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­
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2002
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­
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­
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SC10084
Memorandum
To:
Lynne
Tudor,
U.
S.
EPA
From:
Elizabeth
Strange,
Bob
Raucher,
Dave
Cacela,
Adrienne
Grêt­
Regamey,
Dave
Mills,
Marca
Hagenstad,
and
Tom
Ottem,
Stratus
Consulting
Inc.

Date:
12/
2/
02
Subject:
Analytical
and
Clerical
Errors
in
the
§
316(
b)
Phase
II
Case
Study
Document,
Preamble,
and
Economic
and
Benefits
Analysis
1.
Introduction
This
memorandum
provides
a
list
of
errors
identified
by
Stratus
Consulting
in
the
April
2002
Case
Study
Document,
Economic
and
Benefits
Analysis
(
EBA),
and
Preamble
for
the
proposed
§
316(
b)
Phase
II
rule.
Where
appropriate,
we
indicate
the
likely
magnitude
of
the
effect
of
the
error
on
impingement
and
entrainment
(
I&
E)
estimates
and
the
benefits
results.

Section
2
presents
Case
Study
errors
and
Section
3
presents
Preamble
and
EBA
errors.
These
sections
distinguish
analytical
and
clerical
errors.
Analytical
errors
are
errors
in
the
calculation
of
I&
E
metrics
or
benefits
estimates.
Clerical
errors
result
from
document
production.
Such
errors
do
not
effect
results,
although
they
may
cause
confusion
for
readers.

2.
Case
Study
Document
2.1
Analytical
Errors
2.1.1
Calculation
of
Production
Foregone
The
model
used
to
estimate
production
foregone
was
incorrectly
executed
for
certain
cases.
The
error
was
systematic,
but
affected
the
results
differently
from
case
to
case,
and
species
to
species,
depending
on
peculiarities
of
individual
I&
E
records
for
particular
species
in
particular
years.
Specifically,
the
algorithm
used
to
calculate
production
foregone
performed
correctly
for
cases
where
loss
records
for
sequential
sets
of
fish
life
stages
were
present,
but
gave
incorrect
results
if
certain
life
stages
were
absent
from
the
loss
records.
We
corrected
the
algorithm
and
recalculated
benefits
using
corrected
estimates
of
production
foregone.
The
revised
values,
presented
in
Table
1,
do
not
differ
from
the
original
values
in
most
cases,
but
large
differences
appear
for
Seabrook
(
Part
F),
Monroe
(
Part
I),
and
several
Ohio
River
facilities
(
Part
C).
Stratus
Consulting
Memorandum
Page
2
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2002
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SC10084
Table
1.
Comparison
of
total
economic
damages
at
all
case
study
facilities
before
and
after
changes
in
foregone
production
calculations.

Facility
Total
(
previous)
Total
(
revised)
Change
in
economic
impacts
of
I&
E
%
change
Lowa
Average
Higha
Low
Average
High
Low
Average
High
Low
Average
High
Salem
$
13,115,976$
20,103,728
$
27,091,480
$
13,081,878
$
20,086,679
$
27,091,480
­$
4,098
­$
17,049
$
0
0%
0%
0%

Brayton
$
169,907
$
239,082
$
308,257
$
166,855
$
237,556
$
308,257
­$
3,052
­$
1,526
$
0
­
2%
­
1%
0%

Seabrook
$
142,542
$
228,338
$
314,134
$
138,557
$
158,374
$
178,191
­$
3,985
­$
69,964
­$
135,943
­
3%
­
31%
­
43%

Pilgrim
$
516,413
$
632,817
$
749,221
$
494,527
$
620,731
$
746,934
­$
21,886
­$
12,087
­$
2,287
­
4%
­
2%
0%

Bigbend
$
7,040,178
$
7,221,184
$
7,402,190
$
7,040,178
$
7,221,184
$
7,402,190
$
0
$
0
$
0
0%
0%
0%

Contra
Costa
$
844,716
$
1,077,918
$
1,311,119
$
844,716
$
1,077,918
$
1,311,119
$
0
$
0
$
0
0%
0%
0%

Pittsburg
$
2,056,045
$
2,623,657
$
3,191,268
$
2,056,045
$
2,623,657
$
3,191,268
$
0
$
0
$
0
0%
0%
0%

J.
R.
Whitingb
$
270,726
$
392,611
$
514,496
$
270,600
$
392,548
$
514,496
­$
126
­$
63
$
0
0%
0%
0%

Monroe
$
800,839
$
2,004,857
$
3,208,875
$
785,801
$
1,215,344
$
1,644,886
­$
15,037
­$
789,513
­$
1,563,989
­
2%
­
39%
­
49%

Beckjord
$
43,059
$
168,202
$
293,345
$
28,648
$
57,038
$
85,427
­$
14,411
­$
111,164
­$
207,917
­
33%
­
66%
­
71%

Cardinal
$
7,161
$
27,091
$
47,021
$
7,483
$
27,252
$
47,021
$
322
$
161
$
0
4%
1%
0%

Clifty
Creek
$
75,876
$
222,185
$
368,494
$
20,504
$
194,499
$
368,494
­$
55,371
­$
27,686
$
0
­
73%
­
12%
0%

Kammer
$
17,853
$
34,580
$
51,307
$
3,104
$
27,205
$
51,307
­$
14,750
­$
7,375
$
0
­
83%
­
21%
0%

Kyger
$
99,898
$
211,325
$
322,753
$
93,224
$
207,989
$
322,753
­$
6,673
­$
3,337
$
0
­
7%
­
2%
0%

