Ron Evans/RTP/USEPA/US 

09/19/2008 09:58 AM

	

To

Heidi_R._King@omb.eop.gov

cc

Brian Heninger/DC/USEPA/US@EPA, Charles Fulcher/RTP/USEPA/US@EPA,
Charlotte Bertrand/DC/USEPA/US@EPA, Darryl Weatherhead/RTP/USEPA/US@EPA,
Kathy Kaufman/RTP/USEPA/US@EPA, Nathalie Simon/DC/USEPA/US@EPA, Neal
Fann/RTP/USEPA/US@EPA, Ron Evans/RTP/USEPA/US@EPA, Tom
Walton/RTP/USEPA/US@EPA, Lydia Wegman, Tricia Crabtree/RTP/USEPA/US@EPA

Subject

Answers to questions posed during 10/15 Pb NAAQS RIA cost discussion









Heidi, here are the responses to the questions you raised during the
meeting on Monday the 15th.   We will be happy to address any follow-up
during our Monday.

Ron

Darryl Weatherhead/RTP/USEPA/US

09/18/2008 03:01 PM

	

To

Ron Evans/RTP/USEPA/US

cc

Kathy Kaufman/RTP/USEPA/US@EPA, walton.tom@epa.gov

Subject

Re: followup from this am with Heidi









Difference between Proposal & Final wrt emissions needed from
unidentified controls & monitor areas.

Emissions Needed to Attain 

Standard	Reductions Needed from Unidentified Controls - Proposal RIA
Reductions Needed from Unidentified Controls - Final RIA

0.5 :g/m3 2nd Maximum Monthly Mean	0.02	0.02

0.3 :g/m3 2nd Maximum Monthly Mean	12.4	0.55

0.2 :g/m3 2nd Maximum Monthly Mean	24.4	1.55

0.1 :g/m3 2nd Maximum Monthly Mean	48.2	6.09



Monitors

At proposal 36 monitors were projected to violate 0.05 ug/m3 and 23
monitors were projected to violate 0.1 ug/m3.  Since we have dropped
0.05 ug/m3 from the analysis, and there were updates to monitor
locations etc.  We had 24 monitors projected to violate 0.1 ug/m3.  We
did find an error with the way the baseline was calculated for 1 area,
once this change was rectified, the number of monitors projected to
violate 0.1 ug/m3 was 23.  So the universe of monitors being analyzed in
the Controls & Cost Analysis is 23.

Importance of the Herculaneum rebuild 

The Herculaneum rebuild would reduce emissions by 45.52 tons and is
applicable for all levels of the standard.  The total cost of the
control is estimated to be $184.5 million (2006$)

This represents 50 to 60 % of the emission reductions from identified
Controls.  Although, at Proposal Herculaneum represented between 25% -
30% of the unidentified emission reductions.  In addition, at proposal
unidentified controls at Herculaneum represented between 95% - 55% of
the estimated total costs.

We can provide more data on the Kivcet process or the costing for this
facility as needed.

Can we send the spreadsheets which underlie the presentation materials
(note that Heidi only has Windows 2003 if that makes a difference) (new)

The only data that is not explicitly represented in the presentation is
the graphic for the total cost curve.  I've attached the data used to
graph that curve.

They would like to see the cost numbers with and without the outlier
which causes the numbers to blow up

They would like to see the details on the outlier, what is it and how
much reduction does it get.

Dallas, Texas is an area I consider an outlier.  The numbers we gave in
the briefing included the Dallas dollars per microgram number of
$22,574,852 in the average of the nine areas that made progress that was
used for the four areas that didn't make progress.  The average without
Dallas would be $1,563,131,844 rather than the average we used of
$3,806,779,129.

These are the national summaries with no changes from the briefing:

	.1 Standard	.2 Standard	.3 Standard	.5 Standard

Emission extrapolation	$279,358,740	$204,483,752	$182,546,569
$49,552,362

TC regression	$289,086,708	$207,810,325	$183,930,405	$49,626,820

Ambient Extrapolation	$6,592,679,727	$3,822,228,891	$1,944,833,040
$162,337,535



Here are the numbers if we dropped Dallas out of the average:

	.1 Standard	.2 Standard	.3 Standard	.5 Standard

Emission extrapolation	$279,358,740	$204,483,752	$182,546,569
$49,552,362

TC regression	$289,086,708	$207,810,325	$183,930,405	$49,626,820

Ambient Extrapolation	$4,304,589,698	$2,431,597,776	$1,295,002,815
$95,855,604



if we dropped Dallas out of the average and also computed no cost for
Dallas itself the numbers don't change much because Dallas only has to
go from .10104 to .1 .  The numbers would be:

	.1 Standard	.2 Standard	.3 Standard	.5 Standard

Emission extrapolation	$279,358,740	$204,483,752	$182,546,569
$49,552,362

TC regression	$289,086,708	$207,810,325	$183,930,405	$49,626,820

Ambient Extrapolation	$4,282,014,846	$2,431,597,776	$1,295,002,815
$95,855,604



  

Finally if we were to substitute the Dallas number of  $22,574,852 for
the four areas with no progress rather than use the average we get:

	.1 Standard	.2 Standard	.3 Standard	.5 Standard

Emission extrapolation	$279,358,740	$204,483,752	$182,546,569
$49,552,362

TC regression	$289,086,708	$207,810,325	$183,930,405	$49,626,820

Ambient Extrapolation	$24,897,399,962	$14,947,277,813	$7,143,474,841
$694,192,982



This would increase the cost for .1 by almost a factor of six compared
to the briefing number.

Iron & Steel

I've attached the breakdown of costs by NAICS codes to show how the iron
& steel industry is affected relative to other industries.

