This
note
concerns
discussions
with
OMB
and
SBA
in
January
and
February
2004.
EPA
discussed
various
aspects
with
OMB
and
SBA
on
several
occasions.
We
met
with
OMB
and/
or
SBA
on:
08
Oct
03;
22
Jan
04;
13
Feb
04;
17
Feb
04;
20
Feb
04;
23
Feb
04;
24
Feb
04;
25
Feb
04;
and
26
Feb
04.

EPA
was
represented
by:
Ann
Johnson,
Keith
Mason,
Dave
Guinnup,
Fred
Talcott,
Tom
Gilles,
Kevin
Bromberg,
Lisa
Connor,
Scott
Jenkins,
KC
Hustvedt,
Mike
Thrift,
Bob
Fegley,
Rick
Vetter,
Stan
Durkee,
Jim
Eddinger,
Mary
Tom
Kissell,
Larry
Sorrels,
John
Chamberlin,
Ken
Mitchell,
Sally
Shaver.

OMB
and
SBA
was
represented
by:
Edmond
Toy,
Paul
Nooe,
Rick
Canady,
Nancy
Beck,
Kevin
Bromberg,
Keith
Holman,
Art
Fraas.

October
08,
2004
Handouts
in
Docket
No.
OAR­
2003­
0048
as
item
OAR­
2003­
0048­
0155.

January
22,
2004
Discussed
and
clarified
the
production­
based
compliance
option
and
discussed
EPA's
direction
on
risk
in
PCWP.

February
13,
2004
Discussed
where
EPA
was
going
on
risk
on
draft
language
EPA
sent
OMB.
Draft
language
included
with
email
elsewhere
in
docket.

February
20,
2004
 
OMB
indicated
that
all
comments
that
applied
to
boilers
would
also
apply
to
plywood
 
EPA
indicated
that
the
rule
would
include
only
those
pollutants
that
were
important
to
the
risk
assessment
 
OMB
asked
whether
SO2
emissions
might
not
increase
because
of
the
rule;
EPA
replied
that
this
was
possible
and
that
contacts
at
IPM
would
be
helpful
in
answering
this
 
EPA
indicated
that
it
was
unresolved
on
Appendix
7
C
and
D
but
that
it
would
provide
language
by
the
end
of
today
 
OMB
asked
why
EPA
did
not
include
an
acute
table.
EPA
replied
that
if
it
included
an
acute
table
it
would
change
the
decrease
the
conservatism
of
the
non­
cancer
look­
up
table
by
30%.
 
OMB
observed
that
startup/
shutdown
may
lead
to
an
acute
scenario.
EPA
replied
that
it
is
not
interested
in
regulating
these
situations
February
23,
2004
 
OMB
questioned
whether
the
Reference
Concentration
should
be
treated
as
an
external
document;
EPA
replied
that
it
would
change
this
 
OMB
was
interested
in
whether
compliance
dates
change
depending
on
whether
an
area
source
becomes
a
major
source.
 
EPA
replied
that
sources
still
get
three
total
years
to
comply,
but
that
compliance
would
be
one
year
from
the
effective
date,
plus
60
days
 
OMB
stated
that
there
was
no
mention
of
where
people
live
in
the
risk
assessment
language
 
EPA
stated
it
would
fix
this
and
make
it
more
precise
 
OMB
questioned
whether
sources
could
have
a
choice
between
assessing
risk
at
the
fence
line
and
the
nearest
residential
zone
 
EPA
replied
that
it
would
make
this
change
 
OMB
found
that
EPA
needed
to
correct
language
relating
to
stack
heights
 
EPA
replied
that
it
would
make
this
change
 
OMB
inquired
about
a
table
in
the
auto
rule
that
related
to
generalized
effects
 
EPA
replied
that
it
would
remove
this
table
in
the
Plywood
rule
 
OMB
requested
that
the
rule
include
a
single
table
of
HAPs
that
facilities
could
use
in
a
risk
assessment
 
EPA
replied
that
it
reduced
the
list
to
those
HAPs
important
to
the
risk
assessment
 
OMB
found
that
the
rule
discussed
CO
too
much
 
EPA
replied
that
it
would
tone­
down
its
language
 
OMB
inquired
whether
the
language
concerning
PM,
NOx
and
SO2
would
be
consistent
with
the
final
Interstate
Air
quality
Rule
 
EPA
replied
that
it
would
be
consistent
February
24,
2004
 
OMB
asked
if
the
health
information
for
boilers
applied
to
plywood
and
asked
that
the
language
change
from
boilers
by
transferred
 
EPA
agreed
to
the
change
 
OMB
asked
for
an
update
on
the
assessment
of
mixtures
and
asked
that
language
in
section
7
of
the
appendix
that
refers
to
a
"
scientifically
acceptable
risk
assessment"
be
loosened
to
be
suggestive
and
less
constraining.
 
