From: Chuck French [French.Chuck@epamail.epa.gov] Sent: Tuesday, August 07, 2012 5:37 PM To: Higgins, Cortney Cc: Ann Johnson; Mark Morris; Nathan_J._Frey@omb.eop.gov; Phil Mulrine; Robin Langdon; Tom Walton; Ann Johnson; Hancy, Cindy Wang; Erin Newman; Jan Tierney; Kelly Rimer; Marinshaw, Richard; Sara Ayres; Steve Fruh; Tim Benner Subject: Re: EO 13563 Interagency Comments on Chromium RTR Attachments: Cr Electroplating Interagency Comments

- Responses

- 8

- 7

- 12.docx; 978

- 87

- 92779

- 10

- .pd f

Hi Cortney,

Attached are our responses to the Interagency comments that you sent us on 8/1/2012. Also attached is the Danish study which is referenced in the responses.

Let me know if you have questions.

Thanks.

Chuck French

Phone: 919

- 541

- 7912

(See attached file: Cr Electroplating Interagency Comments

- Responses

- 8

- 7

- 12.docx) (See attached file: 978

- 87

- 92779

- 10

- 6.pdf)

"Higgins, Cortney"

--- 08/01/2012 06:12:13 PM

--- Hi Chuck, Below are interagency comments on the Chromium RTR. I'll be sending over a redline of the

From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> To: Chuck French/RTP/USEPA/US@EPA Date: 08/01/2012 06:12 PM Subject: EO 13563 Interagency Comments on Chromium RTR

Hi Chuck, Below are interagency comments on the Chromium RTR. I’ll be sending over a redline of the preamble in the morning. 1. EPA has provided new data on the behavior of non

- PFOS fume suppressants (FS) in the memo titled Information on non

- PFOS Fume Suppressants in Min nesota Chromium Electroplating Facilities. Although this data appears to support EPA’s position that non

- PFOS FS are cost

- effective replacements for FS with PFOS, Advocacy staff wanted to note that the data has not been seen by the public and has not bee n subject to a notice and comment period. Advocacy staff suggest that EPA issue a Notice of Data Availability (NODA) to provide the public with an opportunity to comment on the newly collected data. 2. Question regarding Attachment 3 to Information on n on

- PFOS Fume Suppressants in Minnesota Chromium Electroplating Facilities: What other conclusions can be drawn about the relationship between FS and surface tension from this spreadsheet besides that the surface tension has remainedunder 33 (surface te nsion limit if measured with a tensiometer)? For instance, some days it takes twice the amount of FS to achieve the same surface tension level e.g. 5/2/2012 and 5/3/2012 or 4/17/2012 and 4/18/2012. 3. Does EPA have any data that contradicts the finding in the new German FS suppressant study performed by Merck that demonstrates that there is no correlation between surface tension level and emissions level? 4. Please find attached a marked

- up copy of the Cr Electroplating Industry Profile 6.27.12 document showing the facilities for which the NASF and EPA data differs. Does EPA believe that the NASF data is reliable and will EPA update this spreadsheet to re flect the most current data for the docket? 5. Page 125, Table 2 to 63.342, Subpart N, item 5, column 2: There are two item "(iv)"s. Delete the first "(iv) Other cleaning method approved by the permitting agency;" because is already covered in item "(v)"

. 6. For consistency EPA should revise section 63.342(c)(2)(iv) by changing "are affected sources other than those that are existing affected sources located at small hard chrome plating facilities" to "are existing affected sources and are located at large hard chrome plating facilities" and by revising section 63.344(f)(i)(A) by changing "an affected source other than an existing affected source located at a small hard chromium electroplating facility" to "an existing affected source located at a la rge hard chrome plating facility." We are referring to the text in the rule that is not currently being revised by EPA. EPA made this change in section 63.342(c)(1)(iii) and section 63.342(c)(2)(i). It is definitely clearer to say a requirement applies to large facilities rather than saying it applies to everything other than small facilities. 7. We would suggest that EPA consider adding some explanation in the discussion about the multipathway analysis on why chemicals that are not PB

- HAP are unlikely to present non

- inhalation risks. 8. Did EPA consider monetizing benefits associated with reduction in cancer risks?

Regards, Cortney

________________________________________________ Cortney Higgins, PhD Policy Analyst OMB/OIRA/NRE 202.395.7 856 chiggins@omb.eop.gov