Miami
Fort
$
96,085
$
191,604
$
287,123
$
25,769
$
73,414
$
121,059
­$
70,316
­$
118,190
­$
166,064
­
73%
­
62%
­
58%

P.
Sporn
$
50,974
$
67,504
$
84,035
$
14,250
$
45,474
$
76,698
­$
36,724
­$
22,030
­$
7,336
­
72%
­
33%
­
9%

Tanners
$
12,819
$
32,032
$
51,245
$
12,409
$
31,827
$
51,245
­$
410
­$
205
$
0
­
3%
­
1%
0%

WH
Sammis
$
7,765
$
40,640
$
73,514
$
8,778
$
41,146
$
73,514
$
1,013
$
507
$
0
13%
1%
0%

a.
Low
and
high
economic
values
as
reported
in
Chapter
4
of
each
case
study
in
the
Case
Study
Documents
(
e.
g.,
Table
H4­
14;
Table
I4­
13).

b.
I&
E
data
from
1977
through
1978:
before
installation
of
the
impingement
deterrent
net.
Stratus
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2.1.2
Part
B:
Delaware
Chapter
B3
 
Salem
Baselines
The
I&
E
rates
presented
in
Table
B3­
22
of
Chapter
B3
of
the
Delaware
case
study
(
Part
B
of
the
Case
Study
Document)
are
for
the
Salem
extrapolation
baseline,
not
the
baseline
under
current
conditions
as
intended.
The
difference
between
these
two
baselines
is
explained
in
Section
B3­
3.4
of
Chapter
B3.
As
a
result,
the
I&
E
rates
reported
in
Table
B3­
22
for
Salem
and
the
regional
total
differ
slightly
from
the
intended
values.
The
effect
of
this
error
was
carried
over
to
Page
B3­
41
of
Chapter
B3,
and
Figures
B6­
1
through
B6­
3
of
Chapter
B7.
The
corrected
version
of
Table
B3­
22,
including
proper
values
for
the
Salem
facility
and
the
regional
total,
is
provided
in
Table
2.

Table
2.
Corrected
version
of
Table
B3­
22
in
Chapter
B3
of
Part
B
of
the
Case
Study
Document.
Number
of
age
1
equivalents
Fishery
yield
(
lb)
Production
foregone
(
lb)

Salem
339,404,878
8,943,422
32,834,248
Hope
Creek
12,220,152
322,005
1,453,133
DuPont
1,379,695
36,355
164,063
Edgemoor
154,131,600
4,061,415
18,328,226
Delaware
City
Refinery
71,744,121
1,890,479
8,531,297
Deepwater
(
without
Chamber
Cogen)
20,616,580
543,253
2,451,576
Chambers
Cogen
7,292,672
192,164
867,192
Gen
Chem
Corporation
6,681,664
176,064
794,536
Spi
Polyols
985,496
25,968
117,188
Sun
Refining
1,182,595
31,162
140,626
Logan
Generating
Co
394,198
10,387
46,875
Hay
Road
315,359
8,310
37,500
Total
616,349,009
16,240,984
65,766,461
2.1.3
Part
C:
Ohio
River
Chapter
C3
 
Section
C3­
9
 
Ohio
River
Poolwise
Extrapolations
The
extrapolation
of
the
primary
I&
E
metrics
(
age
1
equivalents,
foregone
fishery
yield,
and
production
foregone)
from
the
Ohio
River
case
study
facilities
to
other
in­
scope
facilities
was
conducted
on
a
poolwise
basis.
The
extrapolated
I&
E
rates
and
associated
economic
values
for
Markland
Pool
and
Robert
C.
Byrd
Pool
are
incorrect
because
of
an
error
in
computing
the
extrapolation
scalars
for
those
pools;
these
two
pools
included
more
than
one
model
facility,
and
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the
extrapolation
was
incorrectly
based
on
the
average
flow
rate
among
the
model
facilities
rather
than
the
total
flow
rates.
The
reported
values
are
lower
than
the
correct
values
for
these
two
pools.
Specifically,
the
correct
values
of
aggregate
losses
in
Markland
Pool
are
87%
greater
than
the
reported
values,
and
correct
values
of
aggregate
losses
in
Robert
C.
Byrd
Pool
are
78%
greater
than
the
reported
values.
The
extrapolations
in
other
Ohio
River
pools
were
correct
as
originally
reported.

2.1.4
Part
D:
Tampa
Chapter
D4
 
Table
D4­
5,
and
Corresponding
Values
in
Tables
D4­
8,
Table
D4­
9,
and
Comments
on
Page
D4­
7
The
percentage
of
total
pinfish
harvest
in
the
commercial
fishery
sector
used
in
the
calculations
was
30
percent.
However,
the
correct
percentage
is
3
percent.
Therefore,
the
correct
estimate
of
foregone
commercial
catch
of
pinfish
in
Table
D4­
5
is
13.1
lb
(
rather
than
131
lb)
and
the
corresponding
loss
in
commercial
value
is
$
41.80
(
rather
than
$
418).
The
summary
Tables
D4­
8
and
D4­
9,
and
the
comments
on
Page
D4­
7,
require
corresponding
adjustments.

