monitoring Plan 112 100 96 103 Biological Monitoring for Impingement ( Freshwater) 0 92 162 85 Biological Monitoring for Impingement ( Marine) 0 43 86 43 Biological Monitoring for Entrainment ( Freshwater) 0 92 162 85 Biological Monitoring for Entrainment ( Marine) 0 43 86 43 Visual or Remote Inspections 0 135 248 128 Yearly Status Report Activities 0 135 248 128 Verification Study 0 135 248 128 Respondents 331 278 343 317 January 31, 2003 Existing Facility Rule Information Collection Request A5. 1 Directors Year 1 Year 2 Year 3 Sep. 2004  Aug. 2005 Sep. 2005  Aug. 2006 Sep. 2006  Aug. 2007 Annual Average Director Start up Activities 45 0 0 15 Director Permit Issuance Activities Review Permit Application Information 135 113 112 120 Review Proposal for Collection of Information for Comprehensive Demonstration Study 308 78 82 156 Review Source Water Body Flow Information 92 70 80 81 Review Design and Construction Technology Plan 112 100 96 103 Review Impingement Mortality & Entrainment Characterization Study 112 100 96 103 Review Pilot Study for New Impingement & Entrainment Technology 54 44 37 45 Review Restoration Measures 14 11 11 12 Review Information to Support Site Specific Determination of BTA 54 55 46 52 Determine Monitoring Frequency 135 113 112 120 Determine Permit Requirements and Issue Permit 135 113 112 120 Verification Study Review 0 0 0 0 Alternative Regulatory Requirements 10 0 0 3 Annual Director Activities Review of Yearly Status Report 0 135 248 128 Compliance Tracking 0 135 248 128 Determination on Monitoring Frequency Reduction 0 135 248 128 Record Keeping 0 135 248 128 Respondents 45 35 39 40 Sum for Facilities and Directors Year 1 Year 2 Year 3 Sep. 2004  Aug. 2005 Sep. 2005  Aug. 2006 Sep. 2006  Aug. 2007 Annual Average Facilities 331 278 343 317 Directors 45 35 39 40 Yearly Total 376 313 382 357 [ 1] Each facility is one respondent. One respondent may be involved in more than one activity; however, in order to avoid double counting, the maximum number of respondents expected to be involved in the rule activities annually is assumed to be the number of respondents for that year. [ 2] Each Director is one respondent.