Hi Nick,

Below are interagency comments on the CMAS rule. P lease let me know if you have any questions.

Regards, Cortney

Executive Summary Before Section I.A., in a new “A” section, can you please add an executive summary?

Guidance was given to agencies on 1/2/2012 on draft ing an executive summary, which I’ve pasted in belo w. Suggested Template for Executive Summaries (general ly 3-4 pages of a double-spaced Word document maximum, although unusually complex or lengthy regu latory actions may require longer executive summari es) I. Purpose of the Regulatory Action a. The need for the regulatory action and how the a ction will meet that need b. Succinct statement of legal authority for the re gulatory action (explaining, in brief, the legal au thority laid out later in the preamble)

II. Summary of the Major Provisions of the Regulato ry Action In Question (Each major provision should be described clearly a nd separately, along with a brief justification)
III. Costs and Benefits



### Interagency Comments under EO 13563 on the Chemical Manufacturing Area Source rule Higgins, Cortney

to: Nick Parsons 10/04/2012 10:18 AM Cc: Penny Lassiter, JohnB Chamberlin Hide Details From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.g ov>

To: Nick Parsons/RTP/USEPA/US@EPA

Cc: Penny Lassiter/RTP/USEPA/US@EPA, JohnB Chamberl in/DC/USEPA/US@EPA

History: This message has been forwarded. Page 1 of 2

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...(For economically significant regulatory actions, p lease include a table summarizing the assessment of costs and benefits, both quantitative and qualitative I )

For an example of a sample executive summary that f ollows the above guidance, see: http://www.gpo.gov/fdsys/pkg/FR

- 2012

- 09

- 11/pdf/2012

- 20501.pdf

Title V EPA was specifically asked by the petitioners to re consider the requirement that certain major sources that installed air pollution controls to become area sou rces obtain a Title V permit. We are supportive of EPA’s efforts, in this final rule, to ensure greater cons istency in public participation and to improve moni toring and compliance certification efforts. Interagency com menters would like to continue discussions with EPA to better understand the benefits of requiring Title V permit s.

Technical Correction

– Concentration Thresholds In its January 30, 2012, Proposed Rule, EPA suggest ed the following technical correction: A CMPU is subject (to this rule) if the collective concentration of the Table 1 HAPs exceeds 50 parts per million by volume in any process vent stream. This threshold was specified because this concentration defines a process vent, and such emissions streams are subject to control.

In the Final Rule, EPA states: We have revised this language to clarify that the c oncentration thresholds for applicability of Table 1
HAP are to be determined on an individual Table 1 H AP concentration, rather than a collective concentration. In addition, we have also clarified that the 0.1 percent by weight threshold for Table 1 HAP present in liquid streams (process or waste) al so applies to Table 1 HAP present in any continuous process or batch process vent, rather than the prop osed 50 ppmv threshold.

Interagency commenters would like to better underst and EPA’s revisions in the final rule language, and welcomes the opportunity to discuss the final rule language with EPA. 

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