The EPA said comments on the proposed regulation would be accepted for a 60-day period following publication of the standard in the Federal Register, putting the likely deadline for comments in mid-May. The National Paint & Coatings Association is urging coatings manufacturers to submit comments, calling such input "vital" to the industry's interests.
The EPA is scheduled to finalize the standard in one year, and provisions of the measure would go into effect three years later. The proposed standard has been posted on the EPA website located at www.epa.gov/ttn/oarpg/t3pfpr.html.
The proposed standard, a 534-page document, includes detailed hazardous air pollutant emission limits and work-practice standards for a range of batch and continuous-process functions and systems. These include process vents, wastewater streams, waste-management units, storage tanks, and transfer operations.
For example, the EPA is proposing that all major-source surface coating manufacturing facilities install add-on pollution control equipment on all stationary process tanks. Such controls could include condensers, activated carbon, thermal oxidizers, and other abatement devices. The NPCA is estimating that the cost of compliance with the proposed emission standard will run into the millions of dollars per facility.
In a summary of the proposed standard, the NPCA has identified a number of "problematic" regulatory issues that should be addressed in comments submitted to the EPA. The association said it is "vital that each and every affected member review in detail" the entire proposal, and submit written comments to the EPA. The NPCA also said it will develop "form letters" that member companies can use to submit those comments to the EPA.
NPCA member companies can download the association's executive summary of the proposed standard from the website at www.paint.org/member/ committee/emc.htm. More information also is available from the NPCA's David Darling at
firstname.lastname@example.org, phone 202/462.6272.