Lamar is exactly right. (See page 1 of the draft
http://otcair.org/upload/Documents/Meeting%20Materials/OTC%20Solvent%20Degreaser%20Model%20Rule%20for%202011%20STAKEHOLDER%20REVIEW%20DRAFT%20082710B%20GMP%20clean.pdf
.)
The problem as I see it is that the precision cleaning industry (read: ours)
is getting lumped in with some others, to our detriment. But it’s important
to note that the EPA seems open to being shown that the numbers proposed are
too rigid.
*From:* Lamar Young [mailto:[log in to unmask]]
*Sent:* Friday, August 19, 2011 2:26 PM
*To:* TechNet E-Mail Forum; Mike Buetow
*Subject:* Re: [TN] ozone transport rules
The 25 g/L limit refers to the VOC content of the materials. Lowering the
VOC content on materials should reduce ozone (maybe).
Lamar Young
Specialty Coating Systems, Inc.
7645 Woodland Dr.
Indianapolis, IN 46278
(317) 244-1200 Ext. 276
www.scscoatings.com
From: Mike Buetow <[log in to unmask]>
To: <[log in to unmask]>
Date: 08/19/2011 02:16 PM
Subject: Re: [TN] ozone transport rules
Sent by: TechNet <[log in to unmask]>
------------------------------
Doug,
The rules specifically cover ozone. What the EPA is trying to do is reduce
ground-level smog. A big contributor to that, as I understand it, are VOCs.
Mike
*From:* [log in to unmask]
[mailto:[log in to unmask]<[log in to unmask]>
]
*Sent:* Friday, August 19, 2011 2:05 PM
*To:* TechNet E-Mail Forum; Mike Buetow
*Subject:* Re: [TN] ozone transport rules
Mike,
Are you talking ozone emissions or VOC emissions? I suspect the latter.
And I would agree about the hallucinogenic basis of the numbers. Same kind
of crack-smoking, meth inhaling numbers that got us RoHs.
Doug Pauls
*Mike Buetow <[log in to unmask]>*
Sent by: TechNet <[log in to unmask]>
08/19/2011 12:59 PM
Please respond to
TechNet E-Mail Forum <[log in to unmask]>; Please respond to
Mike Buetow <[log in to unmask]>
To
<[log in to unmask]>
cc
Subject
[TN] ozone transport rules
Not sure if any of you have been following this, but the US EPA is proposing
lowering the ozone emissions limit cap to 25 grams/liter in the Northeast
and Mid-Atlantic states. This is in line with the California rules, and what
we are hearing is that most cleaning chemistries that are formulated special
for California manufacturers are not as robust as ones used in other
locales. The EPA says lowering the limits will cut healthcare costs by $120
billion to $290 billion a year by 2014 – or more than 10% of the total
annual US health care spend. (Just the range in that estimate suggests some
serious drug ingestion on the part of those responsible, in my opinion.)
Frankly, I would be more concerned that the major defense contractors all
move to Texas.
There is a meeting near BWI Airport in early September. I strongly suggest
you forward this info to your company environmental compliance officer(s)
and make sure they submit comments and/or attend.
http://circuitsassembly.com/cms/news/11552-ozone-rules-debated-
Best,
Mike
Mike Buetow
Circuits Assembly
w/m 617-327-4702
Twitter: @mikebuetow
>>> The CIRCUITS ASSEMBLY EMS Directory -- over 2,100 listings, in Excel
www.circuitsassembly.com/dems <<<
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