Ag Engines and Suggested Preamble Revision for consistency with, RIA Bromberg, Kevin L. to: RobertJ Wayland 02/16/2010 05:23 PM Melanie King, "Zwicke, Greg Portland, OR", greg.johnson, 

I,Ii, Cc: "Grahame, Thomas, H•gg ns, Cortney, Lee, Amanda Peter Tsirigotis 

These are two outstanding issues in one email: 

documentation 

i. See below for the promised email re: ag engines. We've asked for the 

documentation. 

on this (week before last?), but we didn't get any further 

to 

2. 

address 

Re: DOE issue and preamble language here is the suggested language PM transport. 

Instead of 

"PM emissions 

emissions from 

can 

diese,l 

travel 

engines 

tens or hundreds of miles from their source, so 

in rural areas can impact urban populat<ons." 

Use: 

"While PM emissions can travel tens of hundreds of miles from their 

emissions 

source, and may travel to distant urban populations, ground level 

emitted substantially 

are less likely to travel long distances than PM2.5 emissions 

RIA edit: 

above ground level." To be consistent with DOE 

"Ground level emissions 

PM2.5 emissions 

are less likely to travel long distances than emitted substantially above ground level." 

Other issues to be addressed tomorrow: 

3. Ag Engines Area Sources perhaps EPA should a•sume 1-5% major 

the 

sources, 

I00-300- 

instead of 40% to address the 10% of the engines reflected in HP size category. 

4. PM Transport RIA revisions 

the 

I will 

morning 

be our early tomorrow AM for a tooth extraction, so I may miss call if there is 

handle this without 

one. But I think the participants can 

me. 

Kevin 

Original Message 

From: Bromberg, Kevin L. 

Sent: Tuesday, February 16, 2010 1:49 PM 

To: .'Higgins, Cortney' 

Cc: 

'greg.johnson@por.usda.gov,; 

'King. Melanie@epamail.epa.gov,; 'Zwicke, Greg POrtland, OR'; Wayland. Robertj@epamail.epa.gov; Sorrels.Larry@epamail.epa.gov; Wayland. Robertj@epamail.epa.gov Subject: RE: RICE package Population Statistics Ag Engines 

spreadsheet. 

I believe I Saw these before. I've already opened up the population 

712 CI 

It still doesn't explain how, for example, EPA went from 

(300-600HP) 

ag irrigation engines (cell g7, CI SI summary page) to 18 ag irrigation engines, as--I asked in an earlier email. 
My note came after reviewing this. It does have all the different types 

of engines (gen sets, irrigation, pumps, etc.) and I believe the total 

population -before dividing them further by industry sector but that 

is the missing piece (and perhaps a part about US vs. world division?). 

This may provide some more light about the ag engines (and others). 

Sorry.about the email glut. 

Original Message 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Tuesday, February 16, 2010 12:49 PM 

To: Bromberg, Kevin L. 

Subj'ect: FW: RICE package 

Apologies there's been such a glut of emails surrounding thisrule, 

this email got lost.in the mlx. 

-Original Message 

From: King.Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa.govi 

Sent: Friday, February 12, 2010 12:14 PM 

To: Higgins, Cortney 

Cc: Wayland. Robertj@epamail.epa.gov; Talcott. Fred@epamail.epa.gov; 

horowitz.michael@epamail.epa.gov 

Subject: RE: RICE package 

Hi Cortney, 

Glad you made it back in! 

next week? I hope not. 

Did I hear £here was a chance of more snow 

I sent you the impacts memo that Kevin requested. The underlying 

information for the population estimates comes from the Power Systems 

Research population information that we received from OTAQ. Attached 

•re the spreadsheets used to generate the population estimates. 

(See attached file: OTAQ-PSR 1998 RICE pop-sales data.xls) (See attached 

file: CI Projection 2007-2017 by NAICS January 2009.xls) 

Melanie King 

Energy Strategies Group 

Sector Policies and Progr.ams Division 

Office of Air Quality Planning and Standards U.S. Environmental 

Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

From: 

"Higgins, Cortney" <Cortney_Higgins@Qmb.eop. gov> 
To: 

> 

IMelanie King/RTP/USEPA/US@EPA 

-> 

Date 

102/12/2010 09:20 AM 

-I 

Subject 

RE RICE package 

Hi Melanie, 

Thanks for the update let me know when it will come over. 

I'm in the bffice today! It's good to be back. 

Can 

sector 

you 

estimates 

provide the 

of 

memo (or send the citation for the memo) for the engines? 

Thanks, 

Cortney 

Original Message-•--- 

From: King. Melanie@epamail.epa.gov [maglto:King. Melanie@epamail.epa.gov] 

Sent: Thursday, February ii, 2010 4:30 PM To: Higgins, Cortney 

Subject: RICE package 

Hi Cortney, 
We're finishing up our latest round of revis±ons to the RICE package. 

It's been a bit of a slow go due to difficulties in getting in touch 

with some of the EPA folks up in D.C. We should send you the revised 

package either later tonight or first th±ng tomorrow. 

Take care, 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office Df Air Quality Planning and Standards U.S. Environmental 

Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (91.9) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 
Re: Response re: emission testing costs SBA Rebuttal to EPA Reply. • 

Melanie King to: Bromberg, Kevin L. 02/16/2010 03:32 PM Cc: "Higgins, Cortney", RobertJ Wayland, "Grahame, Thomas" 

Kevin, 

Costs are very much dependant on what you are measuring. There is no portable analyzer method available to measure formaldehyde. The costs to measure formaldehyde are much higher than for measuring CO. 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

"Bromberg, Kevin L. •i•:i[•l••]-•:•te: • b0ut..ti•:•t•ti.•i• •i••i•:ii!•i•i •i•;•i•.•i•i!;ii; 0•i• •:2•)•10:03•24; 59 pM 

From: "Bromberg, Kevin L." <kevin.bromberg@sba.gov> To: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> Cc: Melanie King/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA, "Grahame, Thomas" <Thomas.Grahame@HQ.DOE.GOV> Date: 02/16/2010 03:24 PM 

Subject: Response re: emission testing costs SBA Rebuttal to EPA Reply 

This is what wrote about the testing costs: 

"EPA has overlooked several factors contributin6 to a hisher cost: 

1. Engines are often not co-located together; for example in oil and gas field, and agricultural fields engines are not co4ocated. 

2. Costs are considerably higher if site is remote and without electricity must bring in our 

portable generator to Site. The portable analyzer requires electricity to run. 

3. Costs include mobilization, equipment set-up and take'down, van rental, travel costs, calibrations of equipment, troubleshooting, three hours of actual test runs/engine. It generally 
will take a full day to test one engine, given the set-up time, calibrations before and after each 

one hour test, and troubleshooting." 

And then I cited four sources for higher costs: INGAA ($3000-$5000), IPAA ($8000/engine), the 

independent consultant ($5000) and the testing firm ($5000). I didn't think that the cost would 

depend on whether the firm was analyzing for CO or formaldehyde these are both three one 

hour tests with a portable analyzer. Here is what the consultant said, when I asked about CO (I 

did ask him about the pending rule not about SI engines, after all). IPAA wasn't specific about 

either test, but oil & gas companies do have.both CI and SI engines. 

"Forgot to mention that the portable CO has its own battery thus it does not require a 

electrical source. discussed formaldehyde in general.with XXX testing firm and we 

concluded that the $5000 estimate would cover both species. 

(Yes, there is a savings from not bringing a portable generator, but most of the costs here are 

travel costs and set-up costs not the equipment). 

At a minimum, EPA is not accounting for engines that are not co-located, which alone lowers the 

costs by half. 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-maih kevin.brom bercl(•.sba•flov 

Visit Advocacy's website at http:llwww.sba.govladvo 

Sign up for Advocacy Email Alerts at http:llweb.sba.govllist in order to receive via emaih 

• Advocacy's PressReleases; 

• Advocacy's monthly newsletter The Small Business Advocate 

• Advocacy's Small Business Research; 

• Advocacy's Regulatory News. 

To easily learn about and comment on important proposed regulations visit 

http :llwww.sba.,qovladvollawsllaw re.qalerts.html 

Read the AdvOcacy Blog at httD:llweblo_•.sba.c•ovlbloa.advo 
Subscribe to "What's New at Advocacy" RSS feed at http:l/feeds.feedburner.com/sba/rAIO 
Re: Emission_Testing_memo•021510_v311].doc • 

Melanie King to: Cortney_Higgins Cc: Fred Talcott, RobertJ Wayland 02/16/2010 02:15 PM 

Cortney, 

gas-fired 

The information 

engines 

Kevin is citing from INGAA's corn ments primarily deals with formaldehyde testing for and therefore is not relevant to a discussion of CO testing for diesel engines. The 

estimates 

excerpt from 

for 

the independent consultant also references formaldehyde testing. We will be looking at the testing costs for SI engines as part of the SI rule in August. The lack of electricity is not'a concern for the CO tests required for diesel engines the portable analyzers have batteries. We reviewed 

the 

our 

information 

estimated testing costs during the post-proposal period and we believe that they are accurate. All of cited in Kevin's memo relates to formaldehyde testing. 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

From: "Bromberg, Kevin L." <kevin. bromberg@sba.gov> To: Melanie KinglRTPIUSEPAIUS@EPA, RobertJ WaylandlRTPIUSEPAIUS@EPA, Peter 

Cc: TsirigotislRTPIUS.EPA/US@EPA 

Amanda 

Larry Sor(elslRTPIUSEPNUS@EPA, "H iggins, Cortney" <Cortney Higg ns@omb.eop gov>, '.'Lee, I." <Amanda I. Lee@omb.eop.gov>, "Mancini, Domini•J. "•' 

<Dominic_J._Mancini@omb.eop.gov>, "Zwicke, Greg Portland, OR" <greg.zw cke@por.usda.gov>, "Grahame, Thomas" <Thomas.Grahame@HQ.DOE.GOV>, '!Daniels, Jarad" <JaradoDan els@hq.doe.gov>, <greg.johnson@por.usda.gov> 'Date: 02/16/2010 10:53 AM 

Subject: Emission_Testing_memo _021510_v311].doc 

<<Emission Testing memo 021510_v311].doc>> For EPA's consideration proposed revision of emission testing costs•. Sorry about the lateness of this note. have shared this issue previously with EPA. We believe that the emission testin8 costs are considerably underestimated in the RIA. However, think the revision would not be difficult to accommodate. 

Thanks 

Kevin[attachment "E m•ss•on_Tesbng_memo•O21510_v311].doc,, deleted by Melanie King/RTP/USEPA/US] 
2/15/10 

Costs of Emission Testing Significant Underestimate 

EPA significantly underestimated the cost of emission testing- by assuming $583/engine (2/10/10 EC/R Impacts memo, pages 4-5) and assuming that co-location of two engines that would share a $1165 daily test cost, and more so for locations that are 

remote and have no electricity. It still relies on the costs derived from the 2005 AGT 

memo, which could not have taken into account comments in the current or previous RICE rulemakings. A single engine, additional travel distance, and the lack of electricity makes it more costly and less practicable. See INGAA comments, pages 70-71 for a 

discussion of these additional cost factors. Instead of $500/engine, it could be $3000 to $5000/engine at an isolated site (no co-location). 

EPA has overlooked Several factors contributing to a higher cost: 

1. Engines are often not co-located together; for example in oil and gas field, and agricultural fields engines are not co-located. 

2. Costs are considerably higher if site is remote and without electricity must bring in our portable generator to site. The portable analyzer requires electricity to run. 

Costs include mobilization, equipment set-up and take-down, van rental, travel 

costs, Calibrations of equipment, troubleshooting, three hours of actual test 

runs/engine. It generally will take a full day to test one engine, given the set-up time, calibrations before and after each. one hour test, and troubleshooting. 

An independent consultant to INGAA came up-with the somewhat more than the $3000/engine conclusion (about $5000/engine), who had not even read the INGAA 

comments. He identified all the same issues above, which made the INGAA comments 

even more creditable. One other medium size testing vendor offered a quote of als0 roughly the same estimate (see below). 

Here's an excerpt from the independent consultant and the company that he queried: 

"However, most testing firms would not contract to test a single RICE at that level since it takes time and money to mobilize. If the testing were for formaldehyde, the $1000 figure is low even if the site had multiple RICE to test. If the site was 

remote without electricity and involved testing of only one RICE, the $1000 figure is most likely low by a factor of 4 to 6. 

contacted a local testing firm in the LA area (XXX Testing) to get a handle on the probable costs to test. If testing included formaldehyde testing and the site 

was remote without electricity, the cost most likely would be in the $5000 to $6000 range. They indicated that the $1000 test cost quoted by-EPA would be for use of a hand held CO instrument-and the site was local with electricity. They 
indicated that testing at such a low dollar figure would likely be turned down by 

most established testing companies due tothe normal costs of preparation and 

reporting." (If you need the identity of the testing company, I'll see if Ican get 

permission.) 

In addition to these comments, in the June 2009 comments, IPAA estimated testing costs 

of $8,000 per engine, for oil & gas productionsites. I would presume these estimates are 

accounting for the fact that. these sites are remote, lack electricity, and that travel costs 

constitute a good proportion of the overall costs. 

What is EPA's response on these test costs? This would considerably raise the annual 

costs of testing for HP > 300. 

