EPA-456/R-97-006
NATIONAL EMISSION STANDARDS FOR
AEROSPACE MANUFACTURING AND REWORK FACILITIES:
SUMMARY OF REQUIREMENTS FOR
IMPLEMENTING THE NESHAP
Prepared for:
Information Transfer and Program Integration Division (ITPID)
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
U.S. Environmental Protection Agtney
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
Prepared by:
Pacific Environmental Services, Inc.
5001 South Miami Boulevard
P.O. Box 12077
Research Triangle Park, NC 27709
March 1998
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Disclaimer
This report is not a legally binding document, and is not meant to replace the published
regulation entitled "National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Source Categories: Aerospace Manufacturing and Rework Facilities" (Federal Register. 9/1/95,
beginning on page 45948) or any rule amendments that may be published after September 1,
1995. This document represents specific aspects of the regulation and may not cover all parts of
the regulation. The document is intended solely as guidance and does not represent final Agency
action on the rule. It is also not intended, nor can it be relied upon, to create any rights
enforceable by any party in litigation with the United States. The EPA may change this
document at any time without public notice.
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TABLE OF CONTENTS
Page
1.0 PURPOSE OF DOCUMENT 1-1
2.0 SUMMARY OF THE RULE 2-1
3.0 APPLICABILITY FLOW CHARTS 3-1
4.0 INSPECTION PROCEDURES 4-1
4.1 PREPARING FOR THE INSPECTION 4-1
4.2 FACILITY INSPECTION 4-1
4.2.1 General 4-1
4.2.2 Specific Activities 4-2
5.0 INSPECTION CHECKLISTS 5-1
6.0 QUESTIONS AND ANSWERS - 6-1
7.0 OTHER IMPLEMENTATION MATERIALS 7-1
8.0 EXAMPLE CALCULATIONS 8-1
9.0 LIST OF CLEANING SOLVENT SUBSTITUTIONS 9-1
APPENDIX A. GLOSSARY
APPENDIX B. INITIAL NOTIFICATION FORM
APPENDIX C. GENERAL PROVISIONS APPLICABILITY TO SUBPART GG
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1.0 PURPOSE OF DOCUMENT
On September 1, 1995, the U. S. Environmental Protection Agency (EPA) promulgated
the final rule for the national emission standards for hazardous air pollutants (NESHAP) for
aerospace manufacturing and rework facilities. These standards implement Section 112 of the
Clean Air Act (CAA), and can be found in Title 40 of the Code of Federal Regulations (CFR)
Part 63, Subpart GG. The Aerospace NESHAP was promulgated to reduce emissions of certain
solvents and other materials that have been identified as hazardous air pollutants (HAP) that may
be emitted from four types of operations: cleaning, primer and topcoat application, paint
removal (depainting), and application of chemical milling maskants. As promulgated, the
standards include multiple alternatives to allow owners and operators maximum compliance
flexibility. Alternatives for each of the four operation types are summarized in Section 2.0.
This document focuses on inspection of affected aerospace manufacturing and rework
operations and provides tools for ensuring compliance with the standards. The use of this
^document is not required but, instead, is intended to educate and provide guidance to EPA
Regional, State/local agency personnel, and sources who will be responsible for implementing
and enforcing many of the provisions of this standard through facility inspections. Other EPA
and non-EPA materials have been developed that provide background information on the
Aerospace NESHAP and instruct owners and operators on how to comply. Therefore, this
document does not discuss all the details of the rule exhaustively, but refers the reader to places
where supplementary information is already available.
Sets of applicability flow charts and compliance checklists are included. These checklists
provide the detail needed to help assess compliance with the standards for each of the covered
manufacturing or rework operations. The information presented in the body of this document is
intended to equip those who will be using the checklists and to provide a framework for applying
them in the field. The implementing authority and sources are encouraged to use the checklists
or modify them to meet specific needs.
Section 2.0 briefly discusses the sources to which this NESHAP applies and summarizes
the principal rule provisions. Section 3.0 contains applicability flow charts to indicate which
facilities and operations are affected. Sections 4.0 and 5.0 suggest procedures to follow before,
1-1
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during, and after a field inspection of an aerospace facility, and lists the tools and methods an
inspector will need to use. Commonly asked questions and the EPA's responses are presented in
Section 6.0. Other materials that might be helpful in understanding and enforcing the Aerospace
NESHAP are listed in Section 7.0. Section 8.0 includes example calculations and spreadsheets
for demonstrating compliance with the surface coating (primer and topcoat) requirements. A
listing of cleaning solvent substitutions is provided in Section 9.0. A glossary of terms
associated with the standard is included in Appendix A. A sample initial notification form is
included in Appendix B. Requirements in §63.1 through §63.15 of the General Provisions also
apply to aerospace manufacturing and rework facilities. Appendix C should be consulted to
determine applicable requirements of the General Provisions, as they are not discussed within the
document itself.
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2.0 SUMMARY OF THE RULE
This section summarizes the major provisions of the NESHAP for aerospace
manufacturing and rework facilities. While an attempt has been made to be fairly complete, this
summary should not be used as a substitute for the entire regulation as found in the Code of
Federal Regulations (CFR) and published in the Federal Register on September 1, 1995
(beginning on page 45948). This summary also incorporates the rule amendments that were
proposed in the Federal Register on October 29,1996; signed as final amendments on March 10,
1998 and published in the Federal Register on March 27, 1998 (beginning on page 15006).
Sources subject to the Aerospace NESHAP are also subject to §§ 63.1 through 63.15 of the
General Provisions and should consult Appendix C and the General Provisions for specific
requirements as they have not been incorporated into this document. Additional changes will be
proposed in the future which have not been incorporated and may change portions of this
document.
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AEROSPACE NESHAP REGULATORY OVERVIEW
CFR Location: 40 CFR 63 Subpart GG
Regulatory Activity: Rule Proposal 6/6/94
Rule Promulgation: 9/1/95 [60 FR 45948]
Effective Date: 9/1/95
Rule Corrections: 2/9/96 [61 FR 4902],
12/17/96 [61 FR 66226]
Proposed Amendments/
Release of Draft CTG: 10/29/96 [61 FR 55842]
Final Amendments/
Release of Final CTG 3/27/98 [63 FR 15006]
Compliance and Reporting: See Figure 2-1 for regulation information on compliance
dates, performance testing, and reporting.
AFFECTED FACILITY
Applies to major sources of HAP: > 10 tons/yr of any of the Clean Air Act HAP; or
> 25 tons/yr of any combination of HAP
AFFECTED SOURCES
NESHAP requirements are limited to operations associated with the manufacturing or rework of
aerospace vehicles and components.
All hand-wipe cleaning operations constitute an affected source
Each spray gun cleaning operation constitutes an affected source
All flush cleaning operations constitute an affected source
For organic HAP or VOC emissions, each primer application operation (total of all primer
applications at a facility)
For organic HAP or VOC emissions, each topcoat application operation (total of all topcoat
applications at a facility)
For organic HAP or VOC emissions, each depainting operation (total of all depainting at a
facility)
Each chemical milling maskant application operation (total of all such applications at a
facility)
Each waste storage and handling operation (total of all such operations at a facility)
For inorganic HAP emissions, each spray booth or hangar that contains a primer, topcoat, or
depainting operation.
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Existing sources -
Initial startup before
June 8. 1994
(Rule propoitl date)
September 1, 1997
1 i
i Effective dale i
' September 1. 1995 i
i i
New sources -
Initial startup after
June 8, 1994
(Rule proposal date)
May 1
hi Kiel
Notification Report
September 1, 1997
or 120 dayt after
initial startup,
whichever it later
May 1, 1999
1998 September 1, 1998 performance'test
whichever is earlier
c<""pT.,'u«Tn"°" c°m<*"
K»qu»i /Ma 7
<|oS.74J(a>(4» <»"'
Every 6 months
as 12 months, .
retpectlvely, after
Initial NOCS
bidet Notification of
ce Oat* Compliance
<()) Status (NOCS)
240 dayt after initial
120 dayt before Upon Initial after performance
Initial startup startup tett. whichever it
earlier
Annual Comptance
Reports
(H1.75J)
240 dayt after initial
NOCS It due; and
every 6 months and '
12 monthi,
retpectjvely,
(O
Sources with Initial
startup before
June a, 1994
September 1.1998
Sources with Initial
startup after
June 8,1994
Upon Initial
startup
September 1, 1998
^"^2^
whichever It earlier
December 1, 1998
or 80 dayt before
performance tett,
whichever it earlier
March 1, 1999
sunup, Shutdown,
Malfunction Plan
|Sl.74J(b)
>
Sle-Speclflc
Test Plan
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RULE APPLICABILITY
[63.741]
Various processes that may be performed at aerospace manufacturing and rework facilities are
not covered under 40 CFR 63, Subpart GG. In addition, exemptions from 40 CFR 63,
Subpart GG and from control requirements are also identified within the rule. Listed below are
processes and materials not covered by or exempt from the rule.
The following are EXEMPT from 40 CFR 63, Subpart GG:
Specialty coatings (see Appendix A to 40 CFR 63, Subpart GG)
Sealants and adhesives
Adhesive bonding primers
Primers, topcoats, chemical milling maskants, strippers, and cleaning solvents containing
HAP and VOC <0.1% for carcinogens; <1% noncarcinogens
Low-volume use of primers, topcoats, and chemical milling maskants which does not exceed
50 gal (189 liters) per year per formulation; with a combined annual total of all such primers,
topcoats, and chemical milling maskants used at the facility not exceeding 200 gal (757
liters); otherwise exempt coatings excluded from totals [63.741(g)]
Parts and assemblies not critical to vehicle's structural integrity or flight performance
Activities associated with space vehicles (except for depainting)
Rework of antique aerospace vehicles or components.
s
The following are NOT COVERED under 40 CFR 63, Subpart GG:
Electronic parts and assemblies (except for cleaning and topcoating of completed assemblies)
Research and development
Quality control
Laboratory testing activities
Chemical milling
Metal finishing
Electrodeposition (except the electrodeposition of paints)
Composites processing (except for some cleaning, coating, and composite tooling operations)
Aircraft transparencies manufacturing
Handling of waste subject to RCRA, 40 CFR 262 -268
Wastewater operations.
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CLEANING OPERATIONS
WHAT IS COVERED?
The requirements apply only to the cleaning of aerospace vehicles and components. Cleaning
operations subject to the hand-wipe cleaning, flush cleaning, or spray gun cleaning requirements
are also subject to these requirements.
WHAT IS REQUIRED?
Option 1: Use only cleaning solvents that meet the requirements in the following table
[63.744(a)]:
Cleaning Solvent
Type
Composition Requirements
Aqueous
Cleaning solvents in which water is the primary ingredient (^80% of cleaning solvent
solution as applied must be water).
Aqueous solutions must have a flash point >200°F (93 °C) as reported by the
manufacturer
Solution must be miscible with water
Hydrocarbon-
Based
Cleaners that are composed of a mixture of photochemically reactive hydrocarbons and
oxygenated hydrocarbons
Have a maximum vapor pressure (VP) of 7 mm Hg at 20°C (3.75 in. H2O at 68°F)
Contain no HAP ^
Option 2: If solvent used does not meet the above requirements, the following provisions must
bemet[63.744(a)]:
Solvent-laden absorbent applicators placed in bags or other closeid containers upon
completing their use (cotton-tipped swabs used for very small cleaning operations are exempt
from this requirement)
Containers closed at all times, except when depositing or removing materials
Fresh and spent solvents stored in closed containers (except semi-aqueous cleaners)
Handle and transfer solvents to or from cleaning operations and to waste handling areas in a
manner that minimizes spills.
RECORDKEEPING REQUIREMENTS
All Options, record the following [63.752(b)(l)]:
Name, vapor pressure, and documentation showing the organic HAP constituents of each
cleaning solvent used for an affected cleaning operation.
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REPORTING REQUIREMENTS
All Options, report the following information semiannually (every 6 months from the date of
notification of compliance status) for all cleaning operations regulated under this rule
[63.753(b)]:
If the operation has been in compliance for the semiannual period, a statement that the
cleaning operations have been in compliance and signed by a responsible official. Reporting
of noncompliance is covered under the "Hand-Wipe and" "Spray Gun" cleaning sections.
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HAND-WIPE CLEANING OPERATIONS
WHAT IS COVERED?
Hand-wipe cleaning of aerospace vehicles or components at an aerospace facility.
WHAT IS NOT COVERED?
(Note: Recordkeeping is still required for exempt operations where a noncompliant cleaning
solvent is used. See Recordkeeping Requirements under this section for specific information.)
