This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

1
Originally
prepared
July
25,
2002.
Revised
July
31
to
incorporate
response
to
"
Additional
Tufts
question
#
3"
(
see
page
12
below).

Page
1
of
23
Response
to
Riverkeeper
Questions
Regarding
Phase
II
Proposal
Record
Revised
July
31,
20021
SEABY
QUESTIONS
1.
I
am
looking
at
the
impingement
data
used
in
the
example
of
316b
and
I
have
a
problem.
I
have
been
trying
to
calculate
the
figures
given
in
Table
B4­
2.
I
have
gone
back
to
the
source
Tables
B3­
2
and
B3­
3
and
the
Salem
input
Excel
sheet.
I
can
get
the
annual
impingement
data
to
tally
in
Table
B3­
2
by
use
of
the
adding
the
age
1,
and
Juvenile
1
and
2
fish
from
the
Excel
sheet.
I
then
try
to
move
on
to
get
the
age
1
equivalents
in
Table
B3­
3.
For
each
year
I
calculate
the
Year
1
equivalent
of
the
life
stage
of
interest.

For
example
take
1978
for
weakfish
Action
Juv
1
Juv
2
Age
1
Total
From
Tab.
6,378,530
11,260
1,466
6,391,256
I
cannot
get
from
these
values
to
the
total
age
1
equivalents
of
237,865.
Accepting
that
as
correct
I
cannot
get
from
the
mean
age
1
equivalent
of
65,182
to
the
value
given
in
the
Table
B4­
2
of
55,856.
I
have
tried
following
your
model
in
Section
A5­
3
but
I
cannot
get
it
to
work.
Could
I
have
a
spreadsheet
showing
the
calculations
of
a
single
species
such
as
the
weakfish
from
raw
data
to
the
year
1
equivalents?
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
2
of
23
EPA
Answer
An
elaboration
of
the
calculation
of
age
1
equivalents
is
provided
for
the
reviewer's
convenience
in
Tables
1­
4
below.
Table
1
reports
the
life
history
parameters
that
EPA
used
for
modeling
weakfish
at
Salem.
These
values
are
included
in
the
workbook
"
salem.
input.
data.
xls"
(
DCN
4­
2051).
Table
1
also
shows
the
associated
survival
rates
that
EPA
derived
from
the
basic
life
history
parameters
using
methods
described
in
Chapter
A5
of
Part
A
of
the
Case
Study
Document
(
DCN
4­
0003).
Table
2
provides
further
elaboration
of
the
values
presented
in
Table
1,
and
gives
an
explicit
elaboration
of
how
stage­
specific
survival
rates
are
combined
to
give
effective
stage­
specific
survival
rates
from
the
age
of
entrainment
until
age
1.
Table
3
reports
the
stage­
specific
1978
impingement
losses
of
weakfish,
which
are
included
in
the
workbook
"
salem.
input.
data.
xls"
(
DCN
4­
2051).
Table
4
associates
the
values
in
Table
2
and
Table
3
to
provide
a
stage­
specific
accounting
of
age
1
equivalent
losses
and
indicates
where
the
values
so
derived
were
reported
in
the
Salem
case
study
(
Part
B
of
the
Case
Study
Document).
Table
B3­
3
of
the
Case
Study
Document
(
DCN
4­
0003)
reports
the
mean
annual
number
of
weakfish
age
1
equivalents
as
65,182,
which
summarizes
weakfish
losses
during
1978­
1998.
Table
B4­
2
reports
the
mean
annual
number
of
weakfish
age
1
equivalents
as
55,856,
which
summarizes
losses
that
occurred
during
1995,
1997,
and
a
1998
(
as
presented
in
Table
B3­
18).
The
latter
time
period
was
selected
to
represent
the
current
baseline
losses
at
Salem
for
reasons
described
in
Section
B3­
7
of
Chapter
B3.

Table
1.
Stage­
specific
weakfish
life
history
parameters
(
M,
F,
fraction
vulnerable
to
fishery)
used
to
derive
stage­
specific
weakfish
survival
rates
(
Sj)
at
Salem.
Life
history
parameter
Life
stage
(
j)
M
F
Fraction
of
life
stage
(
j)
vulnerable
to
fishery
F
adj
1
Z
=
M+
F
adj
S
j
=
e­
Z
S*
j
2
Egg
1.043
0.00
0.00
0.00000
1.0430
0.3524
0.5211
Yolk­
sac
larvae
1.341
0.00
0.00
0.00000
1.3410
0.2616
0.4147
Post
yolk­
sac
larvae
6.3325
0.00
0.00
0.00000
6.3325
0.0018
0.0035
Juvenile
stage
1
2.439875
0.00
0.00
0.00000
2.4399
0.0872
0.1604
Juvenile
stage
2
1.483788
0.00
0.00
0.00000
1.4838
0.2268
0.3697
Age
1
0.348575
0.25
0.10
0.02237
0.3709
0.6901
0.8166
1.
F
adj
represents
fishing
mortality
rate
(
F)
adjusted
for
fraction
of
age
class
vulnerable
to
fishery.
2.
S*
j
represents
the
stage­
specific
survival
rate
(
S
j)
adjusted
to
account
for
the
fact
that
the
precise
within­
stage
age
of
entrained
fish
is
unknown.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
3
of
23
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
4
of
23
Table
2.
Elaboration
of
Equation
4
of
Section
A5­
3.1
of
the
Case
Study
Document:
Example
derivation
of
Sj,
1,
the
stage
specific
cumulative
survival
rate
(
as
a
fraction)
from
stage
at
entrainment
(
j)
to
age
1
for
weakfish
entrained
at
Salem;
the
definition
of
Sj,
1
includes
accommodation
for
unknown
within­
stage
age
at
entrainment.

Life
stage
(
j)
Egg
Yolk­
sac
larvae
Post
yolksac
larvae
Juvenile
1
Juvenile
2
Age
1
S
j,
1
Egg
0.52114
0.26158
0.00178
0.08717
0.22678
0.69008
0.0000048
Yolk­
sac
larvae
0.41469
0.00178
0.08717
0.22678
0.69008
0.0000146
Post
yolk­
sac
larvae
0.00355
0.08717
0.22678
0.69008
0.0000702
Juvenile
stage1
0.16036
0.22678
0.69008
0.0363669
Juvenile
stage2
0.36971
0.69008
0.3697119
Age
1
0.81663
1.1833738
1.
S*
j
represents
the
stage­
specific
survival
rate
(
S
j)
adjusted
to
account
for
the
fact
that
the
precise
within­
stage
age
of
entrained
fish
is
unknown.
2.
1.18
=
(
0.81663/
0.6901)
=
effective
inflation
factor
applicable
to
fish
>=
age
1
to
offset
effects
of
S*
j
[
see
Section
A5­
3.1
of
Chapter
A5
of
the
Case
Study
Document
(
DCN
4­
0003)
for
further
explanation].
Table
3.
Weakfish
impingement
losses
at
Salem
NGS
in
1978
[
detail
from
salem.
input.
data.
xls
(
DCN
4­
2051)].