Instead of adopting a different standard for rural area sources between 300-500 HP, EPA 

could decide that 112(d)(5) will make retrofits and emission testing economically and 

technologically impracticable for area sources between 300-500 HP that are in remote 

locations and have no electricity. 
Excerpt INGAA Comments June 2009 Emission Testing Costs (p. 70) 

The cost analysis assumes that the cost to conduct a performance test is the portable analyzer testing cost of $1,000 per engine. The portable analyzer testing is for measuring CO emissions from gas-fired 4SLB and 2SLB engines. The testing requirement for fired 4SRB gas- engines is formaldehyde by FTIR. FTIR testing requires a fully equipped test trailer and testing costs are considerably higher than portable analyzer tests, on the order of $5,000 per engine and likely higher in some cases due to the remote location and related transportation and logistical charges. Because the majority of affected gas-fired engines are 4SRB,. testing costs for gas-fired engines are significantly underestimated. In addition, the cost analysis should consider that the listed .testing costs are only those for the outside testing contractor.and do not include operator testing support in terms of test plan preparation and other reporting, recordkeeping and test coordination requirements, personnel on-site during the testing (especially for unmanned facilities), and engine exhaust access (e.g., man-lift or scaffolding, stack modifications to provide ports and safe access). These operator-incurred costs and the assumotions used to determi ./. ne these costs 

snoum oe mciuaecl in the cost analysis. INGAA believes that EPA assumptions regarding numbers of co-located affected engines at facilities and associated testing cost reductions contribute to a significant underestimation of testing costs. In docket document no. 2008- 0708-0028, EPA appears to assume (i.e., the textis not clearly written) that all engines less than 500 hp are at a facility that has two engines less than 500 hp and that both engines can be tested for a total of $1,000. For engines >500 hp, the apparent assumption is that all enginesgreater than 500 hp are at a facility that has three engines greater than 500 hp and that all three engines can be tested for a total of $1,000. However, the first sentence of the performance testing states, "The cost of conducting performance testing is based on the cost of portable analyzer testing and is $1,000 per engine.". EPA has not provided documentation that affected engines are clustered at facilities as assumed and although INGAA agrees that some affected engines are co-located, the assumption that all affected engines are co-located and can be tested for the reduced cost is not consistent with normal operations and testing costs. Less co-location is especially common for oil and gas production. EPA should base any engine testing cost savings from co-location documented on engine population and proximity data. In addition, the assumption that three large engines can be tested for the same cost as the initial estimate of $1,000 per engine ignores basic emission testing time and logistical requirements. Testing one engine requires 3 one-hour test runs separated by analyzer calibrations, whereas testing three engines require 9 one-hour test runs separated by analyzer calibrations. Testing a large engine could require a man-lift or scaffolding to safely access the sample ports increasing time between tests. Considering travel to and from the engine site, equipment .set up and breakdown, pre- and post-test calibrations, and trouble-shooting, testing three engines in one day would be a challenge under ideal conditions.and additional test team costs for hotel, per diem, etc, would likely be incurred in most cases. The longer test day (i:e., more labor hours andoverhead Charges) would also directly increase testing costs. Similarly, the assumption that two small engines can be tested for the engine same $1,000 per cost is not realistic. Finally, it should be noted that testing timing and logistical assumptions that may be valid for simple portable analyzer testing will often not. apply to FTIR testing for formaldehyde; thus, FTIR testing costs require a separate and more 
detailed analysis. It is not apparent that subsequent (i.e., every 3 years.or 8,760 operating 

hours) performance tests for engines greater than 500 hp have been included inthe cost 

analysis. These costs and the assumptions used to armualize these Costs should be 

included in the analysis. 
RE: RICE package Population Statistics Ag Engines Bromberg, Kevin L. to: Higgins, Cortney 

Cc: Melanie King, "Zwicke, Greg Portland, OR", greg.johnson, RobertJ 

Wayland, Larry Sorrels, RobertJ Wayland 

02/16/2010 01:49 PM 

I believe I saw these before. I've already opened up the population spreadsheet. It still doesn't explain how, for example, EPA went from 712 CI ag irrigation •n•±nes (cell g7, CI SI summary page) (300-600HP) to 18 ag irrigation engines, as--I asked in an earlier email. My 

of engines 

note came after reviewing this. It does have all the different types (gen sets, irrigation, pumps, etc.) and I believe the total population -before dividing them further by industry sector but that is the missing piece (and perhaps a part about US vs. world division?). 

This may provide some more light about the ag engines (and others). 

Sorry about the email glut. 

Original Message 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] Sent: Tuesday, February i6, 2010 12:49 PM 

To: Bromberg, Kevin L. 

Subject.: FW: RICE package 

Apologies there's been such a glut of emails surrounding this rule, this email got lost in the mix. 

•Original Message 

From: King. Melanie@epamail.epa.;gov [mailto:King. Melanie@epamail.epa.gov] 

Sent: Friday, February 12, 2010 12:14 PM 

To: Higglns, Cortney 

Cc: Wayland. Robertj@epamail.epa.gov; Talcot£.Fred@epamail.epa.g0v; horowitz.michael@epamail.epa.gov Subject: RE: RICE package 

Hi Cortney, 

Glad you made it back in! 

next week? I hope not. 

Did I hear there was a chance of more snow 

.I sent you the impacts memo that Kevin requested. The underlying. information for the population estimates comes from the Power Systems Research population information that we receiged from OTAQ. Attached 

are the spreadsheets used.to generate the population estimates. (See attached file: OTAQ-PSR 1998 RICE pop-sales data.xls) (See attached file: CI Projection 2007-2017 by NAICS January 2009.Xls) 

Melanie K±ng 

Energy Strategies Group 

Sector Policies andPrograms Division 

Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919 541-2469 
Fax: (919) 541-5450 

king.meianie@epa.gov 

From 

l"Higglns, Cortney" <Cortney_Higgins@omb.eop.gov> 

> 

l.To: 

> 

Melanie King/RTP/USEPA/US @EPA 

>. 

Date 

"> 

02/12/2010 09:20 AM 

> 

Subject: 

> 

IRE: RICE package 

> 

Hi Melanie, 

Thanks for the update let me know when'it will come over. 

I'm in the office today! It's good to be back. 

Can you provide the memo (or send the citation for the memo) for the 

sector estimates of engines? 
ThankS, 

Cortney 

Original Message 

From: King. Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa.gov] 

Sent: Thursday, February ii, 2010 4:30 PM 

To: Higgins, Cortney• 

Subject: RICE package 

Hi Cortney, 

We're finishing up our latest roUnd of revislons to the RICE package. 

with 

It's been a bit of a slow go due to difficulties in getting in touch some of the EPA folks up in D.C. We should send you the revised package either later tonight or first thing tomorrow. 

Take care, 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 

Mail,Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 
SBA Reply to EPA re: Rural Engines 

SBA Reply to EPA re: Rural Engines Bromberg, Kevin.L. 

to' 

Melanie King, RobertJ Wayland, Peter Tsirigotis 02/16/2010 11:59 AM 

Cc: 

Show 

"Higgins, Cortney", "Amanda Lee", "Schwab, Margo", "Grahame, Thomas", "Daniels, Jarad" Details 

Page 1 of 3 

History: This message has been forwarded. 

SBA Reply to EPA re: Rural Engine Emissions 2/16/10 

Nothing 

emissions 

in the EPA response contradicts the point that most ground level carbonaceous PM2;5 diesel will not travel very far. Furthermore, we are focusing on very small rural emissions, sources of diesel 

travel 

engines with less than 500 HP. Zhu (2002) and other articl-es indicate that ultrafines do not very far. EPA acknowledges that ultrafines travel less than ten kilometers (Table 3-1, U.S. EPA, 2009c). Near ultrafines should be expected to travel further than ultrafines, but not as far as fine particles. Despite the fact that some ofthese particles also aggregate into larger particles, the overall pattern of localized travel for ground level diesel is still observed. 

Ito 

PM 

et 

2.5 

al (2004) demonstrates that sulfate levels show little variability across New York City, but traffic 

urban 

varied considerably. Rao et al also shows that most carbonaceous PM 2.5 is much higher in areas than in rural 

emissions 

areas.. Highway diesel emissions at ground level and RICE ground level diesel are likely to travel in a similar 

level PM2.5 diesel 

manner. These studies combine to support the idea that ground emissions from RICE engines or other certainly sources, are unlikely to travel far, and 

variab•ity. 

travel much less than PM2.5 from high stacks, such as sulfate emissions that shows little urban In sum, while the evidence is not definitive, it appears unlikely that the ground a significant portion of 

being 

level PM2.5 emittedfrom small RICE engines would travel more than several miles before 

1 

reaching background PM 2.5 levels. [Note:. the DOC retrofit only reduces PM emissions by about gram of PM per hour from 

idea that 

a single small engine]. EPA has presented no evidence that contradicts the most ground level PM2.5 emissions would not travel very far, although it is likely true that some small portion of the PM2.5 particulates can travel for tens of miles or more, given the appropriate 

file://C:•Documents and Settingskrnking04\Local Settings\TempLnotesFCBCEE\_web2734 2/17/2010 
SBA Reply to EPA re:-Rural Engines Page 2 of 3 

typography. 

If EPA chooses to uses.this information, it certainly has a substantial factual basis for addressing small 

rural engines far from nearby population in the same manner as emergency engines operating up to 1 O0 

hours in highly populated urban areas. 

Also, EPA needs to consider the suggestion below from DOE: 

Flnally, the language that EPA added (e.g., Language we have added to this 

RIA to address their concerns (excerpts):)is very detalled and ls qulte 

good. But it still doesn't address the fact that there ls substantial 

evidence that ground level PM2.5. concentratlons from sources such as dlesels 

don't travel far and thus are hlghly varlable across a metropolitan area. 

Because such ground level emlssi0ns are shown not to travel very far, e.g.., 

compared to sulfate, an addltlon sentence saying"Ground level emissions are 

less llkely to travel long distances than PM2.5 em±sslonsemitted 

substantiaiiy above ground ieveI, shouId be added. Aiso, a sentence shouid 

be added stating that due to uncertainies about iong distance transport, the 

range of caIcuiated benefits couId be substant±.aiiy wider. 

EPA also needs to properly qualify the below statement in the preamble at 

page 50. Perhaps, Tom Grahame can provide specific language: 

"PM emissions can travel tens or hundreds of miles from their source, 

so emissions from diesel engines in rural areas can impact urban 

populitions." 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin:bromberg@.sba.gov 

Visit Advocacy's website at http:llwww.sba.govladvo 

Sign up for Advocacy Email Alerts at http:llweb.sba.govIlist in order to receive via email: 

• Advocacy's Press Releases; 

• Advocacy's monthly newsletterThe Small Business Advocate; 

• Advocacy's Small Business Research; 

• Advocacy's Regulatory News. 

file://CADocuments and Settingskrnking04\Local Settings\TemphaotesFCBCEE\-web2734 2/17/2010 
SBA Reply to EPA re: Rural Engines Page 3 of 3 

To easily learn about and comment on important proposed regulations visit htt_p ://www.sba.gov/advo/laws/law .regalerts.htrnl 

Read the Advocacy Blog at http://weblog.sba.gov/blog.advo 

Subscribe to "What's New at Advocacy" RSS feed at http:llfeeds.feedburner.comlsbalrAlO 

file://C:•Documents and Settingshnking04\Local Settings\TemphaotesFCBCEE\-web2734 2/17/2010 
Population of Emergency/Non Emergency by Size Page 1 of 2 

Population of Emergency! Non Emergency by Size 

Bromberg, Kevin L. 

to: 

Higgins, Cortney, Melanie King, Larry Sorrels. 

02/12/2010 04:09 PM 

Show Details 

Melanle- we're trylng to use your earlier spreadsheet to calculate cost/engine- but we need to know the emergency/nonemergency split. conflrm these assumptions: Please 

1. We understand that at 500 and above- it is no longer 20/80% because 

engines 

emergency engines are not included above 500. So are all the major sources 

spreadsheet? 

at 500 and above all nonemergency and subject to retrofit in your 

2. And the ones under 500 HP- should be split 20/80%? In other words, the number of englnes belng retrofitted should be the number of englnes listed.divided by flve. 

"The reason the number of engines at major and area sources in the size categories you indicated below don't work out to a 40/60 split in Table 

4-7 is because the rule does not cover emergency engines >500 HP at major sources. So you are comparing non-emergency engines at major sources to all engines (emergency + non-emergency) at area sources, and therefore the split between major and area would not be 40/60." 

Kevin Bromberg 

Office of Advocacy 

U.S. Small.Business Administration 

file://C:kDocuments and SettingsXanking04\Local Settings\Temp•notesFCBCEE\-web4780 2/16/2010 
Population of Emergency/Non Emergency by Size Page 2 of 2 

409.Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.brom berg@.sba.qov 

Visit Adv.ocacy's website at http:llwww.sba.govladvo 

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file://C:•Documents and Settingskmking04\Local Settings\TempLqotesFCBCEE\-web4780 2/16/2010 
RE: RIA 

Bromberg, Kevin L. to: Melanie King Cc: 02/12/2010 03:3.1 PM "Higgins, Cortney" 

Thx I checked the 40/60 on some englnes below 500 HP and that looks right. 

Original Message 

Sent: 

From: King.Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa.gov] 'Friday, February 12, 2010 2:50 PM 

To: Bromberg, Kevin L. 

Cc: Higgins, Cortney; Zwicke, Greq_- Portland, OR; Sorrels.Larry@epamail.epa.gov; Tsirigotis. Peter@epamail.epa.gov; Wayland. Robertj@epamail.epa.gov Subject: RE: RIA 

Kevin, 

The 40/60% assumption was applied across the board. As we've discussed many times, we don't have enough detailed information these engines on the location of 

estimates. 

that would allow us to make more sector-specific 

categories 

The reason the number of engines at major and area sources in the s±ze 

4-7 is because 

you indicated below don't work out to a 40/60 split in Table 

major 

the rule does not cover emergency engines >500 HP at sources. So you are comparing non-emergency engines at major sources to all engines (emergency + non-emergency) at area therefore the split sources, and between major and area would not be 40/60. 

Melanle King 

Energy Strategies Group 

Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

From: 

__> 

l"Bromberg, Kevin L." <kevin.bromberg@sba.gov> 

To: 

-> 
IMelanie King/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA 

> 

Cc: 

"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>, "Zwicke, Greg Portland, 

OR" <greg.zwicke@por.usda.gov>, Larry 

Sorrels/RTP/USEPA/US@EPA, Peter Tsirigotis/RTP/USEPA/US@EPA 

> 

Date: 

> 

102/12/20.10 02:38 PN 

Subject: 

-> 

IRE: RIA 

To follow 6n to Cortney's question let's look for the derivation of 

the 40% major/ 60% area source assumption. 

As I recall, this is an assumption used in the AGT 2008? Population memo 

but just stated generally•across the entire CI engines. I don't 

recall seeing any discussion of whether this is applied differently 

across sectors but I •o see in the RIA that for some engines of 

different sizes different ma]or/area source percentages are applied in 

different industry sectors so the question is two fold where is the 

documentation of the different area/major source assumptions applied to 

each industry/size engine sector, and what is the basis for these 

determinations? 

Table 4.7: 

See breakout for utilities b•low: 
Major Area 

300-600 hp 42,113 97,919 600-750 h• 1,760 16,455 >750 hp 3,828 28,746 

than 

I agree with Greg Z. that it is much more likely that ag is much less 40% major source, for all size engines. 

-Original Message 

From: King. Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa.gov] 

Sent: Friday, February 12, 2010 2:24 PM 

To: Wayland. Robertj@epamail.epa.gov 

Larry 

Cc: Higgins, 

Sorrels; 

Cortney; Zwicke, Greg Portland, OR; Bromberg, Kevin L.; Peter Tsirigotis Subject: Re: RIA 

Cortney and Kevin, I'll be happy ro answer any questions about the population estimates, but I think it would be more productive if sent you 

Conference 

me them 

call. 

via email rather than trying to answer them during a 

Those estimates 

aren't 

were done about 3 years ago so they 

the 

very fresh in my mind, and also our contractor did the bulk of work so I may need to confer with them on some of the questions. I'm looking at the questions you've senz so far, let me know if there are others. 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Prozeczion Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king. melanie@epa, gov 

From 

-> 

RobertJ Wa yland/RTP/USEPA/US 

-> 

To: 

--> 
"Bromberg, Kevin L." <kevin.bromberg@sba.gov>, Melanie 

King/RTP/USEPA/US@EPA 

> 

> 

"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>, "Zwfcke, Greg 

Portland, OR" <greg.zwicke@por.usda.gov>, "Peter Tsirigotis" 

<tsirigotis.petef@epa.gov>, "Larry Sorrels" <sorrels.larry@epa.gov> 

Date 

02/1272010 02:15 PM 

> 

Subject 

> 

Re RIA 

> 

Kevln 

I'-m getting on an amrplane rfght now,'so I'm not available this 

afternoon. I apologize, but when I •lanned this trip, I thought we 

would be been done with RICE on 2/10. If the answers are 

straight-forward, perhaps Melanie or Larry can respond via email this 

afternoon. Otherwise, we{llneed to circle with Peter on Tuesday. 
Thanks! 

