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: 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 documentation. 2. Re: DOE issue and preamble

language

here is the suggested

language to address

PM transport. Instead of "PM emissions

can travel

tens or hundreds

of miles from their source,

so emissions from diese,l

engines

in rural areas can impact

urban populat<ons." Use:"While PM emissions

can travel

tens of hundreds

of miles from their source, and may travel

to distant

urban populations,

ground

level emissions are less likely

to travel

long distances

than PM2.5 emissions emitted substantially

above ground

level."

To be consistent

with DOE RIA edit:"Ground level emissions

are less likely

to travel

long distances

than PM2.5 emissions

emitted

substantially

above ground

level." Other issues

to be addressed

tomorrow: 3. Ag Engines

Area Sources

perhaps

EPA should

a•sume

1-5% major sources, instead

of 40% to address

the 10% of the engines

reflected

in the I00-300-

HP size category. 4. PM Transport

RIA revisions I will be our early tomorrow

AM for a tooth extraction,

so I may miss the morning

call if there is one. But I think the participants

can handle this without

me. Kevin Original

Message From: Bromberg,

Kevin L. Sent: Tuesday,

February

16, 2010 1:49 PM To: .'Higgins,

Cortney' Cc: 'King. Melanie@epamail.epa.gov,; 'Zwicke,

Greg

POrtland,

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

Robertj@epamail.epa.gov; Sorrels.Larry@epamail.epa.gov; Wayland.

Robertj@epamail.epa.gov Subject: RE: RICE package

Population

Statistics

Ag Engines 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

engines

(cell g7, CI SI summary

page) (300-600HP) 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 you provide

the memo (or send the citation

for the memo) for the sector estimates

of engines? Thanks,CortneyOriginal 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.govRe: 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 KingEnergy 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 generallywill

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

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The Small Business

Advocate
• Advocacy's

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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.advoSubscribe to "What's New at Advocacy"

RSS feed at http:l/feeds.feedburner.com/sba/rAIORe: Emission_Testing_memo•021510_v311].doc • Melanie King to: Cortney_Higgins Cc: Fred Talcott, RobertJ Wayland 02/16/2010

02:15 PM Cortney,The information

Kevin is citing from INGAA's corn ments primarily

deals with formaldehyde

testing for gas-fired engines and therefore

is not relevant to a discussion

of CO testing for diesel engines.

The excerpt from the independent

consultant

also references

formaldehyde

testing. We will be looking at the estimates for 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 our estimated

testing costs during the post-proposal

period and we believe that they are accurate.

All of the information

cited in Kevin's memo relates to formaldehyde

testing. Melanie KingEnergy 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 Larry Sor(elslRTPIUSEPNUS@EPA, "H iggins, Cortney" <Cortney

Higg ns@omb.eop

gov>, '.'Lee, Amanda 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. ThanksKevin[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.

Theyindicated 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 gas- fired 4SRB 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

on documented 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 same $1,000 per engine 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 moredetailed 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 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

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: (919 541-2469Fax: (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,CortneyOriginal 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. 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 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.govSBA

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:"Higgins, Cortney",

"Amanda

Lee", "Schwab,

Margo",

"Grahame,

Thomas",

"Daniels,

Jarad" Show Details Page 1 of 3

History: This message

has been forwarded. SBA Reply to EPA re: Rural Engine Emissions

2/16/10 Nothing in the EPA response

contradicts

the point that most ground level carbonaceous

PM2;5 diesel emissions will not travel very far. Furthermore,

we are focusing

on very small rural sources of diesel emissions, engines with less than 500 HP. Zhu (2002) and other articl-es indicate

that ultrafines

do not travel 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 et al (2004) demonstrates

that sulfate levels show little variability

across New York City, but traffic PM 2.5 varied considerably.

Rao et al also shows that most carbonaceous

PM 2.5 is much higher in urban areas than in rural areas.. Highway

diesel emissions

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

These studies combine

to support the idea that ground level PM2.5 diesel emissions

from RICE engines or other sources,

are unlikely

to travel far, and certainly travel much less than PM2.5 from high stacks, such as sulfate emissions

that shows little urban variab•ity. In sum, while the evidence

is not definitive,

it appears unlikely

that a significant

portion of the ground level PM2.5 emittedfrom

small RICE engines would travel more than several miles before being reaching

background

PM 2.5 levels. [Note:. the DOC retrofit only reduces

PM emissions

by about 1 gram of PM per hour from a single small engine].