Life
stage
(
j)
Impingement
losses
Egg
0
Yolk­
sac
larvae
0
Post
yolk­
sac
larvae
0
Juvenile
stage
1
6,378,530
Juvenile
stage
2
11,260
Age
1
1,466
Total
6,391,256
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
5
of
23
Table
4.
Elaboration
of
calculations
to
express
1978
weakfish
losses
to
impingement
at
Salem
as
age
1
equivalents.

Life
stage
(
j)
Number
of
fish
impinged
S
j,
1
Age
1
equivalent
losses
Egg
0
0.00000479
0.0
Yolk­
sac
larvae
0
0.0000146
0.0
Post
yolk­
sac
larvae
0
0.0000702
0.0
Juvenile
stage
1
6,378,530
0.0364
231,967.6
Juvenile
stage
2
11,260
0.370
4,163.0
Age
1
1,466
1.183
1,734.8
Total
6,391,256
237,865.3
matches
Table
B3­
2
of
Case
Study
Document
(
DCN
4­
0003)
matches
Table
B3­
3
of
Case
Study
Document
(
DCN
4­
0003)

2.
At
Salem,
how
is
the
silverside
age
1
equivalent
calculated
for
entrainment?
I
do
not
seem
to
be
able
to
get
this
figure.
I
get
4,886,300,
which
is
some
way
off
the
EPA
figure
in
Table
B4­
3
of
107,867.

EPA
Answer
Age
1
equivalent
losses
of
silversides
were
calculated
using
the
same
general
procedure
that
is
elaborated
for
age
1
equivalent
losses
of
weakfish
in
the
response
to
Question
#
1,
and
described
in
Chapter
A5
of
Part
A
of
the
Case
Study
Document
(
DCN
4­
0003).

3.
In
Table
B4­
3,
how
is
the
total
catch
number
of
the
same
table
obtained?
Is
it
possible
to
calculate
this
figure
from
the
information
given
in
the
documents?
For
example,
for
spot
C
where
they
are
completely
in
the
fishery
at
age
1,
why
is
the
number
lost
to
the
fishery
so
much
less
than
the
age
1
equivalent
value?

EPA
Answer
The
metric
"
Total
Catch
(#)"
presented
in
Table
B4­
3
of
Chapter
B4
of
Part
B
of
the
Case
Study
Document
(
DCN
4­
0003)
is
derived
from
"
Total
Catch
(
lb)"
by
the
relationship:

N
s,
k
=
Y
s,
k
/
E
s,
Equation
1
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
6
of
23
where:

N
s,
k
=
Total
Catch
(#)
=
Foregone
yield
expressed
as
numbers
of
landed
fish
for
species
s
in
year
k
Y
s,
k
=
Total
Catch
(
lb)
=
Foregone
yield
expressed
as
pounds
of
landed
fish
for
species
s
in
year
k
E
s
=
Average
weight
of
landed
fish
(
lbs/
individual)
for
species
s.

The
values
of
E
s
are
not
reported
explicitly
in
the
case
study
reports.
However,
they
are
provided
implicitly
by
the
simple
relationship
described
in
Equation
1,
above.
Values
of
E
s
were
defined
as
the
expected
weight
of
a
landed
fish
of
species
s,
i.
e.,
as
the
average
weight­
at­
age
of
all
age
classes
statistically
weighted
by
the
relative
contribution
of
each
age
class
to
the
overall
age
composition
of
harvested
fish.
In
the
case
of
spot,
E
s
equals
0.41
lbs/
individual.
The
values
N
s,
k
were
not
used
in
the
benefits
analysis
except
for
valuation
of
foregone
recreational
catch.

An
age
1
equivalent
fish
represents
a
living
age
1
fish.
It
is
calculated
under
the
assumption
of
zero
(
or
negligible)
harvest
prior
to
age
1.
The
number
lost
to
the
fishery
is
considerably
less
than
the
number
of
age
1
equivalents
because
most
harvested
fish
are
older
than
age
1
(
and
therefore
fewer
because
of
ongoing
natural
mortality),
and
because
the
fishery
typically
does
not
capture
every
fish
that
survives
to
harvestable
age.

4.
Is
there
any
information
on
the
age
structure
of
impinged
fish
at
any
of
the
case
study
stations?
I
know
that
the
fish
are
measured
at
Salem
but
the
data
does
not
seem
to
be
in
the
documents.

EPA
Answer
The
available
information
about
the
age
composition
of
impinged
fish
varies
between
case
studies
because
of
differences
in
study
design
and
reporting
habits
among
the
facilities.
In
most
cases,
detailed
information
about
age
composition
was
not
available.
EPA
assumed
that
impinged
fish
were
age
1
fish
unless
ages
of
fish
less
than
1
were
reported,
in
which
case
age
classes
younger
than
age
1
were
enumerated
as
reported
in
facility
documents.
All
of
the
available
information
about
age
composition
is
provided
in
the
input
data
files
that
are
available
in
the
docket
(
see
DCN
4­
2051).
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
7
of
23
FOLLOW­
ON
QUESTIONS
 
3
JUL
02
1.
National
benefits
appear
to
be
a
linear
function
of
case
study
benefits,
with
some
facilities
representing
only
themselves
and
some
used
as
the
basis
for
estimating
benefits
at
other
plants.
Thus
it
appears
that
EPA's
estimate
could
be
expressed
as
National
impingement
losses
=
A
*
Salem
+
B
*
Tampa
+
C
*
Ohio­
29
+
D
*
Whiting
+
E
*
Pilgrim
+
F
*
Brayton
Point
+
G
*
Contra
Costa
+
H
*
Pittsburg
+
I
*
Monroe
+
J
*
Seabrook
A
similar
equation
applies
to
entrainment
losses,
perhaps
with
different
coefficients.

