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Specifically, the MON will establish “maximum achievable control technology” (MACT) standards for adhesive and coating manufacturing. The MON will require “major source” facilities to:
- Install covers on all process tanks;
- Control emissions from stationary process tanks to a level of 75% for existing facilities, and control emissions from portable and stationary tanks to a level of 95% for new-source facilities;
- Install internal/external floating roofs on storage tanks or control emission to a level of 90% (depending upon volume and vapor pressure of liquid stored);
- Complete Leak Detection and Repair (LDAR) programs on all equipment components;
- Send certain waste waters offsite for treatment; and
- Control emissions from loading operations to a level of 98% (depending upon throughput and vapor pressure of liquid).
Given the significant compliance costs associated with the MON, it is strongly recommended that as many members of the industry as possible vocalize their concerns in written comments to EPA during the comment period. The National Paint and Coatings Association (NPCA) is asking every member company to submit written comments to the EPA on this important rulemaking. During the comment period, NPCA will post suggested comments that the members can use in the preparation of their own comments on its Web site, www.paint.org.
If you would like more information on this rule-making, please contact David Darling, NPCA’s director of Environmental Affairs, at firstname.lastname@example.org, or call 202-462-6272.