Bob 

Sent from Blackberry Wireless Device 

Dr. Robert J. Wayland 

U]S. EPA 

Office of Air Quality Planning and Standards 109 T.W. Alexander Dr±re, MC D243-01 

RTP, NC 27709 

Phone: (919) 541-1045 

Fax: (919) 541-5450 

Cell: (919) 306-2290 

From: "Bromberg, Kevin L•" [kevin.bromberg@sba.gov] Sent: 02/12/2010 02:01 PM EST 

To: Melanie King; Robertj Wayland Cc: "Higgins, Cortney" <Cortney Higgins@omb.eop.gov>; "Zwicke, Greg Portland, OR" <greg.zwicke@por.us•a.gov> Subject: RIA 

Thanks, EPA for the new spreadsheets showing population distribution information. I have a fsw questions. 

i. Irrig.ation Sets it appears that it irrigation assumes that 20% of sets > 300 HP are nonemergency I assume it should be all .nonemergency. EPA shows for 16 engines a capital cost of under $40,000, the capital cosz for each engine should be around $8000 according to EPA estimates. (table 4.7). 

2. I couldn't find in the spreadsheets the breakout by industry 

did 

sector 

EPA 

that •s in table 4-7 which spreadsheet and sheet has this? How 

of each 

decide 

size, 

how to allocate the gen sets, pumps and air compressors, for example, among industries? 

3. I did find a reference to 712 irr±gation pumps in the CI population statis[ics 

where these 

spreadsheet that were in the 300-600 HP range not allocared to agriculture? Did EPA assume 20% of 712 were nonemergency? 

Perhaps a cal.1 around 4 PM would be a good way to dispose of this and 
other related population questions. 

Table 4.7: Summary of Major Source and Area Source NAICS 

Costs for the CI RICE NESHAP by Number of Engines 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.bromberg@sba.gov 

Visit Advocacy's website at http://www.sba.gov/advo 

Sign up for Advocacy Email Alerts at http://web.sba.gov/list in order to 

receive v.±a email: 

Advocacy's Press Releases; 

Advocacy's monthly newsletter The Small Business Advocate; 

Advocacy's Small Business Research; 

Advocacy's Regulatory News. 

To easily learn about and comment on important proposed regulations 

visit h[tp://www.sba.gov/advo/laws/law_regalerts.html 

Read the Advocacy 81og at http://webl•g.sba.gov/blog-advo 

Subscribe •o "What's New at Advocacy" RSS feed at 

http://feeds.feedburner.com/sba/rAIO 
•: •i• RE: RIA 

Bromberg, Kevin L. o Melanie King, Zwicke,Greg Portland, OR 02/12/2010 03:59 PM 

Cc: "Higgins, Cortney", Lar•y Sorrels Peter Tsirigotis Robe•tJ Wayland 

Greg's point is to reduce both the costs and benefits for 100-300 HP, and I agree with Greg. I agree with you Cortney, it doesn't affect other 

think 

size engines. (> 300 HP ag engines, basically a null set to EPA but I that is wrong). 

Original Message 

From: King.Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa.gov] 

Sent: Friday, February 12, 2010 3:51 PM 

To: Zwicke, Greg Portland, OR 

Cc: Higgins, Cortney; Bromberg, Kevin L.; Sorrels.Larry@epamail.epa.gov; Tsirigotis. Peter@epamail.epa.gov; Wayland. Robertj@epamail.epa.gov Subject: RE: RIA 

Hi Greg, 

irrigation 

I don't disagree that the assumption may not be entirely accurate•for engines, like I've said we just don't have good information 

substantial 

to make t-hese 

impact 

estimates. However, I'm not sure it would make a 

if we said all the irrigation engines were area 

sources. In fact, I think it would reduce the cost, because for engines 100-300 HP, we'd be assumlng they are meeting management practices rat.her than the numerical emission limit that is required for major sources,, and they .wouldn't have to do a performance test since they were 

area sources. So the costs of control and performance testlng would decrease if those engines were moved from the major source column to the area source column. For engines >300 HP, and <i00 HP, the requirements 

difference 

are the same for major and area sources, so it wouldn't make a 

there. 

Melanie, King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail COde D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

From 

I"Zwicke, Greg Portland, OR" <greg.zwicke@por.usda.gov> 
To: 

> 

> 

IMelanie King/RTP/USEPA/US@EPA, "Bromberg, Kevin L." 

<kevin..bromberg@sba.gov> 

> 

Cc: 

>- 

l"Higgins, Cortney" <Cortney±Higgins@omb.eop.gov>, Larry 

Sorrels/RTP/USEPA/US@EPA, Peter Tsirigotis/RTP/USEPA/US@EPA, RobertJ 

IWayland/RTP/USEPA/US@EPA 

Date 

> 

102/12/2010 03:00 PM 

> 

Subject: 

IRE: RIA 

> 

Melanie, 

I think the 40/60% assumption for ag irrigation engines is way off. 

one ofthe calls last week, it sounded like EPA agreed that there 

wouldn't be very many•ag irrigation engines at major sources at all, 

On 
since there really shouldn't be many ag ma3or sources of HAPs. 

using 

I would 

5/95% 

expect 

in 

the real number to be close to 0/100%, but I could see 

looks 

the analysis, just to be sure some are covered. Since it like ag•irrigation engines at ma3or sources account for about 10% 

be 

of the total engines at major sources in the current-RIA, that seems to a pretty significant change that will impact the costs andbenefits substantially. 

Greg 

Greg Zwicke, P.E. 

Air Quality Engineer 

Air Quality and Atmospheric Change Team 

USDA-NRCS 

West National Technology Support Center 

1201 NE Lloyd Bl•d., Suite I000 

Portland, OR 97232 

Phone: (503) 273-2434 

Fax: (503) 273-2401 

E-mail: greg.zwicke@por.usda.gov 

Original Message 

From: King.Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa.gov] 

Sent: Friday, February 12, 2010 11:50 AM 

To: Bromberg, Kevin L. 

Cc: Higgins, Cortney; Zwicke, Greg Portland, OR; Sorrels.Larry@epamail.epa.gov; Tsirigotis. Peter@epamail.epa.gov; Wayland. Robertj@epamail.epa.gov Subject: RE: RIA 

Kevin, 

The 40/60% assumption was applied across the board. As we've discussed many timeS, we don't have enough detailed information these engines on the location of that would allow us to make more sector-specific estimates. 

The 

categories 

reason the number of engines at major and area sources ±n the slze 

4-7 

you indicated below don't work out to a 40/60 split in Table 

major 

is because the rule does not cover emergency engines >500 HP at 

sources. So you are comparing non-emergency englnes at major 

therefore 

sources to all engines (emergency + non-emergency) at area sources, and the split between ma3or and area would not be 40/60. 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Plannfng and Standards U.S. Environmental Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone.: (919) 541•2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 
From: 

> 

l"Bromberg, Kevin L. <kevin.bromberg@sba.gov> 

To: 

Melanie King/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA 

7--- 

> 

"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>, "Zwicke, Greg 

Portland, OR" <greg.zwicke@por.usda.gov>, Larry 

Sorrels/RTP/USEPA/US@EPA, Peter Tsirigotis/RTP/USEPA/US@EPA 

Date 

I02/I•/2010 02:38 PM 

> 

Subject: 
RE RIA 

To follow 

the 40% major/ 

on no 

60% 

Cortney's question let's look•for the derivation of area source assumption. 

As I recall, this is 

but just stated generally 

an assumption used in the AGT 2008? Population memo 

recall seeing across the entire CI engines. I don't any discussion of whether this is applied differently across sectors but I do diff•}ent sizes different see in the RIA than for some engines of major/area different industry source percentages are applied in sectors s$ documentation of 

the question is two fold where is the 

each industry/size 

the 

engine 

different area/major source assumptions applied to 

determinations? sector, and what is the basis for these 

Table 4.7: 

See breakout for utilities below: 

Major Area 

300-600 hp 42,113 97,919< 600-'750 hp 1,760 16,455 >750 hp 3,828 28,746 

than 

I agree 

40% 

with 

major 

Greg Z. that it is much more likely that ag is much less source, for all slze engines. 

Original Message 

From: King. Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa,gov] 

Sent: Friday, February 12, 2010 2:24 PM To: Wayland. Robertj@epamail.epa.gov 

Larry 

Cc: Higgins, 

Sorrels; 

Cortney; 

Peter Tsirigotis 

Zwicke, Greg Portland, OR; Bromberg, Kevin L.; 

Subject: Re: RIA 

population 

Cortney and 

estimates, 

Kevin, I'll be happy to answer any questions about the but I 9hink it would be more productive if sent me them via email rather you 

conference call. Those estimates 

than trying to answer them during a 

aren't very fresh in 

were done about 3 years ago so they 

the work 

my mind, and also our contractor did the bulk of so I may need to confer Wit-h them-on I'm looking some of the questions. at the questions you've sent so far .let are others. me know if there 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 
Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

From 

RobertJ Wayland/RTP/USEPA/US 

To: 

"Bromberg, Kevin L." <kevin.bromberg@sba.gov>, Melanie 

King/RTP/USEPA/US@EPA 

> 

l"Higgins, Cortney" <Cortney Higgins@omb.eop.gov>, "ZwiCke, Greg 

Portland, OR" <greg.zwicke@por?us•a.gov>, "Piter Tsirigotis" 

I<tsirigotis.peter@epa.gov>, "Larry Sorrels" <Sorrels.larry@epa.gov> 

Date 
102/12/2010 02:15 PM 

Subject 

Re: RIA 

Kevin 

I'm getting on an airplane rlght now, so I'm nor available this afternoon. I apologize, but when I planned this trip, I thought we 

would be been done with RICE on 2/10. If the answers are 

straight-forward, perhaps Melanie or Larry can respond via email this afternoon. Otherwise, we'll need tQ Circle with Peter on Tuesday. 

Thanks! 

Bob 

Sent from Blackberry Wireless Device 

Dr. Robert J. Wayland 

U.S. EPA 

Office of Air Quality Planning and Standards 

109 T.W. Alexander Drive, MC D243-01 

RTP, NC 27709 

Phone: (919) 541-1045 

Fax: (919) 541-5450 

Cell: (919) 306-2290 

From: "Bromberg, Kevin L." [kevin.bromberg@Sba.gov] Sent: 02/12/2010 02:01 PM EST 
To: Melanie King; Robertj Wayland 

Cc: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>; "Zwicke, Greg 

Portland, OR" <greg.zwiCke@por.usda.gov> 

Subject: RIA 

Thanks, EPA for the new spreadsheets showing population distribution 

information. I have a few questions. 

I. Irrigation Sets it appears that it assumes that 20% of 

irrigation sets > 300 HP are nonemerg•ncy I assume it should be all 

nonemergency. EPA shows for 16 engines a capital cost of under 

$40,000, the capital cost for each engine should be around $8000 

according to EPA estimates. (table 4.7). 

2. I couldn't find in the spreadsheets the breakout by industry 

sector that is in table 4-7 which spreadsheet and sheet has this? How 

did EPA decide how •o allocate the gen sets, pumps and air compressors, 

of each size, for example, among industries? 

3. I did find a reference to 712 irrigation pumps in the CI 

population statistics spreadsheet that were in the 300-600 HP range 

where these not allocated toagriculture? Did EPA assume 20% of 712 

were nonemergency? 

Perhaps a call around 4 PM Would be a good way to dispose of this and 

other related population questions. 

Table 4.7: Summary of Major Source and Area Source NAICS 

Costs for the CI RICE NESHAP by Number of Engines 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 
Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.bromberg@sba.gov 

Visit Advocacy's website at http://www.sba.gov/advo 

Sign up for Advocacy Email Alerts at http://web.sba.gov/list in order to receive via email: 

Advocacy's Press Releases; 

Advocacy's monthly newsletter The Small Business Advocate; Advocacy's Small Business Research; 

Advocacy's Regulatory News. 

To easily learn about and comment on important proposed regulations visit http://www.sba.gov/advo/laws/lawLregalerts•htm I 

Read the Advocacy Blog at http://weblog.sba.gov/blog-advo 

Subscribe to ."What's New at Advocacy" RSS feed at 

http://feeds.feedburner.com/sba/rAIO 
.•,,,.. Re: Fwd: FW: Annualized Costs CI engines • 

Melanie King o Kevin Bromberg 02/15/2010 11:40PM 

Cc: Larry Sorrels, RobertJ Wayland, "Higgins,Cortney", Ron Evans 

Kevin, 

Perhaps it would be helpful for you if lay out the elements of the costs and what they are per engine: The only one that is dependent on the engine size is the control cost, Also, one thing to keep in mind when you are looking at cost/ton is that when we are evaluating MACT or GACT, we arelooking at the cost/ton of the control device i•self and not incorporating other things like recordkeeping or reporting, 

Capital costs: 

-Capital costs for control device 

-You already have the formulas for the DOC and OCV capital costs 

-Capital costs for continuous parametric monitoring, applicable for non-emergency >500 HP -$560/engine 

Annual costs: 

-Annual cost of control device 

-You already have the formulas for the DOC and OCV annual cost 

-Annual cost of continuous parametric monitoring, applicable for non-emergency >500 HP -$2,583/engine includes one-time initial cost to purchase, install and ca librate, plus monthly recordkeeping 

.Performance testing -$582/engine 

-Intial test required for non-emergency engines 100-500 HP at major source, and non-emergency engines 300-500 HP at area source 

-Subsequent tests required every 3 years for >500 HP 

-Recordkeeping 

-one hour/year for everyoneat $72/hr 

-Reporting 

-No reporting required for emergency engines, engines <100 HP at major sources,rand engines <300 HP at area sources 

-$251/engine in first year of implementation for non-emergency >100 HP at major source an d non-emergency >300 HP at area source. Includes one-time costs for reading instructions and training personnel so would decrease in subsequent years. 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail Code D243-01 

RTP, NC 27711 
Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie•epa.gov 

Kevin Bromberg <kevin.bromberg@gmail.com> wrote: 

To: Larry SorrelslRTPIUSEPNUS@EPA 

From: Kevin Bromberg <kevin.bromberg@gmail.com> 

Date: 02/13/2010 05:08PM 

cc: Melanie KinglRTPIUSEPNUS@EPA, RobertJ WaylandlRTPIUSEPNUS@EPA, "Higgins, Cortney" 

<cortney_higgins@omb.eop.gov>, "Lee, Amanda I." <Amanda I. Lee@omb.eop.gov>, Ron 

EvanslRTP IUSEP NUS@EP A 

Subject: Fwd: FW: Annualized Costs CI engines 

Hi Larry thanks for the reply. 

