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-.pdf

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 Minnesota 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 been 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 non-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 remained 
under 33 (surface tension 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 reflect 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 large 

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 

202.395.7856 

chiggins@omb.eop.gov