2.1.5
Part
F:
Brayton
Point
Chapter
F5
 
Section
F5­
7.2.2,
F5­
7.2.3
and
Table
F5­
39
Section
F5­
7.2.2
develops
an
annualized
cost
for
monitoring
in
tidal
wetlands
where
the
equipment
cost
is
incorrectly
treated
as
a
recurring
annual
expense
and
the
daily
cost
for
the
labor
component
of
the
monitoring
is
incorrectly
used
instead
of
the
expected
annual
cost
involving
5
days
of
labor.

The
original
paragraph
in
F5­
7.2.2
states:

The
sampling
protocol
suggests
that
one
technician
and
two
volunteers
can
provide
the
necessary
labor.
The
estimated
annual
cost
in
the
first
year
of
monitoring
is
$
1,600.
This
cost
comprises
$
490
in
labor
for
the
three
workers
over
5
days
(
3
in
August
and
2
in
the
spring,
with
8­
hour
days,
$
15
per
hour
for
volunteers,
and
$
30
per
hour
for
the
technician).
The
$
1,100
in
equipment
costs
includes
two
fyke
nets
at
$
500
each
and
two
throw
traps
at
$
50
each
(
Neckles
and
Dionne,
1999).
The
annualized
equivalent
of
these
monitoring
costs
is
$
1,146
and
is
applied
as
a
per­
acre
cost
for
monitoring
in
this
HRC
valuation.

Instead,
the
correct
paragraph
in
F5­
7.2.2
should
read:

The
sampling
protocol
suggests
that
one
technician
and
two
volunteers
can
provide
the
necessary
labor.
The
estimated
annual
cost
in
the
first
year
of
monitoring
is
$
2,500.
This
cost
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comprises
$
490
in
daily
labor
costs
for
the
three
workers
over
5
days
(
3
in
August
and
2
in
the
spring,
with
8­
hour
days,
$
15
per
hour
for
volunteers,
and
$
30
per
hour
for
the
technician).
The
$
1,100
in
equipment
costs
includes
two
fyke
nets
at
$
500
each
and
two
throw
traps
at
$
50
each
(
Neckles
and
Dionne,
1999).
The
annualized
equivalent
of
these
monitoring
costs,
treating
the
equipment
costs
as
a
one­
time
expense
in
year
one
and
the
labor
costs
as
a
recurring
expense
over
the
10
year
monitoring
period,
is
$
1,847
and
is
applied
as
a
per­
acre
cost
for
monitoring
in
this
HRC
valuation.

The
original
paragraph
in
F5­
7.2.3
states:

Combining
the
annualized
per­
acre
implementation
and
monitoring
costs
for
tidal
wetland
restoration
results
in
an
annualized
per­
acre
cost
for
tidal
wetland
restoration
of
$
7,904.
This
is
equivalent
to
an
annualized
cost
for
tidal
wetland
restoration
of
$
1.95
per
m2
of
restored
tidal
wetland
(
4,047
m2
=
1
acre)
which
is
incorporated
into
this
HRC
for
consistency
with
the
estimates
of
increased
fish
production
from
tidal
wetland
restoration
which
are
also
expressed
on
a
per
m2
basis.

Instead,
the
correct
paragraph
in
F5­
7.2.3
should
read:

Combining
the
annualized
per­
acre
implementation
and
monitoring
costs
for
tidal
wetland
restoration
results
in
an
annualized
per­
acre
cost
for
tidal
wetland
restoration
of
$
8,606.
This
is
equivalent
to
an
annualized
cost
for
tidal
wetland
restoration
of
$
2.13
per
m2
of
restored
tidal
wetland
(
4,047
m2
=
1
acre)
which
is
incorporated
into
this
HRC
for
consistency
with
the
estimates
of
increased
fish
production
from
tidal
wetland
restoration
which
are
also
expressed
on
a
per
m2
basis.

The
effect
of
incorporating
these
changes
is
an
increase
in
the
total
annualized
HRC
estimate
by
$
1,746,620
in
Table
F5­
39
where
the
combined
I&
E
loss
is
addressed.
This
additional
cost
represents
6.2%
of
the
preferred
existing
best
estimate
of
$
28,206,491
presented
in
this
table.

2.1.6
Part
G:
Seabrook
and
Pilgrim
Chapters
G4,
G6
and
G7
New
Hampshire
and
Massachusetts
recreational
fishery
values
were
treated
in
aggregate,
and
the
average
economic
value
of
recreational
fishery
losses
from
the
consumer
surplus
literature
for
New
Hampshire
and
Massachusetts
was
presented.
However,
values
for
New
Hampshire
and
Massachusetts
should
have
been
used
separately
to
account
for
geographic
differences.
Changes
in
these
values
would
only
slightly
affect
the
results
presented
in
Chapters
G4,
G6,
and
G7,
especially
Tables
G4­
7
through
G4­
10,
Table
G4­
23,
Table
G4­
24,
Figures
G6­
1
through
G6­
6,
Table
G6­
1,
and
Table
G6­
2.
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Chapter
G5
 
Section
G5­
7.2.2
Section
G5­
7.2.2
develops
an
annualized
cost
for
monitoring
in
tidal
wetlands
where
the
equipment
cost
is
incorrectly
treated
as
a
recurring
annual
expense
and
the
daily
cost
for
the
labor
component
of
the
monitoring
is
incorrectly
used
instead
of
the
expected
annual
cost
involving
5
days
of
labor.

