BREDL Comments to EPA regarding NESHAP Paper and Other Web Coating Residual Risk and Technology Review
Nov. 04, 2019: We support the removal of the startup, shutdown, malfunction exemption.
Regarding the industry proposal to create a new type of "work practice standard" malfunction exemption , EPA may not lawfully or rationally create the new kind of malfunction exemption the American Coatings Association has requested.
Although we stress that the EPA should not finalize any type of malfunction exemption because it is unlawful and arbitrary and the Clean Air Act requires emissions standards to apply at all times, the option of continuing operations while doing repairs is especially unacceptable.
BREDL Full Comments