Please
supply
the
values
of
coefficients
A
through
J,
suitable
for
reproducing
the
EBA
estimates
of
impingement
and
entrainment
losses
a)
at
the
539
facilities
that
answered
the
survey,
and
b)
at
all
550
in­
scope
facilities.

EPA
Answer
As
suggested
in
the
question,
national
benefits
are
calculated
as
a
linear
function
of
the
case
study
benefits.
However,
EPA
did
not
calculate
the
coefficients
A
through
J
as
defined
by
Riverkeeper.
Appendix
1
provides
a
detailed
explanation
of
how
EPA
used
a
multi­
step
procedure
to
extrapolate
from
its
case
study
results
to
national
benefit
estimates.

2.
Do
impingement
figures
include
estimates
of
impingement
survival?
If
so,
what
survival
rate
does
EPA
assume?
What
is
the
justification
for
this
assumption?

EPA
Answer
3.
What
is
the
source
of
the
estimated
costs
of
cooling
towers
used
in
the
EBA?
Were
alternative
cost
estimates
examined?
Please
supply
any
cost
estimates
used
or
considered
in
this
analysis.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
8
of
23
EPA
Answer
The
source
of
the
estimated
costs
of
cooling
towers
in
the
EBA
is
explained
in
detail
in
Chapter
2,
section
2.2
of
the
Technical
Development
Document
(
TDD).
The
TDD
provides
the
basis
for
the
estimates
and
identifies
supporting
references.
The
TDD
also
provides
alternative
costing
information
collected
in
support
of
the
estimates,
but
not
used.

TUFTS
QUESTIONS
Wherever
relevant,
indicate
whether
responses
refer
to
the
universe
of
539
in­
scope
facilities,
or
the
extrapolation
to
550
facilities.

*
indicates
items
discussed
and
promised
by
EPA
in
the
conference
call
on
June
18.

1.
The
costs
and
benefits
of
the
policy
options
presented
on
p.
D1­
4
of
the
EBA
do
not
correspond
to
the
costs
and
benefits
of
the
options
described
in
the
Federal
Register.
Please
provide
an
explanation
of
the
conversion
of
EBA
options
and
their
costs
and
benefits
into
the
options,
and
costs
and
benefits,
cited
in
the
Federal
Register.

EPA
Answer
The
benefits
differ
between
the
Preamble
and
the
EBA
because
the
benefits
in
the
Preamble
were
not
sample­
weighted
in
the
same
manner
as
the
costs
were.
The
benefits
in
the
Preamble
are
for
the
539
in­
scope
facilities
for
which
EPA
had
questionnaire
data.
The
benefits
in
the
EBA
are
for
the
550
facilities
that
EPA
believes
will
be
regulated.
after
the
Agency
accounts
for
a
very
small
number
of
facilities
that
received
a
questionnaire
from
EPA
but
did
not
complete
and
return
the
questionnaire.

The
costs
of
the
policy
options
presented
in
the
Preamble
are
total
private
(
post­
tax)
costs.
They
correspond
to
the
costs
presented
in
Part
B
of
the
EBA.
The
costs
presented
on
page
D1­
4
of
the
EBA
are
total
social
(
pre­
tax)
costs.
Table
D1­
2
on
page
D1­
3
presents
a
comparison
between
the
total
private
(
post­
tax)
costs
and
the
total
social
(
pre­
tax)
costs
of
the
different
policy
options
analyzed.

2.*
Please
provide
a
summary
of
the
facilities
that
replied
to
the
questionnaire,
showing
which
facilities
have
provided
flow
data
that
is
not
confidential.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
9
of
23
EPA
Answer
See
Appendix
2
attached.
A
copy
of
this
spreadsheet
is
also
available
in
the
docket
at
entry
number
DCN
4­
4006.

3.*
Provide
total
flow
data
for
all
in­
scope
facilities
on
each
water
body
type.

EPA
Answer
Flow
and
waterbody
information
for
specific
plants
that
did
not
declare
this
information
to
be
confidential
are
available
in
the
Docket
(
See
DCN
4­
4006,
316(
b)
Detailed
Questionaniares
of
In­
Scope
Facilities
for
Phase
II
Rulemaking).
Data
are
available
in
the
Docket
for
each
plant
considered
in
each
option
(
see
DCN
4­
2550,
Model
Plant
Cost
Estimates
for
Regulatory
Options).
However,
these
files
contain
limited
information
for
each
plant
and
have
the
identities
of
the
facilities
concealed.

4.*
Provide
a
sensitivity
analysis
showing
the
results
if
all
impinged
and
entrained
fish
were
valued,
rather
than
just
those
that
would
have
been
landed.
Please
provide
electronic
copies
of
the
spreadsheets
used
for
this
analysis.

EPA
Answer
At
the
time
of
the
initial
teleconference
with
Riverkeeper,
EPA
believed
it
would
be
able
to
readily
complete
such
an
analysis.
However,
upon
further
examination,
EPA
determined
that
the
effort
was
beyond
the
scope
of
what
EPA
can
accomplish
at
this
time.
EPA
will
consider
preparing
such
a
sensitivity
analysis
for
a
Notice
of
Data
Availability
that
the
Agency
anticipates
publishing
this
fall.

5.*
Provide
information
on
the
percentage
of
impinged
and
entrained
fish
that
were
valued
in
the
Ohio
River
case
study,
comparable
to
the
information
provided
for
other
case
studies.

EPA
Answer
The
distribution
of
entrainment
losses
by
species
category
are:
forage
fish:
84.21%;
commercial
and
recreational
fish
valued:
0.22%;
and
commercial
and
recreational
fish
unvalued:
15.57%.
The
distribution
of
impingement
losses
by
species
category
are:
forage
fish:
97.67%;
commercial
and
recreational
fish
valued:
0.01%;
and
commercial
and
recreational
fish
unvalued:
2.24
%.

6.
The
two
San
Francisco
area
case
studies
valued
only
striped
bass
and
special
status
(
threatened
and
endangered)
species.
Were
there
other
species
for
which
the
data
allowed
valuation
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
10
of
23
at
either
Pittsburg
or
Contra
Costa?
If
so,
please
list
the
species
and
provide
summary
data
on
these
species.