Who at EPA did the calculations for the costs in Tables 4.4 in the RIA and didn't they use some 

formulas for calculating costs? This requires the annual costs and the capital costs for each size engine 

(and the number of engines). Or did the contractor do that? suspect Melanie didn't do this herself. 

was hoping it was you. If you can provide the spreadsheet for that Table that would probably have the 

formula in it. 

I'd also like to confirm the $61,000 •ost/ton figure for the 300-500 HP range (from the floor memo), which 

can do once can verify the cost formulas because we have the tons reduced .figures for each size 

range. 

Thanks 

Kevin 

Forwarded message 

From: Bromberg, Kevin L. <kevin.bromber.q@sba.gov> 

Date: Sat, Feb 13, 2010 at 3:06 PM 

Subject: FW: Annualized Costs CI engines 

To: •,evin.bromberg@gmail.com 

From: Sorrels.Larrv•.el•amail.el•a.•ov[SMTP:SORRELS. LARRY•,EPAMAIL.EPA.GOV] 

Sent: Saturday• February 13, 2010 3:06:53 PM 

To: Bromberg, Kevin L. 

Cc: Higgins, Cortney; Wayland.Robertl@epamail.epa:,qov; 

Kin.q Me an e@,epama epa..qov; Evans.Ron@,epama epa..qov 

Subject: Re:. Annualized Costs CI engines 

Auto forwarded by a Rule 

Kevin, 

have no information on how to estimate the costs•Of emissions testing, recordkeeping, and reporting 

Costs beyond what is in the Impacts memo prepared by SPPD's contractor. Melanie is better able to 

answer the question you have on "missing costs." Thanks. 

Larry Sorrels 

Economist 
US EPAIOAQPS/HEIDIABCG 

C439-02 

RTP, NC 27711 

(919) 541-5041 

fax: (919) 541-0839 

"Bromberg, Kevin L." <kevin bromberg(•sba.gov> wrote: 

To: "Higgins, Cortney" <Cortnev Hig_e ns@omb.eop.gov>, Larry SorrelslRTPIUSEPAIUS@EPA From: "Bromberg, Kevin L." <kevin.bromber(]•sba.gov> Date: 02/12/2010 03:15PM 

cc: RobertJ WaylandlRTPIUSEPAIUS@EPA, Melanie KinglRTPIUSEPAIUS@EPA Subject: Annualized Costs CI engines 

Larry do you have a formula we can use for calculating the annual costs of emission tests, recordkeeping and reporting for nonemergency CI engines > 300 HP? We only have the formula for the CI retrofit costs on page 3 .of the Impacts memo. 

know it is $68/hour for recordkeeping/reporting but don't have the•number of hours. And EPA assumed $583/engine for all sectors and sizes for emission tests? Was this for every three years? Any other missing costs? 

Thanks 

Kevin 

Kevi n Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-maih kevin.brom berflL•.sba.•ov 

Visit Advocacy's website at http://www.sba.fl ov/advo 

Sign up for Advocacy Email Alerts athttp://web.sba.flov/list in order to receive via emaih • Advocacy's Press Releases; 

• Advocacy's monthly newsletter The Small Business Advocate 

• Advocacy's Small Business Research; 

• Advocacy's Regulatory News. 

To easily learn about and comm ent on important proposed regulations visit http://www.sba ,qov/advo/laws/law re.qalerts.html 

Read the Advocacy Blog at http://weblog.sba.gov/blog-advo 

Subscribe to "What's New at Advocacy" RSS feed at http://feeds.feedburner.comlsba/rAI¢• 
ILIA Page 1 of 2 

RIA 

Bromberg, Kevin L. 

to: 

Melanie King, RobertJ Wayland 

02/12/2010 02:01 PM 

Cc: 

"Higgins, Cortney", "Zwicke, Greg Portland, OR" 

Show Details 

History: This message has been forwarded. 

Thanks, EPA for the.new spreadsheets showing population distribution information. 

questions. 

I,have a few 

1. Irrigation Sets it appears that it assumes that 20% of irrigation sets > 300 HP are nonemergency 

assume it should be all nonemergency. EPA shows for 16 engines a capital cost of under •40,000, the capital cost for each engine should be around •8000 according to EPA estimates. (table 4:7). 

2. couldnft find in the spreadsheets the breakout by industry sector that is in table 4-7 which 

spreadsheet and sheet has this? How did EPA decide how to allocate the gen sets, pumps and air 

compressors, of each size, for example, among industries? 

3. Idid find a reference to 71.2 irrigation pumps in the CI population statistics spreadsheet that were 

in the 300-600 HP range where these not allocated to agriculture? Did EPA assume20% of 712 were 

nonemergency? 

Perhaps a call around 4 PM -would be a good way to dispose of this and other related population 

file://C:kDocuments and Settingshnking04\Local Settings\Temp•aotesFCBCEE\~web3864 2/17/2010 
Page 2 of 2 

questions. 

Table 4.7: 

by Number of Engines 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.b romberg@,,sba.gov 

Visit Advocacy's website at htt_p://www.sba.gov/advo 

Sign up for Advocacy Email Alerts at http://web.sba.gov/list in order to receive via email: 

• Advocacy's Press Releases; 

• Advocacy's monthly newsletter The Small Business Advocate; 

• Advocacy's Small Business Research; 

• Advocacy's Regulatory News. 

To easily learn about and comment on important proposed regulations visit 

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Summary of Major Source .and Area Source NAICS Costs for the Cl RICE NESHAP 

file://C:•Documents and Settings•nking04\Local Settings\Temp•otesFCBCEE\Nweb3864 2/17/2010 
RE: Fw: Update on Effect of EPA's Draft Final Rule. Using RIA data from 

Table 4-4 on page 4-27 

Higgins, Cortney, Melanie King, RobertJ Bromberg, Kevin L, o 

Wayland, Michael Horowitz 02/09/2010 02:28 PM 

Cc: "Mancini, Dominic J.", "Maresca, Charles A." 

History: This message has been forwarded. 

Corrections and clarifications to my note-below. Thanks, EPA for the quick turnaround. 

Correction:. It should be $744 million, instead of $844 million, meaning th9 

proportion of costs in the 300-600 HP category of total capital costs is even 

higher. That was a typo. 

Correction: I overestimated the number of retrofits by a factor .of five, 

because I overlooked the fact that only 20% of these engines are nonemergency 

engines when I took the number of englnes from an EPA spreadsheet. Thanks, 

EPA for catching this. 

Clarification of the "zero to minimal benefits". The zero benefits refers to 

the specific benefits from the diesel retrofit }equirement on rural engines where no one resides within 300 meters of the englne. The minimal benefits 

refers to the emissions from limited use engines, whose annual output is one 

tenth or less than the average nonemergency engine (i000 annual operating hours). Both types of eng!nes could be regulated like emergency engines which 

also operate less than 100 hours per year. 

Clarification: .I wasn't trying •o compare annual costs and capital costs 

just illustrating the size of the retrofit problem. 

Comment: To be clear, we are overall ±n support of this rule We don't have 

data to contradict EPA's estimate that 95% of the englnes will nor be subject to retrofit. ,We only question whether some of the 5% warrant retrofits, and 

whether those engines should be treated-like emergency engines. 

Thanks again for considering our input. 

Kevin 

"As an example I pulled the data for 300-600 HP engines- of a total 

population of roughly 900,000 engines. The rural/limited use englnes are not 

just 5% of the rule. 

$397 million of the $844 million total in capital costs are from engines in 

the 300-600 HP (150,000 engines),• of which, it is very likely that more than• 

half of these costs are from rural and limited use engines. This means that 

over 75,000 englnes are likely over-regulated mn our v±ew. 

This is not just 5% of the rule. This is more than $200 million in 

capital costs in a single year where the environmen[al benefits are zero to 

minimal. This is a much larger problem than EPA has thought, with 

considerable costs." 
Original Message 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Tuesday, February 09, 2010 1:34 PM 

To: Bromberg, Kevin L. 

Cc: Mancini, Dominic J. 

Subject: Fw: Fw: Update on Effect of EPA's Draft Final Rule. Using RIA data 

from Table 4-4 on page 4-27 

Original Message 

From: Wayland. Robertj@epamail.epa.gov <Wayland. Robertj@epamail.epa.gov> 

To: King. Melanie@epamail.epa.gov <King. Melanie@epamail.epa.gov>; Higgins, 

Cortney 

Cc: Lamson.Amy@epamail.epa.gov •Lamson. Amy@gpamail.epa.gov>; 

Sor<els.Larry@epamail.epa.gov <Sorrels. Larry@epamail.epa.gov>; 

Johnson.Mary@epamail.epa.gov <Johnson. Mary@epamail.epa.gov>; 

Evans.Ron@epamail.epa.gov <Evans.Ron@epamail.epa..gov> 

Sent: Tue Feb 09 13:32:28 2010 

Subject: Re: Fw: Update on Effect of EPA's Draft Final Rule. 

from Table 4•4 on page 4-27 

Using RIA data 

Cortney 

Attached below is our collective response to Ke•in Bromberg•s earlier 

message regarding the limited use subcategory. As ou£1ined below, the 

Agency disputes the assertions made in Kevin's earlier email, and we 

have provided information to support the position we•ve taken which was 

discussed on this morning's call. If you have any questions on this 

information, please feel fr•e to call either Melanie or me. 

thanx! 

bob 

Dr..Robert J. Wayland, Leader 

Energy Strategies Group 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

Sector Policies and Programs Division 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-1045 

Cell: (919) 306-2290 

Fax: (919) 541-5450 

e-mail: wayland.robertj@epa.gov 

DRAFT/Deliberative Document FOIA Exempt 

Kevin Bromberg wrote: 

As an example I pulled the data for 300-600 HP engines.-.of a total 

population of roughly 900,000 engines. The rural/limited use englnes. 

are not just 5% of the rule. 
$397 million of the $844 million total in capital costs are from 

engines in the 300-600 HP (150,000 engines), of which, it is very likely that more than half of these •costs are from rural and limited use 

engines. This means that over 75,000 engines are likely over-regulated in our view. 

This is not just 5% Of the rule. This is more than $200 million in 

capital costs in a single year where the environmental benefits are z•ro 

to minimal. This is a much larger problem than EPA has thought, with 

considerable costs. 

Kevin Bromberg 

Office of Advocaqy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-ma•l: kevin.bromberg@sba.gov 

EPA's Response: 

The total estimated population of existing stationary CI 9ngines is 

936,000. The number of eng±nes that have emission standards based on 

the use of oxidation catalyst control is 44,000. Th±s represents the 

non-emergency engines >300 HP at major and area sources. That is the 

basis for 5% estimate 44,000/936,000 5%. The rural and limited use 

engines would certainly be some smaller subset of the 44,000 and 

therefore would be an even smaller percentage of the affected 

population. 

The estimated number of non-emergency engines at area sources between 

300-600 HP is 22,000. The number of engines that you presented below is 

not correct it is not 150,000 engines that will be installing emission 

controls. That total includes emergency engines, which do not have to 

install emission controls. So you are misrepresenting the affected 

population. 

We do not agree that the environment•l benefits are zero to minimal. 

The overall estimated reductions from the rule are 1,010 tons of HAP and 

2,800 tons of PM. For engines in the 300-600 HP range, the estimated 

reductions are 530 tons of HAP and 1,500 tons of PM. 

The total capital cost of the rule is $744 million, not $844 million. 

Also, the vast majority of costs are for RICE classified using the PSR 

database as in the electric power sector as we state in Section 5 of the 

RIA already. Our analysis of economic impacts and energy impaczs 
already show that this industry is not heavily impacted (almost all 

entities affected in the sector under 1% cost to their sales a measure 

of impact that SBA and EPA advises we use in small enti[y analysis). 

The total capital cost to all engines in the 300-600 HP size range is 

$398 million, and affected RICE have 3 years to install the needed 

controls. In addition, bur economic impact analysis does not show this 

will yield a significant impact to affected entities. It is annual cost 

that is critical to estimating economic impacts,, not the one-time 

capital cost. Finally, the 1,500 tons of PM2.5 reductions that is 

taking place from this rule for engines 300-600 HP is an annual emission 

reduction] nor a one-time PM2.5 reduction. You shouldn't.-compare 

capital cost estimates directly to an annual benefits estimate. 
Urban/Rural Breakout Is it really 17% rural? 

Bromberg,. Kevin Melanie.King, Michael Horowitz, RobertJ L. o 

Wayland 

Cc: "Higgins, Cortney", "Lee, Amanda I.", "Schwab, Margo", "Grahame, 

Thomas", steven.crockett 

02/04/2010 03:45 PM 

In a previous call, I believe EPA was going to prqvide ±nformation on the 9ural/urban split, but I may be wrong- and I' 

ve not seen it. This is what EPA wrote below in the preamble. I 

would like to see the documentation for the 17% estimate. 

"EPA does not believe that existing stationary CI engines are 

more prevalent in rural areas than in urban areas Indeed, EPA estimates that only 17 percent of stationary CI area source 

engines subject to the rule are located in rural areas, using the 

d:efinitions used in the Urban Air Toxics Strategy."Draft 

Preamble, p. 48 

From what I can tell the large number of nonemergency engines come 

only from oil & gas, and irrlgation, which I would expect to be 

about 90% rural. So I don't understand where the 17% figure would. 

come from. Even the emergency engines for utilities (I000 power 

plants), I would guess, are mostly rural. The hospitals are very urban oriented, but I expect these to be entirely emergency 

engines, nor would they contribute much to a 17% rural average. I 

don't know the number or distribution for welding activities. (IT he natura• gas distribution industry presumably uses almost 

entirely SI engines, so I{m not counting them here]. 

In fact, we need to focus on thenonemergencyrural/urban ra•io for area sources- because those are the only sources that are 

subject to the emission limits (emergency engines have no limits) Then, we're really only considering irrigation and oil& gas in terms of large numbers of englnes, and that should be 

predominantly rural, not 17% rural. We don't object to the 

rural engines being subject to the same work practices as 

emergency engines. 

We also believe tha• subjecting oil & gas facilities to emission 

limits is inconsistent with l12(n) (4) (B) of the CAA, as we raised 

earlier and as several •ommentershave pointed out, which indicates that EPA should not be regulating O&G in urban .areas 

only. Regulating RICE engines at rural O&G facilities would be regulating O&G activities in rural areas. 
What we really could use is to determine what portion of the 

nonemergency.universe is rural, and not just the overall,CI 

engines- although it's not clear to me that the emergency 

engines are much more urban. I look forward to seeing the 

documentation on the 17%. 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202,205-6928 

E-maih kevin.brom ber•_sba.gov 

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Existing CI RICE NESHAP costs and emission reductions by HP range 

1-13-10 (3) KB EDIT 102810 (Autosaved).xls 

Bromberg, RobertJ Wayland, Melanie King, Michael Kevin L. o 

Horowitz 

Cc: "Higgins, Cortney", steven.crockett, "Grahame, Thomas", "Schwab, 

Margo", "Lee, Amanda I." 

02/04/2010 01:45 PM 

This is in responseto Bob Wayland's request. We're using EPA estimates for emission 

reductions, number of engines, and average hours of operation for nonemergency engines. 