Wipe cleaning operations involving spray gun cleaning (under separate provision)
[63.744(b)]
Cleaning during manufacture, assembly, installation, maintenance, or testing of:
*- Components of breathing oxygen systems that are exposed to breathing oxygen
[63.744(e)(l)]
-*- Components that are exposed to strong oxidizers or reducers [63.744(e)(2)]
Cleaning during the fabrication, assembly, installation, and maintenance of textile materials
used in the interior of the aircraft [63.744(e)(8)]
Cleaning and surface activation prior to adhesive bonding [63.744(e)(3)]
Cleaning and solvent usage associated with research and development, quality control, or
laboratory testing [63.744(e)(l 1)]
"« Cleaning operations, using nonflammable liquids, conducted within 5 feet of energized
electrical systems [63.744(e)(12)]
Cleaning of:
->- Electronic parts and assemblies containing electronic parts [63.744(e)(4)J
-*- Aircraft and ground support equipment fluid systems that are exposed to fluid
[63.744(e)(5)]
-> Fuels cells, fuel tanks, and confined spaces [63.744(e)(6)]
-*- Surfaces of solar cells, coated optics, and thermal control surfaces [63.744(e)(7)]
-> Metallic and nonmetallic materials used in honeycomb cores [63.744(e)(9)]
*- Aircraft transparencies, polycarbonate, or glass substrates [63.744(e)(10)]
-* Cleaning operations identified as essential uses under the Montreal Protocol
[63.744(e)(13)].
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WHAT IS REQUIRED?
Option 1: Use cleaning solvents that satisfy Option 1 under "Cleaning Operations"
Option 2: Use a cleaning solvent that has a composite vapor pressure of 24.1 in. t^O (45 mm
Hg)orlessat68°F(20°C)
Option 3: Demonstrate that the volume of hand-wipe cleaning solvent usage has been reduced
by at least 60 percent from an approved baseline that is adjusted for production. Requires that an
alternative plan be filed and be approved by the permitting authority, and must demonstrate a
reduction equivalent to Option 1 or 2.
RECORDKEEPING REQUIREMENTS
If Option 1 is used, record the following [63.752(b)(2)]:
Name of each cleaning solvent used
Demonstration that the cleaning solvent complies with one of the composition requirements
Annual records of the volume of each solvent used, from facility purchase or usage records.
If Option 2 is used, record the following [63.752(b)(3)J
Name of each cleaning solvent used
Composite vapor pressure of each cleaning solvent used
All vapor pressure test results (if appropriate), data, and calculations used to determine the
composite vapor pressure of each cleaning solvent
The amount (in gallons) of each cleaning solvent used each month at each operation
If Option 3 is used, maintain a copy of the alternative plan approved by the permitting authority
and all supporting documentation.
If a cleaning solvent used in an exempt hand-wipe cleaning operation does not conform to the
vapor pressure or composition requirements, record the following [63.752(b)(4)]:
The identity and amount (in gallons) of each cleaning solvent used each month at each
operation
A list of processes to which the cleaning operation applies.
REPORTING REQUIREMENTS
Report the following information semiannually (every 6 months from date of notification of
compliance status) [63.753(b)]r
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If Option 1 or 2 is used [63.744(b)(l), (2)]:
Any instance where a noncompliant cleaning solvent is used for a nonexempt hand-wipe
cleaning operation
A list of any new cleaning solvents used for hand-wipe cleaning in the previous 6 months,
including evidence of their compliance..
If Option 3 is used [63.744(b)(3)]:
Facility must demonstrate that the 60% volume reduction in cleaning solvents provides
equivalent reductions to the requirements in Option 1 or 2, and submit the demonstration to
the permitting authority for approval.
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SPRAY GUN CLEANING OPERATIONS
WHAT IS COVERED?
Spray gun cleaning associated with the aerospace manufacturing and rework operations
performed at an aerospace facility [63.744(c)].
WHAT IS NOT COVERED?
Spray gun cleaning operations using cleaning solvent solutions that contain HAP and VOC
<0.1% for carcinogens or <1.0% for noncarcinogens are exempt from the cleaning requirements
[63.744(c)j.
WHAT IS REQUIRED?
Option 1: Enclosed System
Clean spray gun in an enclosed system that is leak checked on a monthly basis
Option 2: Nonatomized Cleaning
Without the use of atomizing air, clean the spray gun by placing solvent into the pressure pot
and forcing the solvent through the spray gun into a waste container that is closed when not
in use
Option 3: Disassembled Gun Cleaning
Clean the disassembled spray gun by hand or by soaking in^a vat that is closed when not in
use or during soaking
Option 4: Atomized Cleaning
Force solvent through the assembled gun and spray directly into a waste container that is
fitted with a device to capture the atomized solvent.
MONITORING REQUIREMENTS
If Option 1 is used, perform the following:
Inspect seals and other potential sources of leaks of each enclosed system monthly (while
operating) [63.751 (a)]
If leak is found, repair within 15 days or remove solvent and shut down system until leak is
repaired [63.744(c)(l)].
If Option 2, 3, or 4 is used, no monitoring is required.
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RECORDKEEPING REQUIREMENTS
If Option 1 is used, record the following for each leak found [63.752(b)(5)]:
Source identification
Date leak was discovered and repaired.
If Option 2. 3 or 4 is used, no recordkeeping is required.
REPORTING REQUIREMENTS
If Option 1 is used, report the following information semiannually (every 6 months from date of
notification of compliance status) [63.753(b)(l)(iii), (iv)]:
Any instance where a noncompliant spray gun cleaning method is used
Any instance where a leaking enclosed spray gun cleaner remains unrepaired and in use for
more than 15 days.
If Option 2. 3, or 4 is used, no reporting is required.
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FLUSH CLEANING OPERATIONS
WHAT IS COVERED?
These requirements apply only to flush cleaning operations associated with an aerospace part or
assembly, or components of a coating unit [63.744(d)].
Flush cleaning is defined as the removal of contaminants such as dirt, grease, and coatings from
an aerospace vehicle or component or coating equipment by passing solvent over, into, or
through the item being cleaned. The solvent may simply be poured into the item being cleaned
and then drained, or be assisted by air or hydraulic pressure, or by pumping [63.742].
WHAT IS NOT COVERED?
Other (nonflush) cleaning operations, spray gun cleaning (which are covered under separate
subsections), and hand-wipe cleaning operations where wiping, scrubbing, mopping, or other
hand action is used, are not subject to the flush cleaning requirements [63.742 and 63.744(d)].
WHAT IS REQUIRED?
Option 1: Use only cleaning solvents that satisfy Option 1 under "Cleaning Operations"; or are
semi-aqueous cleaners (a solution in which >60% of the solvent solution as applied is water)
[63.744(d)].
Option 2: If cleaning solvent used does not meet the requirements in Option 1, the following
provisions must be met [63.744(d)]:
Flushed solvent must be emptied into an enclosed container or collection system or
system with equivalent emission control
Collection system must be kept closed when not in use.
RECORDKEEPING REQUIREMENTS
If Option 1 (semi-aqueous cleaners) is used, record the following [63.752(b)(2)]:
Name of each cleaning solvent used
All data and calculations that demonstrate that the cleaning solvent complies with the
composition requirements
Annual records of the volume of each solvent used, as determined from facility purchase
or usage records.
If Option 1 (nonsemi-aqueous cleaners) is used, no recordkeeping is required.
If Option 2 is used, no recordkeeping is required.
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PRIMER AND TOPCOAT OPERATIONS
(ORGANIC HAP AND VOC CONTROL)
WHAT IS COVERED?
Organic HAP-containing primer and topcoat (including self-priming topcoat) application
operations on aerospace vehicles, parts, or assemblies [63.745(a)-(f)]
WHAT IS NOT COVERED?
Coatings applied to aerospace equipment that is no longer operational, not intended for
public use, and not easily capable of being moved [63.745(a)]
The following are exempt from the application technique requirements only. All other
regulatory requirements apply [63.745(f)]:
->- Operation that normally requires the use of an airbrush or extension on the spray gun
-*- Application of coatings that contain fillers which adversely affect atomization with
HVLP guns (permitting agency determination required)
-*- Applications that normally have a dried film thickness of < 0.0005 in. (0.0013 cm)
(permitting agency determination required)
-* The use of airbrush application methods for stenciling, lettering, or marking
*- Use of hand-held spray cans
-*- Touchup and repair operations.
s"
WHAT IS REQUIRED?
All Options: Use the following application equipment and housekeeping measures:
Handle and transfer in a manner to minimize spills [63.745(b)]
Apply coatings using one or more of the following application techniques [63.745(f)]:
* Flow/curtain coating
-* Dip coat application
*- Roll coating
-*- Brush coating
-*- Cotton-tipped swab application
-*- Electrodeposition (dip) coating
-* HVLP spraying
> Electrostatic spray application
-*- Other application methods that achieve emission reductions equivalent to HVLP or
electrostatic spray.
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Option 1. Uncontrolled Coatings: Use primers and topcoats that comply with the limits below
[63.745(c)]r
Coating Type
Primers
Topcoats
Self-Priming Topcoats
Maximum Content, as Applied3
Organic HAP Content
g/liter
350
420
420
Ib/gal
2.9
3.5
3.5
VOC Content
g/liter
350
420
420
Ib/gal
2.9
3.5
3.5
a HAP content is measured "less water"; VOC content is measured less water and exempt solvents. Include thinner
added to calculation.
Option 2. Uncontrolled Coatings: Use "low HAP content" primers [63.752(c)(3>], along with
the topcoats in Option 1. Option 2 provides reduced recordkeeping and reporting:
Coating Type
Primers
Topcoats (same as Option 1)
Self-Priming Topcoats (same as
Option 1)
Maximum Content, as Applied3
Organic HAP Content
g/liter
250
420
420
Ib/gal
2.1
3.5
3.5
VOC Content
g/liter
250
420
420
Ib/gal
2.1
3.5
3.5
a HAP content is measured "less water"; VOC content is measured less watSr and exempt solvents. Include thinner
added to calculation.
Note: It is permissible to use both Option 1 and Option 2 coatings, so long as the applicable
requirements are met.
Option 3. Uncontrolled Coatings: Averaging scheme [63.745(e)(2)]:
Use any combination of primers or topcoats such that the monthly volume-weighted average
of organic HAP and VOC content complies with the specified content limits as determined
by applicable procedures [63.743(d)J
Averaging primers together with topcoats is not allowed
Averaging schemes must be preapproved by the permitting authority.
Option 4. Controlled Coatings: Use add-on controls [63.745(d)J:
Demonstrate an overall removal efficiency (of both organic HAP and VOC) of > 81 %.
Overall efficiency is the product of the capture efficiency and the destruction efficiency
Conduct initial performance test unless a waiver is obtained [63.749(d)(2)].
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Option 5. Waterborne Coatings: Use waterborne coatings [63.74l(i)]:
Waterborne coatings are exempted from 63.745(d)-(e), 63.749(d), 63.750(c)-(h),
63.752(c), and 63.753(c)
However, operator still must:
* Use required application equipment per 63.745(f)
* Handle and transfer in a manner to minimize spills
-> Maintain manufacturer's data and annual purchase records for 5 years.
Waterborne coatings may be averaged under 63.743(d).
MONITORING REQUIREMENTS [63.751(b)]r
If Option 1, 2, 3. or 5 is used, no monitoring is required.
If Option 4 is used, monitor control device operation as follows:
Control device is a carbon adsorber:
-*- Establish as a site-specific operating parameter the outlet total HAP or VOC
concentration or the control device efficiency [63.75 l(b)(l)]
-*- For nonregenerative carbon systems, the carbon replacement time interval may be
established as the site-specific operating parameter [63.751(b)(2)]
->- For capture systems, submit a monitoring plan that identifies the operating parameter
to be monitored, discusses why this parameter is appropriate, and identifies the
specific monitoring procedures [63.75l(b)(3)(i)]
-* Conduct monitoring in accordance with the submitted plan unless EPA comments
require an alternate monitoring scheme [63.75l(b)(3)(iii)]
-*- Install, calibrate, operate, and maintain a continuous emission monitor that complies
with CFR specifications and requirements [63.75 l(b)(6)(ii), (iii)(A)]
-*- Do not operate the control device at an average control efficiency less than the
required level for three consecutive adsorption cycles or over a 7- to 30-day rolling
average, as applicable [63.75 l(b)(6)(iii)(B), (C)]
-*- Do not operate the capture device at an average parameter value greater or less than
(as appropriate) the established value for any 3-hour period [63.75l(b)(6)(iv)]
Control device is an incinerator:
-* Install, calibrate, maintain, and operate temperature monitoring equipment or a
CEMS. Replace or have temperature sensors recalibrated every 3 months
[63.751(b)(8)]
*- Install a thermocouple equipped with a continuous recorder and operate continuously
(correct locations indicated in rule) [63.751(b)(9), (10)]
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Establish site-specific temperature parameters during each performance test
RECORDKEEPING REQUIREMENTS [63.752(c)]:
If Option 1 is used, record the following:
Name and VOC content as received and as applied for each primer and topcoat used
Mass of organic HAP (Hj) and VOC (Gj) emitted per unit volume of coating as applied for
each coating formulation within each coating category used each month (calculate using
§63.750(c) and (e))
All data, calculations, and test results used in determining Hj and Gj
Volume (gal) of each coating formulation within each coating category used each month.
