MANUFACTURING
    7liJVdc
    COMPANY
    C
    E
    V
    ED
    HELP
    IS
    JUST AROUND
    THE
    CORNER,,
    CLERK’S OFFICE
    DEC
    092008
    November
    26,
    2008
    STATE
    OF
    ILLINOIS
    Pollution
    Control
    Board
    John
    Therriault,
    Chief
    Clerk
    ,
    Clerks
    Office
    Attention
    Docket
    #R09-08
    Illinois
    Pollution
    Control
    Board
    100
    W. Randolph, Suite
    11-500
    Chicago,
    Illinois
    60601
    RE:
    Illinois
    EPA
    ArctecturaI
    and
    Industrial
    Maintenance
    (AIM)
    Coatings;
    Docket
    Dear
    Mr.
    Therriault:
    We
    are
    True
    Value
    Manufacturing,
    a division
    of
    True
    Value
    Company
    and
    employ
    130
    at
    our
    paint
    manufacturing
    facility
    located
    in
    Cary,
    IL.
    We
    have
    been
    an
    active
    entity
    in
    our
    local
    community
    and
    plan
    to
    continue
    that
    in
    the
    future.
    True
    Value
    Manufacturing
    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
    IL
    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.
    Withthe
    new
    AIM
    amendments,
    in
    addition
    to
    changing
    thousands
    of
    formulations,
    paint
    manufacturers
    need
    to
    developand
    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 IL.
    In
    addition,
    it will
    take
    significant
    time
    for
    manufacturers
    to
    properly
    communicate
    the
    new
    VOC
    limit
    changes
    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
    IL
    AIM
    rule
    without
    having
    a
    final
    adopted
    rule
    in
    hand,
    particularly,
    as
    additional
    changes
    may
    occur
    between
    now
    and
    the
    final
    adoption.
    Therefore,
    True
    Value
    Manufacturing
    strongly
    believes
    that
    the
    implementation
    date
    must
    be moved
    to
    July
    1,
    2009.
    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,
    ee
    .
    Marceila
    G.
    Nichols,
    HMM
    Regulatory
    Compliance
    Manager
    cc:’Gene
    Brickhouse
    Sari.
    Pamela
    Althoff
    -
    Quality
    Paint
    Products
    201
    Jandus
    Road
    Cary,
    Illinois
    60013
    Phone:
    847/639-5383 Fax:
    847/639-2058

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