EPA
indicated
that
the
criteria
was
that
the
HI
be
<=
to
1,
and
whether
or
not
this
is
targeted
or
not
did
not
matter
 
OMB
promised
to
send
language
to
fix
this
section
 
SBA
inquired
into
Tim
Hunt's
suggested
limit
on
acrolein
and
benzene
testing
 
EPA
replied
that
table
1
tells
what
process
to
use
for
each
pollutant
 
SBA
questioned
a
14
month
time
period
and
wanted
to
see
as
many
applications
submitted
early
as
possible,
and
wanted
a
90
day
approval
deadline
 
EPA
replied
that
there
was
a
legal
issue
with
moving
deadlines
and
did
not
want
to
create
new
opportunities
for
lawsuits
 
SBA
reiterated
that
it
wanted
early
submittal
to
give
facilities
more
time
to
comply
and
make
facility
changes
and
that
14
months
was
too
short.
 
SBA
again
discussed
the
4
page
memo
from
Mike
Hunt
that
refers
to
processes
that
emit
acrolein
and
benzene
 
EPA
replied
that
it
would
look
into
this
 
SBA
questioned
the
changing
of
the
maximum
offsite
concentration
to
a
residential
area
 
EPA
replied
that
OMB
wanted
this
change
but
that
EPA
did
not.
EPA
further
replied
that
the
objective
of
the
lookup
table
was
to
use
readily
available
information
and
that
more
refined
information
would
be
harder
for
the
EPA
to
check
and
might
introduce
liability
for
the
facility
if
the
fenceline
changes
 
OMB
questioned
whether
switching
to
different
fuel
in
the
boilers
would
trigger
a
similar
process
as
exists
in
plywood
 
EPA
indicated
it
would
follow
an
identical
approach
in
plywood
preamble
on
RIA
as
it
did
for
boilers
EPA
indicated
that
it
would
maintain
two
sets
of
regulatory
impacts
 
one
in
which
the
source
category
was
fully
delisted;
and,
one
in
which
there
were
a
small
number
of
facilities
in
February
25,
2004
 
OMB
requested
an
update
on
the
revisions
to
the
"
de
minimus
section"
 
EPA
replied
that
it
was
still
revising
this
section
and
that
because
it
was
not
relying
on
de
minimus,
that
it
was
not
necessary
 
OMB
replied
that
EPA
should
send
language
reflecting
this
 
EPA
replied
that
it
would
forward
the
necessary
language
 
OMB
inquired
into
the
status
of
acrolein
and
benzene
testing
 
EPA
replied
that
the
data
indicates
that
it
should
be
included;
EPA
stated
that
it
would
come
back
to
this
issue
 
OMB
inquired
into
the
status
of
the
"
may"
issue
 
EPA
replied
that
it
has
generated
a
redline
and
that
it
would
forward
new
language
 
OMB
inquired
into
the
emissions
averaging
issue
 
EPA
replied
that
it
had
not
received
a
response
from
OECA
 
OMB
inquired
into
the
status
of
the
collocation
issue
and
revised
language
 
EPA
replied
that
it
would
revise
the
language
and
that
it
requested
that
OMB
speak
with
John
Graham
 
OMB
inquired
into
the
boundary
issue
 
EPA
replied
that
it
would
remain
the
property
boundary
and
that
it
would
get
back
to
OMB
on
the
"
may"
language
and
the
acrolein
and
benzene
issue
 
SBA
provided
an
overview
of
5
issues
that
they
sent
to
Mary
Tom
Kissell
 
EPA
replied
that
the
collocation
issue
is
undecided
 
SBA
observed
that
EPA
should
mention
the
issue
of
collocation
in
plywood,
even
if
it
is
not
relevant.
SBA
inquired
into
the
status
of
the
property
boundary
issue,
which
is
still
unresolved.
 