If Option 2 is used, record the following [63.752(c)(3)J:
Annual purchase records of the total volume of each primer purchased
All data, calculations, and test results used in determining organic HAP and VOC as applied,
including:
* Manufacturer's certification when the primer is applied as received
-*- All data and calculations used to determine H- if not applied as received.
If Option 3 is used, record the following [63.752(c)(4)]:
Monthly volume-weighted average masses of organic HAP (H&) and VOC (Ga) for all
coatings as applied (calculate using §63.750(d) and (f), as applicable)
All data and calculations used to determine H0 and G_.
a a
If Option 4 is used, record the following [63.752(c)(5), (6)]:
Control device is not a carbon adsorber:
->- Overall control efficiency of the control system and all test results, data, and
calculations used.
Control device is incineration (catalytic and noncatalytic):
* Continuous records of the firebox temperature and all calculated 3-hour averages.
Control device is a carbon adsorber:
-*- Overall control efficiency of the system and all test results, data, and calculations used
* The length of the rolling material balance period and all data and calculations used
-*- The record of the certification of the accuracy for the device that measures HAP or
VOC recovered.
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Control device is a nonregenerative carbon adsorber:
-* Overall control efficiency of the system and all test results, data, and calculations used
->- The record of the carbon replacement time established as the site-specific operating
parameter.
If Option 4 is used, perform the following [63.743(b)]:
Prepare a startup, shutdown, and malfunction plan (excluding any dry paniculate filters
operated per manufacturer's instructions) which includes:
* Requirements in 63.6
->- Operation and maintenance criteria
->- A standardized equipment operation and maintenance checklist
-* Procedures for identifying and reporting malfunctions
-> Procedures to prevent malfunctions due to preventable conditions.
Operate all control equipment in accordance with the startup, shutdown, and malfunction
plan.
If Option 5 is used, record the following [63.741(i)]:
Manufacturer's supplied data and annual purchase records for each exempt waterborne
coating
Retain records for 5 years.
REPORTING REQUIREMENTS [63.753(c)]r
All Options, report the following (except for the use of waterborne coatings):
Semiannual reports occurring every 6 months (from the date of notification of compliance
status) that identify required reporting for each painting category
If the operations have been in compliance for the semiannual period, a statement that the
operations have been in compliance with the applicable standards.
If Option 1 or 2 is used, report the following:
Each value of HJ and Gj that exceeds the applicable organic HAP or VOC content limit.
If Option 3 is used, report the following:
Each value of Ha and Ga that exceeds the applicable organic HAP or VOC content limit.
If Option 4 is used, report the following:
Control device is incineration:
All periods when the 3-hour average combustion temperature is less than the average
combustion temperature established during the most recent performance test
2-17
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Control device is a carbon adsorber:
-*- Each rolling period when the overall control efficiency of the control system is less
than 81%, the initial material balance calculation and any exceedance as demonstrated
through calculations.
Control device is a nonregenerative carbon adsorber:
-> Submit the design evaluation, the continuous monitoring system performance report,
and any excess emissions as demonstrated through deviations of monitored values.
Control device is something other than an incinerator or carbon adsorber:
*- Each exceedance of the operating parameters established for the control device under
the initial performance test during which compliance was demonstrated.
If Option 5 is used, no reporting is required.
2-18
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PRIMER AND TOPCOAT OPERATIONS
(INORGANIC HAP CONTROL)
WHAT IS COVERED?
Inorganic HAP-containing primers and topcoats (including self-priming topcoats) that are spray
applied and are used to coat aerospace parts, assemblies, or vehicles [63.745(g)].
WHAT IS NOT COVERED?
Coatings applied to aerospace equipment that is no longer operational, not intended for public
use, and not easily capable of being moved [63.745(a)]
Touchup of scratched surfaces or damaged paint [63.745(g)(4)(i)]
Hole daubing for fasteners [63.745(g)(4)(ii)]
Touchup of trimmed edges [63.745(g)(4)(iii)]
Coating prior to joining dissimilar metal components [63.745(g)(4)(iv)J
Stencil operations performed by brush or airbrush [63.745(g)(4)(v)]
Section joining and sealant detackifying [63.745(g)(4)(vi), (viii)]
Touchup of bushings and other similar parts [63.745(g)(4)(vii)]
Painting of parts in an area identified in a Title V permit, where the permitting authority has
determined that it is not technically feasible to paint the parts in a booth [63.745(g)(4)(ix)]
Use of hand-held spray can application methods [63.745(g)£4)(x)].
WHAT IS REQUIRED?
All covered coating operations must be conducted in a spray booth or hangar. Air flow must be
downward or across the part and must be exhausted through a control device [63.745(g)].
Control Device Options for Existing Sources [63.745(g)(2)(i)]:
Option 1: Pass air through a dry particulate filter that meets the existing source filtration
efficiencies below [63.745(g)(2)(i)(A)J. Certify control system using test method in rule [see
63.750(o) for specific certification and test method procedures]
2-19
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Performance Requirements for Inorganic HAP Arresters
Filter type/test
conditions
Aerodynamic particle
size (micron)
Minimum required
filtration efficiency (%)
Existing Sources (two-stage arrestor)
Liquid phase
challenge
Solid phase
challenge
>5.7
>4.1
>2.2
>8.1
>5.0
>2.6
>90
>50
>10
>90
>50
>10
Option 2: Pass air through a waterwash system [63.745(g)(2)(i)(B)]
Option 3: Use another control system that meets efficiencies in Option 1 and is approved by
the permitting authority [63.745(g)(2)(i)(C)].
Control Device Options for New Sources [63.745(g)(2)(ii)]:
Option 1: Pass air through a dry filter that meets new source filtration efficiencies below
[63.745(g)(2)(ii)(A)]:
Performance Requirements for Inorganic HAP Arresters
Filter type/test
conditions
Aerodynamic particle
size (micron)
Minimum required
filtration efficiency (%)
New Sources (three-stage arrestor)
Liquid phase
challenge
Solid phase
challenge
>2.0
>1.0
>0.42
>2.5
>1.1
>0.7
>95
>80
>65
>95
>85
>75
Option 2: Use another control system that meets new source efficiencies and is approved by
the permitting authority [63.745(g)(2)(ii)(B)]
Control Device Options for Sources Constructed or Reconstructed After June 6,1994 and Prior
to October 29.1996 [63.745(g)(2)(iii)]:
Option 1: Comply with new source requirements above [63.745(g)(2)(iii)]
Option 2: Pass air through a 2-stage dry filter or a waterwash system [63.745(g)(2)(iii)(A)].
For primers or topcoats containing chromium or cadmium, install a HEPA filter system, 3-
stage filter system, or approved system equivalent to a 3-stage filter [63.745(g)(2)(iii)(B)].
2-20
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MONITORING REQUIREMENTS [63.745(g)(2), (3)]:
For dry filters, perform the following:
Maintain system in good working order
Install differential pressure gauge across filter banks
Continuously monitor pressure drop across filter and record once per shift
Take corrective action when pressure drop exceeds or falls below manufacturer's
recommendation
Shut down operation if scheduled maintenance has not been performed.
For waterwash systems, perform the following:
Continuously monitor the water flow rate and record once per shift
Shut down operation when waterwash fails the visual continuity/flow characteristics check
Shut down operation when recorded water flow rate goes outside of manufacturer's limits
Shut down operation if scheduled maintenance has not been performed.
JIECORDKEEPING REQUIREMENTS [63.752(d)]r
All Options, perform the following [63.743(b)]:
- Prepare a startup, shutdown, and malfunction plan (excluding dry particulate filters operated
per manufacturer's instructions) which includes:
->- Requirements in 63.6
s
-*- Operation and maintenance criteria
-* A standardized equipment operation and maintenance checklist
*- Procedures for identifying and reporting malfunctions
* Procedures to prevent malfunctions due to preventable conditions.
Operate all control equipment in accordance with the startup, shutdown, and malfunction
plan.
If dry filters are used, record the following:
Record the pressure drop across the operating system once each shift during operation
Record the acceptable limit(s) of pressure drop as specified by the filter or booth
manufacturer.
If a waterwash system is used, record the following:
Record the water flow rate through the operating system once each shift during operation
Record the acceptable limit(s) of water flow rate as specified by the booth manufacturer.
2-21
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REPORTING REQUIREMENTS [63.753(c)]:
All Options, report the following:
Semiannual reports occurring (every 6 months from the date of notification) for each category
If the operations are in compliance, a statement that the operations have been in compliance.
If dry filters are used, report the following:
(Semiannual) All times when a topcoat or primer operation was not immediately shut down
when the pressure drop across a dry paniculate filter system was recorded to be outside
specified limits
(Annual) Number of times the pressure drop for each dry filter was outside specified limits.
If a waterwash system is used, report the following:
(Semiannual) All times when a topcoat or primer operation was not immediately shut down
when the waterwash system was recorded to be outside specified limits
(Annual) Number of times the water flow rate for each waterwash system was outside
specified limits.
For booths or hangars that do not have the potential to emit 10 tons/yr or more of an individual
inorganic HAP or 25 tons/vr or more of all inorganic HAP combined [63.743(a)(10)]:
Notify the Administrator of such construction or reconstruction on an annual basis. Make
notification by March 1 of each year for construction or reconstruction during the prior
calendar year and include information in 63.5(b)(4), except that such information is to be
limited to inorganic HAP.
2-22
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DEPAINTING OPERATIONS
WHAT IS COVERED?
Depainting operations on the outer surface areas of completed aerospace vehicles (including the
fuselage, wings, and vertical and horizontal stabilizers of the aircraft) and the outer casing and
stabilizers of missiles and rockets [63.746(a)(l)].
_ Depainting of parts and assemblies for space vehicles designed to travel beyond the limit of the
earth's atmosphere, including but not limited to satellites, space stations, and the Space Shuttle
System (including orbiter, external tanks, and solid rocket boosters) must comply with this
section [63.741(h)].
WHAT IS NOT COVERED?
Aerospace manufacturing or rework facility that depaints 6 or fewer completed aerospace
vehicles per year [63.746(a)]
Depainting of parts or units normally removed from the vehicle for depainting (except for
wings and stabilizers) [63.746(a)(l), (3)]
Equipment that is no longer operational, intended for public display, and not easily moved
[63.746(a)(2)]
Depainting of radomes [63.746(a)(3)J
Mechanical and hand sanding operations are exempt from requirements to perform work in
an enclosed area and use a control system [63.746(b)(5)].
WHAT IS REQUIRED?
Option 1: Non-HAP chemical strippers [63.746(b)(l)]:
Emit no organic HAP from chemical stripping formulations, agents, or chemical paint
softeners.
Option 2: Nonchemical based equipment [63.746(b)(2)]:
Operate and maintain equipment in accordance with manufacturer's specifications
During periods of malfunction, substitute materials may be used during the repair period
* Use substitutes no more than 15 days annually, unless organic HAP-free
* Substitutes that are used shall minimize HAP emissions.
For dry media blasting systems generating airborne inorganic HAP emissions [63.746(bX4)]:
->- Perform depainting operations in an enclosed area (unless a closed-cycle system is
used)
*- For existing sources, pass exhaust air through a dry particulate filter system meeting
existing source filter efficiencies (as identified in "Primer and Topcoat Operations -
2-23
-------
Inorganic HAP Control"), or through a control system meeting existing source filter
efficiencies or a waterwash system prior to exhausting to the atmosphere
-*- For new sources, pass exhaust air through a dry particular filter system meeting new
source filter efficiencies (as identified in "Primer and Topcoat Operations - Inorganic
HAP Control"), or through a control system meeting new source filter efficiencies or
baghouse prior to exhausting to the atmosphere.
Option 3: Organic HAP-containing chemical stripper [63.746(c)]:
Use a control system to reduce organic HAP emissions by 81% for existing sources and 95%
for new sources from baseline established from 1996 and 1997, on a usage per aircraft or
usage per ft of surface basis
* Control system options include carbon adsorption or noncarbon adsorption
-*- Overall efficiency is the product of capture and destruction or removal efficiency, and
accounts for the volume of chemical stripper used
* Perform initial performance test unless a waiver is obtained [63.749(d)(2)].
Spot Stripping and Decal Removal (in addition to Option 1. 2. or 3) [63.746(b)(3)]:
On an annual average basis, use no more than 26 gallons of organic HAP-containing
chemical strippers or alternatively 190 pounds of organic HAP per commercial aircraft
depainted
On an annual average basis, use no more than 50 gallons of organic HAP-containing
chemical strippers or alternatively 365 pounds of organic HAP per military aircraft depainted.
MONITORING REQUIREMENTS [63.746(b)(4)]:
Note: Mechanical and hand sanding operations are exempt from the requirements in
paragraph (b)(4).
If Option 1 is used, no monitoring is required.