EPA
Answer
Records
of
impingement
and
entrainment
losses
at
Contra
Costa
and
Pittsburg
were
reported
in
Ecological
Analysts,
Inc.
(
1981a
and
1981b)
and
Southern
Energy
Delta,
LLC
(
2000).
Tables
1
through
4
(
Appendix
3)
present
the
records
of
the
losses
available
in
these
documents.
(
Literature
Cited:
Southern
Energy
Delta,
LLC.
2000.
Multispecies
Habitat
Conservation
Plan,
Pittsburg
and
Contra
Costa
Power
Plants.
Draft­
Revision
5,
June
30,
2000.
Prepared
for
the
U.
S.
Fish
&
Wildlife
Service,
Sacramento,
CA,
and
the
National
Marine
Fisheries
Service,
Santa
Rosa,
CA;
Ecological
Analysts,
Inc.
1981b.
Pittsburg
Power
Plant
Cooling
Water
Intake
Structures
316b
Demonstration.
Prepared
for
PG&
E;
Ecological
Analysts,
Inc.
1981a.
Contra
Costa
Power
Plant
Cooling
Water
Intake
Structures
316b
Demonstration.
Prepared
for
PG&
E.

7.*
On
p.
D4­
4
of
the
case
studies,
tables
D4­
5
and
D4­
6,
EPA
lists
losses
in
pounds,
then
multiplies
these
losses
by
a
value
per
fish
(
rather
than
per
pound)
to
obtain
total
valued
losses.
Please
clarify
the
error
involved
and
provide
a
correctly
labeled
version
of
these
tables.

EPA
Answer
The
relevant
column
heading
in
Tables
D4­
5
and
D4­
6
should
read
"
Commercial
Value/
lb"
instead
of
"
Commercial
Value/
Fish."

8.*
The
calculation
for
black
drum
on
case
study
p.
D4­
4,
footnote
to
table
D4­
6,
rejects
the
reported
data
and
substitutes
a
much
lower
judgmental
alternative.
Please
provide
a
narrative
explanation
of
the
basis
for
this
alternative.
Were
similar
alternatives
used
in
place
of
observed
data
at
any
other
points
in
the
case
studies?

EPA
Answer
To
represent
realistic
losses
to
the
commercial
fishery,
EPA
decided
to
cap
the
losses
of
black
drum
at
double
the
landings
when
the
black
drum
fishery
was
healthy.
This
was
the
only
case
in
which
estimated
impingement
and
entrainment
losses
appeared
unreasonably
high,
and
therefore
this
was
not
done
in
other
case
studies.

9.*
Please
provide
any
recent
studies
of
nonuse
values
that
support
or
conflict
with
the
50%
rule
used
to
estimate
these
values
in
the
EBA.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
11
of
23
EPA
Answer
Brown.
T.
1993.
"
Measuring
Non­
use
Value:
A
Comparison
of
Recent
Contingent
Valuation
Studies."
In
Bergstrom
J.
C.,
Benefits
and
Costs
Transfer
in
Natural
Resource
Planning.
Sixth
Interim
Report,
University
of
Georgia,
Department
of
Agricultural
and
Applied
Economics;
Athens,
GA.

10.
Describe
any
alternative
approaches
to
nonuse
values
that
were
considered
in
the
preparation
of
the
EBA,
and
explain
why
these
approaches
were
rejected.

EPA
Answer
In
the
absence
of
empirical
data,
one
approach
is
to
describe
the
nonuse
values
qualitatively,
and
not
include
a
quantitative
value.
Another
option
that
is
often
used
to
value
nonuse
changes
is
to
apply
willingness­
to­
pay
(
WTP)
values
by
household.
However,
EPA
did
not
find
studies
and
did
not
have
the
time
or
resources
to
conduct
original
research
to
estimate
a
household
WTP
for
reductions
in
impingement
and
entrainment.
We
believe
the
50%
rule
provides
an
acceptable
though
very
conservative
estimate
of
nonuse
value.

11.
Regarding
the
flow
chart
summarizing
Pittsburg/
Contra
Costa
case
study
data,
p.
E6­
2,
please
clarify
the
apparent
transposition
of
impingement
vs.
entrainment
data
between
boxes
3
and
4,
and
between
boxes
2
and
5.
Did
this
error
affect
any
later
calculations?
Please
provide
corrected
versions
of
the
flow
chart
and
any
other
calculations
affected
by
this
error.

EPA
Answer
In
boxes
4
and
5
of
Figure
E6­
1,
the
impingement
and
entrainment
numbers
are
switched
due
to
a
clerical
error.
Box
4
should
read
"
I:
27,200
(
11,600
lb)"
and
"
E:
185,100
(
79,000
lb).
Box
5
should
read
"
I:
145,00
fish"
and
"
E:
145,000
fish."
The
dollar
values
stated
in
the
boxes
are
correct
as
they
read.
This
clerical
error
occurred
only
in
this
figure
and
not
in
the
spreadsheet
EPA
used
for
its
calculations.

12.
The
value
of
forage
fish
(
per
fish)
in
the
Monroe
case
study
appears
to
be
orders
of
magnitude
larger
than
in
other
case
studies.
Please
explain
the
difference.
Are
there
other
case
studies
or
plants
where
the
higher
forage
value
seen
at
Monroe
would
be
appropriate?
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
12
of
23
EPA
Answer
The
value
of
entrained
forage
fish
from
the
Monroe
case
study
was
estimated
to
average
$
2.00
per
fish,
using
the
methods
presented
in
Section
A5­
3
of
Chapter
A5
of
Part
A
of
the
§
316(
b)
Phase
II
Case
Study
Document
(
DCN
4­
0003).
This
is
much
higher
than
the
per
fish
values
obtained
for
impinged
fish
at
Monroe
and
for
both
impinged
and
entrained
fish
in
the
other
case
studies.
We
will
look
into
the
cause
for
this
difference.

13.
Entrainment
kills
many
more
fish
than
impingement
at
most
case
study
facilities,
but
the
reverse
is
true
(
that
is,
impingement
kills
more
year
1
equivalent
fish
than
entrainment)
at
Monroe
and
Whiting.
What
accounts
for
this
difference?

EPA
Answer
EPA
notes
that
there
are
multiple
factors
that
influence
rates
of
impingement
and
entrainment.
Some
of
the
factors
resulting
in
high
impingement
rates
at
Whiting
and
Monroe
are
indicated
in
facility
documents
in
the
docket.
For
example,
Jude
et
al.
(
1983)
note
that
most
impingement
losses
at
Monroe
are
of
gizzard
shad
which
may
result
from
(
1)
cold
shock
making
them
more
susceptible
and
(
2)
attraction
to
the
warmwater
discharge
plume.
Wapora
(
1980)
observed
that
in
November
1979
"
The
extremely
high
impingement
densities
for
gizzard
shad
were
the
result
of
an
onshore
movement
by
youngof
the­
year
individuals."

