From: Jones, Danielle [ mailto:Danielle_Y_Jones@omb.eop.gov ]

Sent: Thursday, January 14, 2016 12:52 PM

To: Cogliano, Gerain < Cogliano.Gerain@epa.gov > Subject: RE: EO 12866/13563 Interagency Review: Modernization of the Accidental Release Prevention Regulations Under Clean Air Act (RIN 2050

- AG82)
Attachments: EO 12866 Interagency Comments RMP 2.docx

Gerain,

Here are the remaining comments.

Thanks,
Danielle

From: Cogliano, Gerain [ mailto:Cogliano.Gerain@epa.gov ]

Sent: Thursday, January 14, 2016 6:59 AM

To: Jones, Danielle < Danielle_Y_Jones@omb.eop.gov > Subject: RE: EO 12866/13563 Interagency Review: Modernization of the Accidental Release Prevention Regulations Under Clean Air Act (RIN 2050

- AG82)

Thanks, Danielle!

From: Jones, Danielle [ mailto:Danielle_Y_Jon es@omb.eop.gov ]

Sent: Wednesday, January 13, 2016 4:15 PM

To: Cogliano, Gerain < Cogliano.Gerain@epa.gov > Subject: EO 12866/13563 Interagency Review: Modernization of the Accidental Release Prevention Regulati ons Under Clean Air Act (RIN 2050

- AG82)

Hello Gerain,

Attached please find the interagency comments on the EPA’s Modernization of the Accidental Release Prevention Regulations Under Clean Air Act proposed rule. We are still waiting for comments from one additional review that will be sent separately.

Best,
Danielle

Danielle Y. Jones Policy Analyst Office of Management and Budget Phone: (202) 395

- 1741 | djones@omb.eop.govAttachment s : EO 12866 Interagency Comments RMP 2.docx



## Summary of Interagency Working Comments on Draft Language under
EO12866 /13563 Interagency Review. Subject to Further Policy Review.

2 1. EPA Guidance entitled “Guidance for Implementing Agencies (February 1998, >http://www.epa.gov/sites/production/files/2013

- 10/documents/iguidfnl.pdf<)” states: “EPA expects that the rule will cover all petroleum refineries, many chemical manufacturers (mostly manufacturers of basic chemicals), food processors and distributors who have ammonia refrigeration systems, other manufacturers such as pulp and paper mills and primary and

secon dary metal manufacturers, propane and agricultural retailers, chemical wholesalers, drinking water and wastewater treatment systems, electric utilities, and Federal installations, such as military bases and Department of Energy facilities.” EPA’s proposed rule currently does not discuss the applicability of the rule to Federal installations, and it would be useful to clarify the applicability. At this time, the only mention of Department of Defense or other Federal agencies is with respect to disclosure o f information: “The disclosure of information classified by the Department of Defense or other Federal agencies or contractors of such agencies shall be controlled by applicable laws, regulations, or executive orders concerning the release of
classified in formation.”

2. Page 25, recommended edit: (chaired by EPA, OSHA, and Department of Homeland Security [ ( DHS ] ) )

3. Page 78, insert comma after (ISD) in the following sentence: “ STAA includes concepts known as IST or inherently safer design (ISD)

, which are those s trategies that reduce or eliminate the hazards associated with materials and operations used in a process.

4. Page 90, recommended edit: Numerous trade associations (ACC, SOCMA, Independent
Petroleum Association of America [ ( IPAA ] ) and American Exploratio n & Production Council [ ( AXPC ] )

,