If Option 2 is used, ensure the following:
If dry paniculate filter system is used:
* Maintain system in good working order
->- Install differential pressure gauge across filter banks
-* Continuously monitor the pressure drop across the filter
-*- Shut down operation when pressure drop exceeds or falls below manufacturer's limits
-* Shut down if scheduled maintenance procedures have not been performed.
If waterwash system is used:
->- Continuously monitor the water flow rate
-> Shut down operation when waterwash fails the visual continuity/flow characteristics
or water flow rate
2-24
-------
-* Shut down operation when recorded water flow rate exceeds manufacturer's limits
* Shut down operation if scheduled maintenance procedures have not been performed.
If Option 3 is used, monitor control device operation as follows:
Control device is a carbon adsorber:
*- Establish as a site-specific operating parameter the outlet total HAP or VOC
concentration or the control device efficiency [63.751(b)(l)]
* For nonregenerative carbon systems, the carbon replacement time interval may be
established as the site-specific operating parameter [63.75 l(b)(2)]
-*- For capture systems, submit a monitoring plan that identifies the operating parameter
to be monitored, discusses why this parameter is appropriate, and identifies the
specific monitoring procedures [63.751(b)(3)(i)]
-*- Conduct monitoring in accordance with the submitted plan unless EPA comments
require an alternate monitoring scheme [63.75 l(b)(3)(iii)]
-* Install, calibrate, operate, and maintain a continuous emission monitor that complies
with CFR specifications and requirements [63.751(b)(6)(ii), (iii)(A)]
->- Do not operate the control device at an average control efficiency less than the
required level for three consecutive adsorption cycles or over a 7- to 30-day rolling
average, as applicable [63.75 l(b)(6)(iii)(B), (C)]
-*- Do not operate the capture device at an average parameter value greater or less than
(as appropriate) the established value for any 3-hour period [63.75l(b)(6)(iv)].
Control device is an incinerator:
s"
-*- Install, calibrate, maintain, and operate temperature monitoring equipment or a
CEMS. Replace or have temperature sensors recalibrated every 3 months
[63.75 l(b)(8)]
-*~ Install a thermocouple equipped with a continuous recorder and operate continuously
(correct locations indicated in rule) [63.751(b)(9), (10)]
* Establish site-specific temperature parameters during each performance test
2-25
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RECORDKEEPING REQUIREMENTS [63.752(e)]:
All Options, record the following [63.752(e)(4)]:
For each aircraft, a listing of the parts, subassemblies, and assemblies normally removed from
the aircraft before depainting
> Prototype, test models, or aircraft that exist in low numbers (<25 aircraft) are exempt.
For HAP strippers used for spot stripping and decal removal, record the following [63.752(e)(6)]:
Volume of organic HAP-containing chemical stripper used or weight of organic HAP used
Annual average volume of organic HAP-containing stripper or volume of organic HAP used
per aircraft
Annual number of aircraft stripped
All data and calculations.
If Option 1 is used, record the following [63.752(e)(l)]:
Name of each chemical stripper
Monthly volumes or weights of each HAP stripper used.
If Option 2 is used, record the following [63.752(e)(5)]:
Name and type of nonchemical based equipment
Malfunction information, including:
-*- The nonchemical method or technique that malfunctioned
-> The date the malfunction occurred
s"
->- A description of the malfunction
* The methods used to depaint during the malfunction period
-*- The dates that these methods were begun and discontinued
* The date the malfunction was corrected.
If the control system is a dry paniculate filter system [63.752(e)(7)]:
-*- Actual pressure drop across the paniculate filters once each shift during operation
->- Record the acceptable limit(s) of pressure drop as specified by the filter or booth
manufacturer.
If the control system is a waterwash system [63.752(e)(7)]:
-*~ Record the water flow rate through the operating system once each shift during
operation
->- Record the acceptable limit(s) of visual continuity of the water curtain and water flow
rate as specified by the booth manufacturer or in locally prepared operating
procedures.
2-26
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If Option 3 is used, record the following [63.752(e)(2), (3)]:
The name of each chemical stripper used
Monthly volumes of each organic HAP stripper used
Control system information including:
-*- For carbon adsorption systems:
+ Overall control efficiency
+ All test results, data, and calculations used in determining efficiency
f Length of the rolling material balance period and all data and calculations
+ A record of the certification of the accuracy of the device that measures the
amount of HAP or VOC recovered.
-> For nonregenerative carbon adsorption systems:
+ Overall control efficiency
+ All test results, data, and calculations used in determining efficiency
+ The record of the carbon replacement time established as the site-specific
operating parameter.
> For other control devices:
+ Overall control efficiency
+ All test results, data, and calculations used in determining efficiency.
For Options 2 and 3, perform the following [63.743(b)]:
s1
Prepare a startup, shutdown, and malfunction plan (excluding dry particulate filters operated
per manufacturer's instructions) which includes:
* Requirements in 63.6
-*- Operation and maintenance criteria
->- A standardized equipment operation and maintenance checklist
-*- Procedures for identifying and reporting malfunctions
-> Procedures to prevent malfunctions due to preventable conditions.
Operate all control equipment in accordance with the startup, shutdown, and malfunction
plan.
2-27
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REPORTING REQUIREMENTS [63.753(d)]r
All Options, report the following [63.753(d)(l)(viii), (ix)]:
Report semiannually (every 6 months from the date of notification of compliance status):
-*- If the operations have been in compliance, a statement that the operations have been
in compliance
->- A list of new and discontinued aircraft models depainted at the facility
-*- A list of parts normally removed for depainting for each new aircraft model being
depainted.
For spot stripping and decal removal, report the following [63.753(d)(2)(i)]:
Report annually:
-* The average volume per aircraft of organic HAP-containing chemical strippers used
for spot stripping and decal removal operations when depainting limits in
63.746(b)(3) or weight of organic HAP are exceeded.
For booths or hangars that do not have the potential to emit 10 tons/yr or more of an individual
inorganic HAP or 25 tons/vr or more of all inorganic HAP combined [63.743(a)(10)]:
Notify the Administrator of such construction or reconstruction on an annual basis. Make
notification by March 1 of each year for construction or reconstruction during the prior
calendar year and include information in 63.5(b)(4), except that such information is to be
limited to inorganic HAP.
If Option 1 or 2 is used, report the following [63.753(d)(l)(v), (vi)]:
Report semiannually: s
-*- Any new nonchemical depainting technique used at the facility since the notification
of compliance status or any subsequent semiannual report
-*- Any periods of equipment malfunction
+ The nonchemical method or technique that malfunctioned
+ The date the malfunction occurred
+ A description of the malfunction
+ The methods used to depaint during the malfunction period and dates begun and
discontinued
+ The date the malfunction was corrected.
If Option 2 is used, also report the following [63.753(d)(l)(vii), (d)(2)]:
Report semiannually:
-> The periods where a nonchemical depainting operation was not immediately shut
down when the pressure drop or water flow rate was outside acceptable limits
2-28
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Report annually:
* Description of any control device currently used that was not listed in the notification
of compliance status or any subsequent report
-> The number of times the pressure drop for each filter system exceeds acceptable
limits
->- The number of times the water flow rate for each waterwash system exceeds
acceptable limits.
If Option 3 is used, report the following [63.753(d)(l)(i)-(iv)]:
Report semiannually [63.753(d)(l)(i)-(iv)J:
* Any 24-hour period where organic HAP were emitted from the depainting of an
aerospace vehicle
-> Any new chemical stripper used at the facility during the reporting period
-*- The organic HAP content of these new chemical strippers
* The organic HAP content of each chemical stripper that undergoes reformulation.
Report annually [63.753(d)(2)]:
-* Description of any control device currently used that was not listed in the notification
of compliance status or any subsequent report
* If carbon adsorber is used:
; + Each rolling period when the overall control efficiency is calculated to be less
than 81% for existing systems and 95% for new systems, the initial material
balance calculation, and any exceedances as demonstrated through the calculation.
-* If nonregenerative carbon adsorbers are used:
+ Submit design evaluation, the continuous monitoring system performance report,
and any excess emissions as demonstrated through deviations in monitoring
values.
*- If other control devices are used:
+ Each exceedance of the operating parameters established for the control device
under the initial performance tests.
2-29
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CHEMICAL MILLING MASKANT OPERATIONS
WHAT IS COVERED?
Chemical milling maskant application operations on aluminum aerospace vehicles, parts, and
assemblies. The provisions apply to applications associated with either Type I or Type n
etchants [63.742, 63.747].
WHAT IS NOT COVERED?
Chemical milling maskants used to touch-up scratched surfaces, trimmed edges, or damaged
maskant [63.747(c)(3)]
Bonding maskants, critical use and line sealer maskants and seal coat maskants [63.742]
Maskants that must be used with a combination of Type I and Type n etchants [63.742].
WHAT IS REQUIRED?
Option 1, Uncontrolled Maskants: Use compliant coatings.
Use only chemical milling maskants that comply with the maximum HAP and VOC content
limits as shown in the table below [63.747(c), (e)(l)], or
Use any combination of chemical milling maskants that have a monthly average content level
that complies with specific content limits, as determined by applicable procedures.
Averaging of uncontrolled maskants is permitted and averaging schemes must be
preapproved by the permitting authority [63.747(e)(2)] ""
Operate in a manner that minimizes spills [63.747(b)].
Coating Type
Type I Maskant
Type II Maskant
Maximum Content, As Applied
Organic HAP Content
g/liter
622
160
Ib/gal
5.2
1.3
VOC Content
g/liter
622
160
Ib/ga!
5.2
1.3
a HAP content is measured "less water"; VOC content is measured less water and exempt solvents. Include thinner
added to calculation.
Option 2, Controlled Maskants: Use add-on controls. [63.747(d)]
Demonstrate an overall removal efficiency (of both organic HAP and VOC) of >81 %.
Overall removal efficiency is the product of the capture efficiency and the destruction
efficiency
2-30
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Operate in a manner that minimizes spills [63.747(b)]
Perform initial performance testing unless a waiver is obtained [63.749(d)(2)].
Option 3. Waterborne Maskants: Use waterborne maskants. [63.741(i)]
Waterborne maskants are exempted from 63.747(d)-(e), 63.749(h), 63.750(k)-(m),
63.752(e), and 63.753(e).
->- Handle and transfer in a manner to minimize spills
->- Maintain manufacturer's data and annual purchase records for 5 years
-* Waterborne coatings may be averaged under 63.743(d).
MONITORING REQUIREMENTS [63.751(b)]:
If Options 1 and 3 are used, no monitoring is required.
If Option 2 is used, monitor control device operation as follows:
Control device is a carbon adsorber [63.75 l(b)(l)-(7)1:
* Establish as a site-specific operating parameter the outlet total HAP or VOC
concentration or the control device efficiency [63.751(b)(l)]
* For nonregenerative carbon systems, the carbon replacement time interval may be
established as the site-specific operating parameter [63.75l(b)(2)]
-*- For capture systems, submit a monitoring plan that identifies the operating parameter
to be monitored, discusses why this parameter is appropriate, and identifies the
specific monitoring procedures [63.751(b)(3)(i)] ^
-*- Conduct monitoring in accordance with the submitted plan unless EPA comments
require an alternate monitoring scheme [63.75l(b)(3)(iii)]
-*- Install, calibrate, operate, and maintain a continuous emission monitor that complies
with CFR specifications and requirements [63.751(b)(6)(ii), (iii)(A)]
-*- Do not operate the control device at an average control efficiency less than the
required level for three consecutive adsorption cycles or over a 7- to 30-day rolling
average, as applicable [63.75 l(b)(6)(iii)(B), (C)]
-* Do not operate the capture device at an average parameter value greater or less than
(as appropriate) the established value for any 3-hour period [63.75 l(b)(6)(iv)].
Control device is an incinerator [63.751 (b)(9)-( 12)]:
* Install, calibrate, maintain, and operate temperature monitoring equipment or a
CEMS. Replace or have temperature sensors recalibrated every 3 months
[63.751(b)(8)]
* Install a thermocouple equipped with a continuous recorder and operate continuously
(correct locations indicated in rule) [63.751(b)(9), (10)]
-*- Establish site-specific temperature parameters during each performance test
2-31
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RECORDKEEPING REQUIREMENTS [63.752(f)]:
If Option 1 is used, record the following:
When nonaveraging methods are used [63.752(0(1)1:
-*- Mass of organic HAP (Hj) and VOC (Gj) (less water and exempt solvents) emitted
per unit volume of chemical milling maskant as applied (less water) for each maskant
formulation used each month (calculate using §63.750(k) and (m))
* All data, calculations, and test results used in determining H- and G-
-> Volume (gal) of each chemical milling maskant used each month.
When averaging methods are used [63.752(f)(2)]:
-*- Monthly weighted volume of organic HAP (Ha) and VOC (G&) emitted per unit
volume of chemical milling maskant as applied for each maskant formulation used
each month (calculate using §63.750(1) and (n))
->- All data, calculations, and test results used in determining Ha and G&.