EPA has presented

no evidence

that contradicts

the idea that 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 2/17/2010SBA

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 2/17/2010SBA

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 2/17/2010Population 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 emergency engines

are not included

above

500. So are all the major

sources engines at 500 and above all nonemergency

and subject

to retrofit

in your spreadsheet? 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 2/16/2010Population 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 Sign upfor Advocacy

Email Alerts at http:Hweb.sba.gov/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 comment

on important

proposed

regulations

visit http://www.sba govladvollawsllaw_regalerts.html Read the Advocacy

Blog at http:flweblog.sba.govlblog-advo Subscrib• to "What's New,at Advocacy"

RSS feed at http:llfeeds.feedburner.comlsbalrAlO

file://C:•Documents and Settingskmking04\Local Settings\TempLqotesFCBCEE\-web4780 2/16/2010RE: RIABromberg, Kevin L. to: Melanie King 02/12/2010

03:3.1 PM Cc: "Higgins, Cortney"
Thx I checked

the 40/60 on some englnes

below 500 HP and that looks right. Original Message From: King.Melanie@epamail.epa.gov [mailto:King.

Melanie@epamail.epa.gov] Sent: '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

on the location

of these engines

that would allow us to make more sector-specific estimates. The reason

the number

of engines

at major and area sources

in the s±ze 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. 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 I agree with Greg Z. that it is much more likely

that ag is much less than 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 Cc: Higgins,

Cortney;

Zwicke,

Greg

Portland,

OR; Bromberg,

Kevin L.; Larry Sorrels;

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 you sent me them via email rather

than trying

to answer

them during

a Conference call.

Those estimates

were done about 3 years ago so they aren't very fresh in my mind, and also our contractor

did the bulk of the 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

>

KevlnI'-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!BobSent from Blackberry

Wireless

Device Dr. Robert

J. Wayland U]S. EPAOffice 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 assumes

that 20% of irrigation 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 sector that •s 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. I did find a reference

to 712 irr±gation

pumps in the CI population statis[ics

spreadsheet

that were in the 300-600

HP range where these 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 andother 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: RIABromberg, 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 size engines.

(> 300 HP ag engines,

basically

a null set to EPA but I think 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, I don't disagree

that the assumption

may not be entirely

accurate•for irrigation engines,

like I've said we just don't have good information to make t-hese estimates.

However,

I'm not sure it would make a substantial impact

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 are the same for major and area sources,

so it wouldn't

make a difference 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, Onsince there really

shouldn't

be many ag ma3or sources

of HAPs. I would expect

the real number

to be close to 0/100%,

but I could see using 5/95% in the analysis,

just to be sure some are covered.

Since it looks like ag•irrigation

engines

at ma3or sources

account

for about 10% of the total engines

at major sources

in the current-RIA,

that seems to be a pretty

significant

change

that will impact

the costs andbenefits substantially. GregGreg 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

on the location

of these engines

that would allow us to make more sector-specific estimates. The reason

the number

of engines

at major and area sources

±n the slze 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

englnes

at major sources to all engines

(emergency

+ non-emergency)

at area sources,

and therefore 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.govFrom:

>

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

on no 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 do see in the RIA than for some engines

of diff•}ent sizes

different

major/area

source

percentages

are applied

in different industry

sectors

s$ 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

below: Major Area 300-600 hp

42,113

97,919< 600-'750 hp

1,760 16,455 >750 hp

3,828 28,746 I agree with Greg Z. that it is much more likely

that ag is much less than 40% major 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 Cc: Higgins,

Cortney;

Zwicke,

Greg

Portland,

OR; Bromberg,

Kevin L.; Larry Sorrels;

Peter Tsirigotis Subject: Re: RIA Cortney and Kevin,

I'll be happy to answer

any questions

about the population estimates,

but I 9hink it would be more productive

if you sent me them via email rather

than trying

to answer

them during

a conference call.

Those estimates

were done about 3 years ago so they aren't very fresh in my mind, and also our contractor

did the bulk of the work so I may need to confer

Wit-h them-on

some of the questions. I'm looking

at the questions

you've

sent 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

Protection

AgencyMail

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>

Date102/12/2010 02:15 PM

Subject

Re: RIA

KevinI'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!BobSent from Blackberry

Wireless

Device Dr. Robert

J. Wayland U.S. EPAOffice 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 ESTTo: 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,

SWWashington, 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 KingEnergy 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 27711Phone: (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.ThanksKevin 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 EconomistUS

EPAIOAQPS/HEIDIABCG C439-02RTP, 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?ThanksKevin 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
RIABromberg, 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 2/17/2010Page 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 http :llwww.sba.

govladvollawsllaw

regalerts.html Read the Advocacy

Blog at http:llweblog.sba.govlblog-advo Subscribe to "What's New at Advocacy"

RSS feed at http:llfeeds.feedburner.comlsbalrAlO 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 2/17/2010RE: Fw: Update on Effect of EPA's Draft Final Rule. Using RIA data from Table 4-4 on page 4-27Higgins,

