March 6 , 2012

Mr. Steve Fruh Sector Policies and Programs Division (D243

– 02) Office of Air Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, NC 27711

RE: Request for Comment Extension

National Emission S tandards for Hazardous Air Pollutant Emissions for Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks, Supplemental Proposed Rule, 77 Fed. Reg. 6628 (2012)

Docket ID No. EPA

– HQ

– OAR

– 2010

– 0600

Dear Mr. Fruh:

The National Association f or Surface Finishing (NASF) respectfully requests that EPA extend the comment period for at least 30 days on the February 8, 2012 proposed National Emissions Standards for Hazardous Air Pollutant (NESHAP) for hard and decorative chromium electroplating and chromium anodizing tanks. 77 Fed. Reg. 6628 (2012). Members of the NASF will be directly impacted by the supplemental proposed

rule.

The NASF has nearly 2,000 members that include surface finishing and coatings companies, surface finishing suppliers, and professional /academic members. The surface finishing industry plays a vital role in the global manufacturing value chain across key sectors, including automotive and transportation, aerospace/defense, electronics, energy, communications, medical, con struction and other sectors, and contributes significantly to

the nation’s economy . The industry’s role in corrosion protection alone provides an estimated $200 billion annual economic benefit to the nation.

NASF has been working with EPA officials and providing technical information to ensure that the Agency can make informed decisions on this rulemaking. For the reasons2

stated below, EPA and the public would benefit from an extension of the comment period.

1 ) The February 2012 supplemental proposal is substantially different from the October 2010 proposed rule. Specifically, EPA has now included revised emission limits and surface tension levels for chromium electroplating and anodizing tanks.

2 ) To support the supplemental proposal, EPA based its conclu sions on data newly gathered from over 28 state regulatory agencies regarding chromium electroplating and anodizing operations. Based on our initial review of these new data, NASF has begun to identify significant potential errors in the data, including:

• data from facilities that have been closed for several years,

• data from facilities that no longer process hexavalent chromium,

• data from facilities that predated the implementation of the 1995 chromium electroplating MACT standard, and

• data that are not r epresentative of the most recent operations at facilities.

3 ) The supplemental proposed rule relies on this and other data to support several technical claims such as revised surface tension levels, revised emission limits, current industry emissions control practices, new fume suppressant technology, residual risk analysis and cost impacts. Accordingly, more time is needed for NASF to continue its review of the data in the record, particularly the new data added for the supplemental proposal, to have the op portunity to comment effectively on the proposed rule.

4 ) It is critical to ensure that the data in the record are accurate and reflective of the practices and operational status of chromium electroplating and anodizing

facilities. Additional time to review , evaluate and comment on the data would

assist EPA’s effort to make an informed decisions based on credible data regarding available control technologies and practices in the surface finishing industry.

NASF recognizes that EPA is facing a court

- ordered deadline for the issuance of the final rule. Nonetheless, a 30

- day extension of the comment period would allow NASF and the public to provide input that will improve the technical basis for

— and legal soundness

of

— - EPA’s rule.

On behalf of the National A ssociation for Surface Finishing (NASF), we appreciate your consideration of this request, and look forward to hearing from you soon. If you have any questions or would like additional information, please contact us by email or phone

at crichter@thepolicygroup.com or 202

- 257

- 0250 and jhannapel@thepolicygroup.com or 202

- 257

- 3756.3

Respectfully submitted,

Christian Richter Jeffery S. Hannapel The Policy Group On Behalf of the National Association for Surface Finishing

cc: Chuck French

Phil Mulrine