<<Existing CI RICE NESHAP. costs and emission reductions by HP range 1-13-10 (3) KB EDIT 102810 

(Autosaved).xls>> 

Look at sheet 3 for the comparisons with limited use engines and rural engines used •;250/I b as the point benefits estimate. ($500,O00/ton)• 

At 100 hours, all size limited use engines cost more than $250/Ib. EPA already excludes limited use enginesat100 hours/year for engines above 500 HP. Why should we 

treat smaller engines differently? 

Kevin Existing CI RICE NESHAP costs and emission reductions by HP range 1-13-10 (3) KB EDIT 102810 [Autosaved).xls 

Summary of Major Source and Area,Source Emission Reductions for the RICE NESHAP Size Range (HP) Emission Reductions (tpy) 

Major Sources 

50-100 

100-175 

175-300 

300-500 

500-600 

600-750 

>750 

Total 

Area Sources 

50-100 

100-175 

175-300 

300-600 

600-750 

>750 

Total 

Total 

Number 

of 

HAP CO PM SO2 VOC Engines 

0 0 

44 2,072 

57 1,571 

145 2,362 

18 209 

11 107 

36 236 

312 6,558 

0 

123 

161 

4O7 

50 

31 

102 

.874 

0 

229 

301 

761 

93 

58 

190 

1,632 

0 92,734 

1,183 121,507 

1,549 92,144 

3,923 48,481 

478 4,298 

300 2,200 

982 4,853 

8,416 366,217 

0 0 0 

0 0 0 

0 0 0 

368 5,314 1:031 

92 891 259 

243 1,578 680 

703 7,784 1,970 

1,014 14,342 2,844 

0 

0 

0 

,712 

484 

,271 

3,467 

5,100 

0 127,973 

0 167,679 

0 127,159 

9,930 100,355 

2,497 16,822 

6,553 29,802 

18,980 569,790 

27,395 936,007 

Pounds 

PM/Eng 

0 

2.0 

3.5 

16.8 

23.1 

28.4 

42.0 

4.8 

0.0 

0.0 

0.0 

20.5 

30.8 

45.7 

6.9 

6.1 
Summary of Major Sour Pounds Limited Rural 

Number 

Size Range of 

(HP) Engines 

Major Sources 

PMIEng 

50•100 92,734 0 

100-175 121,507 2.0 

175-300 92,144 3.5 

300-500 48,481 16.8 

500-600 4,298 23.1 

600-750 2,200 28.4 

>750 4,853 42.0 

Total 366,217 4.8 

Area Sources 

50-100 

100-175 

175-300 

300-600 

600-750 

>750 

Total 

127,973 

167,679 

127,159 

100,355 

16,822 

29,802 

569,790 

Overall 936,007 Total 

Number 

of 

Engines 

Cap Ann Annual Min. Delivered 

Cost/Eng Cost/Eng Costllb Cost/Ib Costllb 

92,734 $0 $72 

121,507 $198 $320 $160 $1,600 

92,144 $390 ,$355 $101 $!,014 

48,481 $2;224 $790 $47 $470 

4,298 $3,054 $1,401 $61 $606 

2,200 $3,746 $1,527 $54 $538 

4,853 $5,544 $1,856 $44 $442 

366,217 $590 $368 $77• $768 

20.5 

30.8 

45.7 

6.9 

127,973 

167,679 

127,159 

100,355 

16,822 

29,802 

569,790 

$0 $72 

$0 $126 

$0 $126 

$2,718 $1,094 $53 $534 

$4,071 $1,686 $55 $548 

$6,026 $2,044 $45 $447 

$914 $431 $62 $625 

6.1 936,007 $787 $406 $67 $666 

Average Benefit/Ib $250 (assuming $500,000/ton) 

Limited Use -Assume Max. of 100 hours 

Corn pared to 1000 average CI non-emergency engine 

Rural Delivered Cost/Pound assum es benefit in rural settings 1/400 

of benefit in urban setting API derived population densities 

With about 75% urban population, virtually all of the benefits are driven 

by the urban engines the'rural engines at 1/400 the risk reduction 

is barely noticeable 

$21,351 

$21,902 

$17,887 

$24,980 

$26,653 
RE: Questions for 12:30 RICE Call (as promised yesterday) Page l of 3 

RE: Questions for 12:30 RICE Call (as promised yesterday) Bromberg, Kevin L. 

to: 

Melanie King, RobertJ Wayland, Michael Horowitz 

02/04/2010 12:14 PM 

Cd: 

"Higgins, Cortney", "Lee, Amanda I.", "Grahame,Thomas", steven.crockett 

Show Details 

Correction on Item III that was the 100-300 HP limit (157 ppmvd CO), not the 300-500 HP limit, as 

EPA probably already knows, 

Thx 

Kevin 

From-" Bromberg, Kevin L. 

Sent= Thursday, February 04, 2010 11:09 AM 

To= •ng.Melame@epamail.epa.gov; VVayland.Robe•@epamaiI.epa.gov; horowitz.michaeI@epa.gov Cc: Higgins, Cor•new Lee, Amanda I.• Grahame, Thornas• steven.crockett@nrc.gov S,,bject: Questions for 12:30 RICE Call (as promised yesterday) 

I. :Retrofit Costs 1/29 DOC Cost Memo and 2000 CARB Memo 

CARB Memo- has EPA attempted to update the 2000 catalyst costs or the maintenancecosts? Do CARB maintenance costs account for unmanned facilities w/o electricity? Won't it be more costly to do thermal cleaning of the DOC, at a remote facility that is unmanned? 

In the Control Cost memo, EPA assumed an installation cost ors 3000 (direct and indirect costs) for a 

DOC for a 400 HP engine. This appears to be based on a methodology from an EPA control manual that assumes that the installation cost is only 58% of the equipment cost (PEC purchased equipment cost). 

file://C:\Documents and Settingskmking04\Local Settings\TempkqotesFCBCEE\•web3468 2/17/2010 
RE: Questions for 12:30 RICE Call (aspromised yesterday) Page 2 of 3 

Does this account for: retrofit in remote locations, retrofit for unmanned locations, no electricity (are we 

driving the engine to a shop?); difficulty of working with engine housing, or working in tight spaces? 

contracted out installation? 

II. Annual Costs RIA 

Why does EPA exclude the maintenance-costs for oil change, belt check, and other engine-related 

maintenance (RIA page 4-23)? Commenters who wish to follow the manufacturer recommendations 

will be forced to rely on the EPA-mandated frequencies, and may no.t seek or get,approval from state 

permit authorities for an alternate schedule. This would be particularly costly for unmanned sites 

without electricity. 

III. When will the MACT Floor and Above the Floor Memoranda be released for review? 

In particular, weare concerned with the 300-500 HP emission limit, that is based, I believe from a single 

test on a single engine. This limit, I believe, was not modified for variability, unlike the other two 

emission limits. 

IV. Limited Use Engines 

From the UARG list of limited engines, does EPA have an estimate of the number of engines, size of 

engines and operating hours for 

Generators used to provide voltage support in remote areas 

Generators at power plants to support peak loads 

Generators and diesel compressor engines used during planned outages, especially at nuclear power 

plants 

Irrigation Engines (not from UARG list)? 

V. What is the amount of diesel emissions used by the•vendor to drive out to the site to retrofit the 

diesel engine and perform the initial and follow-up emission tests compared to the emission reductions 

achieved solely by the addition of the DOC (not including the USLD change)? 

VI. Under the draft final proposal, a 500 HP nonemergency diesel engine is estimated by EPA to 

reduce emissions by 20 lbs/1000 working hours or .02 lbs/hr or 1 gram/hr. How far would this one gram 

travel, given a typical typography and weather, andthat the expected height of these engines is about 5 

feet high or less? How many people wouldlive within this range in rural areas? How would the 

estimate of the range of benefits of the 1.1- 2.6 billion dollars be revised if all the engines were located 

file://C :kDocuments and Settingskmking04\Local Settings\TempknotesFCBCEE\-web3468 2/17/2010 
RE: Questions for 12:30 RICE Call (as promised yesterday) Page 3 of 3 

in rural areas, vs. 

is approximately. 

all the engines being located in urban areas? Rural areas have population density that 1/400 of the urban areas. Isn'tthis cost range more appropriate for. urban isn't 99%-• areas, and of the benefits derived solely from the sources in urban areas? (Given that each source in rural a area would contribute roughly 1/400 of a source in rural an urban area, even with 85% rural sources, the 

observations 

sources would still contribute under 1% of total benefits) This illustrates why Tom Grahame's yesterday were important. Therefore, isn't it reasonable to have a different approach for engines that operate in rural areas, even wittiout a more detailed risk assessment? 

EPA's Statement from the 2007 Dehydrator Rule: 

'"'Since the areas located outside UA plus offset and UC boundaries those inside UA plus are sparsely populated compared to offset and UC boundaries, extending we do not believe the additional cost associated with the add-on control requirement to sourcesqn this area is justified." 

VII. SSM Sources may not be able to shutdown unit a malfunctioning unit immediately because (1) the must continue to run in order to diagnose the malfunction, or (2) it may by unsafe (possible explosion hazard, for example) to shut the unit down. too quickly. Could 63.6(g) for a source petition under 40 CFR an alternate work practice standard to address this issue? Can the incident? you use this retroactively after 

Does it make more sense to modify the malfunction standard by rule to account for excursions like the above? 

file://C:kDocuments and Settingshnking04\Local Settings\TempknotesFCBCEE\_web3468 2/17/2010 
RE: Electric Power Peak Shaving Bromberg, Kevin L. to: MelanieKing Cc: Michael Horowitz, RobertJ Wayland 

02/03/2010 02:32 PM 

Will check on that. 

Original Message 

From: King. Melanie@epamail.epa.gov [mailto:King. Melanie@epamail.epa.gov] Sent: Wednesday, February 03, 2010 2:31 PM 

To: Bromberg, Kevin L. 

Cc: horowitz.michael@epamail.epa.gov; Wayland. Robertj@epamail.epa.gov Subject: RE: Electric Power Peak Shaving 

Did they provide any indicat,ion of the typical s±ze of these engines? Also, are they stationary? 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency' 

Mail Code D243:01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

From 

l"Bromberg, Kevin L." <kevin.bromberg@sba.gov> 

--> 

To: 

IMelanie King/RTP/USEPA/US@EPA 

Cc: 

.> 
Michael Horowitz/DC/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA 

Date 

> 

I02/03/2010 02:27 PM 

Subject: 

RE: Electric Power Peak Shaving 

Response from NEI agrees with odr guesses below RICE during outages 

inCludes planned events, thus would not qualify f•r the emergency 

definition. 

This category covers cases where normal power sources are unavailable 

or inadequate to meet power needs •uring a planned outage. An example 

would be use of diesel air compressors to supplement normal plant air 

supplies in instances where outage work would otherwise strain normal 

sources. The air compressors, in this example, would be non-emergency 

limited use engines used to address planned outage activities." 

Original Message 

From: Bromberg, Kevin L. 

Sent: Wednesday, February 03, 2010 12:47 PM 

To: 'King.Melanie@epamail.epa.gov' 

Cc: horowitz.michael@epamail.epa.gov;.Wayland. Robertj@epamail.epa.gov 

Subject: RE: Ele•tric Power Peak Shaving 

"Emergency stationary RICE means any stationary R•CE whose operation is 

limited to emergency s{tuations and 

required testing and maintenance. Examples include stationary RICE used 

to produce power for critical networks 

or equipment (including power supplied to portions of a facility) when 

e•ectric power from the local utility (or the 

normal power source, if the facility runs on its own power production 

is interrupted, or Stationary RICE used 

to pump water--in the case of f{re or flood, etc. Stationary RI-CE used 

for peak shaving are not considered emergency 
stationary RICE. Stationary ICE used to supply power to an electric grid 

or that supply power as parr of a financial 

arrangement with another entity are not considered ro be emergency 

engines." 

Given this definition, I would tend to agree with regard to the back-up 

power engines listed below. RICE during outages may be frequent enough 

to net meet this definition. 

Of course, my point is that I doubt that EPA can identify all the 

limited use engines, such that it should not separately.provide for 

them. We know there are irrigation pumps and utility engines .that are 

nonemergency limited use, among others. 

Original Message. 

From: King. Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.goV] 

Sent: Wednesday, February G3, 2010 12:06 PM 

To: Bromberg, Kevin L. 

Cc: horowitz.michael@epamail.epa.gov; Wayland. Robertj@epamail.epa.gov Sub3ect: Re: Electric Power Peak Shaving 

Hi Kevin, 

Could you providelsome.more context as to why it is believed that the 

following engines that NEI listed wouldnor be considered emergency 

engines: 

RICE that provide back-up power, to critical information technology infrastructure, 

RICE that provide back-up power to emergency support facilities, and 

RICE that provide back-up fire suppression water. 

Generally I thinkof an engine that provides back-up power as an 

emergency engine. Are you saying that they provide back-up power during times other than emergencies? 

On the "RICE used during outages" are those engines used to provide 

emergency power at all, or is the usage• limited to providing power 

during planned outages? 

Thanks, 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail Code D243i01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

From 

.> 
l"Bromberg, Kevin L." <kevin.bromberg@sba.gov> 

To: 

> 

IMelanie King/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA, 

Michael Horowitz/DC/USEPA/US@EPA 

Date 

> 

I01/29/2010 04:32 PM 

Subject 

> 

Electric Power Peak .,Shaving 

> 

What are we doing with these non-emergency engines are these subject 

to limits? See comments of NEI below. These are subject to limits, 

yes? 

2. EPA Should Expand the Subcategory of Limited Use Engines 
Under the current rule, RICE that have a rating of more than 500 HP and are located a.r major sources do not need to-comply with emissions limits if they qualify as limited use engines. 40 C.F.R. • 63.6600(c). "Limite.d use" 

year." 

includes any stationary RICE that operates less than I00 hours per Id. • 63.6675. 

EPA •id nor propose any revisions to • 63.6600, nor-did it propose to extend the exclusiJon of limited use RICE to include engines at or below 500 HP or engines located a[ area sources. NEI believes that EPA should revise the limited use exclusion to include all sizes of regulated engines, area sources in addition to major sources, and expand the definition of limited use to include•operation Such 

up co 300 hours per year. units should also be exempt from performance te@ting and only be obliged to maintain and report records of annual operating hours co show that they qualify as limited use RICE. 

In proposing the current limited use provision, the Agency explained that it would apply to "engines used for electric power peak shaving" that "operate only during peak energy use periods, typically in the 

summer months" (67 FR77851). The main categories of non-emergency "limited-use" engines operated at nuclear power station include: 

RICE that provide black-starz capability to the facility, 

RICE that provide back-up power to critical information technology infrastructure, 

RICE used during outages, 

and 

RICE that provide back-up power to emergency support facilities, 

RICE that provide-back-up fire suppression water. 

RICE installed at nuclear power station should be allowed a "limited use" exemption. 

NEI concurs with the UARG letter (dated June 3, 2009) and its associated comments ,that support an expansion for limited use RICE. 

