United
States
Forest
Southern
Fisheries
Research
Unit
Department
of
Service
Research
1650
Ramble
Road
Agriculture
Station
Blacksburg,
VA
24060
_____________________________________________________________________
_________

June
22,
2004
Denise
M.
Keehner
USEPA
Headquarters,
Office
of
Water
Standards
and
Health
Protection
Division
(
4305T)
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Dear
Ms.
Keehner:

I
am
writing
to
formally
retract
my
prior
peer
review
of
EPA's
draft
"
Aquatic
Life
Water
Quality
Criteria
for
Selenium
 
2002",
as
transmitted
to
you
via
my
letter
dated
April
23,
2002.
Since
that
time,
several
issues
have
been
brought
to
my
attention
which
raise
serious
questions
as
to
the
scientific
credibility
of
the
draft
document.
Chief
among
the
concerns
are:
(
1)
the
full
utility
of
the
experimental
design
of
my
1993
winter
stress
study,
which
was
the
controlling
experiment
used
by
EPA's
contractor
(
Great
Lakes
Environmental
Center)
to
derive
the
7.9
µ
g/
g
dw
chronic
criterion,
went
unrecognized,
(
2)
the
crucial
linear
regression
equation
relating
selenium
concentrations
in
fish
ovaries
to
concentrations
on
a
whole­
body
basis
was
erroneously
reported,
and
(
3)
assessments
of
risk
to
aquatic­
dependent
wildlife
were
based
on
out­
of­
date
information.
I
have
re­
examined
my
own
study
as
well
as
original
data
and
reports
of
other
research
cited
in
the
draft
document.
In
the
course
of
this
analysis
it
became
clear
that
the
3
concerns
listed
above
are
indeed
legitimate
and,
I
believe,
constitute
fatal
flaws
in
the
calculations
and
reasoning
used
by
GLEC
to
prepare
the
draft;
ergo,
the
chronic
criterion
should
be
substantially
lower
than
7.9.
A
detailed
discussion
of
these
concerns
has
been
provided
to
the
EPA
(
Charlie
Delos)
on
June
16,
2004
in
the
form
of
a
draft
manuscript
written
by
several
colleagues
and
myself.
Because
of
the
serious
flaws
I
cannot
ethically
continue
to
let
my
previous
endorsement
of
the
7.9
criterion
stand.
Please
take
notice
that
I
no
longer
support
the
criterion
as
proposed
in
the
draft
document.
I
will
be
glad
to
discuss
this
matter
further
if
you
wish
(
540­
231­
6663;
dlemly@
fs.
fed.
us).

Sincerely,

A.
Dennis
Lemly,
Ph.
D.
Senior
Scientist
in
Aquatic
Toxicology
cc:
Dr.
John
Besser,
Dr.
Gregory
Moller,
Mr.
Steve
Canton,
Mr.
Robin
Reash,
Mr.
Greg
Masson
