MEMORANDUM

To: Carbon Power Plan for Existing Power Plants; Docket id: OAR-2013-0602

From: Region 5, EPA

Subject: 8/27/14, Conference Call Regarding Proposed Carbon Plan for Existing Power Plants

Summary: A conference call was held between EPA and attendees from Ohio on October 7, 

2014 to discuss the proposed Carbon Power Plan for Existing Power Plants. The following list 

of questions was submitted for discussion by the Ohio Environmental Protection Agency

Attendees may have included: Carbon Pollution Input; Ward, Adam; Czerniak, George; Cain, 

Alexis; Furey, Eileen; Newman, Erin; Wilson, Erika; Dalcher, Debra; Solomon, David; 

Ketcham-Colwill, Jim; Santiago, Juan; Torres, Elineth; Topham, Nathan; Bremer, Kristen; 

Stevens, Gabrielle; Culligan, Kevin; Clouse, Matt; Fisher, Brian; Adamantiades, Mikhail; 

Bryson, Joe; Conlin, Beth; Sherry, Christopher; Eschmann, Erich; Dietsch, Nikolaas; Sims, 

Ryan; Murray, Beth; Harvey, Reid; Boswell, Colin; Fellner, Christian

The following questions were submitted prior to the call. 
Ohio EPA - Questions for USEPA Call

Scheduled for August 27, 2014

Rate to Mass Conversion:

1. Can U.S. EPA please describe what an acceptable Rate-to-Mass conversion?

What are the attributes of an acceptable conversion equation?

Can USEPA please provide examples of an approved conversion?

How will shutdowns from the MATS rule be counted in the conversion to a mass based 

plan?

If shutdowns must be accounted for in determining a rate based goal, why are these 

shutdowns not accounted for in the mass determination in a manner that would give 

credit for the millions of tons of CO2 emissions that will be prevented by these 

shutdowns?

If guidance and/or examples are not available, when will they be provided?

Other Questions:

2. Can the data and analysis used in the projection of the 6% heat rate improvement be 

provided? Specifically, the database of existing CFPP units and 16 facilities that have 

achieved HRI of 3-8 percent year after year. Also, the EPA Region 7 study for seven 

coal fired units at three anonymous plants with details on the specific equipment 

upgrades. Per GHG Abatement Measures page 2-32

IPM Related Questions: 

3. To date, numerous pieces of data and IPM support documentation have not been released 

including, but not limited to, the following:

 IPM Parsed Files: Option 1 State, 2030

 IPM Parsed Files: Option 1 Regional, 2025

 IPM Parsed Files: Option 1 Regional, 2030

 IPM Parsed Files: Option 2 State, 2025

During a recent conversation with USEPA, staff indicated that these parsed data files 

were unavailable for review and there was no intention of releasing them. We would like 

confirmation that this is the case. Alternatively, will EPA issue a NODA similar to the 

process in CSAPR when missing information was identified?

4. How did USEPA examine the IPM data to assess feasibility, projections and cost in the 

modelling data inputs and results if parsed data files were not available? Was there any 

state or unit specific analysis of the feasibility of the results performed?
5. Does EPA plan to reexamine mistakes in IPM modeling that states comment on? If so, 

what will be the process for correcting the errors?

6. Did EPA look at any other “base” year than 2012? Can an inventory of units in other 

years besides 2012 be provided to Ohio in the same format and parsed in the same 

manner as used for the goal setting portion? 2008 would be very valuable. This would be 

the same format and have the same data as the TSD Excel spreadsheet tsd-plant-leveldata-unit-level-inventory_App7.xlsx and tsd-egrid-methodology.xlsx.

7. Can a state, in a state plan, take credit for all nuclear generation, or only 5.8%?

8. Can USEPA confirm that the shadow cost for Ohio in the IPM model was $11.30 in 

2030?

9. How was EE represented and constrained in the IPM model?

10. Was any consideration given to base-load generation vs peaking generation in IPM?

11. Can USEPA confirm that no new NGCC generation was projected for Ohio by IPM in 

Option 1 – State scenario?

12. Was “remaining useful life” of specific units accounted for in the IPM model? How can 

states account for remaining useful life in examining their state goal and in developing 

their state plans?

13. Can a spreadsheet detailing the determination of the RE goals be provided?

14. How were renewables/RE accounted for in IPM in the Option 1 – State scenario?

15. Can updated capacity factor data for eGrid-2010 (2007 data) be provided? Capacity

factor data is largely absent in this data set.

16. There is a ~10% difference between heat rates in IPM and those derived following 

USEPA’s methodology in the goal setting TSD. What is the cause of this difference?

17. Can USEPA confirm that the capacity factors projected by IPM case Option – 1 State are 

around 80 to 85% for coal?