14.
Please
provide
a
list
of
all
the
endangered
species
known
to
be
affected
by
each
of
the
case
study
facilities,
and
describe
any
attempts
EPA
made
to
calculate
the
value
of
losses
of
these
species.

EPA
Answer
EPA
does
not
have
a
list
of
endangered
species
known
to
be
affected
at
each
of
the
case
study
facilities.
EPA
would
consider
any
information
it
receives
concerning
this
issue.

ADDITIONAL
TUFTS
QUESTIONS
1.
Flow
data:
are
you
able
to
provide
information
on:
a.)
water
flow
at
each
of
the
case
study
facilities
and/
or
b.)
total
flow
at
all
of
the
facilities
in
each
of
the
five
categories
EPA
uses
in
its
extrapolations
(
non­
gulf
estuary,
gulf
estuary,
rivers,
ocean,
great
lakes)?
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
13
of
23
EPA
Answer
Sum
of
Operational
Flows
Per
Waterbody
Type
(
MGD)
Estuary/
Tidal
River
(
Non­
Gulf)
39,183
Estuary/
Tidal
River
(
Gulf)
13,793
Freshwater
Systems
144,764
Great
Lakes
4,617
Oceans
13,457
2.
Percent
of
losses
valued
in
each
case
study:

a)
In
all
the
case
studies
where
commercial
or
recreational
losses
are
taken
into
account
in
the
final
analysis,
we
would
like
to
know
what
percentage
of
the
age
1
equivalent
fish
lost
to
I&
E
were
assigned
a
monetary
value.
Often
it
seems
that
only
the
fraction
that
would
have
been
caught
by
commercial
or
recreational
fishing
are
valued.
In
some
cases,
this
percentage
is
clear
from
the
information
provided.
In
other
cases,
it
is
ambiguous.

Can
you
tell
us
the
percentage
of
I&
E
losses
that
were
valued
at
each
site?

EPA
Answer
As
summarized
from
our
teleconference
discussions
of
June
18,
2002,
the
following
text
gives
the
percentages
or
references
to
the
§
316(
b)
Phase
II
Case
Study
Document
(
DCN
4­
0003):

°
For
the
Delaware
case
study
analysis,
this
information
is
provided
on
pages
B6­
3
and
B6­
4.
°
For
the
Ohio
River
case
study
analysis,
the
distribution
of
entrainment
losses
by
species
category
is:
landed
commercial
and
recreational
fish
(
0.22%);
forage
fish
(
84.21%);
and
unharvested
(
and
thus
not
valued)
commercial
and
recreational
species
(
15.57%).
The
distribution
of
impingement
losses
by
species
category
is:
landed
commercial
and
recreational
fish
(
0.01%);
forage
fish
(
97.67%);
and
unharvested
(
and
thus
not
valued)
commercial
and
recreational
species
(
2.24%).
°
For
the
Tampa
Bay
case
study
analysis,
this
information
is
provided
on
pages
D6­
3
and
D6­
4.
°
For
the
San
Francisco
Bay
case
study
analysis,
the
distribution
of
entrainment
losses
by
species
category
is:
landed
recreational
fish
(
4.72%);
unharvested
(
and
thus
not
valued)
recreational
fish
(
70.14%);
and
special
status
species
(
25.14%).
The
distribution
of
impingement
losses
by
species
category
is:
landed
recreational
fish
(
8.34%);
unharvested
(
and
thus
not
valued)
recreational
fish
(
79.53%);
and
special
status
species
(
12.13%).
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
14
of
23
°
For
the
Brayton
Point
Station
case
study
analysis,
this
information
is
provided
on
pages
F6­
4
and
F6­
5.
°
For
the
Seabrook
case
study
analysis,
this
information
is
provided
on
pages
G6­
3
and
G6­
4.
°
For
the
Pilgrim
case
study
analysis,
this
information
is
provided
on
pages
G6­
6
and
G6­
7.
°
For
the
J.
R.
Whiting
case
study
analysis,
this
information
is
provided
on
pages
H6­
3
and
H6­
4.
°
For
the
Monroe
case
study
analysis,
this
information
is
provided
on
pages
I6­
3
and
I6­
4.

b)
In
the
Ohio
River
and
the
Big
Bend
case
studies,
EPA
provides
values
for
"
pounds
of
production
foregone"
and
"
pounds
of
fishery
yield
lost."
Can
you
define
these
terms?
Does
"
pounds
of
production
foregone"
refer
to
the
weight
of
the
total
number
of
year
1
equivalent
fish
lost
through
I&
E,
or
does
it
refer
to
something
else?
Does
"
pounds
of
fishery
yield
lost"
refer
to
the
fraction
of
the
total
losses
to
which
EPA
is
assigning
a
monetary
value?

EPA
Answer
Foregone
production
and
foregone
fishery
yield
are
both
derived
measures
of
resources
that
are
unavailable
due
to
the
fact
that
impingement
or
entrainment
occurred.
In
contrast
to
actual
I&
E
rates,
which
are
direct
measures,
foregone
production
and
foregone
fishery
yield
cannot
be
literally
measured.
Instead,
they
are
derived
from
actual
I&
E
using
modeling
procedures
that
reflect
biological
processes
such
as
growth
and
mortality.

Briefly,
foregone
production
is
the
total
biomass
(
expressed
as
pounds)
that
fish
killed
by
I&
E
would
have
produced
in
their
subsequent
lifetime,
had
they
not
been
killed.
Thus,
this
measures
fish
lost
to
the
waterbody.
The
model
used
to
calculate
foregone
production
includes
consideration
of
both
growth
and
mortality
during
all
life
stages.
Conceptually,
the
biomass
that
is
considered
is
accumulated
at
all
life
stages
subsequent
to
the
time
of
death.

Briefly,
foregone
fishery
yield
is
an
estimate
of
fish
harvest
(
expressed
in
pounds
or
as
numbers
of
individuals)
that
would
have
occurred
at
some
time
in
the
future,
had
I&
E
not
occurred.
The
model
used
to
calculate
foregone
fishery
yield
considers
natural
(
nonfishing
mortality
rates,
fishing
mortality
rates,
and
the
weight
(
as
pounds)
of
harvested
fish.