The
original
paragraph
in
G5­
7.2.2
states:

The
sampling
protocol
suggests
that
one
technician
and
two
volunteers
can
provide
the
necessary
labor.
The
estimated
annual
cost
in
the
first
year
of
monitoring
is
$
1,600.
This
cost
comprises
$
490
in
labor
for
the
three
workers
over
5
days
(
3
in
August
and
2
in
the
spring,
with
8­
hour
days,
$
15
per
hour
for
volunteers,
and
$
30
per
hour
for
the
technician).
The
$
1,100
in
equipment
costs
includes
two
fyke
nets
at
$
500
each
and
two
throw
traps
at
$
50
each
(
Neckles
and
Dionne,
1999).
The
annualized
equivalent
of
these
monitoring
costs
is
$
1,146
and
is
applied
as
a
per­
acre
cost
for
monitoring
in
this
HRC
valuation.

Instead,
the
correct
paragraph
in
G5­
7.2.2
should
read:

The
sampling
protocol
suggests
that
one
technician
and
two
volunteers
can
provide
the
necessary
labor.
The
estimated
annual
cost
in
the
first
year
of
monitoring
is
$
2,500.
This
cost
comprises
$
490
in
daily
labor
costs
for
the
three
workers
over
5
days
(
3
in
August
and
2
in
the
spring,
with
8­
hour
days,
$
15
per
hour
for
volunteers,
and
$
30
per
hour
for
the
technician).
The
$
1,100
in
equipment
costs
includes
two
fyke
nets
at
$
500
each
and
two
throw
traps
at
$
50
each
(
Neckles
and
Dionne,
1999).
The
annualized
equivalent
of
these
monitoring
costs,
treating
the
equipment
costs
as
a
one­
time
expense
in
year
one
and
the
labor
costs
as
a
recurring
expense
over
the
10
year
monitoring
period,
is
$
1,847
and
is
applied
as
a
per­
acre
cost
for
monitoring
in
this
HRC
valuation.

The
original
paragraph
in
G5­
7.2.3
states:

Combining
the
annualized
per­
acre
implementation
and
monitoring
costs
for
tidal
wetland
restoration
results
in
an
annualized
per­
acre
cost
for
tidal
wetland
restoration
of
$
7,904.
This
is
equivalent
to
an
annualized
cost
for
tidal
wetland
restoration
of
$
1.95
per
m2
of
restored
tidal
wetland
(
4,047
m2
=
1
acre)
which
is
incorporated
into
this
HRC
for
consistency
with
the
estimates
of
increased
fish
production
from
tidal
wetland
restoration
which
are
also
expressed
on
a
per
m2
basis.
Stratus
Consulting
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Page
7
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­
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2002
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Instead,
the
correct
paragraph
in
G5­
7.2.3
should
read:

Combining
the
annualized
per­
acre
implementation
and
monitoring
costs
for
tidal
wetland
restoration
results
in
an
annualized
per­
acre
cost
for
tidal
wetland
restoration
of
$
8,606.
This
is
equivalent
to
an
annualized
cost
for
tidal
wetland
restoration
of
$
2.13
per
m2
of
restored
tidal
wetland
(
4,047
m2
=
1
acre)
which
is
incorporated
into
this
HRC
for
consistency
with
the
estimates
of
increased
fish
production
from
tidal
wetland
restoration
which
are
also
expressed
on
a
per
m2
basis.

The
combined
impact
of
these
changes
it
to
increase
the
annualized
per­
unit
cost
per
m2of
monitoring
for
tidal
wetlands
by
$
0.17.
This
would
increase
the
estimated
cost
for
compensating
for
combined
I&
E
losses
at
Pilgrim
by
$
413,068
(
4.5%
of
the
existing
total
of
$
9,233,362).

2.2
Clerical
Errors
2.2.1
Rounding
of
I&
E
Rates
In
certain
tables
presented
in
the
third
chapter
of
each
case
study
report
("
Evaluation
of
I&
E
Data"),
age
1
equivalents,
foregone
yield,
and
production
foregone
were
reported
as
zero,
while
in
other
chapters
the
corresponding
economic
values
were
reported
as
greater
than
zero.
This
apparent
discrepancy
occurs
because
I&
E
results
were
rounded
to
the
nearest
integer
in
the
I&
E
tables,
and
therefore
values
<
0.5
were
not
reported.
However,
the
actual
values
were
used
in
the
benefits
calculations,
and
therefore
corresponding
economic
values
are
greater
than
zero.

2.2.2
Part
A
of
the
Case
Study
Document
The
statement
"
stage­
specific
natural
mortality
rates
for
>
10
stages
per
species"
is
not
applicable
to
all
species
because
some
species
have
fewer
than
10
life
stages.
The
number
of
modeled
life
stages
varied
by
species
depending
on
species
life
history
characteristics.

There
is
a
typographical
error
in
Equation
7
of
Chapter
A5
of
Part
A
of
the
Case
Study
Document.
The
correct
equation
is:
Stratus
Consulting
Memorandum
Page
8
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­
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2002
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or
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(
)
Y
LSWFZ
e
k
a
j
jk
ja
a
a
a
Za
=
 
 
 
 
(
)
1
where:

Y
k
=
foregone
yield
(
pounds)
due
to
I&
E
losses
in
year
k
L
jk
=
losses
of
individual
fish
of
stage
j
in
the
year
k
S
ja
=
cumulative
survival
fraction
from
stage
j
to
age
a
W
a
=
average
weight
(
pounds)
of
fish
at
age
a
F
a
=
instantaneous
annual
fishing
mortality
rate
for
fish
of
age
a
Z
a
=
instantaneous
annual
total
mortality
rate
for
fish
of
age
a
(
Equation
7)

2.2.3
Part
B
of
the
Case
Study
Document
Chapter
B3
Table
B3­
1
Silversides
and
blue
crab
are
species
designated
as
Representative
Important
Species
(
RIS)
by
PSE&
G.
Therefore,
they
should
be
in
bold
font.