If Option 2 is used, record the following:
For carbon adsorption systems F63.752(f)(3)(i)1:
-*- Overall control efficiency
-*- All test results, data, and calculations used in determining efficiency
->- Length of the rolling material balance period and all data and calculations
->- A record of the certification of the accuracy of the device that measures the amount of
HAP or VOC recovered ^
For nonregenerative carbon adsorption systems f63.752(f)(3)(ii)1:
*- Overall control efficiency
-*- All test results, data, and calculations used in determining efficiency
-*- The record of the carbon replacement time established as the site-specific operating
parameter.
For other control devices [63.752(0(4)1:
-*- Overall control efficiency
* All test results, data, and calculations used in determining efficiency.
For incineration (catalytic and noncatalytic') F63.752(f)(4)(ii), (iii)1:
-*- Continuous records of the firebox temperature and all calculated 3-hour averages.
If Option 3 is used, no recordkeeping is required.
2-32
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REPORTING REQUIREMENTS [63.753(e)]:
All Options, report the following:
Semiannual reports occurring every 6 months (from the date of notification of compliance
status) which identify required reporting for each category. If the operations have been in
compliance for the semiannual period, a statement that the operations have been in
compliance with the applicable standards
All chemical milling maskants currently used that were not listed in the notification of
compliance status or any other subsequent semiannual report.
If Option 1 is used, report the following:
When nonaveraging methods are used [63.753(e)(l)]:
-*- Each value of Hj and Gj that exceeds the applicable organic HAP or VOC content
limit.
When averaging methods are used [63.753(e)(2)]:
-* Each value of H& and Ga that exceeds the applicable organic HAP or VOC content
limit.
If Option 2 is used, report the following [63.753(e)(5)]:
Description of any control devices currently in use that were not listed in the notification of
compliance status or any subsequent reports
Control device is incineration [63.753(e)(3)(i)]:
* All periods when the 3-hour average combustion temperature is less than the average
combustion temperature established during the mostrecent performance test
demonstrating compliance.
Control device is a carbon adsorber [63.753(e)(3)(ii)(A)]:
->- Each rolling period when the overall control efficiency of the control system is less
than 81%, the initial material balance calculation, and any exceedance as
demonstrated through calculations.
Control device is a nonregenerative carbon adsorber [63.753(e)(3)(ii)(B)]:
-*- Submit the design evaluation, the continuous monitoring system performance report,
and any excess emissions as demonstrated through deviations of monitored values.
Control device is something other than an incinerator or carbon adsorber f63.753(e)(3)(iii)1:
-* Each exceedance of the operating parameters established for the control device under
the initial performance test during which compliance was demonstrated.
2-33
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3.0 APPLICABILITY FLOW CHARTS
The simplified flow charts in this section illustrate the applicability decision process for
facilities potentially subject to the provisions of the Aerospace NESHAP. Since these charts are
in a condensed form, the rule provisions should be consulted prior to making any final
applicability decision. In addition, the EPA or the permitting authority should be consulted with
any questions related to applicability.
3-1
-------
Chart 1
General Applicability
Is the facility a
Major Source of
HAP?
NO
YES
NO
Is the facility engaged
in manufacture or
rework of aerospace
vehicles or components?
YES
Cleaning
Provisions
Do Not Apply
NO
Perform Cleaning Operations on
aerospace vehicles or components
(Hand-Wipe, Spray Gun, Flush)?
YES
Cleaning Provisions
Apply, See Chart 2
Coating
Provisions
Do Not Apply
NO
Perform Coating Operations
(Primer, Topcoat, Self-Priming
Topcoat) on aerospace
vehicles or components ?
YES
Coating Provisions
Apply, See Chart 3
I \
Continued
3-2
-------
Chart 1
General Applicability
(Concluded)
Perform Depainting
Operations on aerospace
vehicles or components
(Chemical Stripping,
Blasting, Other)?
NO
Depainting
Provisions
Do Not Apply
YES
Depainting Provisions
Apply, See Chart 4
Chemical Milling
Maskant Provisions
Do Not Apply
NO
Apply Chemical Milling
Maskant to aerospace
vehicles opcomponents?
YES
i
Chemical Milling
Maskant Provisions
Apply, See Chart 5
Produce waste
which contains
HAP?
NO
YES
Handling and Storage
of Waste Provisions
Do Not Apply
Handling and Storage
of Waste Provisions
Apply, See §63.748
(RCRA waste not subject)
3-3
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Chart 2
Cleaning Operations Applicability
Do you perform Cleaning
Operations on aerospace
vehicles or components?
YES
NO
Do you perform
Hand-Wipe
Cleaning Operations?
Tingjjpj
YEsI
NO
Hand-Wipe Provisions
Apply. See §63.744(b).*
Spray Gun
Provisions
Do Not Apply
NO
i
Cleaning
Provisions
Do Not Apply
Hand-Wipe
Provisions
Do Not Apply
LJL
Do you perform Spray
Gun Cleaning Operations?
YESI'
Spray Gun Provisions
Apply. See §63.744(c).*
1 » »
Do you perform Flush
Cleaning Operations?
YEsl
NO
Flush Cleaning Provisions
Apply. See §63.744(d).*
Flush Cleaning
Provisions
Do Not Apply
* Cleaning housekeeping requirements also apply. See §63.744(a).
3-4
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Chart3
Primer/Topcoat* Operations Applicability
Do you perform Primer or
Topcoat* Application on
aerospace vehicles or
components?
YES
Do you apply primers or
topcoats* containing organic
HAP and/or VOC?
YESl
NO
Organic HAP and/or VOC
Coating Provisions Apply.
See § 63.745(c)-(f).
NO
Inorganic HAP
Coating Provisions
Do Not Apply
NO
Primer and
Topcoat* Provisions
Do Not Apply
Organic HAP
Coating Provisions
Do Not Apply
LA
Do you sp"ray apply primers or
topcoats* containing inorganic
HAP?
YESl
Inorganic HAP Coating
Provisions Apply.
See § 63.745(g).
Including self-priming topcoat
3-5
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Chart 4
Depainting Operations Applicability
Do you depaint the outer
surface of 7 or more
completed aerospace
vehicles per year?
NO
Depainting
Provisions
Do Not Apply
i
YES.
PICK ONE OR
MORE OPTIONS
Perform dry or non-chemical
depainting operations
(blasting or other).
Use stripper
containing HAP with
a control system.
i
Use non-HAP
chemical strippers.
Dry or non-chemical
provisions apply.
See §63.746(b).
Control system
provisions apply.
See §63.746(c).
Non-HAP chemical
provisions apply.
See§63.746(b)(1).
May use an annual average of up to 26 gal
of HAP strippers (commercial) or 50 gal (military)
per aircraft depainted (spot/decal). See §63.746(b)(3).
3-6
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Chart5
Chemical Milling Maskant
Operations Applicability
Do you apply Type 1 or Type II
chemical milling maskants to
aluminum aerospace components?
NO
Maskant
Provisions
Do Not Apply
YES.
PICK ONE OR
BOTH OPTIONS
I
Use compliant
maskants.
See §63.747 (c).
I
Use add-on controls.
See §63.747 (d).
3-7
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4.0 INSPECTION PROCEDURES1
This section contains guidelines for conducting an onsite or self inspection of an
aerospace manufacturing or rework facility that is presumed or known to be subject to the
Aerospace NESHAP. The next section includes inspection checklists which should be useful
tools in carrying out an inspection at the site.
4.1 PREPARING FOR THE INSPECTION
It is important to obtain as much information about the facility prior to the site visit. You
may want to review the information available in the source file, including:
permit applications;
approved permits;
equipment lists;
conditions for each permit unit;
previous inspections including reports of violation;
breakdown reports;
enforcement actions taken;
complaints; '
variance history;
alternative emission control plans;
lists of operations conducted; and
cleaning solvents and coatings in use.
The inspector should become familiar with any aerospace operations claimed by the
facility as exempt, as well as with the compliance options chosen by the source. The provisions
of the NESHAP, including allowable exemptions, must also be understood.
Exerpted from the Aerospace Coating Operations Manual, January 1997 Compliance
Division, California U. S. Environmental Protection Agency. See page 7-1, document 1.
4-1
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4.2 FACILITY INSPECTION
4.2.1 General
The appropriate compliance checklists (see Section 5.0) are intended to guide the
inspector through the inspection for the four principal regulated operations: cleaning, primer and
topcoat application, depainting, and chemical milling maskant application. It may be most
efficient to concentrate on each of these operations in turn. Keep in mind that depainting is
essentially a rework and not a manufacturing operation, and that the use of chemical milling
maskants is a usually a fairly specialized operation carried out by the larger manufacturers or by
companies that specialize in doing chemical milling on a subcontractor basis.
In using the checklists, the inspector first checks the box for the compliance option or
options chosen for the operation (in instances where options are available), and then checks
"Yes" or "No" to indicate the status of the facility with each individual requirement. A separate
log for notes and explanations pertaining to certain entries (especially "No" entries) is advised to
describe details of the plant's status.
After all of the operations have been inspected, the inspector may need to review the file
information with facility personnel a second time to clarify and correct certain information based
on the observations made. Records from the facility files should also be checked to verify
compliance, both with operational requirements and with the requirements to keep the records
themselves. Material safety data sheets (MSDS) and/or other product data sheets for the cleaning
solvents, primers, topcoats, and chemical milling maskants in use could also be collected if they
have not already been obtained.
When the inspection and the file review are complete, a wrap-up meeting with
appropriate facility personnel should be held to summarize findings, explain any compliance
violations noted, and review next steps in the process.
4.2.2 Specific Activities
4.2.2.1 Cleaning Operations. Be aware of operations exempted from the cleaning
requirements (and note whether the exemption applies to all requirements or to hand-wipe only).
The inspector needs to view records of all cleaning solvent usages, and the type of cleaning
performed with each. Note any open containers for solvents or applicators, and general
4-2
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housekeeping practices (spill provision). Remember, cleaning solvents are used throughout a
facility in practically every facet of the production process.
Determine how spray guns are cleaned, and verify that one or more of the allowed options
(or equivalents) are being used. Verify through observation or by questioning the painter that
solvent containers or reservoirs associated with these cleaners are kept closed except when parts
are added or removed.
4.2.2.2 Primers and Topcoats. The coatings storage/mix room should be inspected in
order to observe coating labels and other records for organic HAP and VOC content. Note
whether the information is as-supplied or as-applied. Look for any manufacturer mixing
instructions. Ask the painter how he or she reduces the coatings (i.e., is thinner applied), how the
viscosity is measured, and what is done if the viscosity is too high or too low. Verify what
solvents are used for reduction.
Examine each coating operation to identify the coatings in use (including exempt
operations and use of specialty coatings and waterbome coatings). Determine the application
equipment used and compare with the allowable equipment (equipment claimed as equivalent
should have a demonstration as outlined in the standard). Observe that all electrostatic systems
are operated correctly (power on with a clean ground attached, etc.).
For HVLP type spray guns, maximum air pressure as spray exits the gun is specified as
10 psig. The inspector should check to see whether individual spray guns meet these limits.
(Some manufacturers supply a small kit that allows the exit air pressure to be measured, while
others may supply a gauge for the same purpose.) The gun operator should be able to supply
some assistance on how the required air pressure is achieved or measured. If different
application methods than those specified in the NESHAP are in use, determine if a demonstration
of equivalent transfer efficiency has been approved. Verify that current conditions match
demonstration conditions.
4.2.2.3 Spray Booths. Dry filter systems or waterwash systems are used for either
inorganic HAP-containing primer and topcoat (including self-priming topcoat) application or
depainting operations. The maintenance of the booth (including filters, fan, and ductwork) is
very important in the continuing control efficiency for fine paniculate generated by these
operations (i.e., paint overspray or dry media/paint residue from blast depainting). Check
4-3
-------
whether any parts of the filter bank are missing, damaged, or improperly installed. Note how
often filters are replaced and if the filters appear to be overloaded. Examine the pressure drop
across the filters or the water flow rate of the waterwash, and compare the value with the
manufacturer's value as contained in the operator's log. Note whether the pressure drop
instrument (manometer) contains fluid and is functional (attains a nonzero reading when the fan
is activated). For waterwash systems, observe whether the curtain has dry spots, and whether it
appears uniform and regular.
4.2.2.4 Depainting. If a facility selects the option of using a new nonchemical paint
removal system (i.e., dry media blasting), they will need to install a dry filter system or other
control device that meets required efficiencies. For existing removal systems, they will need to
install a dry filter system, waterwash system, or other equivalent control device. Ask about the
facility's maintenance practices for the filters, fan, and ductwork. As with the paint spray booth,
check the condition of the filters for completeness and freedom from damage. Note whether the
pressure drop instrument (manometer) contains fluid and is functional (attains a nonzero reading
when the fan is activated). For waterwash systems, observe whether the curtain has dry spots,
and whether it appears uniform and regular. Determine the maintenance and chemical additives
schedule. ^
Except for spot stripping allowances, a facility that selects the use of HAP-containing
chemical strippers (i.e., methylene chloride), which are not specifically exempted from the
regulation, is required to have an add-on control device in place. See the next subsection for a
discussion of add-on controls.
