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
Dave­

Please
see
the
answers
embedded
after
your
questions
and
I
will
try
again
to
contact
you
to
discuss.
Debbi
Question:
Thank
you
for
your
response
to
my
questions.
Regarding
the
Excel
workbooks
you
referenced,
we
have
not
had
the
opportunity
to
access
them.
However,
when
we
divide
the
stage
mortality
by
the
number
of
days
in
a
stage
(
reported
in
literature),
we
cannot
duplicate
the
daily
mortality
rates.
So
this
is
still
a
puzzle.

EPA
Answer:
As
indicated
in
the
previous
email,
the
EXCEL
workbooks
for
the
Ohio
facilities
(
available
in
the
docket
on
the
CD­
ROM
at
DCN
#
4­
1305)
provide
details
on
the
data
inputs
and
sources
for
these
calculations.
Please
note
that
in
cases
where
stage­
specific
mortality
rates
were
not
available
(
i.
e.,
larval
and
age
0+
survival
rates
of
bluntnose
minnow,
logperch,
muskellunge,
paddlefish,
and
skipjack
herring)
stage­
specific
rates
were
calculated
according
to
Equation
1
presented
in
Section
A5­
2.3
of
Chapter
A
of
the
Case
Study
Document
(
DCN
4­
0003).

Question:
Your
response
regarding
EPA's
use
of
the
Salem
data
is
also
puzzling.
We
don't
understand
how
you
could
indicate
that
the
Salem
data
were
used
"
in
a
few
limited
cases"
when
in
fact
the
majority
of
egg
and
larval
natural
mortality
rates
listed
in
the
Ohio
River
Case
Study
Appendix
C1
are
referenced
to
the
Salem
316(
b)
report.

EPA
Answer:
Due
to
a
clerical
error,
some
of
the
tables
in
Appendix
C1
cite
PSEG
1999
as
the
source
of
rates
of
survival
from
egg
to
larvae.
In
fact,
when
survival
from
egg
to
larvae
was
not
available,
Stratus
Consulting
estimated
that
1
in
10
eggs
hatch.
This
follows
the
precedent
in
Stone
&
Webster
Engineering
Corporation,
1977,
Supplemental
Assessment
in
Support
of
the
316
Demonstration,
Pilgrim
Nuclear
Power
Station
Units
1
and
2,
Boston
Edison
Company.
September.
Boston,
MA.
Thus,
the
reference
"
PSEG
(
1999c)"
in
Table
C1­
2,
Table
C1­
4
to
Table
C1­
11,
Table
C1­
13,
Table
C1­
14,
and
Table
C1­
16
of
Appendix
C1
should
be
replaced
by
the
Stone
&
Webster
citation.
Again,
please
see
the
EXCEL
workbooks
for
the
Ohio
facilities
available
in
the
docket
on
the
CD­
ROM
at
DCN
#
4­
1305
for
a
complete
listing
of
data
sources.

Question:
A
PSE&
G
representative
suggested
to
us
that
EPA
may
have
used
their
"
Average
Stage
Survivals
used
for
Non­
RIS
Species"
(
Appendix
F­
4
Table
9
of
PSE&
G
[
1999])
as
surrogates
for
many
of
the
Ohio
River
species.
Can
you
confirm
that?

EPA
Answer:
Only
the
mortality
rates
of
striped
bass
and
the
egg
to
larvae
mortality
rate
of
yellow
perch
were
taken
from
PSEG
(
1999).