Table
B3­
3
and
Table
B3­
12
The
footnotes
on
Table
B3­
3
and
Table
B3­
12
are
misleading.
Impinged
fish
were
assumed
to
be
age
1
only
in
cases
when
impinged
fish
were
age
>
1
or
when
ages
were
unknown.
In
cases
where
impinged
fish
were
known
to
be
younger
than
age
1,
their
known
ages
were
used
in
determining
the
loss
metrics,
so
the
effect
described
in
the
footnote
may
not
be
apparent.

Page
B3­
27,
Third
Last
paragraph
"
Tables
B37..."
should
read
"
Tables
B3­
7..."

Appendix
B1
Throughout
Appendix
B1,
the
table
captions
indicating
"...
1978­
1998"
should
read
"...
1977­
1998".

Chapter
B4
Stratus
Consulting
Memorandum
Page
9
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­
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2002
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­
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or
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The
values
for
pounds
of
foregone
recreational
yield
reported
in
Tables
B4­
2
and
B4­
3
are
incorrect.
Correct
values
are
provided
in
Tables
3
and
4.

Table
3.
Correction
for
Table
B4­
2.

Species
Corrected
recreational
yield
(
lbs)
Alewife
0
American
shad
53
Atlantic
croaker
4,720
Blue
crab
598
Spot
382
Striped
bass
8,040
Weakfish
13,613
White
perch
31
Non­
RIS
fishery
species
5,013
Total
32,450
Table
4.
Correction
for
Table
B4­
3.

Species
Corrected
recreational
yield
(
lbs)
Alewife
0
American
shad
10
Atlantic
croaker
334,986
Atlantic
menhaden
0
Silversides
0
Spot
480,776
Striped
bass
564,789
Weakfish
296,243
White
perch
224
Non­
RIS
fishery
species
322,383
Total
1,999,412
Stratus
Consulting
Memorandum
Page
10
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­
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2002
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2.2.4
Part
C
of
the
Case
Study
Document
Chapter
C3
Table
C3­
2
Table
C3­
2
indicates
that
impingement
sampling
at
Clifty
Creek
was
conducted
only
in
1977.
In
fact,
impingement
sampling
was
conducted
in
1977
and
in
1985­
1986
(
EA
Science
and
Technology,
1987).
This
error
was
carried
over
to
Page
C3­
21,
last
paragraph
of
section
C3­
4
and
the
last
paragraph
of
Page
C7­
1;
the
text
indicating
"
for
only
a
single
year
of
sampling"
should
read
"
for
only
a
single
year
of
sampling,
except
at
Clifty
Creek,
where
impingement
sampling
was
conducted
in
two
years."

Table
C3­
9
Some
of
the
column
labels
in
Table
C3­
9
are
misplaced.
The
correct
labeling
for
Table
C3­
9
is
provided
in
Table
5.
The
effect
of
this
clerical
error
is
limited
to
the
presentation
in
this
particular
table;
no
subsequent
reporting
errors
result
from
this
error.

Table
5.
Corrections
to
original
labeling
of
Table
C3­
9.
Original
label
Correct
label
longear
sunfish
logperch
minnow
sp.
longear
sunfish
paddlefish
muskellunge
perch
sp.
paddlefish
sauger
river
carpsucker
skipjack
herring
sauger
smallmouth
bass
skipjack
herring
striped
bass
smallmouth
bass
sucker
spp.
striped
bass
sunfish
sp.
sucker
sp.

walleye
sunfish
sp.

white
bass
walleye
yellow
perch
white
bass
Stratus
Consulting
Memorandum
Page
11
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­
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2002
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or
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The
data
for
yellow
perch
were
omitted
from
the
Table
C3­
9.
The
correct
values
for
rows
1­
10
of
Table
C3­
9
representing
yellow
perch
are
0,
1,
0,
0,
1,
0,
0,
0,
3,
1.

Pages
C3­
38
through
C3­
51,
Tables
C3­
14
through
C3­
15
and
C3­
17
through
C3­
32
The
pool
designation
"
Newburgh
Pool"
should
be
"
New
Cumberland
Pool."

Chapter
C7
Page
C7­
1,
Third
Last
Paragraph
This
paragraph
states:
"....
$
1.7
million
to
$
2.3
million
per
year
for
a
50%
impingement
reduction
and
$
7.3
million
to
$
7.8
million
per
year
for
a
10%
reduction...."
Instead,
it
should
read:
"....
$
1.7
million
to
$
2.3
million
per
year
for
a
50%
impingement
reduction
and
$
9.0
million
to
$
9.7
million
per
year
for
a
10%
reduction..."

2.2.5
Part
D
of
the
Case
Study
Document
Chapter
D3
Page
D3­
25,
Paragraph
5
The
sentence
states:
Differences
were
less
than
26
million
age
1
equivalents
per
year
except
for
bay
anchovy.
Instead
it
should
read:
Differences
were
less
than
33
million
age
1
equivalents
per
year
except
for
bay
anchovy
Chapter
D4
Tables
D4­
5
and
D4­
6
The
third
column
label
should
be
"
Commercial
Value/
lb"
(
instead
of
"
Commercial
Value/
Fish").