SBA
argued
that
facilities
should
be
allowed
to
report
a
rolling
annual
average
of
emissions
rather
than
a
monthly
average
because
this
will
provide
more
flexibility
for
the
facilities
to
comply
 
OMB
agreed
with
SBA
and
said
that
if
acute
was
not
a
concern,
that
there
was
no
need
to
take
a
rolling
average
 
EPA
replied
that
this
was
an
OECA
issue
and
that
their
defense
was
that
if
facilities
could
choose
what
part
of
the
month
to
monitor,
that
they
would
have
to
monitor
every
month
and
that
by
not
forcing
facilities
to
use
continuous
monitors,
they
would
be
eliminating
any
monitoring
spikes
anyway.
While
OECA
would
still
see
the
data
with
the
rolling
average
method,
they
would
be
unable
to
act
upon
it
for
enforcement
 
SBA
requested
that
EPA
commit
to
a
3­
month
response
 
EPA
replied
that
it
could
not
do
this,
but
that
it
could
go
to
24
months
to
allow
facilities
to
submit
their
assessments.
EPA
also
promised
to
include
language
that
would
ensure
expeditious
review
of
the
assessment
and
to
encourage
facilities
to
submit
their
assessment
early
 
SBA
questioned
the
term
"
may"
in
reference
to
EPA's
approval
of
the
lookup
table
assessment
 
EPA
replied
that
it
needed
to
preserve
its
discretion
 
OMB
replied
that
it
already
exercised
discretion
in
creating
the
table
 
EPA
replied
that
it
would
develop
new
language
to
insert
 
SBA
requested
an
update
on
the
acrolein
and
benzene
issue
 
EPA
replied
that
it
was
reviewing
the
documentation
that
SBA
sent
it
 
OMB
made
several
edits­
o
Page
326
 
delete
sentence
o
Page
329
 
delete
sentence
o
Page
330
 
delete
sentence
 
EPA
noted
that
it
was
not
going
to
include
collocated
sources
in
either
the
boilers
or
the
plywood
packages
 
OMB
made
several
more
edits
 
o
Page
332
 
strike
language
o
Page
333
 
insert
<=
TOSHI
 
EPA
stated
that
it
would
insert
new
language
 
OMB
made
an
additional
edit
 
o
Page
329
 
change
"
required
to
use"
 
EPA
replied
that
it
would
make
this
change
and
that
it
would
change
all
plywood
to
"
affected
source"
 
OMB
asked
if
EPA
had
an
update
on
the
formaldehyde
issue
 
EPA
said
that
it
did
and
offered
two
options:
o
Combine
paragraph
one
and
2
o
Go
back
to
second
paragraph
 
OMB
observed
that
it
definitely
did
not
want
to
add
in
the
longer
option
and
preferred
the
second
option
 
EPA
stated
that
it
did
make
the
health
effects
language
consistent
across
both
packages
 
OMB
stated
that
it
would
call
Larry
Sorrels
later
to
discuss
RIA
language
 
EPA
noted
that
it
would
fax
and
e­
mail
comments
by
2:
30
today
for
plywood
and
4pm
for
boilers
 
OMB
questioned
whether
the
RIA
included
cancer
incidence
 
EPA
replied
that
there
was
no
reference
in
the
preamble
and
that
they
were
still
fleshing
this
issue
out
in
the
RIA
 
OMB
said
that
they
would
provide
further
comment
if
it
was
in
the
preamble
February
26,
2004
 
OMB
described
a
series
of
page­
by­
page
edits,
to
which
EPA
agreed:
o
Page
3
 
decrease
in
HAP
should
be
in
ranges,
as
in
boilers
o
Page
60
 
"
Instead
of
using"
is
not
a
complete
sentence
o
Page
57
 
Inserted
text
from
ORD
o
Page
64
 
Insert
early
submission
text
o
Page
80­
81
 
Delete
sentence
on
potential
energy
increase
o
Page
81
 
Potential
increase
in
premature
mortality
deletion
o
Page
79
 
Table
3
delete
mortality
o
Page
171
 
Delete
Sentence
o
Page
224
 
Strike
word
o
Page
225
 
Strike
"
very"
and
"
contained"
o
Page
229­
230
 
Add
word
o
Page
231
 
Delete
Word
o
Page
232
 
Individual
versus
population
exposure
language
 
make
specific
to
chronic
and
acute
o
Page
233
 
Delete
sentence
o
Page
235
 
Delete
sentence
o
Page
236
 
Add
sentence
o
Page
243
 
Keep
previously
deleted
sentence
because
it
responds
to
comments
o
Page
245
 
Delete
first
sentence
o
Page
246
 
Delete
most
of
paragraph
o
Page
306
 
Delete
clause
o
Page
317
 
Delete
sentence
o
Page
330
 
Add
language;
use
same
language
as
page
57
o
Page
242
 
Make
conforming
change
with
page
230
o
Page
336
 
Take
out
"
required"
o
Page
524
 
Change
decreases
o
Page
522
 
Conforming
change
 
EPA
stated
that
it
approved
SBA
language
allowing
for
no
testing
for
benzene
and
acrolein
if
those
facilities
use
certain
process
units