Cribbed from NEI Comments 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 
409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.bromberg@sba.gov 

Visit Advocacy's'website at http://www.sba.gov/advo 

Sign up for Advocacy Email Alerts at http://web.sba.gov/list in order to 

receive via email• 

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History: 

RE: NonEmergency Limited Use Engines 

Bromberg, Kevin L. o Melanie King 

"Hi gg•ns, Cortney", RobertJ Wayland, Michael Horowitz• "Maresca, 

Cc: Charles A.", "Grahame, Thomas", "Lee, Amanda I.",•Michael 

Horowitz 

02/03/2010 10:31 AM 

This message has been forwarded. 

Melanie, thanks for pointing out the size of these engines, which was not focused on. 

Mr. Gaskill, of course, doesn't know.that EPA is not promulgating m ts .for area source engines <300 HP 

-.that is confidential information. And thankfully, would suspect that a large proportion of the limited 

use engines are <300 HP. But EPA decided to exempt only one class of limited engines by name -the 

"black start" CI engines, rather than the many classes of limited engines which is of unknown scope 

and number. don't see an analysis of the other classes of limited engines that are > 300 HP that would 

be captured by EPA's draft final rule. UARG and NEI collectively provided a list of about 8 Or more 

different limited use engines. Other commenters may have listed others. Why should they be treated 

differently? Why not have a 300 hour cutoff? Or at least the 100 hour cutoff? 

was trying to make two points with the Gaskill email: (1) the number of type of limited use engines is 

unknown and may be fairly large and (2) another difficulty of retrofitting is interference with engine housing, addressed below. was trying to say that there are man•/reasons for exempting limited use 

engines from emission limits. Given that limited use engines >500 HP at major sources do not have 

limits, failure to address the other classes of limited use engines (other than "black start") is 

inconsistent. 

From= King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov] Sent: Tuesday, February 02, 20:[0 8:08 PM 

To: Bromberg, Kevin L. 

Cc: Higgins, Cortney; Wayland.Robert-j@epamail.epa.gov; horowitz.michael@epamail.epa.gov; Maresca, Charles A.; Grahame, Thomas; Lee, Amanda •[.; horowitz.michael@epa.gov Subject; Re: NonEmergency Limited Use Engines 

Hi Kevin, 

Could you clarify w•hat youare suggested should be required for these engines? Mr. Gaskill states in his email that the wind engines are 150-200 HP. If those engines are located at area sources, then they are 

not.subject to emission limitations since they are <300 HP, they are subject to management practices. He also mentions that few of the irrigation pumps are larger than 300 HP, so again in that instance they would not be subject to emission limitations. 

Thanks, 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail Code D243-01 
RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie(•epa..qov 

"Bromberg, Kevin L." <kevin.bromberg@sba.gov> wrote: 

To: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>, Melanie KinglRTPIUSEPNUS@EPA, RobertJ 

WaylandlRTPIUSEPNUS@EPA, Michael Horowitz/DC/USEPNUS@EPA 

From: "Bromberg, Kevin L.". <kevin.bromberg@sba.gov> 

Date:-02/02/2010 05:28PM 

cc: "Maresca, Charles A." <Charles.Maresca@sba.gov>, "Grahame, Thomas" 

<Thomas.Grahame@HQ.DOE.GOV>, "Lee, Amanda I." <Amanda_l._Lee@omb.eop.gov> 

Subject: NonEmergency Limited Use Engines 

This note is an example of why I'm particularly interested in limited .use engines. Even the irrigation 

pumps often use limited use engines- which didn't realize. Most apparentlywill be mobile and not 

covered, but others wil/be stationary. We don't want people just putting these engines on wheels to 

escape regulation when these engines are very similar to emergency engines that .will not require 

retrofitting: Furthermore, many of these limited use engines are in rural areas (e.g. irrigation pumps) 

where the benefits are much lower. 

Ais0, although EPA did exclude one identified limited use engine those used to start combustion 

turbines -it is really efficient to list all the limited use engines by category. There are rhany, and several 

probably unknown to EPA- see the wind machine example below. 

In my mind, the only real issue is whether 100 hours or 300 hours should cover these smaller engines, 

given that EPA has excluded limited Use engines of 100 hours to 500 HP and above. We could use more 

information about the operating hours for these engines. 

Kevin 

From: Ron Gaskill [mailto:rong@fb.org] 

Sent: Monday, February 01, 2010 2:25 PM 

To-" Bromberg, Kevin L. 

Subject; Non Emergency Limited Use. Engines 

Thanks Kevin, I was just going to write you a note on this subject. 

In agriculture the main use of limited use engines will be on irrigation pumps most will be CI 

though a few could be SI and the number of hours Will vary annuallyby need: from 0 to a 

several hundred hours per season. Few will be over 300 hp. Rarely will they run year-round and 

rarely will they run 24 hours per day. Most irrigation pumps are on wheels and portable, so the 

proposed RICE rule for stationary engines doesn't apply to them which is even more reason to 

except the limited use of the few stationary types that exist. 

An even more limited use engine in agriculture will be on wind machines that are permanently 

placed in orchards for the purpose of protecting sensitive crops against frost during the bloom 

period. There are at most only a couple of thousand of these in existence across the country, 

mostly in California and the Pacific Northwest. The engines are small, maybe 150-200 hp. They 
power a large rotor, similar to a small helicopter rotor only vertically oriented, not horizontal, to move large volumes of air. They are equally CI and SI because they're used so sparingly- maybe 50-60 hours a year. 

In both of these examples, retrofit with emission control equipment will be confined constricted by the engine housing. or 

Many of these engines are older because it takes several to expend their useful life. years An extreme case in point is my father, who still runs an irrigation 

of 

pump.with 

parts that 

a 

he 

1950 Caterpillar diesel engine because it doesn't quit. He eventually will.run out can no longer buy, so he'll have no choice but to get a new one. But in the meantime you can't convince him that there's any reason to spend thousands of dollars engine when the existing on a new 

one is purring just as it should. And he's not alone in his thought. 

Thanks for your advocacy on this Kevin, it's much appreciated as is all the work you do environmental issues on 

on behalf.of small business. 

Ron 

Ronald L. Gas•'ll, Senior Director 

Congressional Relations for Labor & Environment American Farm Bureau Federatiot• ® 

600 Maryland Ave., SW; Suite IO00W 

Washington, D.C. 20024 USA 

Phone (202) 406-3674 Fax (202) 406-3604 

Cell (202) 213•0179 E-mail: rong@/b.org 
History: 

RICE Limited Use Engines at Nuclear Power Plants Non- Emergency Engines 

.Bromberg, Kevin L. Higgins, Cortney, Melanie King, Michael o. Horowitz, RobertJ Wayland 

Cc: "Grahame, Thomas", "Lee, Amanda I." 

This message has been forwarded. 

02/01/2010 12:28 PM 

<<06-03,09_EPA_lndustry Comments on Proposed EPA Rule for RiCE.pdf>> 

As promised, these are the limited use non-emergency engines at nuclear power plants. Full NEI letter is attached. 

EPA did exclude the first category (black-start capability) but think, all the others are not excluded by the RICE rule. We recommend that all limited use engines follow the same practices as emergency engines. 

"The main categories of non-emergency "limited-use" engines operated at, nuclear power station include: 

RICE that provide black-start capability to the facility, 

RICE that provide back-up power to critical information technology infrastructure, 

RICE used during outages, 

RICE that provide back-up power to emergency support facilities, and 

RICE that provide back-up fire suppression water. 

RICE installed at nuclear power station should be allowed a "limited use" exemption." 

06-03-09._EPA_lndustry Comments on Proposed EPA Rule for F] ICE.pdl 
HU{]EEAi• EHEi•GY INSTITUTE 

John C, Butler 

D•RECTOR 

OPERATfONS SUPPORT 

NUCLE•,R GENERATION DWISfON 

June 3, 2009 

Air and Radiation Docket and Information Center 

Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Mail Code 6102T 

Washington, DC 20460 

Subject: NEI Comments on Proposed EPA Rule for National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (74 Fed. Reg. 9698 (March 5, 2009)) Docket ID No. EPA-HQ-OAR-2008-0708. 

The 

the 

Nuclear Energy Institute (NEI) appreciates the opportunity to provide comments on behalf of nuclear industry on the proposed rule for National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (Docket ID No. EPA-HQ-OAR-2008- 0708). 

NEI members include all entities licensed to operate commercial nuclear power plants in the United States. Each of the 104 nuclear power plants in the United States utilizes reciprocating internal combustion 

in the 

engines (RICE) for the purposes of providing electric power to critical plant components event of a plant emergency or loss of electric power. As discussed below, NEI has a number of concerns with the proposed rule and its potential impact on both emergency use and limited RICE at nuclear use 

power plants.- 

N EI.is the organization responsible for establishing unified industry policy on matters affecting industry, including the regulatory the nuclear energy 

entities licensed 

aspects of generic operational and technical issues. NEYs members include all 

architect/engineering 

to operate 

firms, 

commercial nuclear power plants in the United States, nuclear plant designers, .major 

involved in the nuclear 

fuel fabrication facilities, nuclear materials licensees, and other organizations and entities energy industry. 

17761Street. NW Suite400 Washington, DC 20006-3708 P:202.7398108 F:202,533.0113 jcb@nei.org www.nei.org 
Air and Radiation Docket and Information Center 

June 3, 2009 

Page 2 

1. EPA Should Createand Exempt a Subcategory of RZCE at Nuclear Power Plants 

Every nuclear Power plant in the U hired States utilizes reciprocating internal combustion engines 

(RICE) for the purpose of ensuring safe operation and shutdown of the nuclear reactor by providing 

back-up power to critical systems (e.g., cooling water, fire protection, security) and to emergency 

support facilities. In most cases, these RICE are required by the United States Nuclear Regulatory 

Commission (NRC) and comply with strict regulatory requirements. It is critical that the proposed 

EPA requirements do not interfere with. or jeopardize the critical safety functions of these RICE. 

Emergency back-up generators at nuclear power plants that are required to meet NRC requirements 

should be exempted from the RICE National Emission Standards for Hazardous Air Pollutants 

(NESHAPs). Any requirement to retrofit control devices on emergency back-up generators used in 

nuc.lear plant applications would negatively impact their ability to meet stringent NRC requirements. 

Additionally, emergency back-up generators in. nuclear power plants, are contained in structures 

designed to meet NRC seismic (10 CFR 50 Appendi x S) and tornado (10 CFR 50 Appendix A) 

specifications. Modifying these structures to accommodate additional emissions equipment would 

be extremely difficult and costly. 

NEI is concerned that the EPA has not adequately considered the reduction in. RICE reliability and 

performance resultant from the addition of post combustion control required in this proposed rule. 

NRC regulations require in most cases that-emergency RICE at nuclear power plants be designed to 

reach rated speed in less than 10 seconds and be at full load in less than 90 seconds. Additionally, 

the NRC has strict .reliability and availability standards for emergency RICE. NEI believes that the 

requirements of this proposed rule would adversely impact the ability of emergency RICE, installed 

at nuclear power stations, to corn ply with NRC requirements. 

Nuclear powerplants have been exempted from many EPA regulations in recognition of unique 

safety and support equipment requirements and existing regulation by the NRC. For example, the 

following is quoted from the EPA Federal Register notice for implementing 40 CFR Part 60 with 

regard to NOx New Source Performance Standards (NSPS): 

Emergency standby engines also require special consideration. These engines operate lessthan 

200 hours per year under all but very unusual circumstances. Consequently, they add relatively 

little to regional or national total NOx emissions. The largest category of emergency standby 

units is for nuclear power plants, where these engines provide power for the pumps used for 

cooling the reactors. These engines must attain a set speed in ten seconds and must assume 

full rated load in 30 seconds. /n some cases, application of the demonstrated NOx Control 

technique limits the responsiveness of these engines in emergency situations. Therefore, all 

emergency standby engines are exempted from standards of performance. [44 FR 43156, 

]uly 23, 1979; "Stationary [nternal Combustion Engines; Standards of Performance for New 

Stationary Sources and Addition to the List of Categories of Stationary Sources'] 
Air and Radiation Docket and Information Center 

June 3, 2009 

Page 3 

From the EPA Register notice for 40 CFR Part 112, Oil Pollution Prevention; Spill Preventic•n, Control, and Countermeasure Rule Req uirements Subpart O, Underground Emergency Diesel Generator Tanks at Nuclear Power Stations: 

Under this/•nal action, EPA is exempting underground oil storage tanks deferred under 40 CFR part 280, as originally promulgated, that supply emergency diesel generators at nuclear power generation facilities licensed by Nuclear Regulatory Commission (NRC) and that meet the NRC design criteria and quality assurance criteria. 

Additionally, The California regulations for compression ignition (CI) engines contain an exemption for engines covered by NRC regulations (Barclays Official California Code of Regulations, Title 17. Public Health Division 3, Air Resources Chapter 1, Air Resources Board Subchapter 7.5, Airborne Toxic Control Measures). The exemption states: 

(i) Exemption for Emergency Engines at Nuclear Facilities. The requirements in section 93115.5('b)(3) do not apply to any in-use stationary diesel-fueled C[ engines for which all of the- following criteria are met: 

(1) the engine is an emergency standby engine; (2) the engine is subject to the requirements of the U.S. Nuclear Regulatory Commission 

(3) the engine is used solely for the safe shutdown and maintenance of a nuclear facility when normal power service fails or is lost," and 

(4) the engine undergoes maintenance and testing operations for no more than 200 hours cumulatively per calendar year. 

NEI recommends that the following exemption be added to the proposed rule: 

Exemption for Emergency Engines at Nuclear Facilities. The requiren•ents in 40 CFR Part 53 do not apply to any stationary RICE for which one or more of the following criteria are met: 

('I) the engine is regulated by the U.•. Nuclear Regulatory Commission; (2) the engine is used solely for the safe shutdown and maintenance of a nuclear facility when normal power service fails or is lost," or 

(3) the engine is an emergency standby engine. 

As noted previously, some aspects of the proposed rule do not consider the unique safety requirements that exist for critical nuclear power plant systems. The following exam pies are provided-in further support of an exemption for emergency engines at nuclear facilities. 
Air and Radiation Docket and Information Center 

June 3, 2009 

Page 4 

RICE at Nuclear Power Plants Should Not Have Any Annual Restrictions for 

Maintenance and Testing that Conflict with Any Current or Future NRC 

Requirements 

The RICE at nuclear power plants should not be subject to operating limits that conflict with 

NRC requirements. In addition, it is imperative that any initial testing under the final Subpart 

ZZZZ rule be consistent with what is allowable under the NRC rules. Requiring nuclear plant 

operators to corn ply with two different regulatory regimes for emergency.back-u p generators 

could create substantial problems and would not..serve the public interest. 

For example, emergency RICE at nuclear power plants should not be restricted to 100 hours 

per year or less whenever the req uired NRC maintenance and reliability testing necessitates 

longer operation. Nuclear generation facilities maintain records documenting the hours of 

operation for required maintenance and testing and should not be required to petition for 

approval to operate more than 100 hours. Emergency RICE are not used for peak shaving and 

are not connected to the electric grid for energy sales. Their primary function is to safely 

shutdown a nuclear reactor in the event that normal power sources become unavailable. 