Chapter
D7
Stratus
Consulting
Memorandum
Page
12
Internal
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­
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December
2002
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­
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­
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Cite
or
Distribute
SC10084
Header
says
"
Chapter
F7"
and
should
be
"
Chapter
D7."

2.2.6
Part
E
of
the
Case
Study
Document
Chapter
E5
Tables
E5­
4
and
E5­
5
The
captions
of
these
tables
are
incomplete.
They
should
indicate
that
the
reported
losses
are
expressed
as
age
1
equivalents.

Chapter
E6
The
I&
E
losses
stated
in
Box
4
were
switched.
It
should
read:
"
I:
27,200
(
11,600
lb)
$
474,000
E:
185,100
(
79,000
lb)
$
3.2
million"
The
I&
E
losses
stated
in
Box
5
were
switched
as
well.
It
should
read:
"
I:
145,000
$
27
million
E:
269,300
$
50
million"

2.2.7
Part
F
of
the
Case
Study
Document
Chapter
F6
Figure
F6­
3
Numbers
of
age
1
equivalents
should
be
3.8
million
per
year
for
entrainment.

Figure
F6­
4
Numbers
of
age
1
equivalents
should
be
69,300
per
year
for
impingement.
Stratus
Consulting
Memorandum
Page
13
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­
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2002
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2.2.8
Part
G
of
the
Case
Study
Document
Chapter
G5
Table
G5­
1
Table
G5­
1
reports
the
number
of
blue
mussel
age
1
equivalents
as
15.
The
correct
value
is
150.

Chapter
G6
Figure
G6­
4
Figure
G6­
4
indicates
HRC
loss
values
of
$
840,000/
year
associated
with
impingement,
but
the
correct
value
is
$
0.5
million/
year.
Figure
G6­
4
indicates
HRC
loss
values
of
$
12.3
million/
year
associated
with
entrainment,
but
the
correct
value
is
$
9.1
million/
year.

Page
G6­
5
Box
8
should
read
I:
$
0.5
million,
E:
$
9.1
million.

Chapter
G7
Page
G7­
1
The
text
on
line
7
should
read
"...
and
over
$
9.1"
(
instead
of
"$
19.1").

2.2.9
Part
I
of
the
Case
Study
Document
Chapter
I4
The
values
for
pounds
of
foregone
recreational
yield
reported
in
Tables
I4­
2
through
I4­
3
are
incorrect.
Correct
values
are
provided
in
Tables
6
and
7.

Table
6.
Correction
for
Table
I4­
2.

Species
Corrected
recreational
yield
(
lbs)
Bluegill
0
Stratus
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Page
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Bullhead
spp.
0
Carp
0
Channel
catfish
14
Crappie
7
Freshwater
drum
0
Gizzard
shad
0
Muskellunge
0
Smallmouth
bass
6
Smelt
22
Suckers
0
Sunfish
2
Walleye
334
White
bass
25,235
Yellow
perch
282
Commercial
and
recreational
species
total
25,901
Table
7.
Correction
for
Table
I4­
3.

Species
Corrected
recreational
yield
(
lbs)
Burbot
103
Carp
0
Channel
catfish
322
Crappie
195
Freshwater
drum
0
Gizzard
shad
0
Smallmouth
bass
1,972
Smelt
383
Suckers
0
Stratus
Consulting
Memorandum
Page
15
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Sunfish
113
Walleye
247
White
bass
29,423
Whitefish
37
Yellow
perch
605
Commercial
and
recreational
species
total
33,399
3.
Preamble
and
EBA
3.1
Analytical
Errors
3.1.1
Benefits
of
Option
6
were
not
reported
in
the
Preamble
The
EBA
reports
benefits
of
a
sixth
option
(
Option
6)
that
was
added
to
the
national
benefits
analysis
after
the
Preamble
was
completed.
The
expected
reductions
in
I&
E
and
the
economic
benefits
of
Option
6
are
reported
in
Chapter
C4
of
the
EBA
but
not
in
the
Preamble.

3.1.2
Preamble,
Section
VI.
Best
Technology
Available
for
Minimizing
Adverse
Environmental
Impact
at
Phase
II
Existing
Facilities
The
benefits
estimates
for
the
dry
cooling
option
(
called
Option
5
in
the
benefits
analysis)
have
been
updated.

The
statement
"
annual
benefits
of
$
138.2
million
for
impingement
reductions
and
$
1.33
billion
for
entrainment
reductions."
should
read
"
annual
benefits
of
$
143.9
million
for
impingement
reductions
and
$
1.39
billion
for
entrainment
reductions."

3.1.3
Concurrence
between
scaling
of
national
costs
and
benefits
In
the
Preamble,
the
number
of
facilities
represented
in
the
national
benefits
estimates
is
fewer
than
the
number
of
facilities
represented
in
the
national
cost
estimates.
This
discrepancy
does
not
appear
in
the
EBA.
Stratus
Consulting
Memorandum
Page
16
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­
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2002
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The
Preamble
uses
statistical
weighting
factors
to
extrapolate
costs
and
benefits
at
model
facilities
to
the
national
scale.
The
national
cost
estimates
reported
in
the
Preamble
are
correctly
scaled
to
represent
all
550
in­
scope
facilities.
However,
the
national
benefit
estimates
reported
in
the
Preamble
(
Exhibits
25­
34)
were
incorrectly
scaled
to
represent
only
539
in­
scope
facilities.
Therefore,
the
Preamble
reports
expected
total
baseline
losses
and
benefits
that
are
slightly
less
than
the
correct
total.
In
contrast
to
the
Preamble,
the
summary
of
costs
and
benefits
presented
in
the
EBA
is
consistently
scaled
to
represent
550
facilities.

