National
Paint&
Coatings
Association
May 19, 2008
Clerk's Office
Attention Docket #2008-017
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601
RE:
Illinois EPA Architectural and Industrial Maintenauce (AIM) Coatings;
Docket
#2008-017;
Final Draft; NPCA Comments
To Whom it May Concern:
The National Paint and Coatings Association (NPCA)l submits the following comments
on the final
draft amendments to the Illinois
EPA (ILEPA) AIM rulemaking. NPCA appreciates the changes that
ILEPA has made to the AIM rulemaking in response to our comments to date.
NPCA sent a letter to Illinois Enviromnental Protection Agency (EPA) on October 23, 2007 to request
among other things, that ILEPA include additional definitions and limits for specific specialty coatings
(i.e., Conversion varnish, Calcimine recoaters, Impacted Immersion coating, Nuclear coating,
Thermoplastic Rubber coating and Mastics) in the IL AIM rule
in order to be consistent with the
Ozone Transport Connnission (OTC) states as well as the national AIM rule. Subsequently, IL EPA
made the suggested changes. Unfortunately, NPCA inadvertently neglected to request the addition of
another specialty category and limit - "Concrete surface retarder" at 780 gil.
Again, for consistency with the OTC states, NPCA respectively requests that the following definition
be added to Section 223.307 Definitions for Subpart
C; the following limit of780 gil be added to
Section 223.310 Standards (Subsection (a) YOM Content Limits); and Concrete surface retarder be
added to Section 223.310 Standards (Subsection (c) Most Restrictive Limit):
"Concrete surface retarder means a mixture
of retarding ingredients such as extender pigments,
primary pigments, resin, and solvent that interact chemically with the cement to prevent hardening on
the surface where the retarder is applied, allowing the retarded mix
of cement and sand at the surface to
be washed away to create an exposed aggregate finish."
I
NPCA is a voluntary, nonprofit trade association representing some 350 manufacturers of paints, coatings, adhesives,
sealants, and caulks, raw materials suppliers to the industry, and product distributors. As the preeminent organization
representing the coatings industry
in the United States, NPCA'sprimary role is to serve as ally and advocate on legislative,
regulatory and judicial issues at the federal, state, and local levels. In addition, NPCA provides members with such
services as research and technical information, statistical management information, legal guidance, and community service
project support.
~ingS
carew
1500 Rhode Island Avenue, NW • Washington, DC 20005-5597 • Phone: 202/462-6272 • Fax: 202/462-8540/
E-mail: members@painr.org (NPCA members); or ncpa@paint.org (general public) • Web sire: www.paint.org
Electronic Filing - Received, Clerk's Office, May 19, 2008
* * * * * PC #2 * * * * *
Thank you for your consideration of our request. Please do not hesitate to contact us if you have any
questions or need additional information.
Sincerely,
~~~~:_-~
lison Keane '__-
Counsel, Government Affairs
David F. Darling, P.E.,
Director, Environmental Affairs
**
Sent via email and in hard-copy
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Electronic Filing - Received, Clerk's Office, May 19, 2008
* * * * * PC #2 * * * * *
