----- Forwarded by Brian Shrager/RTP/USEPA/US on 02/18/2011 03:03 PM

-----

From: Bryan Hubbell/RTP/USEPA/US

To: courtney_higgins@omb.eop.gov

Cc: Amy Lamson/RTP/USEPA/US@EPA, Ron Evans/RTP/USEPA/US@EPA, Tom

 Walton/RTP/USEPA/US@EPA, Kirk Baker/RTP/USEPA/US@EPA, Ines

 Pagan/RTP/USEPA/US@EPA, Brian Shrager/RTP/USEPA/US@EPA

Date: 02/16/2011 04:45 PM

Subject: Fw: Additional Interagency Comments on Boilers RIA

Courtney,

Thank you for providing additional written comments on the boiler RIA.

We have reviewed the benefits and air quality comments, and we are

quickly working to update the RIA to incorporate these edits. We will

be accepting the line edits in whole with the three minor exceptions

below. In addition, we are adding the maps discussed yesterday and

cascading all of the appropriate changes to the CISWI RIA. The entire

benefits group will be in a mandatory training all day tomorrow, and as

such, we would love to find out if there are any remaining benefits

issues today, if possible.

1. We have revised the differential toxicity statement throughout the

document to be consistent with the conclusion of the PM ISA. "These

models assume that all fine particles, regardless of their chemical

composition, are equally potent in causing premature mortality because

the scientific evidence is not yet sufficient to allow differentiation

of effect estimates by particle type (U.S. EPA, 2009c)"

2. We have deleted references to "resource limitations", but we have

clarified that the time limitations are due to the court-ordered

schedule for these rules throughout the document.

3. We have revised the HAP language on acrolein to address OMB's

concern.

"Results from the 2002 NATA suggest that acrolein is the primary driver

for noncancer respiratory risk.(footnote 1) Large reductions in HAP

emissions may not necessarily translate into significant reductions in

health risk because toxicity varies by pollutant and whether or not

there are exposures at or above levels of concern is not known. For

example, acetaldehyde mass emissions are more than double acrolein

emissions on a national basis, according to EPA’s 2005 National

Emissions Inventory (NEI). However, the Integrated Risk Information

System (IRIS) reference concentration (RfC) for acrolein is considerably

lower than that for acetaldehyde, suggesting that acrolein could be

potentially more toxic than acetaldehyde. Thus, it is important to
account for the toxicity and exposure, as well as the mass of the

targeted emissions when designing reduction strategies to maximize

health benefits.

(footnote 1) Details about the overall confidence of certainty ranking

of the individual pieces of NATA assessments including both

quantitative (e.g., model-to-monitor ratios) and qualitative (e.g.,

quality of data, review of emission inventories) judgements can be found

at http://www.epa.gov/ttn/atw/nata/roy/page16.html. "

4. OMB asked where the LML statement regarding confidence down to 7.5

ug/m3 was made previously. This statement was in the Cement NESHAP RIA,

as this was the last RIA that had air quality modeling.

Regards,

Bryan

Dr. Bryan J. Hubbell

Leader, Risk and Benefits Group

Health and Environmental Impacts Division

U.S. EPA/OAQPS (C504-02)

RTP, NC 27711

(919) 541-0621

 

From: Brian Shrager/RTP/USEPA/US 

 

To: Amy Lamson/RTP/USEPA/US@EPA 

 

Date: 02/15/2011 10:37 PM 

 

Subject: Fw: Additional Interagency Comments on Boilers RIA 

 

I believe this was meant for you and not Amy Hambrick.

Brian

-----Forwarded by Brian Shrager/RTP/USEPA/US on 02/15/2011 10:20PM -----

To: Brian Shrager/RTP/USEPA/US@EPA

From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

Date: 02/15/2011 06:58PM

Cc: Tom Walton/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA, Amy

Hambrick/RTP/USEPA/US@EPA

Subject: Additional Interagency Comments on Boilers RIA

(See attached file: Boiler

RIA__2_11_11_interagencycommentsunderEO12866Feb15.doc)
Hi Brian,

Attached are additional interagency comments on the Boilers RIA.

Regards,

Cortney

[attachment "Boiler

RIA__2_11_11_interagencycommentsunderEO12866Feb15.doc" deleted by Amy

Lamson/RTP/USEPA/US