3.1.4
Omission
of
Seabrook
from
national
extrapolation
In
the
Preamble,
the
case
study
results
from
the
Seabrook
facility
were
incorrectly
omitted
from
the
totals
reported
in
Exhibits
25­
34.
The
extrapolation
for
Oceans
reports
the
total
of
benefits
among
all
in­
scope
facilities
except
Seabrook.
This
results
in
a
minor
inaccuracy
in
the
baseline
loss
and
benefits
estimates
for
oceans
and
for
the
total
of
all
in­
scope
facilities.
In
contrast
to
the
Preamble,
the
analysis
reported
in
the
EBA
(
Chapters
C3
and
C4
and
Appendix
C1)
includes
the
Seabrook
results.

3.1.5
Estimated
percent
reductions
under
the
regulatory
options
Stratus
Consulting
still
has
some
uncertainty
about
the
exact
definitions
of
the
various
regulatory
options
and
their
effects
on
I&
E
loss
rates.
Thus,
the
options
as
defined
for
the
costs
may
not
be
the
same
as
the
options
defined
for
the
benefits.
Clarification
of
this
issue
is
needed
to
determine
if
there
is
an
inconsistency
that
requires
a
re­
analysis.

3.2
Clerical
Errors
3.2.1
EBA,
Chapter
C2
­
Table
C2­
1
Table
C2­
1
in
Chapter
C2
of
the
EBA
reports
incorrect
values
for
impingement
and
associated
dollar
values
because
of
a
clerical
error.
The
correct
version
of
Table
C2­
1
is
provided
as
Table
8.

Table
8.
Corrected
version
of
Table
C2­
1
of
Chapter
C2
of
the
EBA.
Impingement
Entrainment
Four
in­
scope
facilities
Age
1
equivalent
fish
lost
>
7.5
million/
yr
>
526.3
million/
yr
#
lbs
lost
to
landed
fishery
>
268,800
lb/
yr
>
13.8
million
lb/
yr
Stratus
Consulting
Memorandum
Table
8.
Corrected
version
of
Table
C2­
1
of
Chapter
C2
of
the
EBA.
Impingement
Entrainment
Page
17
Internal
Draft
­
2
December
2002
Draft
­
Deliberative,
Predecisional
­
Do
Not
Quote,
Cite
or
Distribute
SC10084
$
value
of
loss
(
2001$)
$
0.50
million
­
$
0.8
million/
yr
$
16.8
million
­
$
30.5
million/
yr
3.2.2
EBA,
Chapter
C2
­
Section
C2­
2,
page
C2­
3
second
paragraph
The
sentence
states:
"
EPA
estimates
that
more
than
450
million
age
1
bay
anchovy
.
.
.
(
over
85
percent
of
the
total
of
over
526
million...)"
Instead
it
should
read:
"
EPA
estimates
that
more
than
500
million
age
1
bay
anchovy
.
.
.
(
over
75
percent
of
the
total
of
over
633
million...)"

3.2.3
EBA,
Chapter
C4
­
Table
C4­
3
and
C4­
4
The
information
for
Option
6
in
Table
C4­
3
is
incorrect.
The
percent
reductions
for
Option
6
should
be
presented,
not
the
dollar
values.
The
correct
column
is:

Option
6
Estuary
 
Non­
Gulf
78.3%

Estuary
 
Gulf
78.3%

Freshwater
9.8%

Great
Lake
57.8%

Ocean
72.8%

3.2.4
Preamble,
Summary
of
Benefits
Findings
Due
to
clerical
error,
several
of
the
exhibits
in
Part
E,
Summary
of
Benefits
Findings:
Case
Studies,
contain
incorrect
data.
The
correct
values
are
reported
in
the
EBA,
Chapter
C2.

Errors
in
Exhibits
13­
22
are
summarized
and
the
corrected
data
are
included
in
the
following
tables.
Stratus
Consulting
Memorandum
Page
18
Internal
Draft
­
2
December
2002
Draft
­
Deliberative,
Predecisional
­
Do
Not
Quote,
Cite
or
Distribute
SC10084
Exhibit
13
Preamble
data
were
not
updated
to
reflect
most
current
estimates.

Table
9.
Corrected
Exhibit
13:
Baseline
impacts
(
annual
average)
at
four
in
scope
facilities
in
transition
zone
of
the
Delaware
Estuary.
Impingement
Entrainment
Four
in­
scope
facilities
Age
1
equivalent
fish
lost
>
12.2
million/
yr
>
526.3
million/
yr
#
lbs
lost
to
landed
fishery
>
374,000
lb/
yr
>
13.8
million
lb/
yr
$
value
of
loss
(
2001$)
$
0.50
million
­
$
0.8
million/
yr
$
16.8
million
­
$
30.5
million/
yr
Exhibit
14
Preamble
estimates
of
"#
lbs
lost
to
landed
fishery"
were
not
updated
to
reflect
most
current
estimates.

