The proposed regulation will require coatings and resin manufacturers to comply with maximum achievable control technology (MACT) standards by installing add-on air pollution-control equipment to reduce emissions of hazardous air pollutants from manufacturing processes.

The NPCA submitted more than 100 pages of comments to the EPA on the proposed standard, and is urging the agency to make changes in rules for stationary process tanks, the lead-detection and repair (LDAR) program, and transfer operations. The association also is seeking elimination of any controls for cleaning operations and revisions in terminology "to appropriately address the scope of this rule." In addition, the NPCA urged the EPA to offer a "viable pollution-prevention alternative."

The NPCA also said the EPA is "grossly underestimating" the overall economic impact of the standard on the coatings-manufacturing industry, and the association listed a series of criticisms of various aspects of the proposed regulation.

The NPCA said the regulation, as proposed, would have an annual economic impact of more than $100 million, and constitutes a "significant rulemaking" that warrants "full review by the Office of Management and Budget."

More information on the NPCA's comments to the EPA is available from the association's website at www.paint.org/ind_issue/current/sept/issue01.htm. Association members also can contact Dave Darling or Alison Keane for further information.