Subject: EO 13563 Interagency Comments on Chromium RTR

Attachments: E O 12866_CromiumElectroplatingSteelPickling_2060

- AQ60P_Promulgation

- 7

- 13

- 2012_OMBcommentsunderEO13563.docx

From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To: Chuck French/RTP/USEPA/US@EPA

Date: 08/02/2012 11:40 AM Subject: RE: EO 13563 Interagency Comments on Chromium RTR

Hi Chuck, Attached is a redline of the preamble with interagency comments under EO 13563.

Thanks, Cortney

From: Chu ck French [mailto:French.Chuck@epamail.epa.gov] Sent: Thursday, August 02, 2012 10:20 AM To: Higgins, Cortney Subject: Re: EO 13563 Interagency Comments on Chromium RTR Hi Cortney,

Thanks for the comments. We are reviewing them.. Regarding comment # 4, it refers to an attachment (Profile document). However, I did not receive the attachment. Could you please send that document.

Thanks.

Chuck

Phone: 919

- 541

- 7912

"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: 08/01/2 012 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 n on

- 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 thepublic 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 opportun ity 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

emis sions 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 sp readsheet 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 covere d 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 requi rement 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

- H AP 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(See attached file: E O 12866_CromiumElectroplatingSteelPickling_2060

- AQ60P_Promulgation

- 7

- 13

- 2012_OMBcommentsunderEO13563.docx)