Table
10.
Corrected
Exhibit
14:
Baseline
impacts
(
annual
average)
in
the
Ohio
River
at
in­
scope
facilities.
Impingement
Entrainment
29
in­
scope
facilities
Age
1
equivalent
fish
lost
>
11.3
million/
yr
>
23.0
million/
yr
#
lbs
lost
to
landed
fishery
>
14,900
lb/
yr
>
39,000
lb/
yr
$
value
of
loss
(
2001$)
$
3.5
million
­
$
4.7
million/
yr
$
9.3
million
­
$
9.9
million/
yr
Exhibit
15
Preamble
estimates
of
"
Age
1
equivalent
fish
lost"
and
"
Number
of
striped
bass
lost
to
recreational
catch"
were
not
updated
to
reflect
most
current
estimates.
Stratus
Consulting
Memorandum
Page
19
Internal
Draft
­
2
December
2002
Draft
­
Deliberative,
Predecisional
­
Do
Not
Quote,
Cite
or
Distribute
SC10084
Table
11.
Corrected
Exhibit
15:
Baseline
impacts
(
annual
average)
for
special
status
fish
species
at
two
facilities
in
the
San
Francisco
Bay/
Delta
Impingement
Entrainment
Two
in­
scope
facilities
Age
1
equivalent
fish
lost
>
431,700/
yr
>
2.2
million/
yr
Number
of
striped
bass
lost
to
recreational
catch
27,203
185,073
$
value
of
combined
loss
(
2001$)
$
12.8
million
­
$
43.2
million/
yr
$
25.6
million
­
$
83.2
million/
yr
Exhibit
16
Preamble
estimates
of
"
Age
1
equivalent
fish
lost"
and
"#
lbs
lost
to
landed
fishery"
were
entered
incorrectly
and
were
not
updated
to
reflect
most
current
estimates.

Table
12.
Corrected
Exhibit
16:
Baseline
impacts
(
annual
average)
for
J.
R.
Whiting
without
net.
Impingement
Entrainment
One
Great
Lakes
facility
Age
1
equivalent
fish
lost
>
21.4
million/
yr
>
1.8
million/
yr
#
lbs
lost
to
landed
fishery
>
844,300
lb/
yr
>
70,000lb/
yr
$
value
of
loss
(
2001$)
$
0.4
million
­
$
1.2
million/
yr
$
42,000
­
$
1.7
million/
yr
Exhibit
17
Preamble
table
title
and
estimates
of
"
Age
1
equivalent
fish
lost"
and
"#
lbs
lost
to
landed
fishery"
were
entered
incorrectly
and
were
not
updated
to
reflect
most
current
estimates.

Table
13.
Corrected
Exhibit
17:
Baseline
impacts
(
annual
average)
for
J.
R.
Whiting
with
net.
Impingement
Entrainment
One
Great
Lakes
facility
Age
1
equivalent
fish
lost
>
1.6
million/
yr
NA
#
lbs
lost
to
landed
fishery
>
62,700
lb/
yr
NA
$
value
of
loss
(
2001$)
$
29,000
­
$
99,000/
yr
NA
Exhibit
18
Stratus
Consulting
Memorandum
Page
20
Internal
Draft
­
2
December
2002
Draft
­
Deliberative,
Predecisional
­
Do
Not
Quote,
Cite
or
Distribute
SC10084
Data
reported
in
Preamble
is
correct.

Exhibit
19
Data
reported
in
Preamble
is
correct.

Exhibit
20
Preamble
data
was
reported
for
the
wrong
case
study.

Table
14.
Corrected
Exhibit
20:
Baseline
impacts
(
annual
average)
for
Seabrook.
Impingement
Entrainment
One
in­
scope
facility:
Seabrook
Age
1
equivalent
fish
lost
>
13,000/
yr
>
4.5
million/
yr
#
lbs
lost
to
landed
fishery
>
1,800
lb/
yr
>
29,300
lb/
yr
$
value
of
loss
(
2001$)
$
3,000
­
$
5,000/
yr
$
142,000
­
$
315,000/
yr
Exhibit
21
Preamble
data
was
reported
for
the
wrong
case
study.

Table
15.
Baseline
impacts
(
annual
average)
for
Pilgrim.
Impingement
Entrainment
One
in­
scope
facility:
Pilgrim
losses
using
benefits
transfer
Age
1
equivalent
fish
lost
>
52,700
million/
yr
>
214.3
million/
yr
#
lbs
lost
to
landed
fishery
>
4,200
lb/
yr
>
91,000
lb/
yr
$
value
of
loss
(
2001$)
$
3,000
­
$
5,000/
yr
$
0.5
million
­
$
0.7
million/
yr
Pilgrim
losses
using
HRC
as
upper
bounds
and
benefits
transfer
midpoints
as
lower
Age
1
equivalent
fish
lost
>
52,700/
yr
>
14.3
million/
yr
#
lbs
lost
to
landed
fishery
>
4,200
lb/
yr
>
91,000
lb/
yr
$
value
of
loss
(
2001$)
$
4,000
­
$
507,000/
yr
$
0.6
million
­
$
9.3
million/
yr
Exhibit
21
Stratus
Consulting
Memorandum
Page
21
Internal
Draft
­
2
December
2002
Draft
­
Deliberative,
Predecisional
­
Do
Not
Quote,
Cite
or
Distribute
SC10084
Preamble
data
was
reported
for
the
wrong
case
study.

Table
16.
Baseline
losses
at
(
annual
average)
Monroe
(
using
HRC).
Impingement
Entrainment
One
in­
scope
facility
Age
1
equivalent
fish
lost
>
35.8
million/
yr
>
11.6
million/
yr
#
lbs
lost
to
landed
fishery
>
1.4
million
lb/
yr
>
608,300
lb/
yr
$
value
of
loss
(
2001$)
$
0.7
million
­
$
5.6
million/
yr
$
1.3
million
­
$
13.9
million/
yr
