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NPCA Submits Comments to EPA ON Urban Air Toxics Regs for Industry Area Sources



Published August 11, 2005
According to NPCA, inaccurate information and arbitrary deadlines are the foundation of the U.S. Environmental Protection Agency’s (EPA) Area Source listing for the Paint and Allied Products category. NPCA has expressed this concern that these are the forces propelling EPA’s standards for industry’s area sources under the agency’s Urban Air Toxics program, over good science and cooperative efforts with industry. In comments submitted to EPA, NPCA articulated its opposition to the listing, citing the rulemaking’s basis in 1999 National Emission Inventory (NEI) data that doesn’t tally with industry statistics and is seriously flawed and not representative the paint and coatings industry. NPCA also criticized EPA for not providing adequate notice and opportunity to comment on the area source category listings.
According to NPCA, the NEI database contained numerous errors, including duplicative facility listings, at least 50 major source facilities listed as area sources, and a large number of sources that have been identified as non-paint and allied products sources. Similar review of the 1998 Toxic Release Inventory discovered that the three Urban Air Toxics hazardous air pollutant (HAP) chemicals (chromium, lead and nickel) that formed the basis to list the industry’s source category are no longer used to a large extent in the paint and coatings industry and do not therefore justify a percentage of EPA’s 90% emission threshold under the Clean Air Act.
EPA is currently in litigation over the timeline for the Urban Air Toxic rules, feeding NPCA concern that the agency will be forced to push through these rulemakings, arbitrarily regulating sources without proper justification and taking emission reduction credit where little or no environmental benefit actually exists. For comparison, the MACT standards recently promulgated for major sources in our industry will cost individual facilities as much as $1 million over the next three years in capital costs alone.
NPCA stressed to EPA that MACT criteria for this regulation are not appropriate for the paint and coatings industry. Rather, VOC regulations, the NESHAP for miscellaneous coatings manufacturing, and MACT standard for surface coatings operations already in place, as well as the Control Techniques Guidelines for consumer products, architectural paints and automobile refinishing coatings, are the appropriate mechanism to reduce the emissions inventory.
NPCA has requested the establishment of a Small Business Administration SBREFA Panel—under the Small Business Regulatory Enforcement and Fairness Act—for the Paint and Allied Products Source Category should rulemaking activity move forward. Since the costs of regulation under the area source standards will be borne by small businesses disproportionately, this review helps to ensure that any subsequent reg


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