The Proposed NESHAPs for Start-upr Shutdown and Malfunction are Not Supported 

for Operating Practices at Nuc!ear Power Plants 

The EPA has not provided Sufficient data to justify finalizing the start-up, shutdown and 

malfunction C'SSM") NESHAPs that it has proposed. NEI believes that the catalytic converter 

will not function for 15 to 30 minutes after starting and that it will also not meet the proposed 

standards during shutdown. For the emergency RICE installed at nuclear power plants, this 

would mean that for the nominal 1.5 hour monthly surveillance test of the emergency RICE 

they may only be in compliance for 30-45 minutes. Emission controls vendors have also stated 

that the emissions equipment will probably not function during light or no load conditions. 

During an emergency condition at a nuclear power station where the electrical grid remains 

available, the emergency RICE will start and remain unloaded and will probably never reach an 

exhaust temperature that will enable effective operation of the emissions equipment. The only 

time the emissions equipment will be effective is during the 24-hour.surveillance test performed 

each refueling interval, approximately once every 18 to 24 months, or during an actual loss of 

electrical grid condition where•the emergency RICE could be loaded for significant periods. 

EPA has Underestimated the Cost of the Proposed Rule for Nuclear Power Plants 

Components installed in nuclear applications are subject to a variety of quality assurance 

requirements, specifications, and code requirements. None of the current catalytic converter 

manufacturers are qualified to nuclear safety related standards. The cost of producing catalytic 

converters to nuclear safety .related standards, estimated at $0.85 million, is expected to be 5 
Air and Radiation Docket and Information Center 

June 3, 2009 

Page 5 

to 10 times the cost of commercial applications. Installation costs associated with additional piping, supports, fire protection, HVAC, etc., are estimated to be $2-4 million per RICE. 

Emergency RICE are housed in substantial structures designed to protect the equipment from tornado/hurricane winds, missiles, fire, and seismic events. Most of the installations do not have room in the existing structures for additional equipment such as catalytic converters. The cost of providing additional structures to protect this equipment is estimated at $3-5 million per RICE. With approximately 250 emergency RICE Currently installed at nuclear power plants, the total cost is estimated to exceedS2 billion. NEI believes that this large cost is not justified by the insignificant amount of emission reduction that would result from adoption of the proposed rule. 

TheCompliance Date for the Proposed Rule Does Not Consider the Procurement and Znstallation Requirements at Nuclear Power Plants 

The compliance date of three years from the effective date of the rule would-not be sufficient for installation at nuclear power plants. As previously noted, components installed in nuclear applications are subject to a variety of quality assurance requirements, specifications, and code requirements. None of the current catalytic converter manufacturers are qualified to 'nuclear safety related standards. The time frame for current vendors to meet the stringent quality assurance standards and produce an acceptable catalytic converter is estimated to be beyond the 3-year compliance period. 

NEI concurs with the Utility Air Regulatory Grou p (UARG) letter (dated June 3, 2009).and its comments that support an exemption for RICE at nuclear power plants. 

2. EPA Should Expand the Subcategory of Limited Use Engines 

Under the current rule, RICE that have a rating of more than 500 HP and are located at major sources do not need to comply with emissions limits if they qualify as limited use engines. 40 C.F.R. § 63.6600(c). "Limited use" includes any stationary RICE that operates less than 100 hours per year." Id. § 63.6675. 

EPA did not propose any revisions to § 63.6600, nor did it propose to extend the exclusion of limited use RICE to include engines at or below 500 HP or engines located at area sources. NEI- believes that EPA should revise the limited use exclusion to include all sizes of regulated engines, area 

sources in addition to major sources, and expand the definition of limited use to include operation up to 300 hours per year. Such units should also be exempt from performance testing and only be obliged to maintain and report records of annual operating hours to show that they qualify as limited use RICE. 
Air and Radiation Docket and Information 'Center 

June 3, 2009 

Page 6 

In proposing the current limited use provision, the Agency explained that it would apply to "engines 

used for electric power peak shaving" that "operate only during peak energy use periods, typically in 

the summer months" (67 FR77851). The main categories of non-emergency "limited-use" engines 

operated at nuclear power station include: 

RICE that provide black-start capability to the facility• 

RICE that provide back-up power to critical information technology infrastructure, 

• RICE used during outages, 

RICE that provide back-up power to emergency support facilities, and 

RICE that provide back-up fire suppression water. 

RICE installed at nuclear power station should be allowed a "limited use" exemption. 

NEI concurswith the UARG letter (dated June 3, 2009) and its associated comments that support an 

expansion for limited use RICE. 

If you have any questions about this information, please contact me at (202) 739-8108; _icb@nei.org 

or Russell Smith at (202) 739-8058; ras@nei.om. 

Sincerely, 

John C. Butler 

C: Mr. R. W. Borchardt, EDO, NRC 

Mr. Steven F. Crockett, OGC/GCLR/LCLSP, NRC 
SBA RICE Final Rule Comments 02_01_ 10 .doc 

Bromberg, Kevin L. o Higgins, Cortney, RobertJ Wayland, Melanie King, Michael Horowitz 

Cc: "Grahame, Thomas" 

This message has been forwarded, 

02/01/2010 10:58 AM 

History: 

SBA RICE Final Rule Cornrnent•s 02_01_10 .doc 
SBA Final Rule Comments 

A. Emission Standards (Note some issues overlap) 

v.2 2/1/10 

So 

Area Sources No Standards below 500 HP only work practices and ULSD-. [Small firms do not have the expertise and resources to retrofit engines with oxidation catalysts hnd many locations 

EPA underestimating are unmanned and lack electricity and 

for 

costs of retrofit, and possibly not including additional costs more remote locations] Major Sources No standards below 300 HP emission limit between 100-300 HP based on a single data point with no variability (157 ppmvd) only work practices and ULSD 

Area Source Alternative No standard below 300 HP, MACT floor only between 300-500 HP only work practices and ULSD 

Rural Area Sources No emission standards De minimis risk reduction for large cost GACT allows consideration of costs and benefits (work practices only and ULSD) [2007 dehydrator rule relied on this justification: '"'Since the areas located outside UA plug offset and UC boundaries are sparsely populated compared to those inside UA plus offset and UC boundaries, we donor believe the additional cost associated with extending the add-on control requirement to sources in this area is justified." This approach would likewise yield benefits in rural areas through work practices and ULSD.] Limited Use Engines All engines major source or. area source large or small 

ofnonemergency 

should have exclusion of up to 300 hours [NEI requested 300 hours for variety 

than 

engines at nuclear power plants, for example (engines greater 500 HP already benefiting from J100 hours limiteduse exclusion) Should include peak shaving for electric power {Were limited use engines ever part of the original MACT inventory? }] 

EPA Calculation What is the amount of diesel emissions used by the vendor to drive out to the site to reti'ofit the diesel engine and perform the initial and follow-up emission 

(Reductions 

tests compared to the emission reductions achieved solely by the addition of the DOC? from use of USLD will occur even without the DOC) 

B. Oil Change Frequency 

Manufacturer's Recommendation or Oil Analysis Program (with EPA presumed approval after 60 day review) Note: API did provide specifications and acceptable ranges for the specifications in November 30, 2009 a 

memorandum. 

SSM 

Malfunction should be excluded from. emission standard work practices should be adopted for malfunction malfunctions should be addressed as expeditiously as possible, including immediate reporting? 
Needed Follow-up Need to examine documents establishing MACT floor and above 

the floor and compliance costs (in particular, retrofit costs) 

June 2009 UARG's List of Limited Use Engines (page 13): 

"The main categories of non-emergency "limited use" engines owned or operated 

by electric utilities are the following. 

Generators in remote sections of transmission/distribution systems that 

usually provide voltage support to maintain mandated system voltage. 

Generators atpower plants that support peak loads and provide black-start 

capability to the facility. 

Generators and diesel compressor engines used during outages at power 

plants, especially at nuclear power plants (not all of which are regulated bythe NRC 

pursuant to 10 C.F.R. pt. 50). 

Generators used in electrical distribution circuits to delay installing new 

station/substation electrical equipment during peak load periods to reduce strain on 

existing equipment (Le., loads above equipment rating). 

Generators on a truck trailer that can beused during maintenance on an 

isolated distribution circuit to keep customers with power while the repairs are 

performed. 

.Generators exclusively used to provide short-term power during start.up of 

combustion turbines. 

Customer-owned emergency generators that can be used to meet peak 

loads, or required reserve margin, during unexpected plant outages. 

Because of the low capacity factor of these limited use RICE (300 hours per year is a 

capacity factor of about 3.4%),. the emissions from this subcategory are inherently low 

and would not pose a significant health hazard to the public." 
Control Costs for Existing Stationary CI RICE Not mentioned in the call 

Bromberg, Kevin L. Higgins• Cortney, RobertJ Wayland, o. Melanie King 01/27/2010 05:34 PM 

Cc: thornas.grahame 

What is the status of this document? When can this become available? This is a very key document w.r.t, the practicability and costs of retrofits. Can you really retrofit an engine of 100-300 HP (major sources only) and does this make sense for a PM reduction of 2.0 (100-175 HP) to 3.5 (175-300 HP) pounds per year? 

Kevin 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-maih kevin.bromberfl@.sba.•ov 

Visit Advocacy's website at http:llwww.sba.flovladvo 

Sign up for Advocacy Email Alerts at ,http://web.sba.govllist in order to receivevia emaih 

• Advocacy's Press Releases; 

• Advocacy's monthly newsletter The Small Business Advocate 

• Advocacy's Small Business Research; 

• Advocacy's Regulatory News. 

To easily learn about and comment on important proposed regulations visit http://www.sba.,qov/advo/laws/law re,qalerts.html 

Read the Advocacy Blog at http:l/weblog.sba.govlblo_•-advo 

Subscribe to "What's New at Advocacy" RSS feed at http:llfeeds.feedburner.comlsbalrAlO 
History: 

RE: List of Issues/Questions RICE so far heads up for tomorrow (may refine this list tomorrow AM) 

Bromberg, Kevin L, o Melanie King, RobertJ Wayland 

Cc: "Holman, Ke th W., H•ggms, Cortney, thomas.grahame 

This message has been replied to and forwarded. 

01/26/2010 05:40 PM 

13. Please provide copy of "Control Costs forExisting Stationary:Cl RICE" (page 107, draft 

preamble). 

From: Bromberg, Kevin L. 

Sent: Tuesday, .January 26, 2010 5:00 PM 

To: 'King.Mela•nie@epamail.epa.gov'; 'Wayland.Robe•@epamail.epa.qov' Cc: Holman, Keith W 'Hi gg ins Cortne Y, ': 'thom as.grahame@hq.doe.gov Subject: List of Issues/Questions RICE so far heads up for tomorrow (may refine this list tomorrow AN) 

1. Limited Use Engines could we expand this to small engines too and large engines at areasources? 100 hour limit is already used at major sources, believe. 

2. USLD is it available in Alaska should we be using the mobile source provision that 

provides some flexibility for Alaska (and maybe 'other remote locations)? 

3. Rural vs. Urban Area sources Exempting all rural OR rural below 500 HP. Do PM 

releases of an approximately additional 20-50 pounds (per year) of PM from a single engine really travel,tens or hundreds of miles from their source" (draft preamble page 50). 

4. SSM Exempt Malfunction and Shutdown from Testing; Malfunction not definable 

need work practice to address malfunction; shutdown since EPA assumes that shutdown only reduces emissions- why test this scenario? 

5. How is variability applied to the setting of the MACT floors? Why should the MACT floor 

be multiplied by the catalyst efficiency, instead of the average emissions times the catalyst efficiency for the above the floor.standard? 

6. Shouldcyclicenginesbeexemptfrom emissionstandards? "For engines operating at reduced speed or loads resulting in a reduced 

exhaust temperature, EPA believes that the emlssion standa.rds are 

still appropriate and there is no 3ustification to only require work practice standards during these situations." Page 61 how does EPA know this? 

7. Should there be an emission standard for major or area sources below ,500 HP? Is. it 
practicable to retrofit these engines? Should major source engines between 100 and 300 HP 

have emission standards? 

8. Oil changes Should EPA allow an oil analysis program with appropriately defined 

paramaters (such as those three addressed by API) to suffice for an alternate oil change 

frequency? Can EPA agree to submission to the permit authority, with approval granted after 

60 day review if no response by permit authority? There appears to be a low probability that 

the permit authority would disagree with the approval, and requiring this approval would be 

very burdensome on permit authorities with inadequate resources. 

9. Alaska Engines greater than 300 HP area sources- should it be greater than 500 HP 

and not limited to engines accessible by Federal highway? 

10. Could we get a copy of the new Subcategorization and MACT FioorDetermination memo 

and is there a separate memofor above the floor determinations? 

11. Crankcase ventilation control system or filtration emission .control system where these 

in the proposal and what was the response if they were? 

12. Are there enough.testing firms to test this large population of regulated engines? No one 

tests these engines today. 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.bromberg•,sba..qov 

Visit Advocacy's website at http:llwww.sba.govladvo 

Sign up for Advocacy Email Alerts at http:llweb.sba.govllist in order to receive via emaih 

• Advocacy's Press Releases; 

• Advocacy's monthly newsletter The Small Business Advocate 

• Advocacy's Small'Business Research; 

• Advocacy's Regulatory News. 

To easily learn about and comment on important proposed regulations visit 

http://www.sba.,qov/advo/laws/law re,qa erts html 
Read the Advocacy Blog at http://weblofl.sba.govlblog-advo 

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RE: Options for Area sources RICE 

Bromberg, Kevin L. Higgins Cortney, MelanieKing, Michael to: Horowitz 

Cc: RobertJ Wayland, thomas.grahame, "Holman, Keith W." 

01/21/2010 02:22 PM 

make 

For clarity 

this 

I'm nor asking if EPA can" make the appropriate legal findings to work we may be-debating that just. whether it is permissible 

be 

under 

made. 

the 

This 

framework 

is Why 

of the Clean Air Act if the appropriate legal findings can 

I don't think a call is needed. 

A 

allow 

call is needed on whether EPA canmake the appropriate legal findings to t.he option to be promulgated. 

-original MessageFrom: Bromberg, Kevin L. 

Sent: Thursday, January 21, 2010 2:19 PM 

To: 'Higgins, Cortney'; King.Melanie@epamail•.epa.gov; horowitz.michael@epamail.epa.gov Cc: Wayland. Robertj@epamail.epa.gov; thomasl, grahame@hq.doe.gov; Holman Keith W. 

S•bject: RE: Options for Area sources RICE 

straightforward 

I'd prefer to see the written response from Michael I think this is fairly basic CAA interpretation, and I think we're golng over old ground here. 

Michael if you could just respond yes, or yes but to each option that would.be 

options 

appreciated. (I understand EPA did not necessarily evaluate these in its development of the proposed rule.) 

