Springsteen
B.,
EERGC
Inc.,
personal
communication,
September,
2003
Phone
Call
between
Bruce
Springsteen
of
EERGC
and
Jason
Price
of
Industrial
Economics.

Jason
Price
called
Bruce
Springsteen
at
EERGC
to
ask
a
number
of
questions.
These
questions
are
presented
below,
followed
by
Springsteen's
answers.

 
Question
(
JP):
Do
estimated
engineering
costs
need
to
include
costs
to
new
systems
the
EPA
anticipates
will
come
on
line
in
the
future?
 
Answer
(
BS):
New
systems
that
come
on
line
will
more
than
likely
face
no
additional
costs
because
of
the
HWC
MACT
standards
because,
as
new
facilities,
they
are
built
with
more
recent
technology
that
would
make
them
compliant
with
the
MACT
standards.
Systems
using
activated
carbon
to
control
emissions
of
dioxin/
furans
and
mercury
will
generate
almost
11,000
tons
of
carbon
on
an
annual
basis.

 
Question
(
JP):
Will
mobile
incinerators
need
to
do
anything
to
comply
with
the
standards?
 
Answer
(
BS):
No.
Stack
gas
emissions
from
mobile
incinerators
are
low
enough
for
compliance.
Also,
very
few
mobile
incinerators
are
currently
in
use.

 
Question
(
JP):
How
is
the
statistical
design
level
estimated?
 
Answer
(
BS):
First,
all
sources
are
rank
ordered
and
then
the
average
of
the
top
12
percent
(
in
terms
of
lowest
emissions)
is
calculated.
Then
a
variability
factor,
based
on
the
variance
in
the
performance
of
the
top
12
percent
of
sources,
is
estimated.
The
SDL
is
based
on
this
variability
factor
and
the
average.

 
Question
(
JP):
Are
shut
down
costs
included
in
EERGC's
engineering
cost
estimates?
 
Answer
(
BS):
Yes.
EERGC
assumes
shutdown
costs
are
zero
because
retrofitting
can
be
done
during
routine
maintenance.
