OMB meeting for Shipbuilding and Wood Furniture RTR, 10/5/11

Attendees: Via phone: George Woodall (ORD), Sarah Mazur (ORD), Ann Johnson (OP), Mark 

Kataoka (OGC), Rick Vetter (OGC) Courtney Higgins (OMB), Christine Kymn (OMB) Rafeal 

Sanchez (OECA); In person (OAQPS): Keith Barnett, Tina Ndoh, Robin Dunkins, Nicholas 

Swanson

Discussion items from EPA:

EPA provided an overview of the rulemaking by going over a presentation titled “OMB 

Briefing PPT 10.5.11 for all.ppt”

Clarifying questions were answered as they pertained to the rulepackage

There were no specific questions on preamble language or rule text language as this 

meeting preceded review of the package.

OMB had questions on the risks from the rule, but the discussion was tabled until EPA risk 

experts could be available for a call. 

OMB meeting for Shipbuilding and Wood Furniture RTR, 10/6/11

Attendees: Via phone: George Woodall (ORD), Sarah Mazur (ORD), Ann Johnson (OP), Mark 

Kataoka (OGC), Rick Vetter (OGC) Courtney Higgins (OMB), Christine Kymn (OMB); In person 

(OAQPS): Keith Barnett, Tina Ndoh, Robin Dunkins, Nicholas Swanson, Dave Guinnip, Jim 

Hirtz

Discussion items from OMB:

OMB requested clarification on risk estimation with allowable vs actual. Dave Guinnip 

gave an overview of how allowable and actual risks are determined and gave the values 

for actual and allowable as provided in the risk report. 

OMB asked for clarification on the statutory authority under which EPA plans to finalize 

the amendments to the Wood Furniture rule. EPA responded that amendments will be 

finalized under 112 (d)(6) or the technology review portion. 

OMB asked for clarification on how the 1% formaldehyde limit was determined. EPA 

provided explanation that 400 lb limit was not achievable by certain facilities with high 

production, and that the described method for achieving the 400 lbs in the proposal was 

for facilities to use low or no formaldehyde coatings, which we have worked with industry 

to determine that 1% is considered an upper bound for low formaldehyde coating. 

Following comment that the 400 lb limit would not be achievable without having facilities 

decrease production or employ technology that was not cost-effective, EPA moved 

forward with the final rule language that source could comply by meeting the 1% 

formaldehyde limit or meet an alternative compliance option of 400lbs. 
OMB meeting for Shipbuilding and Wood Furniture RTR, 10/21/11

Attendees: Via phone: George Woodall (ORD), Sarah Mazur (ORD), Ann Johnson (OP), Mark 

Kataoka (OGC), Nancy Beck (OMB), Christine Kymn (OMB); In person (OAQPS): Jim Hirtz, 

Dave Guinnup, Tina Ndoh, Robin Dunkins, Kim Teal

Discussion items from OMB:

Discussion on risk values for formaldehyde and acceptability determinations- EPA is 

providing OMB with a chart to summarize risk decisions across all current RTR rules. 

There were no specific questions to be addressed. 

Discussion on 1% and alternative compliance for formaldehyde- EPA clarified that the 

expectation is that all sources can currently meet one of the two alternatives. We also 

clarified that we expect that all but one high production facility can meet the 400 lb hard 

cap, and that we confirmed with that one facility that the alternative compliance option 

can be met. 

Discussion on consistency for 112(d)(6) authority for formaldehyde limit between Wood 

Furniture „changes since proposal‟ section and „response to significant comments‟ 

section. EPA agreed to review text in both sections, and make sure language is 

consistent as appropriate. 

Recordkeeping and reporting requirements- OMB raised concern over comment on 

costs associated with recordkeeping and reporting requirements. EPA agreed to look at 

the language, and edit as appropriate. EPA also noted that there was no data or 

information provided to substantiate the claim that the costs were overly burdensome, 

and that recordkeeping is the primary method for assuring compliance with this rule. 

Discussion on preamble comment on spray guns-OMB requested more explicit 

statement of how HVLP spray guns will result in lower emissions. EPA agreed to edit 

text to be more explicit. 

Request to move text discussing changes to both rules since proposal to earlier point in 

document- EPA reviewed the text and found that there is discussion on changes to both 

rules since proposal early in the preamble language. Specifically, there is text on 

multiple pages of Section III stating that there are no changes since proposal for the 

Shipbuilding rule, and 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. 

OMB meeting for Shipbuilding and Wood Furniture RTR, 10/28/11

Attendees: Via phone: George Woodall (ORD), Sarah Mazur (ORD), Ann Johnson 

(OP), Mark Kataoka (OGC), Nancy Beck (OMB), Christine Kymn (OMB), Jim 

Hirtz(OAQPS)Keith Barnett (OAQPS); In person (OAQPS):Nick Swanson, Tina Ndoh, 

Robin Dunkins

Logical outgrowth discussion continued from last call- OMB requested that EPA add 

language clarifying that industry understanding of low formaldehyde is less than 1%, and 
that we clarify language that 1% is cost effective, but we cannot assure that requiring a 

more stringent option of less than 1% is still cost effective. Discussion referenced 

language in the draft Response to Comment document on this subject.

OMB requested that EPA clarify language in the preamble and clearly state that „risk is 

not the catalyst for technology update‟, clarify that „risk are acceptable‟. EPA agreed to 

look over the language and make revisions 

OMB discussed concerns with formaldehyde risk values used. The item was tabled to 

be addressed on a later call that would focus on formaldehyde risk language across all 

pending RTR packages.