4.2.2.5 Chemical Milling Maskants. Chemical milling maskants are considered a coating
along with primers and topcoats. The organic HAP/VOC contents of the maskants need to be
verified in a similar manner to the other types of coatings. Content and use records are also
similar. Each maskant has to be characterized with respect to its use with either Type I or Type n
etchants.
As with primer and topcoat applications, and depainting, the use of an add-on control
device is an optional approach if the use of compliant coatings is not feasible or desirable.
Inspection approaches for add-on controls are addressed in subsection 4.3.2.6.
4-4
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4.2.2.6 Control Devices. Check the integrity of ductwork and any collection hoods.
Observe the structural integrity of the device to determine any possible locations of fugitive
leaks. Examine the latest source test records to verify that the required capture and control
efficiency is being attained. Read the operating parameter value and compare with the
established value and monitoring records provided by the source. Ensure that all required
records are available from the source.
4.2.2.7 Sampling Techniques. It is important that, if any samples are to be collected,
they be collected and preserved in accordance with defensible procedures. All samples should be
representative of the cleaning solvent or coating as applied. Observe the operator if he is filling
your container. Do not let the filled container leave your sight or control. The EPA has issued
procedures in the document EPA-340/191-010, "Standard Procedure for Collection of Coating
and Ink Samples for Analysis by Reference Methods 24 and 24A." As a general rule, samples
should be collected into containers that are clean, dry, unbreakable, scalable, nonreactively lined
(if needed), and appropriate for the material to be sampled.
4.2.2.8 Materials Documentation. Material safety data sheets (MSDS) are guides to
workplace safety and, as such, they have limited usefulness in determining the precise content or
emission potential of materials. The inspector should be aware-that the HAP or VOC listed on
.the MSDS sheets is not necessarily representative of the content of a specific batch of cleaner or
coating, or these contents may not be listed at all. Source operators, further, are free to add
materials before applying the cleaner or coating.
Technical specification sheets are provided by the manufacturer usually upon request of
the user. They are often tailored for air pollution regulations to include VOC or HAP contents as
supplied, and include recommended mixing and thinning ratios. Be sure to ask for the latest
MSDS, specification sheet, or product technical bulletin, because formulations may be changed
over time. When calculating VOC or HAP in accordance with the test procedures identified
within the rule, it may be helpful to review EPA document EPA-340/1-86-016, "A Guideline for
Surface Coating Calculations," July 1986; and EPA-450/3-84-019, "Procedures for Certifying
Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings,"
December 1984.
4-5
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5.0 INSPECTION CHECKLISTS
This section contains checklists for use in performing NESHAP inspections of the four
production operations covered by the regulation: cleaning, primer and topcoat application,
depainting, and chemical milling maskant application. These checklists may serve as useful tools
for agencies and sources tasked to implement the rule. You will find that the checklists will,
when necessary, refer the user back to Section 2.0, Summary of the Rule. However, since the
checklists and the rule summary do not contain all details of the NESHAP, the rule itself and any
amendments should be referred to when performing facility inspections. Separate sheets may be
needed to record more specific information about the operations at individual facilities.
5-1
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CHECKLIST A
APPLICABILITY CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: This checklist will establish whether a facility or operations within a facility are subject
to this NESHAP.
1. GENERAL INFORMATION
A. Date of Inspection:
B. Facility Name:
C. Facility Address:
D. Facility Contact:
(Name, Title, and Phone)
E. Is the facility a major or an area source? Major a Area n
(NESHAP applies to major sources only)
F. Inspector(s):
Name Title/Affiliation Phone Number
2. SOURCE IDENTIFICATION
A. Does this facility engage in the manufacture or rework of aerospace vehicles,
assemblies, or components? Yes n No D (If No, do not proceed, this rule
does not apply)
B. Does this facility perform any of the following operations on aerospace vehicles,
assemblies, or components? (If Yes to any, proceed, the rule applies)
Cleaning operations Yes Q No n
Hand-wipe cleaning Yes n No o
Spray gun cleaning Yes n No o
Flush cleaning Yes n No n
Topcoat or primer application Yes n No D
Depainting operations Yes D No n
Chemical milling maskant Yes n No o
Handling and storage of waste Yes n No n
5-2
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A - APPLICABILITY
3. RULE APPLICABILITY
Various processes that may be performed at aerospace manufacturing and rework facilities are
not covered under 40 CFR 63, Subpart GG. In addition, exemptions from 40 CFR 63, Subpart
GG and from control requirements are also identified within the rule. Listed below are processes
and materials not covered or exempt from the rule. This listing of overall exemptions is not
repeated within individual checklists. The cited regulatory provision and §63.742 Definitions
should be consulted for more details and for any qualifications on the exemptions. Complete the
form by checking off all that apply.
Citation
§63.74 l(e)
§63.741(f)
Process
Handling of waste subject to RCRA,
40 CFR 262-268
Research and development
Quality control operations
Laboratory testing activities
Chemical milling
Metal finishing
Electrodeposition (except the
electrodeposition of paints)
Composite parts that do not become
part of aerospace vehicle or
component, or are not composite
tooling that contacts composite
aerospace parts prior to cure (except
for some cleaning and coating
operations)
Aircraft transparencies manufacturing
Wastewater operations
Electronic parts and assemblies (except
for cleaning and topcoating of
completed assemblies)
Parts and assemblies not critical to the
vehicle's structural integrity or flight
performance
Specialty coatings
Sealants and adhesives
Measurement,
Calculation, or
Observation
t'
,
-
Does Facility
Perform Indicated
Operation?
Yes
No
5-3
-------
A - APPLICABILITY
Citation
§63.741(0
§63.741(g)
§63.74 l(h)
§63.741(i)
§63.741(j)
Process
Adhesive bonding primers
Use ofde minimis primers, topcoats,
chemical milling maskants, strippers,
and cleaning solvents (HAP and VOC
<0.1% for carcinogens, <1.0% for
noncarcinogens)
Low- volume use of primers, topcoats,
and chemical milling maskants which
do not exceed 50 gal (189 liters) per
year per formulation, with a combined
annual total of all such primers,
topcoats and chemical milling maskants
used not to exceed 200 gal (757 liters).
Otherwise exempt coatings are
excluded from totals.
Space vehicles (except for depainting)
Waterborne coatings exempt from HAP
and VOC requirements
Antique vehicles and components
Measurement,
Calculation, or
Observation
Does Facility
Perform Indicated
Operation?
Yes
No
4. CHECKLISTS:
If it has been determined that the facility or plant is subject to this NESHAP, go to the
appropriate Checklist indicated below and complete the form.
Cleaning operations
Hand-wipe cleaning
Spray gun cleaning
Flush cleaning
Topcoat & Primer application
Depainting operations
Chemical milling maskant
Go to Cleaning Checklist (Checklist B)
Go to Hand-Wipe Cleaning Checklist (Checklists B & C)
Go to Spray Gun Cleaning Checklist (Checklists B & D)
Go to Flush Cleaning Checklist (Checklists B & E)
Go to Primer/Topcoat Checklist (Checklist F)
Go to Depainting Checklist (Checklist G)
Go to Chemical Milling Maskant Checklist (Checklist H)
5-4
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A - APPLICABILITY
5. INSPECTOR COMMENTS:
END OF CHECKLIST A
5-5
-------
CHECKLIST B
CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: Cleaning operations requirements are applicable only to the cleaning of aerospace
vehicles, assemblies, and components. Cleaning operations subject to the hand-wipe cleaning
(Checklist C), flush cleaning (Checklist D), or spray gun cleaning (Checklist E) requirements are
also subject to these requirements.
1. GENERAL INFORMATION
A. Source Location (if applicable):
B. Installation Date (if applicable):
2. REQUIREMENTS
Owners/operators may choose one of the following options. Complete the table below by
checking either "Yes" or "No" to document the measurement, calculation, or observation
meeting the NESHAP requirement(s). It may be necessary to write "N/A" (not applicable) for
some requirements.
Citation
Option 1
(§63.744(a))
Must meet either of
the "Table 1"
criteria to comply,
or the de minimis
levels of §63. 74 l(f).
(See page 5-4 for de
minimis levels.)
Requirement
Aqueous cleaning solvents (2 80% water
content as applied), miscible with water,
flash point > 200°F (93 °C) are used
Hydrocarbon based cleaning solvents
(mixture of photochemically reactive
HC and oxygenated HC), maximum
vapor pressure (VP) of 3.75 in. H2O at
68°F (7 mm Hg at 20°C), and
containing no HAP are used
Measurement,
Calculation, or
Observation
^
Yes
No
If using Option 1, skip Section 3 and go directly to Section 4.
Option 2
(§63.744(a))
Solvent not meeting requirements in
Option 1
If using Option 2, go to Section 3, Housekeeping Measures
5-6
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B - CLEANING
3. HOUSEKEEPING MEASURES
Housekeeping measures are required if Option 2 is used to comply with the cleaning operation
requirements. Check either "Yes" or "No" to document the measurement, calculation, or
observation meeting the NESHAP requirement.
Citation
§63.744(aXl )
§63.744(a)(2)
§63.744(a)(3)
Requirement
Place absorbent applicators in closed
containers upon completing use (except
cotton-tipped swabs).
Store fresh and spent cleaning solvents
in closed containers (except semi-
aqueous cleaners).
Handle and transfer solvent between
containers in a manner that minimizes
spills.
Measurement,
Calculation, or
Observation
Yes
No
4. RECORDKEEPING
The following recordkeeping is required for all options. Check either "Yes" or "No" to
document the measurement, calculation, or observation meeting the NESHAP requirement.
Additional requirements will be found in individual sections of-the hand-wipe, spray gun, and
flush cleaning checklists.
Citation
§63.752(b)(l)
§63.10(b)(l)
Requirement
Name, vapor pressure, and
documentation showing the organic
HAP constituents for each cleaning
solvent
Necessary records to be maintained for
5 years (2 years onsite)
Measurement,
Calculation, or
Observation
Yes
No
5-7
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B - CLEANING
5. INSPECTOR COMMENTS:
END OF CHECKLIST B
5-8
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CHECKLIST C
HAND-WIPE CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP "*
NOTE: Cleaning operations subject to the hand-wipe cleaning requirements are also subject to
the cleaning requirements (Checklist B).
1. GENERAL INFORMATION
A. Source Location (if applicable):
B. Installation Date (if applicable):
2. EXEMPTIONS
The following hand-wipe cleaning operations are exempted from portions of the regulatory
NESHAP provisions shown in the table (please note that some recordkeeping is required for
exempt operations where a noncompliant cleaning solvent is used). The cited regulatory
provision and §63.742 Definitions should be consulted for more details and for any qualifications
on the exemptions.
The following exemptions apply specifically to the use of hand-wipe cleaning solvents:
Citation
§63.744(e)(l)
§63.744(e)(2)
§63.744(e)(3)
§63.744(e)(4)
§63.744(e)(5)
§63.744(e)(6)
§63.744(e)(7)
§63.744(e)(8)
Exempt Operation
Cleaning of components of breathing
oxygen systems that are exposed to the
breathing oxygen
Cleaning related to parts that are exposed
to strong oxidizers or reducers
Cleaning and surface activation prior to
adhesive bonding
Electronic parts, and assemblies
containing electronic parts
Aircraft and ground support equipment
fluid systems exposed to the fluid (e.g.,
air-to-air heat exchangers and hydraulic
fluid systems)
Fuel cells, fuel tanks, and confined spaces
Solar cells, coated optics, and thermal
control surfaces
Cleaning related to upholstery, curtains,
carpet, and other textiles used in aircraft
interiors
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
5-9
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C - HAND-WIPE CLEANING
The following exemptions apply specifically to the use of hand-wipe cleaning solvents:
Citation
§63.744(e)(9)
§63.744(e)(10)
§63.744(e)(ll)
§63.744(e)(12)
§63.744(e)(13)
Exempt Operation
Metallic and nonmetallic materials used
in honeycomb cores
Aircraft transparencies, polycarbonates,
and glass substrates
Cleaning associated with R&D, quality
control, or laboratory testing
Cleaning operations conducted within
5 feet of energized electrical systems
Cleaning operations that are "essential
uses" under the Montreal Protocol
(40 CFR §82.4)
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
3. REQUIREMENTS
Check off the compliance option or options selected by the owner/operator for hand-wipe
cleaning operations.
^
A. Option 1: (§63.744(b)(l)) Meet Table 1 composition requirements
[Table 1 found in rule and in Checklist B (Cleaning), Section 2]
B. Option 2: (§63.744(b)(2)) Meet Composite vapor pressure limit
Requirement:
Is the composite vapor pressure 24 in. H2O (45 mm Hg) or less at 68 °F (20°C)?
Yes D
No D
D
D
C. Option 3: (§63.744(b)(3)) Solvent usage reduction t
Requirement:
Was the hand-wipe cleaning solvent usage reduced at least 60% from a baseline value,
adjusted for production?