The
metric
"
age
1
equivalent"
is
also
a
derived
measure
of
fish
that
are
"
absent"
from
the
waterbody,
at
a
future
time,
due
to
the
fact
that
impingement
or
entrainment
occurred.
As
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
15
of
23
a
general
rule,
most
fish
killed
by
I&
E
are
less
than
1
year
old.
The
metric
age
1
equivalent
depicts
the
numbers
of
fish
killed
by
I&
E
that
would
have
survived
until
they
reached
age
1
by
considering
mortality
rates
of
young
fish.
The
metric
is
in
terms
of
numbers
of
fish
(
not
pounds).

Although
these
three
metrics
share
some
conceptual
similarities,
they
are
not
strictly
dependent
on
each
other.
In
particular,
neither
foregone
production
nor
foregone
fishery
yield
is
derived
from
the
estimate
of
age
1
equivalent
losses.

Age
1
equivalents,
foregone
production
and
foregone
fishery
yield
are
all
formally
defined
in
Chapter
A5
of
the
Case
Study
Document
(
docket
number
DCN4
­
0003).
Please
refer
to
this
chapter
for
a
more
complete
discussion.

EPA's
monetary
valuation
of
losses
involves
consideration
of
foregone
fishery
yield,
along
with
other
factors.
It
would
be
incorrect
to
call
it
a
"
fraction
of
the
total
losses
to
which
EPA
is
assigning
a
monetary
value."
In
effect,
foregone
fishery
yield
is
the
major
driving
factor
for
scaling
the
economic
losses.
All
of
the
losses
that
EPA
has
quantified
flow
from
the
estimates
of
foregone
fishery
yield,
but
the
economic
benefits
include
disparate
kinds
of
economic
benefits
such
as
the
dockside
value
of
commercially
harvested
fish,
the
revealed
value
recreation
fishing
experiences,
consumer
surplus
derived
from
fishing
activities,
and
non­
use
values.

c)
On
p.
D4­
4,
tables
D4­
5
and
D4­
6,
EPA
lists
losses
in
pounds,
then
multiplies
these
losses
by
a
value
per
fish
to
obtain
total
valued
losses.
There
appears
to
be
an
error
in
these
tables,
perhaps
only
in
labelling:
either
the
losses
are
actually
numbers
of
fish
(
not
pounds),
or
the
values
are
actually
values
per
pound
(
not
per
fish).
If
the
figures
in
both
of
these
columns
are
correct,
then
the
figures
in
the
final
column
are
wrong,
because
they
are
the
product
of
"
pounds
of
fish"
multiplied
by
"
value
per
fish."
Can
you
clarify
the
calculations
in
these
tables?

EPA
Answer
The
relevant
column
heading
in
Tables
D4­
5
and
D4­
6
should
read
"
Commercial
Value/
lb"
instead
of
"
Commercial
Value/
Fish."

d)
Also
on
p.
D4­
4,
in
a
footnote
to
table
D4­
6,
EPA
notes
that
the
value
of
black
drum
entrainment
losses
is
capped
at
$
137,756,
a
small
fraction
of
the
value
that
would
be
calculated
without
the
cap.
What
is
the
rationale
for
setting
a
cap
on
this
number?
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
16
of
23
Were
similar
caps
applied
to
calculated
values
elsewhere
in
the
analysis
of
this
or
other
case
studies?

EPA
Answer
To
represent
realistic
losses
to
the
commercial
fishery,
EPA
decided
to
cap
the
losses
of
black
drum
at
double
the
landings
when
the
black
drum
fishery
was
healthy.
This
was
the
only
case
in
which
estimated
impingement
and
entrainment
losses
appeared
unreasonably
high,
and
therefore
this
was
not
done
in
other
case
studies.

3.
Values
chosen
as
"
baseline"
for
extrapolations:

What
is
the
rationale
for
using
HRC
values
as
the
basis
for
extrapolations
for
the
ocean
and
great
lake
categories,
while
using
the
midpoint
between
the
high
and
low
cost
estimates
for
other
categories
where
HRC
analysis
was
conducted?
Why
were
HRC
figures
not
used
in
all
cases
where
they
were
available,
if
EPA
considers
them
more
indicative
of
true
costs
than
the
figures
obtained
through
other
methodologies?

EPA
Answer
See
Federal
Register
Tuesday,
April
9,
2002
/
Vol.
67,
No.
68
/
page
17205,
for
explanation.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
17
of
23
JUNE
27
QUESTIONS
You
have
confirmed
that
the
option
numbering
between
the
EBA
and
Fed
Reg
corresponds
as
follows:

Federal
Register
Proposed
Option
=
EBA
Option
3
Federal
Register
Option
1
=
EBA
Option
4
Federal
Register
Option
2
=
EBA
Option
6
Federal
Register
Option
3
=
EBA
Options
1
and
2
Federal
Register
Option
4
=
EBA
Option
3a
Table
D1­
3
in
the
EBA
presents
total
national
costs
and
benefits
for
each
option
as
follows:

EBA
Optio
n
#
EBA
description
Benefits
Costs
Net
1
Waterbody/
capacity
based
option,
"
all
track
1"
$
1,034
$
969
$
65
2
Waterbody/
capacity
based
option,
"
track
1
and
2"
$
890
$
610
$
280
3
Proposed
rule:
"
Alternative
less
stringent
requirements
based
on
both
costs
and
benefits
are
allowed."
$
735
$
283
$
452
3a
I&
E
controls
everywhere
$
749
$
300
$
449
4
All
cooling
towers
$
1,223
$
3,507
$
(
2,284)
5
Dry
cooling
$
1,536
$
2,054
$
(
518)
6
Waterbody
based
option
$
1,159
not
costed
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
18
of
23
This
does
not
match
the
Federal
Register
numbers,
which
at
67
FR
17154­
59
give
the
following
national
costs
and
benefits:

FR
Optio
n
#
FR
description
Benefits
(*
b)
Costs
(*
c)
Alternate
costs
(*
a)
Net
0
Proposed
option:
(
67
FR
17181,17145)
$
703
$
178
$
525
1
Closed­
cycle
for
all
facilities.
$
1,164
$
2,260
$
2,320
$(
1,096)

2
Closed­
cycle
based
on
waterbody
type
$
1,328
not
calculated
not
calculated
3
Closed
cycle
based
on
waterbody
type
and
proportional
flow
$
849
$
585
$
595
$
264
4
Impingement
mortality
and
entrainment
controls
everywhere
$
65
$
191
$
195
$
(
126)

(*
a)
Alternate
costs
for
FR
option
1
includes
compliance
costs
for
9
facilities
that
are
projected
to
be
baseline
closures.
Alternate
cost
for
FR
option
4
includes
costs
for
11
facilities
projected
to
be
baseline
closures.
(*
b)
Benefits
for
FR
option
1:
"$
83.9
million
per
year
[
for
impingement?]
and
$
1.08
billion
for
entrainment
reductions."

