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

To: Sharon Nizich/RTP/USEPA/US@EPA 

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

Date: 08/10/2010 02:15 PM 

Subject: Part of E.O. 12866 Review: EPA Staff response to the redline and clean copy of discussed 

revisions - MCL pertaining to NESHAP: Mercury Emissions from Mercury Cell Chlor-Alkali Plants 2060-

AN99

 

Can you send a copy of this article: 

Levy, J.I., L.K. Baxter, and J. Schwartz. 2009. Uncertainty and variability in health-related damages from 

coal-fired power plants in the United States. Risk Anal. 29(7):1000-1014.

-----Original Message-----

From: Nizich.Sharon@epamail.epa.gov [

mailto:Nizich.Sharon@epamail.epa.gov]

Sent: Tuesday, August 10, 2010 10:22 AM

To: Higgins, Cortney

Cc: Jones.Donnalee@epamail.epa.gov; Fruh.Steve@epamail.epa.gov; 

Chamberlin.JohnB@epamail.epa.gov; thrift.mike@epamail.epa.gov; Walton.Tom@epamail.epa.gov; 

Evans.Ron@epamail.epa.gov; Lamson.Amy@epamail.epa.gov; norwood.phil@ecrweb.com

Subject: Fw: Redline and clean copy of discussed revisions - MCL

Hello CortneyI have attached more responses to questions from our discussion last week. These were developed 

before we got your 9:57 a.m. email: answers to number (1) on that email are partially answered below. 

We can discuss the rest this pm.

THANKS.

Sharon V. Nizich

Metals and Minerals Group

Sector Policies and Programs Division

OAQPS - US EPA

RTP NC 27711

919/541-2825

----- Forwarded by Sharon Nizich/RTP/USEPA/US on 08/10/2010 10:19 AM

-----

From: Amy Lamson/RTP/USEPA/US

To: Sharon Nizich/RTP/USEPA/US@EP

Cc: Tom Walton/RTP/USEPA/US@EPA

Date: 08/10/2010 09:38 AM

Subject: Re: Redline and clean copy of discussed revisions - MCL

More information for OMB regarding their questions on the energy co-benefits.

1. Are these models and data peer-reviewed?
Only the emissions data from eGRID (for NOx, SO2, CO2, Hg) and COBRA (for PM2.5, NH3, VOC) were 

used, and both rely on previously published EPA and EIA data. eGRID incorporates EPA’s Emissions 

Tracking System/Continuous Emissions Monitoring data. COBRA emissions are based on EPA's emissions 

inventory for CAIR. Emissions data undergoes quality assurance at the facility, state, and federal levels.

2. What year is the data?

The emission information for eGRID is based on 2005 data. The emissions inventory for CAIR was 

developed in 2005, and projected to 2010 and 2015. The energy portfolio is from the 2010 annual 

reports of the electricity providers.

3. What are the major assumptions?

The same as the underlying data.

4. What other rules have calculated the health benefits associated with reduced electricity consumption.

We did not identify any previous air rules that calculated the health benefits associated with reduced 

electricity consumption, but we identified other recent efforts that are similar.

EPA Air Rules calculating energy disbenefits (health)

· Portland Cement NESHAP (2010): increased electricity and fuel usage

EPA Air Rules calculating energy benefits from decrease fuel usage (health)

· Light Duty Vehicle Greenhouse Gas Rule (2010): upstream generation and consumption

· Heavy Duty Greenhouse Gas Rule (forthcoming 2010): upstream generation and consumption

·Renewable Fuel Standard (2010): Upstream generation and distribution, not fuel savings

·Locomotive Marine Rule (2008): maybe just consumption

EPA Air Rules calculating health benefits from reducing emissions from EGUs

· Federal Transport Rule (2010)

·SO2 NAAQS (2010)

·CAIR (2005)

Other studies estimating health benefits associated with reducing electricity consumption

· National Research Council. 2010. Hidden Costs of Energy: Unpriced Consequences of Energy Production 

and Use. National Academies Press: Washington, D.C.: 466 pp.

· Levy, J.I., L.K. Baxter, and J. Schwartz. 2009. Uncertainty and variability in health-related damages from 

coal-fired power plants in the United States. Risk Anal. 29(7):1000-1014.

 Amy Lamson

 Air Benefit and Cost Group

 Office of Air Quality Planning and Standards

 US Environmental Protection Agency

 109 TW Alexander Dr. (C439-02)

 Research Triangle Park, NC 27711

 Phone: (919) 541-4383

 Fax: (919) 541-0839

 

From: Sharon Nizich/RTP/USEPA/US

To: cortney_higgins@omb.eop.gov
Cc: Steve Fruh/RTP/USEPA/US@EPA, Donnalee

Jones/RTP/USEPA/US@EPA, Amy Lamson/RTP/USEPA/US@EPA, Tom Walton/RTP/USEPA/US@EPA, 

Mike Thrift/DC/USEPA/US@EPA, JohnB Chamberlin/DC/USEPA/US@EPA, Ron 

Evans/RTP/USEPA/US@EPA, Teresa Clemons/RTP/USEPA/US@EPA, norwood.phil@ecrweb.com

Date: 08/09/2010 12:40 PM

Subject: Redline and clean copy of discussed revisions - MCL

Hello CortneyPlease find attached the red line and clean copy of revisions you requested last week. Also there are 

links here to economics info, courtesy of Amy Lamson.

So we'll talk to you tomorrow - thank you.

[attachment "Suppl-Hgcell-prop 08-09-10 redline.doc" deleted by Amy Lamson/RTP/USEPA/US] 

[attachment "Suppl-Hgcell-prop 08-09-10 clean.doc"

deleted by Amy Lamson/RTP/USEPA/US]

Link to CAMR RIA: http://www.epa.gov/ttn/ecas/regdata/RIAs/mercury_ria_final.pdf

Link to all OAQPS RIAs: http://www.epa.gov/ttn/ecas/ria.html

Link to BPT estimates: http://www.epa.gov/air/benmap/bpt.html

[attachment "fann 2009.pdf" deleted by Amy Lamson/RTP/USEPA/US]

Sharon V. Nizich

Metals and Minerals Group

Sector Policies and Programs Division

OAQPS - US EPA

RTP NC 27711

919/541-2825