Yes D No D
5-10
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C - HAND-WIPE CLEANING
Does the plan demonstrate a reduction equivalent to Option 1 or 2, and has an >
alternative plan been filed?
Yes D No D
4. RECORDKEEPING
.Recordkeeping requirements are based on the option or options selected by the owner/operator.
Check either "Yes" or "No" to document the measurement, calculation, or observation meeting
the NESHAP requirement(s).
For hand-wipe solvents complying with Option 1 Table 1 criteria
Citation
§63.752(b)(2)
Requirement
Keep records of:
1 . name of each cleaning solvent,
2. data and calculations demonstrating
compliance with Table 1, and
3. annual volume of each solvent used
(facility purchase or usage records).
Measurement,
Calculation, or
Observation
Yes
No
_
vFor hand-wipe solvents complying with Option 2 vapor pressure limit
s§63.752(b)(3)
Keep records of:
1 . name of each cleaning solvent,
2. composite vapor pressure of each
solvent,
3. test results (if applicable), data, and
calculations for composite VP, and
4. monthly volume of each solvent used
at each operation.
,/-
For hand-wipe solvents used in exempt cleaning operations that do not comply with Option I or 2
§63.752(b)(4)
Keep records of:
1 . identity and monthly volume of each
solvent used at each operation, and
2. a list of the exempt operations in
which these solvents are being used.
5-11
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C - HAND-WIPE CLEANING
5. INSPECTOR COMMENTS:
END OF CHECKLIST C
5-12
-------
CHECKLIST D
SPRAY GUN CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: Cleaning operations subject to the spray gun cleaning requirements are also subject to
the cleaning requirements (Checklist B).
1. GENERAL INFORMATION
A. Source Location (if applicable):
B. Installation Date (if applicable):
2. REQUIREMENTS
Owners/operators may choose one of the following options. Determine what type of spray gun
cleaning operations are performed by completing the table below.
Citation
Option 1
§63.744(c)(l)
Option 2
§63.744(c)(2)
Option 3
§63.744(c)(3)
Option 4
§63.744(c)(4)
Requirement
Enclosed system cleaning
Nonatomized cleaning
Disassembled gun cleaning (manual or soaking)
Atomized cleaning
Measurement,
Calculation, or
Observation
-
Does Facility
Perform
Indicated
Operation?
Yes
No
5-13
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3. RECORDKEEPING
D - SPRAY GUN CLEANING
A. Option 1: (§63.744(c)(l)) Enclosed System
D
Citation
Compliance
§63.744(c)(l)(i)
Monitoring
§63.751(a)
Compliance
§63.744(c)(l)(ii)
Recordkeeping
§63.752(b)(l)
Recordkeeping
§63.752(b)(5)
Requirement
Clean spray gun in enclosed system kept
closed except when inserting or removing
gun. Cleaning consists of forcing the
cleaning solvent through the gun.
Visually inspect seals and other potential
leak sources monthly, while system is in
operation.
Repair any leak in system as soon as
practicable, but no later than 15 days after
finding leak. Shut down system if not
repaired within 15 days. Repair and
restart, or decommission.
Keep records of name, vapor pressure, and
organic HAP constituents for each cleaning
solvent.
Keep records of leaks showing source ID,
date each leak found, and date each leak
repaired.
Measurement,
Calculation, or
Observation
s"
Yes
No
B. Option 2: (§63.744(c)(2)) Nonatomized cleaning
D
Citation
Compliance
§63.744(c)(2)
Recordkeeping
§63.752(b)(l)
Requirement
Clean spray gun by forcing solvent
through gun with atomizing cap in place.
No atomizing air is used. Collect
solvent from gun in closed container.
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
Measurement,
Calculation, or
Observation
Yes
No
5-14
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D - SPRAY GUN CLEANING
C. Option 3: (§63.744(c)(3)) Disassembled manual cleaning or soaking D
Citation
Compliance
§63.744(c)(3)
Recordkeeping
§63.752(b)(l)
Requirement
Clean disassembled spray gun by hand
(vat kept closed when not in use), or
soak components (vat kept closed when
not inserting or removing components).
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
Measurement,
Calculation, or
Observation
Yes
No
D. Option 4: (§63.744(c)(4)) Atomized cleaning with emissions capture
D
Citation
Compliance
§63.744(c)(4)
Recordkeeping
§63.752(b)(l)
Requirement
Clean spray gun by forcing solvent
through gun, collect atomized spray into
container that captures the solvent
emissions.
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
Measurement,
Calculation, or
Observation
X-
Yes
No
4. INSPECTOR COMMENTS:
END OF CHECKLIST D
5-15
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CHECKLIST E
FLUSH CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: Cleaning operations subject to the flush cleaning requirements are also subject to the
cleaning requirements (Checklist B). Flush cleaning means the removal of contaminants by
passing solvent over, into, or through the item (spray guns not included) being cleaned.
1. GENERAL INFORMATION
A. Source Location (if applicable):
B. Installation Date (if applicable):
2. REQUIREMENTS
Check off the compliance option or options selected by the owner/operator for flush cleaning
operations.
NOTE: Exempt from the compliance requirements of §63.744(d) are: (1) semi-aqueous
cleaning solvents (^60% water as applied), and (2) Table 1 cleaning solvents (Checklist B,
Section 2).
A. Option 1: Table 1 or semi-aqueous cleaning solvents D
[See Checklist B, Section 2 or Table 1 in rule.
Semi-aqueous: ^60% water content as applied.] '
B. Option 2: Enclosed system or collection system D
5-16
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E - FLUSH CLEANING
3. RECORDKEEPING
For operations using an enclosed system for flush cleaning (does not apply to spray gun cleaning)
Citation
Compliance
§63.744(d)
Requirement
Empty the used cleaning solvent from
flush cleaning into enclosed container or
collection system and keep it closed
when not in use, or empty into system
with equivalent emission control.
Measurement,
Calculation, or
Observation
Yes
No
For all flush cleaning operations, unless otherwise noted
Recordkeeping
§63.752(b)(D
Recordkeeping
§63.752(b)(2)
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
For semi-aqueous cleaning solvents
(used under Option 1), record name,
documentation that each meets
composition requirements, and annual
volume usage or purchase records.
Table 1 solvents are not subject to this
recordkeeping requirement.
4. INSPECTOR COMMENTS:
END OF CHECKLIST E
5-17
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CHECKLIST F
PRIMER/TOPCOAT CHECKLIST
Aerospace Manufacturing and Rework NESHAP
1. GENERAL INFORMATION
A. Source Location (if applicable):
B. Installation Date (if applicable):
C. The following coating application operations are performed at the facility/plant:
D topcoating (containing organic/inorganic HAP)
n priming (containing organic/inorganic HAP)
n self-priming topcoating (containing organic/inorganic HAP)
n application of waterborne coatings
2. EXEMPT OPERATIONS
The following primer/topcoat (including self-priming) operations are exempt based on the
regulatory NESHAP provisions shown in the table. The cited regulatory NESHAP provision and
§63.742 Definitions should be consulted for more details and for any qualifications on the
exemptions.
The following exemptions apply to all primer and topcoat applications:
Citation
§63.741(i)
§63.745(a)
Exempt Operation
Waterborne primers/topcoats (limited
exemption, see rule for specific information)
Public display, nonoperational, and not
easily moved equipment
f
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
5-18
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F - PRIMER/TOPCOAT
Citation
Exempt Operation
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
The following are exempt from the application technique requirements for organic HAP requirements only.
All other requirements apply.
§63.745(f)(3)
Application
Equipment
§63.745(f)(3)
Application
Equipment
Use of airbrush or spray gun extension
Coating containing fillers that adversely
affect atomization with HVLP
Film thicknesses <0.0005 inch
Airbrushed stenciling, lettering, or marking
Hand-held spray cans
-Touchup and repair
The following are exempt from the inorganic HAP requirements only.
§63.745(g)(4)
Inorganic HAP
'*>
Touchup of scratches, paint damage
Hole daubing for fasteners
Touchup of trimmed surfaces
Coating prior to joining dissimilar metal
components
Stencil operations performed by brush or
airbrush
Section joining
Touchup of bushings
Sealant detackifying
Use of hand-held spray cans
Coating of parts that the permitting authority
has determined (and which is identified in a
Title V permit) is not technically feasible to
paint in a booth
.»
5-19
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F - PRIMER/TOPCOAT
3. COMPLIANCE OPTIONS - ORGANIC HAP EMISSIONS
There are five options for demonstrating compliance with the organic HAP emissions
requirements. Check off the compliance option/options selected by the owner/operator. Owners
and operators are required to meet the application techniques and housekeeping measures
identified below regardless of the compliance option(s) chosen:
A. All Options: Application techniques and Housekeeping (§63.745(b) and (f)) D
B. Option 1: Primers/topcoats meet organic HAP/VOC limits (§63.745(e)(l)) D
C Option 2: Primers meet "low HAP content" limit (§63.152(c)(3» D
D. Option 3: Weighted average content (§63.745(e)(2)) D
E. Option 4: Add-on controls (§63.745(d)) D
F. Option 5: Use ofwaterborne coatings (§63.741(i)) D
4. REQUIREMENTS - ORGANIC HAP EMISSIONS
Document compliance with the specific option or options chosen by the owner/operator by
checking "Yes" or "No" for each item in the table for that option. If application or requirement
is not applicable, write "N/A" across the "Yes" or "No" column.
A. All Options: Application techniques, Housekeeping, and Recordkeeping.
Citation
Compliance
§63.745(b)
Compliance
§63.745(0
Recordkeeping
§63.10(b)(l)
Requirement
Handle primers and topcoats in such a
manner that minimizes spills
Apply coatings using one or more of the
following methods:
flow/curtain coating
dip coat application
roll coating
brush coating
cotton-tipped swab application
electrodeposition (dip) coating
HVLP spraying
electrostatic spray
other approved methods that meet
HVLP or electrostatic spray
Necessary records to be maintained for
5 years (2 years onsite)
Measurement,
Calculation, or
Observation
Yes
No
5-20
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F - PRIMER/TOPCOAT
B. Option 1: Primers/topcoats meet organic HAP/VOC limits (uncontrolled coatings)
Citation
Compliance
§63.745(c)and(e)(l)
Recordkeeping
§63.752(c)(l)
Recordkeeping
§63.752(c)(2)
(without averaging)
Requirement
Each primer and topcoat in use meets
the following content limits for both
organic HAP and VOC:
Primers: 2.9 Ib/gal (350 g/liter)
Topcoats: 3.5 Ib/gal (420 g/liter)
Keep records of name and VOC and
HAP content of each primer and
topcoat as received and as applied.
Keep monthly records of mass of
organic HAP and VOC emitted per unit
volume of coating as applied for each
coating formulation, all documentation
for these emission values, and the
monthly volume usage for each primer
and topcoat formulation.
Measurement,
Calculation, or
Observation
Yes
No
C. Option 2: Primers meet "low HAP content" limit (uncontrolledprimers)
Citation
Recordkeeping
§ 63.752(c)(3)(i)
Recordkeeping
§ 63.752(c)(3)(ii)
Requirement
Keep annual volume purchase records
of each low HAP or VOC content
coating (<2.1 Ib/gallon).
Keep all data, calculations, and test
results, if applicable, used in
determining low organic HAP and
VOC content as applied, or
manufacturer's certification when
primer is applied as received.
Measurement,
Calculation, or
Observation
Yes
No
5-21
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F - PRIMER/TOPCOAT
D. Option 3: Weighted average content (uncontrolled coatings)
Citation
Compliance
§63.745(c) and (e)(2)
Reco rdkeeping
§63.752(c)(4)
Requirement
Any combination of primers or
topcoats such that the monthly volume-
weighted average organic HAP and
VOC contents of the combination meet
the following limits:
Primers: 2.9 Ib/gal (350 g/liter)
Topcoats: 3.5 Ib/gal (420 g/liter)
Keep records of monthly volume-
weighted average mass of organic HAP
and VOC per unit volume of coating as
applied for all primers and all topcoats,
and all documentation for these
calculations.
Measurement,
Calculation, or
Observation
Averaging scheme, if
applicable, approval
date
Yes
No
E. Option 4: Add-on control system (controlled coatings)
Citation
Compliance
§63.745(d)
Monitoring
§63.75 l(b)(3)(iii) and
(b)(4)
Monitoring
§63.75 l(b)(6)(iii)(A)
Monitoring
§63.75 l(b)(6)(ii)
Monitoring
§63.75 l(b)(6)(iii)(D)
Requirement
Use a control system that reduces
organic HAP and VOC emissions with
at least 81% overall efficiency
(= capture efficiency x removal
efficiency).
Conduct monitoring of capture and
operating parameters established by plan
and calculate site specific operating
parameter value(s) that demonstrate
compliance.
Install, calibrate, operate, and maintain a
continuous emission monitor to measure
total HAP or VOC concentration
exhausted from control device (portable
monitor allowed for nonregenerative
carbon adsorbers).