Thus,
comparing
the
two
sets
of
numbers
yields
the
following:

FR
Option
EBA
Option
FR
Benefits
EBA
Benefits
FR
Costs
EBA
Costs
Proposed
3
$
703
$
735
$
178
$
283
1
4
$
1,164
$
1,223
$
2,260
$
3,507
2
6
$
1,328
$
1,159
Not
costed
Not
costed
3
1
and
2
$
849
$
1,034/$
890
$
585
$
969/$
610
4
3a
$
65
$
749
$
191
$
300
1.
As
you
can
see,
none
of
the
costs
or
benefits
match
up,
even
when
the
options
are
properly
ordered.
Please
explain.
In
addition,
since
Option
3
in
the
EBA
was
calculated
for
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
19
of
23
"
all
plants
follow
Track
I"
and
"
Some
Track
I
and
some
Track
II",
please
explain
what
that
now
means
in
light
of
the
fact
that
the
proposed
rule
has
Track
I,
II
and
III.

EPA
Answer
The
benefits
differ
between
the
Preamble
and
the
Economic
and
Benefits
Analysis
(
EBA)
because
the
benefits
in
the
Preamble
were
not
sample­
weighted
in
the
same
manner
as
the
costs
were.
The
benefits
in
the
Preamble
are
for
the
539
in­
scope
facilities
for
which
EPA
had
questionnaire
data.
The
benefits
in
the
EBA
are
for
550
facilities
that
EPA
believes
would
be
regulated,
based
on
a
small
number
of
facilities
that
received
but
did
not
complete
a
questionnaire.
Appendix
1
provides
more
information
about
how
EPA
extrapolated
benefits
to
account
for
facilities
that
did
not
complete
a
questionnaire.

The
costs
of
the
policy
options
presented
in
the
Preamble
are
total
private
(
post­
tax)
costs.
They
correspond
to
the
costs
presented
in
Part
B
of
the
EBA.
The
costs
presented
on
page
D1­
4
of
the
EBA
are
total
social
(
pre­
tax)
costs.
Table
D1­
2
on
page
D1­
3
presents
a
comparison
between
the
total
private
(
post­
tax)
costs
and
the
total
social
(
pre­
tax)
costs
of
the
different
policy
options
analyzed.

The
proposed
rule
provides
three
alternatives
for
establishing
best
technology
available
including
demonstrating
that:
(
1)
existing
design
and
construction
technologies,
operational
measures,
and/
or
restoration
measures
meet
the
performance
standards;
(
2)
additional
selected
and
implemented
design
and
construction
technologies,
operational
measures,
and/
or
restoration
measures
will
meet
the
performance
standards;
or
(
3)
a
site­
specific
determination
of
best
technology
available
is
appropriate.
In
developing
benefits
and
costs
for
the
proposed
option,
EPA
used
available
data
(
collected
using
the
questionnaires)
to
determine
existing
conditions
(
i.
e.,
plant
characteristics)
at
the
facility
to
estimate
which
alternative
a
facility
might
choose.
Facilities
that
currently
have
technologies,
operational
measures,
and/
or
restoration
measures
that
should
be
able
to
meet
applicable
impingement
and/
or
entrainment
reduction
requirements
of
the
rule
(
based
on
facility
characteristics
such
as
waterbody
type,
proportion
of
waterbody
flow,
etc.)
were
estimated
to
comply
under
alternative
number
1.
These
facilities
were
estimated
to
have
no
costs
associated
with
complying
with
the
performance
standards.
Facilities
that
did
not
currently
have
technologies
in
place
to
meet
applicable
performance
standards
were
estimated
to
have
to
select
and
install
additional
technologies,
operational
measures,
and/
or
restoration
measures.
EPA
estimated
the
costs
for
additional
technologies
at
these
facilities.
EPA
did
not
attempt
to
estimate
how
many
facilities
would
choose
a
site­
specific
demonstration,
as
well
as
what
monetary
impact
they
might
incur,
because
EPA
judged
that
a
facility
would
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
20
of
23
only
pursue
this
third
alternative
if
it
would
be
less
costly
than
either
alternatives
1
or
2.
EPA
believes
that
costing
facilities
to
comply
under
alternatives
1
or
2
provides
a
conservative
cost
estimate.

2.
Finally,
since
the
Federal
Register
contains
the
proposed
regulation
and
alternative
approaches
to
be
commented
on,
please
direct
us
to
the
support
for
its
costs
and
benefit
totals,
if
not
contained
within
the
three
primary
support
documents.

EPA
Answer
to:
 
the
EBA,
Chapter
C3
(
docket
#
DCN
4­
0002)
 
Federal
Register
Vol.
67,
No.
68,
Section
IX,
pages
17189­
17208,
 
docket
documents
DCN
4­
2070,
DCN
4­
2212,
and
DCN
4­
2213,
and
 
Appendix
1.

For
details
on
costs
please
refer
to:
 
the
EBA,
Chapters
B1
and
B2
(
docket
#
DCN
4­
0002),
 
Federal
Register
Vol.
67,
No.
68,
Section
VIII,
pages
17181­
17189,
 
Docket
#
DCN
4­
2550,
and
 
the
Technical
Development
Document,
Chapters
2,
4,
and
5.

ENERGY/
ENGINEERING/
COSTS
QUESTIONS
FROM
CONFERENCE
CALL
1.
Please
verify
the
following
reconciliation
of
the
options
listed
in
the
Federal
Register
Notice
and
the
options
examined
in
the
"
Economic
and
Benefits
Analysis
for
the
Proposed
Section
316(
b)
Phase
II
Existing
Facilities
Rule"
("
EBA"):
Federal
Register
Proposed
Option
=
EBA
Option
3
Federal
Register
Option
1
=
EBA
Option
4
Federal
Register
Option
2
=
EBA
Option
6
Federal
Register
Option
3
=
EBA
Options
1
and
2
Federal
Register
Option
4
=
EBA
Option
3a
If
this
table
is
incorrect,
please
reconcile
the
options
in
the
Federal
Register
Notice
and
the
options
discussed
in
the
EBA.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
21
of
23
EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.