Original Message.- 

From: Higgins, Cortney [mailto:CortneyLHiggins@omb.eop.gov Sent: Thursday, January 21, 2010 2:12 PM 

To:. King. Melanie@epamail.epa.gov; Bromberg, Kevin L•; horowitz.michael@epamail.epa.gov Cc: Wayland. Robertj@epamail..epa.gov; thomas.grahame@hq.doe.gov Subject: RE: Options for Area sources RICE 

I'd suggest we flag this question for the next interagency phone call. 

Original Message 

From: King. Melanie@epamail.epa.gov [mailto•King. Melanie@epamail.epa.gov] Sent: Thursday, January 21, 2010 2:11 PM 

To: Bromberg, Kevin L.; horowitz.michael@epamail.epa.gov Cc: Higgins, Cortney; Wayland. Robertj@epamail.epa.gov; thomas.grahame@hq.doe.gov 

Subject:.Re: Options for Area sources RICE 

I'll defer to OGC to answer questions about what-EPA can do under the CAA I'm copying Michael on this.. 

Melanie King 

Energy Strategies Group 

Seczor Policies and Programs Division 

Office of Air Quality Planning and S.tandards U.S. Envlronmentai Protection Agency 
Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (9-19) 541-5450 

king.melanie@epa.gov 

From 

l"Bromberg, Kevin L." <kevin.bromberg@sba.gov> 

> 

> 

To: 

> 

l"Higgins, Cortney" <Cortney_Higgins@omb.eop.govb, Melanie 

King/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA 

>- 

Cc: 

> 

<thomas. grahame@hq, doe. gov• 

> 

Date: 

101/21/2010 02:06 PM 

Subject: 

lOptions for Area sources RICE 
Just to be clear under the cAA 

or all engine sizes, 

I believe, for a variety of engine slzes, thaz we have the options of: 

i. All area sources could 5e subject to GACT, not MACT which allows all area sources to escape emission standards 

2. Under {l12(k)?}, EPA can divide area sources into rural and urban sources and separately exempt rural sources from any MACT or GACT standards 

3 Under l12.(h), using th6 appropriate findings, EPA could choose work practi.ces alone to substitute for standards for area. sources and major sources. 

EPA 

final 

has already made some use of the work practice l12(h) option in the draft rule. 

Bob, Melanie have I stated this correctly? 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tel: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.bromberg@sba.gov 

Visit Advocacy's website at http://www.sba.gov/advo 

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recelve via email: 

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To easily learn about and comment on important proposed regulations visit 

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RE: RICEquestion 

t 

Bromberg, Kevin L. o Melanie King 

Cc: RobertJ Wayland, "Higgins,Cortney". "Holman, Keith W.", Michael 

Horowitz 

History: This message has been replied to and forwarded. 

01/12/2010 09:46 AM 

Just to be clear- there is no applicable emission standard for malfunction but there is for normal operation and shutdown, and work standards for. startu p -yes? Isn't the statutory requirement -SSM 

-startup, shutdown and malfunction? How does EPA address this? 

(I promise I'll save the rest for the review of the actual text) 

From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov] Sent= Monday, January 11, 2010 8:10 PM 

To: Bromberg, Kevin L. 

Cc: Wayland.Robertj@epamail.epa.gov; Higgins, Cortney; Holman, Keith W.; horowitz.michael@epa.gov Subject: Re: RICE question 

Kevin, 

The draft final rule does not have separate requirements for malfunction, 

Melanie King 

Energy •Strateg ies Gtoup 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919)541-2469 

Fax: (919) 541-5450 

king.melanie@epa.oov 

"Bromberg, Kevin L." <kevin.bromberg@sba.gov> wrote: 

To: RobertJ Wayland/RTP/USEPA/US@EPA, Melanie King/RTP/USEPA/US@EPA From: "Bromberg, Kevin L." <kevin.bromberg@sba.gov> Date: 01/11/2010 05:36PM 

cc: "Higgins, Cot=hey" <Cortney_Higgins@omb.eop.gov>, "Holman, Keith W." <Keith.Holman@sba:gov> 

Subject: RICE question 

What was the requirement for a malfunction? I understood the requirements for start-up, and shutdown. 

Original Message 

From: Wayland. Robertj@epamail.epa.gov [mailto:Wayland. Robertj@epamail.epa.gov] 
Sent: Friday, January 08, 2010 5:05 PM 

To: Bromberg, Kevin L. 

Cc: Higgins, Cortney; Holman, Keith W. 

Subject: Re: Monday presentation for RICE (i0:00 AM) 

Kevin 

Let me check with Melanie, I'm not sure b/c I've been on travel all week 

until today. 

sorry! 

bob 

Dr. Robert J. •ayland; Leader 

Energy Strategies Group 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

Sector Policies and Programs Division 

Mail Code D243-01 

RTP, NC 27711 

Phone: (919) 541-1045 

Cell: (919) 306-2290 

Fax: (919) 541-5450 

e-mail: wayland.roberrj@epa.gov 

DRAFT/Deliberative Document FOIA Exempt 

From-: 

l"Bromberg, Kevin L." <kevin.bromberg@sba.gov> 

To: 

> 

l"Higgins, Cortney" <Cortney Higgins@omb.eop.gov> 

Cc: 

> 
IRobertJ Wayland/RTP/USEPA/US@EPA, "Holman, Keith W." <Keith..Holman@sba.gov> 

-> 

Date: 

-> 

01/08/2010 04:45 PM 

Subject 

-l 

IMo•day presentation for RICE (i0:00 AM) 

Available yet? 

Kevin Bromberg 

Office of Advocacy 

U.S. Small Business Administration 

409 Third Street, SW 

Washington, DC 20416 

Tei: 202-205-6964; Fax: 202-205-6928 

E-mail: kevin.bromberg@sba.gov 

Visit Advocacy's website at http://www.sba:qov/advo 

Sign up for Advocacy Email-Alerts at http://web.sba.gov/list in order to 
receive via email: 

Advocacy's Press Releases; 

Advocacy's monthly newsletter The Small Business Advocate; 

Advocacy's Small Business Research; 

Advocacy's Regulatory News. 

To easily learn about and comment on important proposed regulations 

visit http://www.sba.gov/advo/laws/law reqalerts.html 

Read the Advocacy Blog at http://weblog.sba.•ov/bloq-advo 

Subscribe •o "What's New at Advocacy" RSS feed at 

http://feeds.feedburner.com/sba/rAIO 
Re: Fwd: FW: Annualized Costs CI engines 

Kevin Bromberg o Melanie King 

Cc: Larry Sorrels, RobertJ Wayland, "Higg ns,COrtney", Ron Evans, Lee, Amanda I. 

02/16/2010 12:01 AM 

Thanks please look at the spreadsheet question I sent today with file KLB vl included. 

My eXisting concerns (re:. costs) center around: 

1. How many engines are subject to retrofit by size/major/area source in RIA (question above)? 

2. Source of estimates for industry sector/size engines couldn't find any documentation for example that identifies how the ag population of 700+ in 300-600 HP became 18 or,so engines in RIA question from last week 

3. accuracy of the emissions testing cost 

This was quite helpful below, explaining the actual costs used for recordkeeping reporting, .etc (perhaps this should go in a separate memo in the record)? 

Kevin 

On Mon, Feb 15, 2010 at 11:40 PM, <King Melanie@epamail epa gov> wrote" Kevin, 

The 

Perhaps it would be helpful for you if lay out the elements of the costs and what they are per engine. 

when 

only one that is dependent on the engine size is the control cost. Also, one thing to keep in mind you are looking at cost/ton is that when we are evaluating MACT or GACT, we are looking at the cost/ton of the control.device itself and not incorporating other things like recordkeeping or reporting. 

Capital costs: 

-Capital costs for control device 

-You already have the formulas for the DOC and OCV capital costs 

-Capital 

-$560/engine 

costs for continuous parametric monitoring, applicable for non-emergency >500 HP 

Annual costs: 

-An nual cost of control device 

-.You already have the formulas for the DOC and OCV annual cost 

-Annual 

-$2,583/engine 

cost Of continuous parametric monitoring, a pplicable for non-emergency >500 HP -includes one-time initial cost to purchase,, install and calibrate, plus monthly recordkeeping 

-Performance testing -$582/engine 

engines 

-Intial test 

300-500 

required for non-emergency engines 100-500 HP at major source, and non-emergency HP at area source. 

-Subsequent tests required every 3 years for >500 HP 
-Recordkeeping 

-one hour/year for everyone at $72/hr 

:Reporting 

-No reporting required for emergency engines, engines <100 HP at major sources, and engines <300 

HP. at area sources 

-$251/eng ine in first year of implementation for non-emergency >100 HP at major source and 

non-emergency >300 HP at area source. Includes one-time costs for reading instructions and training 

personnel so would decrease in subsequent years. 

Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail codeD243-01 

RTP, NC 27711 

Phone: (919) 541-2469 

Fax: (919) 541-5450 

king.melanie@epa.gov 

Kevin Bromberg <kevin.bromberg@gmail.cem> wrote: 

To: Larry Sorrels/RTPIUSEPNUS@EPA 

From: Kevin Bromberg <kevin.bromberg@gmail.com> 

Date: 02/13/2010 05:08 PM 

cc: Melanie KinglRTPIUSEPNUS@EPA, RobertJ WaylandlRTPIUSEPNUS@EPA, "Higgins, Cortney" 

<cortney higgins@omb.eop.gov>, "Lee, Amanda/." <Amanda I. Lee•omb.eop.gov>, Ron 

EvanslRTPIUSEPNUS@EPA 

Subject: Fwd: FW: Annualized Costs CI engines 

Hi Larry thanks for the reply. 

Who at EPA did the calculations for the costs in Tables 4.4 in the RIA and didn't they use some 

formulas for calculating costs? This requires the annual costs and the capital costs for each size 

engine (and the number of engines). Or did the contractor do that? suspect Melanie didn't do this 

herself. was hoping it was you. If you can provide the spreadsheet for that Table that would 

probably have the formula init. 

I'd also like to confirm the $61,000 cost/ton figure for the 300-500 HP range (from the floor memo), 

which can do once can verify the cost formulas because we.have the tonsreduced figures for each 

size range. 

Thanks 

Kevin 

Forwarded message 

From: Bromberg, Kevin L. <kevin.bromberg@sba.gov> 

Date: Sat, Feb 13, 2010 at 3:06 PM 

Subject: FW: Annualized Costs CI engines 

To: kevin.bromberq•gmail.com 
From: Sorrels.Larrv•epamail.epa..Qov[SMTP:SORRELS.LARRY•EPAMAIL.. EPA.GOV] Sent: Saturday, February 13, 2010 3:06:53 PM 

To." Bromberg, Kevin L. 

Cc: Higgins, Cortney; Wayland.Roberti•epamail.epa..qov; Kin.q Me an e•.epamail.epa .qov; Evans.Ron•,epamail.epa ,qov 

Subject: Re: Annualized Costs CI engines Auto forwarded by a Rule 

Kevin, 

have no information on how to estimate the costs of emissions testing, recordkeeping, and reporting costs beyond what is in the Impacts memo prepared by SPPD's contractor. Melanie is better able to answer the question you have on "missing costs.'" Thanks. 

Larry Sorrels 

Economist 

US EPNOAQPSIHEIDIABCG 

C439-02 

RTP, NC 27711 

(919) 541-5041 

fax: (919) 541-0839 

"Bromberg, Kevin L." <kevin,bromber.q•sba.qov> wrote: 

To: "Higgins, Cortney" <Cortney Hi_aginsC•omb.eop.gov>, Larry SorrelslRTPIUSEPNUS@EPA. From: "Bromberg, Kevin L." <kevin. br0mber.q@sba•(]ov> Date: 02/12/2010 03:15PM 

cc: RobertJ WaylandlRTPIUSEPNUS@EPA, Melanie KinglRTPIUSEPNUS@EPA Subject: Annualized Costs CI engines 

Larry do you have a formula.,we can use for calculating the annual costs of emission tests, recordkeep ng and reporting for nonemergency CI engines > 300 HP? We only have the formula for the CI ,retrofit costs on page 3 of the Impacts memo. 

know it is $68/hour for recordkeeping/reporting but don't have-the number of hours. And EPA assumed •;583/engine for all sectors and sizes for emission tests? Was this for every three years? Any other missing costs? 

Thanks 

Kevin 

Kevin Bromberg 

Office of Advocacy 

U.S, SmallBusiness Administration 

409 Third Street, SW 
Washington, DC 20416 

Tel: 202-20516964; Fax: 202-205-6928 

E-maih kevin.brom berg@,s ba.flov 

Visit Advocacy°s website at http:llwww.sba.govladvo 

Sign up for Advocacy Email Alerts at http:llweb.sba.govllist in order to receive via emaih 

• Advocacy°s Press Releases; 

• Advocacy's monthly newsletter The Small Business Advocate 

• • Advocacy's Small Business Research; 

• .Advocacy's Regulatory News. 

To easily learn about and comment on impoPtant proposed regulations visit 

http://www.sba..qov/advo/laws/law re.qalerts.html 

Read the Advocacy Blog at httl•:llweblo_cl.sba.•ovlbloq-advo 

Subscribe to "What's New at Advocacy" RSS feed at http:llfeeds.feedburner.comlsbalrAlO 
Questions about Melanie's spreadsheet and the 80/20 non-emergency assumption RICE 

Kevin Bromberg Higgins, Cortney, Melanie King, RobertJ o. Wayland, Larry Sorrels, Lee, Amanda I. 02/15/2010 03:45 PM 

I think EPA may not have used the 80/20 emergency nonemergency split in ,all its calculations. See attached spreadsheet. 

engines 

What is 

in 

the 

the 

correct approach? It appears that EPA may have included only the nonemergency table of the larger area source engines, instead of al engines? 

Also, the 300-500 HP engine costs appear to be higher than the 500-600 HP costs in the major source category, which implies that using the 80/20 assumption at 300-500 HP may not be correct. Maybe, there are 48,000 engines inthat cateogry being retrofitted? 

Thanks 

Kevin Cop•, of Existing CI RICE NESHAP cost• and emission reductions by HP range 1-13-10_KLB vl.xl• 

Summary of Major Source and Area Source Emission Reductions for the RICE NESHAP Size Range (HP) Emission Reductions (tpy) 

HAP CO PM SO2 VOC M•orSources 

50-100 0 0 0 0 100-175 44 2,072 123 229 175-300 57 1,571 161 301 300-500 145 2,362 407 761 500-600 18 209 50 93 600-750 11 107 31 58 >750 36 236 102 190 Total 312 6,558 874 1,632 

Area Sources 

50-100 

100-175 

175-300 

300-600 

600-750 

>750 

Total 

Total 

0 

1,183 

1,549 

3,923 

478 

30O 

982 

8,416 

0 0 0 0 0 

0 0 0 0 0 

0 0 0 0 0 

368 5;314 1,031 1,712 9,930 

92 891 259 484 2,497 243 1,578 680 1,271 6,553 

703 7,784 1,970 3,467 18,980 

1,014 14,342 2,844 5,100 27,395 

1,488