Email Correspondence Between The EPA and OMB Regarding Wood Furniture 

Manufacturing Operations NESHAP

10/25/2011 5:22pm

To: OMB (Christine Kymn, Cortney Higgins, Nancy Beck)

cc: Tina Ndoh, Keith Barnett, James Hirtz, Dave Guinnup, Mark Kataoka, Sarah Mazur, Ann 

Johnson, Chuck French

From: Nicholas Swanson via Robin Dunkins

Robin,

Attached are our edits for OMB. Both copies are in RLSO form. 

Concerning the meeting that occurred on Friday:

OMB expressed concerns regarding the impacts of using background risk --> We did not take 

background risk into consideration because of unreliable data and uncertainty

OMB noticed an apparent inconsistency with commenters regarding our justification using 

112(d)(6) --> The sentence in question on page 29 has been deleted and an explanation is 

provided in the significant comment section on page 60. 

OMB raised concern over comment on costs associated with recordkeeping and reporting 

requirements --> We did not receive data that shows that our R&R requirements are overly 

burdensome and are not reacquired to demonstrate compliance.

OMB requested a more explicit explanation of how non-conventional spray guns decrease 

emission --> Additional language has been added on pages 15 & 75

OMB requested that changes to the rules since proposal be discussed earlier in the preamble. --

> There is text on pg. 11 stating that there are no changes since proposal for the Shipbuilding 

rule, and text on pgs. 13 and 15 discussing the changes since proposal for the formaldehyde 

limit and spray gun requirements for Wood Furniture. This is in addition to the lengthier 

discussion found in section IV, Summary of Significant Changes since Proposal. 

We also believe that upon our explanation in Friday's meeting in conjunction with OMB 

rereading the package that the formaldehyde limit of 1% of coating formulation with an 

alternative option of 400 lb/year is clear. We request additional feedback if this is not the case 

from OMB

In addition to OMB's concerns, on pages 21 & 26 there are revisions to citations for affirmative 

defense. Pages 26-28 contain the new language to help bolster the argument. I also eliminated 

the word "add-on" from "add-on control device" throughout the document to maintain consistent 

language from the original NESHAP for wood furniture.
10/27/2011 1:05pm

To: OMB (Christine Kymn, Cortney Higgins, Nancy Beck)

cc: Tina Ndoh, Keith Barnett, James Hirtz, Dave Guinnup, Mark Kataoka, Sarah Mazur, Ann 

Johnson, Chuck French

From: Nicholas Swanson via Robin Dunkins

Robin, 

I have many of the edits requested by OMB. There are still outstanding issues re: CIIT vs IRIS 

for formaldehyde that have not been addressed and we would like to discuss them in the 

meeting to come. Also please note that some of the edits made are under the label of "EPA" 

and some are under the generic "Author." All comment bubbles that are in the document are 

from OMB and are retained for the sake of retaining ability to discuss. Thanks

11/2/2011 12:05pm

To: OMB (Christine Kymn, Cortney Higgins, Nancy Beck)

cc: Tina Ndoh, Keith Barnett, James Hirtz, Dave Guinnup, Mark Kataoka, Sarah Mazur, Ann 

Johnson, Chuck French

From: Nicholas Swanson via Robin Dunkins

Robin,

Attached is a revised version of what was sent over to OMB yesterday. This includes the 

chronic formaldehyde language that has been of much discussion. It is consistent with the 

ferroalloys language. This is on page 60. Also the new language regarding "rounding" and 

ACGIH values is on page 44. The sentence of concern has been deleted and replaced with 

recommended language from ORD. There were two other small edits from our end. The first is 

that I changed the name of a supporting memo to exclude the name "Dick Titus." His name has 

been changed to changed to "a Representative." This is seen on pages 16 & 38 in the 

footnotes. Finally, on page 62, the word "limit" has been replaced with "level" regarding the 

sentence: "Above certain exposure limits..."

Thanks