From:	Brian Shrager/RTP/USEPA/US
To:	"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>
Cc:	Jim Eddinger/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA
Date:	12/01/2011 02:11 PM
Subject:	Re: Interagency comments on Boilers rules (both Major and  Area)

Cortney,

Here are our responses (for major sources) to this set of comments. I will send the responses to set of preamble edits shortly.

Thanks!

Brian

Strikeout Issue:
.              In the major source rule, are the values in the third column of Tables 1 and 2 to subpart DDDDD correct?  These have changed in recent versions, and we want to make sure the reg text is correct.

The limits are correct.

Definition of Qualified Energy Assessor:
.              In the area source rule Page 92/93. Consider deleting the words "for opportunity" after the word "opportunities."
.              In the major source rule on page 295: The definition should probably be the same as in the area source rule.

Change made.

Definition of EGU:
.              EPA revised the definition in the area source rule on page 88.  The definition in the major source rule on page 282 should probably be changed to match the area source rule.  The definition on page 821 of the EGU NESHAP might also need to be changed to match the area source rule.

Change made so that major matches the definition in area.

Other definitions also differ between the area and major source rules.
Some differences might be intentional but others might need to be changed to be consistent.  Definitions that differ that might need to be made more similar include (but may not be limited to):

Some differences are intentional due to differences in coverage of the rules (major covers gas units and process heaters while area does not).
I've indicated below where we have made changes.

.              Hot Water Heater-Added "Hot Water Boiler" sentence at end of definition
.              Liquid Fuel-no change
.              Period of gas curtailment or supply interruption-Changed major to match area source definition
.              Process Heater-no change
.              Residential Boiler (major source rule version might be best)-no change (area source changed to match major)

--------------------------------------------------------------------------------

From:	"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>
To:	Brian Shrager/RTP/USEPA/US@EPA, Jim
            Eddinger/RTP/USEPA/US@EPA
Cc:	RobertJ Wayland/RTP/USEPA/US@EPA
Date:	11/30/2011 03:48 PM
Subject:	Interagency comments on Boilers rules (both Major and Area)


Hi all,

I wanted to pass along these interagency comments on the latest drafts you've shared with us today.  I will also be sending a redline of the major source rule shortly, but thought I'd send these ahead of the
redline:

Strikeout Issue:
.              In the major source rule, are the values in the third column of Tables 1 and 2 to subpart DDDDD correct?  These have changed in recent versions, and we want to make sure the reg text is correct.

Definition of Qualified Energy Assessor:
.              In the area source rule Page 92/93. Consider deleting the words "for opportunity" after the word "opportunities."
.              In the major source rule on page 295: The definition should probably be the same as in the area source rule.

Definition of EGU:
.              EPA revised the definition in the area source rule on page 88.  The definition in the major source rule on page 282 should probably be changed to match the area source rule.  The definition on page 821 of the EGU NESHAP might also need to be changed to match the area source rule.

Other definitions also differ between the area and major source rules. Some differences might be intentional but others might need to be changed to be consistent.  Definitions that differ that might need to be made more similar include (but may not be limited to):
.              Hot Water Heater
.              Liquid Fuel
.              Period of gas curtailment or supply interruption
.              Process Heater
.              Residential Boiler (major source rule version might be best)

Regards,
Cortney

