-----Forwarded by Melanie King/RTP/USEPA/US on 07/28/2010 11:02PM -----

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

From: Melanie King/RTP/USEPA/US

Date: 07/28/2010 04:21PM

cc: "Kymn, Christine J." <Christine_J._Kymn@omb.eop.gov>, "Higgins, Cortney"

<Cortney_Higgins@omb.eop.gov>, "Johnson, Nancy" <Nancy.Johnson@hq.doe.gov>,

RobertJ Wayland/RTP/USEPA/US@EPA, Fred Talcott/DC/USEPA/US@EPA, Larry

Sorrels/RTP/USEPA/US@EPA, Amy Lamson/RTP/USEPA/US@EPA, Peter

Nagelhout/DC/USEPA/US@EPA, Michael Horowitz/DC/USEPA/US@EPA

Subject: Re: FW: Emission Factors and Percent Reduction by Catalysts

Kevin,

Where are you seeing that the CO % reduction for 4SLB should be 71%? If you 

look at the

table for 4SLB which is Table 2, see the far right column, the % reductions 

for CO are all

greater than 90%. The % reductions for formaldehyde, which is what we use 

for HAP and

VOC, is provided in each table (see CH2O). Table 4 for 4SRB engines does 

show the NOx %

reductions, see the far right column. None of the other subcategories has 

NOx reductions.

The emission factors come from our Emissions Database that was put together 

several years

ago, plus we supplemented that information with new data where we could. 

We're working

on a memo that documents the information.

Melanie King

Energy Strategies Group

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

Mail Code D243-01

RTP, NC 27711

Phone: (919) 541-2469

Fax: (919) 541-5450

king.melanie@epa.gov

"Bromberg, Kevin L." ---07/28/2010 04:06:55 PM---Hi - Melanie - I'm 

forwarding this

because I think Cortney is jammed. Not sure if we will get to thi

From:

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

To:

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

Cc:

"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>, "Kymn, Christine J."

<Christine_J._Kymn@omb.eop.gov>, "Johnson, Nancy" <Nancy.Johnson@hq.doe.gov>

Date:

07/28/2010 04:06 PM

Subject

:

FW: Emission Factors and Percent Reduction by Catalysts

Hi – Melanie – I’m forwarding this because I think Cortney is jammed. 

Not sure if we will

get to this tomorrow in preamble questions, because it’s really about the 

RIA. But these are

pretty basic, and your contractor could probably readily answer these.

Kevin

_____________________________________________

From: Bromberg, Kevin L.

Sent: Wednesday, July 28, 2010 11:25 AM

To: 'Higgins, Cortney'; Kymn, Christine J.

Cc: Lee, Amanda I.
Subject: Emission Factors and Percent Reduction by Catalysts

<<EPA-HQ-OAR-2002-0059-0665[1].pdf>>

Cortney, Christine – I think we should forward this to EPA this AM. See 

below:

This document is cited on page 2 of in the July 26 Cost/Ton memo, as the 

source of the control

efficiencies represented in Table 2. The July 26 memo reports CO emission 

reductions of 94%

and 49% for 4 SLB and 4 SRB respectively, and the figures in this document 

appear to indicate

71% and 49% respectively by my inspection. Although, EPA has properly 

identified the 49%

reduction, it appears that the 4SLB figure used by EPA is incorrect: it 

should be 71% instead of

94% reduction.

More importantly, this document does not provide the percent emission 

reductions for HAPs,

VOCs, or NOx – where is this document? Perhaps, EPA meant to cite a 

different document in

footnote 3 of the July 27 th document?

Most importantly, the July 26 memo does not identify the source of the 

original emission

factors of uncontrolled emissions listed in Table 2, before adoption of the 

percent reductions.

What is the source of the original emission factors?

Without this information, I can’t verify EPA’s emission reductions in two 

ways – can’t verify the

control efficiencies or the original emission factors – which can very much 

modify the cost

reasonableness of the GACT analyses.

I thought I should send this in advance of tomorrow’s questions to give you a 

heads-up. If you

could answer today, that would be even better.

Thanks

Kevin

Thanks

Kevin (See attached file: EPA-HQ-OAR-2002-0059-0665[1].pdf)