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 pers on (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 the y 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 co uld 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 a ctual risk s 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

p roduction, 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%
form aldehyde 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) , Chris tine Kymn (OMB); In person (OAQPS): Jim Hirtz,
Dave Guinnup , Tina Ndoh , Robin Dunkins, Kim Teal

Discussion item s from OMB:

Discussion on risk values for formaldehyde and acceptability determinations

- EPA is providing OMB with a chart to summarize risk deci sions 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 . W e 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 requ irements

- 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 cl aim 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 m ove 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 req uirements 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 requ ested that EPA add language clarifying that industry understanding of low formaldehyde is less than 1%, andthat 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 effect ive. 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 acceptabl e‟. 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.