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 Standards 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 for 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, construction 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 reasons 
2

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 conclusions 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 representative 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 opportunity 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 Association 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