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, CortneyCc: 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 CortneyAttached 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!bobDr..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

impaczsalready 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? Melanie.King, Michael Horowitz,

RobertJ Bromberg,. Kevin 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 Visit Advocacy's

website at http:llwww.sba..qovladvo Sign up for Advocacy

Email Alerts at http:llweb.sba.govllist 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..qov/advo/laws/law re.qalerts.html Read the Advocacy

Blog at httD://weblog.sba..clov/blog-advo Subscribe.to "What's New at Advocacy"

RSS feed at http://feeds.feedburner.com/sba/rAIOExisting CI RICE NESHAP

costs and emission

reductions

by HP range 1-13-10 (3) KB EDIT 102810

(Autosaved).xls RobertJ Wayland,

Melanie King, Michael Bromberg, 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).xlsSummary of Major Source and Area,Source

Emission

Reductions

for the RICE NESHAP Size Range (HP)

Emission

Reductions

(tpy) Major Sources 50-100100-175175-300300-500500-600600-750>750TotalArea Sources 50-100100-175175-300300-600600-750>750TotalTotal Numberof 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

01231614O75031102.874

022930176193581901,632

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

000,712484,2713,4675,100

0 127,9730 167,6790 127,159 9,930 100,355 2,497 16,822 6,553 29,802 18,980 569,790 27,395 936,007

PoundsPM/Eng 02.03.516.823.128.442.04.8
0.00.00.020.530.845.76.96.1Summary 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 50-100100-175175-300300-600600-750>750Total

127,973167,679127,159100,35516,82229,802569,790936,007 Overall Total NumberofEngines

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

20.530.845.76.9 127,973167,679127,159100,35516,82229,802569,790

$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$26,653RE:

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, ThxKevin

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 2/17/2010RE:

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 plantsIrrigation 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 2/17/2010RE:

Questions

for 12:30 RICE Call (as promised

yesterday) Page 3 of 3 in rural areas, vs. all the engines being located in urban areas? Rural areas have population

density that is approximately.

1/400 of the urban areas. Isn'tthis

cost range more appropriate

for. urban areas, and isn't 99%-• of the benefits

derived solely from the sources in urban areas? (Given that each source in a rural area would contribute

roughly

1/400 of a source in an urban area, even with 85% rural sources,

the rural sources would still contribute

under 1% of total benefits)

This illustrates

why Tom Grahame's observations 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

are sparsely

populated

compared

to those inside UA plus offset and UC boundaries,

we do not believe the additional

cost associated

with extending the add-on control requirement

to sourcesqn

this area is justified." VII. SSM Sources may not be able to shutdown

a malfunctioning

unit immediately

because

(1) the unit 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 a source petition under 40 CFR 63.6(g) for an alternate

work practice

standard

to address this issue? Can you use this retroactively

after the incident?

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 2/17/2010RE: 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

emergencystationary 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 EnginesUnder 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" includes

any stationary

RICE that operates

less than I00 hours per year." 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 up co 300 hours per year. Such 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

Administration409 Third Street,

SW Washington, DC 20416
Tel: 202-205-6964;

Fax: 202-205-6928
E-mail: kevin.bromberg@sba.gov
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newsletter

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Advocate; Advocacy's Small Business

Research; Advocacy's Regulatory

News.

To easily

learn about and comment

on important

proposed

regulations v±sit http://www.sba.gov/advo/laws/law_regalerts.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.com/sba/rAIOHistory: 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 KingEnergy Strategies

Group Sector Policies and Programs

Division Office of Air Quality Planning

and Standards U.S. Environmental

Protection

Agency Mail Code D243-01RTP,

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. KevinFrom: 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. Theypower 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

or constricted by the engine housing.

Many of these engines are older because

it takes several years to expend their useful life. An extreme

case in point is my father, who still runs an irrigation pump.with a 1950 Caterpillar

diesel engine

because

it doesn't quit. He eventually

will.run

out of parts that he 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 on a new engine when the existing

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 on environmental issues on behalf.of

small business. RonRonald 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.orgHistory: RICE Limited Use Engines

at Nuclear

Power Plants

Non- Emergency Engines Higgins, Cortney,

Melanie King, Michael .Bromberg, Kevin L. 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.pdlHU{]EEAi• EHEi•GY

INSTITUTE
John C, Butler D•RECTOROPERATfONS SUPPORT NUCLE•,R GENERATION DWISfON

June 3, 2009
Air and Radiation

Docket and Information

Center Environmental Protection

Agency 1200 Pennsylvania

Avenue,

NW Mail Code 6102TWashington, 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 Nuclear Energy Institute

(NEI) appreciates

the opportunity

to provide comments

on behalf of the 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 engines (RICE) for the purposes

of providing

electric power to critical plant components in the 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 use RICE at nuclear power plants.-

N EI.is the organization

responsible

for establishing

unified industry policy on matters affecting the nuclear energy industry, including the regulatory

aspects of generic operational

and technical issues. NEYs members include all entities licensed to operate commercial

nuclear power plants in the United States, nuclear plant designers,

.major architect/engineering firms, fuel fabrication

facilities, nuclear materials licensees, and other organizations

and entities involved in the nuclear energy industry.

