TELEPHONE:
    847-214-2100
    W.
    R.
    MEADOWS,
    INC.
    1
    SEA1I1GHT®J”
    RO.
    BOX
    338 • HAMPSHIRE,
    IL 601 40-0338
    Website:
    www.wrmeadows.com
    e-mail:
    wrmil@wrmeadows.com
    November 14, 2008
    John Therriault, Chief Clerk
    Clerks
    Office
    Attention Docket
    #R09-08
    NOV
    142008
    Illinois
    109
    W.
    Pollution
    Randolph,
    Control
    Suite
    11-500
    Board
    pouT
    E
    0
    sr
    Control
    Board
    Chicago, Illinois 60601
    RE:
    Illinois EPA
    Architectural and Industrial Maintenance
    (AIM)
    Coatings;
    Dear Mr. Therriault:
    Docket
    #Rø98
    t
    7
    W.R. MEADOWS, INC. is
    a
    manufacturer of architectural coatings utilized in the commercial concrete
    construction market and has
    a
    manufacturing operation in Hampshire, Illinois.
    W.R. MEADOWS, INC. is
    a
    member of the National Paint
    &
    Coatings Association (NPCA) and supports
    NPCA’s request
    to
    extend the implementation date of the AIM rulemaking from January 1, 2009
    to
    July 1,
    2009
    to
    allow Illinois
    adequate
    time to finalize and
    adopt
    the amendments
    to
    the AIM rule, and more
    importantly,
    provide
    adequate
    time for industry
    to
    make necessary changes in order
    to comply with the
    amendments.
    With the new
    AIM
    amendments,
    in addition
    to
    changing
    thousands of formulations, paint manufacturers
    will need
    to
    develop and print new labels for the reformulated products, Further, computer
    systems and
    other
    “lock-out” systems need
    to be
    upgraded
    to
    prevent shipment of
    “non-compliant” products into
    Illinois.
    In addition, it
    will take significant time for
    manufacturers
    to
    properly communicate the new
    VOC
    limits to all distributors, customers, and specifiers
    in
    order
    to
    ensure their compliance with the new
    products. It is impossible for manufacturers
    to
    make these necessary
    changes
    and properly
    communicate
    the
    details
    of
    the
    Illinois ATM rule without having
    a
    final
    adopted rule in hand, particularly,
    as
    additional
    changes
    may occur between
    now and the final adoption.
    Therefore, W.R. MEADOWS, iNC. strongly
    believes that the implementation
    date
    must
    be
    moved
    to
    July 1, 2009.
    Thank
    you
    for your consideration of our
    request.
    If
    you have any questions or require additional
    information please contact me
    at
    (847) 214-2232.
    Dave
    Sincerely,
    Carey, CHMM,
    Q
    Vic-President
    Plant
    Operations
    CC: Jim Dwyer, Matt Price, Harry Meadows, Brent
    Weber, Dave Duewel
    ENVIRONMENTALLY
    RESPONSIBLE
    CONCRETE
    PERFORMANCE
    PRODUCTS

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