HD12 - Estimated Costs and Personnel Requirements for Administering MTBE Laboratory Tests for Public Water Supply Operators


Executive Summary:
The Department of General Services (DGS), Division of Consolidated Laboratory Services (DCLS) performs scientific analyses for the health, environmental, and consumer protection programs of state and local governments, and local water authorities. DCLS also maintains a laboratory certification program for laboratories under the Federal Safe Drinking Water Act.

§ 15.2-2144, part B, of the Code of Virginia (COV) requires every Public Water Supply (PWS) operator to test the public water supply for the presence of methyl tertiary-butyl ether (MTSE) at least quarterly and to maintain a record of all testing conducted pursuant to this subsection of the code (Attachment A). If the results of any test conducted pursuant to this subsection indicate the presence of MTBE in excess of fifteen parts per billion, the locality shall immediately notify the Department of Environmental Quality and the Department of Health. The Division of Consolidated Laboratory Services will maintain and make available, upon the request of any person, a list of laboratories located throughout the Commonwealth that possess the technical expertise to analyze water samples for the presence of MTSE. These laboratories shall be accredited laboratories under the provisions of the federal Safe Drinking Water Act (42 U.S.C. § 300f et seq.) to analyze water samples for the presence of MTBE. A listing of accredited laboratories as of November 1, 2000 can be found in Attachment C. Any lab seeking accreditation under the Safe Drinking Water Act may contact the Division of Consolidated Laboratory Services. The Division of Consolidated Laboratory Services is also directed to establish a fee system to offset the costs of tests performed on behalf of public water supply operators. Further, DCLS is required to report to the Governor and the General Assembly no later than November 1, 2000, on the estimated costs and personnel requirements for performing the MBTE tests on behalf of public water supply operators.

As stated in part A, § 15.2·2144 of the COV, the purpose of the inspection of public and private water supplies by the localities is to prevent the pollution of such water supplies and to prevent the transmission or distribution of water when it is found to be polluted, adulterated, impure or dangerous. MBTE is regarded as such a pollutant when found to exist in excess of fifteen parts per billion.

The analysis of MTBE is performed using EPA Method 524.2.This method specifies both the instrumentation and preparations necessary to determine the amount of MTBE in water. The method requires analysts skilled in the operation of highly sophisticated instrumentation and interpretation of the data. Strict adherence to quality control criteria must be met prior to and during analysis. The average time to analyze, interpret and report data is approximately 1.4 hours per sample.

For purposes of this report, workload projections are based upon data retained in the Virginia Department of Health's database of Public Water Supply (PWS) systems. These data include 1,352 Community systems, 1,904 Non-Community systems, and 646 Non-Transient/Non-Community systems. These 3,902 PWS systems include about 100 systems with multiple sampling sites. For purposes of this cost analysis, a 4.500·sample load per Quarter is estimated, which included these multiple distribution sites.

Attachment B provides a detailed cost package for MTBE analysis to support this report. The cost will vary with workload and the number of systems that commit to using DCLS to provide this service. Variables considered in this analysis include the following:

1. DCLS Manpower: Current staffing will only support testing 80 samples per quarter. Increased staffing of up to 11.0 FTEs will be needed to support the proposed increases in MTBE testing.

2. Instrumentation: DCLS can analyze for 546 samples per quarter using existing instrumentation and assumes instrumentation downtime of approximately two weeks per quarter. Additional instrumentation will need to be purchased and installed to meet the proposed increases in MTBE testing.

3. Maintenance & Repair: Based upon historical experience this cost is estimated as 12% of the instrument cost.

4. Supply & Materials: Costs are estimated from previous work experience.

5. Minor Equipment: Large volume refrigerators will be required for preserving samples until analysis. Additional data entry stations (computers) will be necessary for efficient workflow tracking and reporting. As the workload increases so does the need for additional refrigerators and data entry stations.

6. Renovation: As the workload increases so does the need for additional space to accommodate the additional staff and equipment. To achieve full testing capacity, an estimate of 1600 square feet of space will need renovation. The cost for this renovation is estimated as $150,000.

7. Facilities: Full cost recovery for MTBE analysis includes rent at $18 a square foot.

8. Indirect Cost: Based on experience this cost is 30% of direct costs.

9. Treasury Loans: To purchase instrumentation and perform renovation it will be necessary to obtain Treasury Loans.