2.(
Reference
EBA
page
B1­
1)
Please
explain
why
EPA
didn't
consider
$/
MWH
or
cents/
kwh
as
a
unit
cost
measure?

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.
See
also
hard
copy
attachment
"
Deliberative
Draft
Analysis
of
Cooling
Water
Flow
and
Electric
Generating
Capacity".

3.(
Reference
EBA
page
B1­
4)
Please
explain
why
the
EPA
lists
a
different
"
retrofit"
factor
(
20%
vs.
30%)
and
contingency
factor
(
10%
vs.
15%)?

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.

4.
Please
explain
the
empirical
data
that
was
used
to
support
the
assumption
that
there
is
a
need
to
apply
any
"
retrofit"
factor
to
the
cost
of
building
a
cooling
tower
at
a
new
facility.

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.

5.(
Reference
EBA
page
B1­
5)
Explain
whether
the
analyses
in
the
EBA
assume
that
there
would
be
any
improved
power
plant
performance
or
reduced
O&
M
as
a
result
of
the
upgrading/
refurbising
of
the
condenser
tube
materials
to
stainless
steel.

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.
6.(
Reference
EBA
page
B1­
6)
Please
describe
in
more
detail
the
methodology
used
to
develop
the
capital
cost
estimates
for
the
"
dry
cooling"
alternative.

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
22
of
23
7.(
Reference
EBA
page
B1­
8)
Please
specify
the
efforts
or
analyses
that
have
been
made
to
evaluate
the
reasonableness
of
the
use
the
historic
data
from
1995
to
1999
to
look
at
future
costs
and
revenues
in
2008,
etc.

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.

8.
Please
explain
whether
ICF
assumed
that
any
power
uprates
would
be
implemented
at
nuclear
power
plants.
If
the
answer
is
yes,
please
specify
what
power
uprates
were
assumed.

EPA
Answer
The
EPA
Base
Case
2000
did
not
assume
any
power
uprates
for
nuclear
power
plants.

9.
Please
explain
whether
ICF
assumed
that
any
nuclear
power
plant
operating
licenses
would
be
renewed
and,
consequently,
that
nuclear
power
plant
operating
lives
would
be
extended.
If
the
answer
is
yes,
please
specify
which
plants
and
how
long
each
such
plant's
operating
life
was
assumed
to
be
extended.

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.

10.(
Reference
EBA
page
B2­
1)
Explain
the
basis
for
selecting
the
30
year
period
over
which
costs
are
annualized.
Please
explain
why
it
isn't
possible
that
plants
would
operate
for
more
than
30
more
years.

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.

11.(
Reference
EBA
page
B2­
1)
Please
explain
the
basis
for
the
assumed
seven
percent
discount
rate.

EPA
Answer
This
question
was
fully
answered
verbally
during
a
teleconference
call.
Therefore,
as
agreed,
we
are
not
providing
a
written
answer
to
this
question.
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
23
of
23
12.(
Reference
EBA
page
B3­
7)
Where
can
we
find
a
list
of
the
new
capacity
assumed
to
be
added
to
the
U.
S.
electric
system
each
year
during
the
study
period?

EPA
Answer
This
information
can
be
found
in
the
Phase
II
docket,
under
DCN
4­
3052,
pages
164
to
173.
The
information
is
presented
for
2008
and
2013,
by
NERC
region
and
technology
type.
Note
that:
1d
=
Base
Case
with
EPA
Electricity
Demand
Assumption
2d
=
Base
Case
with
AEO
Electricity
Demand
Assumption
3d
=
Option
1
with
EPA
Electricity
Demand
Assumption
4c
=
Option
1
with
AEO
Electricity
Demand
Assumption
5d
=
Option
4
with
EPA
Electricity
Demand
Assumption
13.(
Reference
EBA
page
B8­
6)
When
ICF
considered
plant
repowerings,
did
they
assume
that
the
facility
was
repowered
to
the
same
MW
output
or
did
they
assume
any
increases
in
plant
MW
output
as
a
result
of
the
repowering?

EPA
Answer
The
capacity
of
a
repowered
unit
is
twice
the
capacity
of
the
original
unit.

RIVERKEEPER
REQUESTS
FROM
R.
SUPER
ELECTRONIC
MESSAGE
OF
7/
11/
02
1.
The
analysis
showing
that
the
relationship
between
capacity
and
flow
had
too
much
variation
to
use
$/
MWH
as
unit
cost
measure
(
relates
to
Synapse
Question
No.
1).

EPA
Answer
Please
see
the
attached
note
to
the
316(
b)
Phase
II
Administrative
Record
(
subject:
Deliberative
Draft
Analysis
of
Cooling
Water
Flow
and
Electric
Generating
Capacity).

2.
The
case
studies
used
to
come
up
with
the
retrofit
factor
to
adjust
costs
for
a
retrofit.

EPA
Answer
Per
our
June
25,
2002,
teleconference
discussion,
here
are
the
docket
entries
that
refer
to
retrofits
of
cooling
towers:
DCN
4­
2526
(
Capital
Costs
of
Two
"
Retrofit"
Cooling
System
Conversions)
and
DCN
4­
2537
(
Unit
Cost
Estimates
Comparison
 
Bowline
Point
Cooling
Tower
Retrofit).
3.
The
assumptions
in
the
IPM
runs
for
new
capacity
additions.
Ideally,
we'd
like
specifics
This
document
represents
the
best
judgment
of
the
EPA
staff
conducting
analyses
to
support
the
Phase
II
Section
316(
b)
rule
at
this
time.
It
does
not
represent
the
final
position
of
the
Administrator
or
EPA
on
this
rulemaking.
EPA
reserves
the
right
to
change
or
amend
any
of
the
statements
within
this
document
up
until
the
time
that
the
EPA
Administrator
takes
final
action
on
this
rule.

Page
24
of
23
here­­
plant
names.

EPA
Answer
Please
see
response
to
question
#
12
above
(
Energy/
Engineering/
Costs
Questions
from
Conference
Call).

4.
The
assumptions
in
the
IPM
runs
for
nuclear
plant
uprates
and
license
extensions.
Again,
by
plant
would
be
best,
unless
confidential.

EPA
Answer
Please
see
response
to
question
#
8
above
(
Energy/
Engineering/
Costs
Questions
from
Conference
Call).