17761Street. NW Suite400

Washington,

DC 20006-3708

P:202.7398108

F:202,533.0113

jcb@nei.org

www.nei.orgAir

and Radiation

Docket and Information

Center June 3, 2009Page 21. 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, 2009Page 3From 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, 2009Page 4RICE 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 5Air and Radiation

Docket and Information

Center June 3, 2009Page 5to 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, 2009Page 6In 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,

NRCSBA 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

.docSBA 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

are unmanned

and lack electricity

and EPA underestimating

costs of retrofit, and possibly

not including

additional

costs for 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 should have exclusion

of up to 300 hours

[NEI requested

300 hours for variety ofnonemergency engines at nuclear power plants, for example

(engines

greater than 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 tests compared

to the emission

reductions

achieved

solely by the addition

of the DOC? (Reductions 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 a November 30, 2009 memorandum.
SSMMalfunction 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 Higgins• Cortney,

RobertJ Wayland, Bromberg, Kevin L. 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.comlsbalrAlOHistory: 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 ins Cortne ': 'thom gg Y, 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

atareasources? 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. itpracticable 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 htmlRead the Advocacy

Blog at http://weblofl.sba.govlblog-advo Subscribe to "What's New at Advocacy"

RSS feed at http:/Ifeeds.feedburner.com/sba/rAIORE: Options

for Area sources

RICE Higgins Cortney,

MelanieKing,

Michael Bromberg, Kevin L. to: Horowitz Cc: RobertJ Wayland,

thomas.grahame,

"Holman, Keith W."

01/21/2010

02:22 PM

For clarity

I'm nor asking

if EPA can" make the appropriate

legal findings

to make this work

we may be-debating

that

just. whether

it is permissible under the framework

of the Clean Air Act if the appropriate

legal findings

can be made.

This is Why I don't think a call is needed. A call is needed

on whether

EPA canmake

the appropriate

legal findings

to allow t.he option

to be promulgated. -originalMessageFrom: 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 I'd prefer

to see the written

response

from Michael

I think this is fairly straightforward 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 appreciated.

(I understand

EPA did not necessarily

evaluate

these options 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 AgencyMail 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

RICEJust to be clear

under the cAA I believe,

for a variety

of engine

slzes, or all engine

sizes,

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 has already

made some use of the work practice

l12(h)

option

in the draft final 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 Sign up for Advocacy

Email Alerts

at http://web.sba.gov/list in orderrecelve 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/lawregalerts.html
Read the Advocacy

Blo@ at http://weblog.sba.gov/blog-advo
Subscribe to "What's

New at Advocacy"

RSS feed at http://feeds.feedburner.com/sba/rAIORE: 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 Re: RICE question Subject:Kevin,The draft final rule does not have separate

requirements

for malfunction, Melanie KingEnergy •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) KevinLet me check with Melanie,

I'm not sure b/c I've been on travel

all week until today. sorry!bobDr. 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 toreceive 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/rAIORe: 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)? KevinOn Mon, Feb 15, 2010 at 11:40 PM, <King Melanie@epamail

epa gov> wrote" 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 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 costs for continuous

parametric

monitoring,

applicable

for non-emergency

>500 HP -$560/engine Annual costs: -An nual cost of control device -.You already have the formulas

for the DOC and OCV annual cost -Annual cost Of continuous

parametric

monitoring,

a pplicable

for non-emergency

>500 HP -$2,583/engine -includes

one-time

initial cost to purchase,,

install and calibrate,

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 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 KingEnergy 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.ThanksKevin 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.comFrom: 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 SorrelsEconomistUS EPNOAQPSIHEIDIABCG C439-02RTP, 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?ThanksKevin Kevin Bromberg Office of Advocacy U.S, SmallBusiness

Administration 409 Third Street, SWWashington, 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

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RSS feed at http:llfeeds.feedburner.comlsbalrAlOQuestions about Melanie's

spreadsheet

and the 80/20 non-emergency assumption RICE Higgins, Cortney,

Melanie King, RobertJ Kevin Bromberg

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. What is the correct approach?

It appears that EPA may have included

only the nonemergency engines in the 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? ThanksKevin 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 50-100100-175175-300300-600600-750>750TotalTotal 01,1831,5493,92347830O9828,416
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