Perform a quarterly audit of the
continuous emission monitor.
For nonregenerative carbon adsorption
systems, replace the carbon at a regular
predetermined time interval.
Measurement,
Calculation, or
Observation
^
Yes
No
5-22
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F - PRIMER/TOPCOAT
Citation
Monitoring
§63.75 l(b)(8)
Monitoring
§63.75 l(b)(9)
Monitoring
§63.75 l(b)( 10)
Recordkeeping
§63.752(c)(6)
Recordkeeping
§63.752(c)(5)
Requirement
For incinerators, install, calibrate,
maintain, and operate temperature
monitoring equipment according to
manufacturer's specifications. Every
3 months, replace or recalibrate
temperature sensors (or use a CEMS to
verify destruction efficiency).
For noncatalytic incinerators, install
thermocouples with continuous
recorders immediately downstream of
the firebox.
For catalytic incinerators, install
thermocouples with continuous
recorders immediately before and after
the catalyst bed.
Records for carbon adsorbers, as
appropriate for the type of system:
1. Overall control efficiency, with all
data and calculations used to calculate
efficiency;
For mass balance calculation:
2. Length of rolling material balance
period, with all data and calculations;
3. Certification of accuracy for the
device that measures recovered HAP or
VOC; and
For nonregenerative carbon adsorbers:
4. Record of carbon replacement time,
as required.
Records for other control devices, as
appropriate:
1 . Overall control efficiency;
2. Continuous records of firebox
temperature and calculated 3-hour
averages;
3. Continuous records of temperature
before and after the catalyst bed.
Measurement,
Calculation, or
Observation
V
X"
4**
Yes
No
5-23
-------
F - PRIMER/TOPCOAT
F. Option 5: Use waterborne coatings
Citation
Compliance
§63.741(i)
Recordkeeping
§63.741(i)
Requirement
Coating contains more than 5% water by
weight as applied in its volatile fraction
and meets applicable HAP and VOC
limits. Exemptions from several rule
requirements are specified in the rule.
Keep manufacturer's supplied data and
annual purchase records for each exempt
waterborne coating for 5 years.
Measurement,
Calculation, or
Observation
Yes
No
5-24
-------
F - PRIMER/TOPCOAT
5. COMPLIANCE OPTIONS - INORGANIC HAP EMISSIONS
There are several options for meeting the inorganic HAP emissions requirements based on
whether the source is new or existing. Check off the compliance option(s) selected by the
owner/operator. If the requirement is not applicable, write "N/A" across the "Yes" or "No"
portion of the applicable column.
Citation
All Options
§63.745(g)(l)
Option 1
§63.745(g)(2)(i)
Option 2
§63.745(g)(2)(ii)
'Option 3
§63.745(g)(2)(iii)(A)
§63.745(g)(2)(iii)(B)
Requirement
Apply coatings in a booth or hangar in
which air flow is directed downward
onto or across the part or assembly
being coated.
For existing sources, use a waterwash
system, a dry paniculate filter meeting
the efficiencies in Tables 1 and 2 of
§63.745, or equivalent approved system.
For new sources, use a dry paniculate
filter meeting the efficiencies in
Tables 3 and 4 of §63.745, or equivalent
approved system.
For new sources constructed between
6/6/94 and JO/29/96, use a 2-stage dry
filter, or a waterwash system.
For new sources constructed between
6/6/94 and 10/29/96 that apply primers
or topcoats containing chromium or
cadmium, use a HEPA filter, 3-stage
filter, or approved equivalent to a
3-stage control system.
Measurement,
Calculation, or
Observation
T
X-
V
Does Facility
Perform
Indicated
Operation?
Yes
No
5-25
-------
F - PRIMER/TOPCOAT
6. REQUIREMENTS - INORGANIC HAP EMISSIONS
These requirements apply to the spray application of primers or topcoats that contain
inorganic HAP. If the requirement is not applicable, write "N/A" across the "Yes" or "No"
portion of the applicable column.
Citation
Requirement
Measurement,
Calculation, or
Observation
Yes
No
Is facility using a dry particulate filter system to control the coating operation? If Yes:
Compliance
§63.745(g)(2)(iv)(A)
Compliance
§63.745(g)(2)(iv)(B)
Compliance
§63.745(g)(2)(iv)(C)
Compliance
§63.745(g)(2)(iv)(D)
Compliance
§63.745(g)(3)
Recordkeeping
§63.752(d)(l)
Recordkeeping
§63.752(d)(3)
Maintain dry particulate filter in good
working order.
Install a differential pressure gauge
across the filter banks.
Continuously monitor pressure drop
across filter, read and record pressure
drop once per shift in which coating
occurs.
Take corrective action when pressure
drop goes outside manufacturer's
recommended limit(s).
Shut down coating operation and take
corrective action if pressure drop goes
outside specified limit(s).
Shut down coating operation if specified
maintenance procedures have not been
performed as scheduled.
Record pressure drop across operating
filter system once per shift in which
coating occurs.
Log shall include acceptable limit(s) for
pressure drop.
,*
Is facility using a waterwash system to control the coating operation? If Yes:
Compliance
§63.745(g)(2)(v)
Compliance
§63.745(g)(3)
Continuously monitor the water flow
rate, and read and record the water flow
rate once per shift in which coating
occurs.
Shut down coating operation and take
corrective action:
1 . If water path fails visual
continuity/flow characteristics check or
water flow rate goes outside specified
limit(s), or
2. If specified maintenance procedures
have not been performed as scheduled.
5-26
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F - PRIMER/TOPCOAT
Citation
Recordkeeping
§63.752(d)(2)
Recordkeeping
§63.752(d)(3)
Requirement
Record water flow rate through system
once each shift in which coating occurs.
Log shall include acceptable limit(s) for
water flow rate.
Measurement,
Calculation, or
Observation
Yes
No
7. INSPECTOR COMMENTS:
END OF CHECKLIST F
5-27
-------
CHECKLIST G
DEPAINTING OPERATIONS
Aerospace Manufacturing and Rework NESHAP
NOTE: The rule covers depainting operations on the outer surface areas of completed aerospace
vehicles (including the fuselage, wings, and vertical and horizontal stabilizers of the aircraft) and
the outer casing and stabilizers of missiles and rockets. The rule also applies only to facilities
that depaint more than six completed aerospace vehicles per calendar year.
1. GENERAL INFORMATION
A. Source Location (if applicable):
B. Installation Date (if applicable):
2. EXEMPT OPERATIONS
Depainting performed in the situations or on the parts shown in the table is exempted from the
control requirements in §63.746. The cited regulatory NESHAP provisions and §63.742
Definitions should be consulted for more details and for any qualifications on the exemptions.
Citation
§63.746(a)(l)
§63.746(a)(2)
§63.746(a)(3)(i)
§63.746(a)(3)(ii)
§63.746(b)(5)
Exempt Operation
Parts normally removed from vehicle for
depainting (except wings and stabilizers)
Public display, nonoperational, and not
easily moved equipment
Depainting of radomes
Parts, subassemblies, and assemblies
normally removed from primary aircraft
structure before depainting
Mechanical and hand sanding operations
are exempt from the requirements to
perform work in an enclosed area and
use a control system. All other
requirements apply.
Measurement,
Calculation, or
Observation
./-
Does Facility
Depaint Indicated
Parts?
Yes
No
5-28
-------
G - DEPAINTING
3. REQUIREMENTS
(Check off the compliance option or options selected by the owner/operator and check "Yes" or
"No" for each item in the table for that option. If the requirement is not applicable, write "N/A"
across the "Yes" or "No" portion of the applicable column.
Citation
Option 1
§63.746(b)(l)
Option 2
§63.746(b)(2)
Option 3
§63.746(c)
Requirement
Non-HAP chemical strippers and
technologies
Nonchemical based equipment
Organic HAP chemical strippers
(emissions reduced by control system)
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
A. Option 1: (§63.746(b)(l)) Non-HAP chemical strippers and technologies
D
Check "Yes" or "No" for each item in the table when using non-HAP chemical strippers
and technologies.
Citation
Compliance
§63.746(b)(l)
Compliance
§63.746(b)(3)
Recordkeeping
§63.752(e)(l)(i)
Requirement
Each chemical stripping formulation or
agent, and each chemical paint softener,
used for depainting shall emit no
organic HAP during depainting
operations, except for spot stripping and
decal removal.
For spot stripping and decal removal,
use no more than:
1 . 26 gal organic HAP-containing
chemical strippers or 190 Ib organic
HAP per commercial aircraft depainted,
and
2. 50 gal HAP strippers or 365 Ib
organic HAP per military aircraft
depainted, on an annual average basis.
Keep records of name of each stripper
used.
Measurement,
Calculation, or
Observation
*
Yes
No
5-29
-------
G - DEPAINTING
Citation
Recordkeeping
§63.752(e)(l)(ii)
Recordkeeping
§63.752(e)(4)
Recordkeeping
§63.752(e)(6)
Requirement
Keep records of monthly volume of each
organic HAP containing stripper or
weight of organic HAP used for spot
stripping and decal removal.
For each aircraft type depainted, a
listing of the parts, subassemblies, and
assemblies normally removed before
depainting. Exempted aircraft types:
prototype, test model, and aircraft of
which <25 exist.
For spot stripping and decal removal:
1 . Volume of organic HAP stripper or
weight of organic HAP used;
2. Annual average volume of organic
HAP stripper or weightof organic HAP
used per aircraft;
3. Annual number of aircraft stripped;
and
4. All data and calculations used.
Measurement,
Calculation, or
Observation
Yes
No
B. Option 2: (§63.746(b)(2)) Nonchemical based equipment
Check "Yes" or "No" for each item in the table when using nonchemical based
equipment.
Citation
Compliance
§63.746(b)(2)
Requirement
Maintain nonchemical based depainting
equipment according to manufacturer's
specifications or locally prepared
procedures.
During malfunctions, use substitute
materials that minimize HAP emissions.
Substitute materials are not to be used
for more than 15 days annually, unless
non-HAP.
Measurement,
Calculation, or
Observation
Yes
No
5-30
-------
G - DEFAULTING
Citation
Requirement
Measurement,
Calculation, or
Observation
Yes
No
Does facility use dry media blasting equipment that generates airborne inorganic HAP emissions? If Yes:
Compliance
§63.746(b)(4)(i)
Compliance
§63.746(b)(4)(ii)(A)
Compliance
§63.746(b)(4)(ii)(B)
Perform depainting in an enclosed area
or use a closed-cycle depainting system.
For existing sources, use a watenvash
system, baghouse, or a dry particulate
filter. Dry particulate filters must meet
the efficiency data points in Tables 1
and 2 of §63.745.
For new sources, use a dry particulate
filter system meeting the efficiency data
points in Tables 3 and 4 of §63.745 or a
baghouse.
Is facility using a dry particulate filter system to control the media blasting operation? If Yes:
Compliance
§63.746(b)(4)(iii)(A)
Compliance
§63.746(b)(4)(iii)(B)
Compliance
J63.746(b)(4)(iii)(C)
Compliance
*§63.746(b)(4)(iii)(D)
Compliance
§63.746(b)(4)(v)
Maintain dry particulate filter in good
working order.
Install a differential pressure gauge
across the filter banks.
Continuously monitor pressure drop
across the filter.
Take corrective action when pressure
drop goes outside manufacturer's
recommendation.
Shut down depainting operation and take
corrective action if filter pressure drop
goes outside specified limits.
Shut down depainting operation and take
corrective action if specified
maintenance procedures have not been
performed as scheduled.
*
x-
Is facility using a water-wash system to control the media blasting operation? If Yes:
Compliance
§63.746(b)(4)(iv)
Compliance
§63.746(b)(4)(v)
Compliance
§63.746(b)(4)(v)
Continuously monitor the water flow
rate.
Shut down depainting operation and take
corrective action if water path fails
visual continuity/flow characteristics
check or the water flow rate goes outside
specified limits.
Shut down depainting operation and take
corrective action if specified
maintenance procedures have not been
performed as scheduled.
5-31
-------
G - DEPARTING
Citation
Requirement
Measurement,
Calculation, or
Observation
Yes
No
For a dry particulate filter or a waterwash system;
Monitoring
§63.75 l(d)
Recordkeeping
§63.752(e)(4)
Recordkeeping
§63.752(e)(5)(i)
Recordkeeping
§63.752(e)(5)(ii)
Recordkeeping
§63.752(e)(7)
Continuously monitor pressure drop
across dry filter or water flow rate
through waterwash system, and read and
record these parameters once per shift.
For each aircraft type depainted, a
listing of the parts, subassemblies, and
assemblies normally removed before
depainting. Exempted aircraft types:
prototype, test model, and aircraft of
which <25 exist.
Records of names and types of
nonchemical based equipment (dry
media blast, etc.)
For malfunction periods, the technique
that malfunctioned, date, description of
malfunction, methods used during the
period, dates these methods were begun
and stopped, and date the malfunction
was corrected.
Records of actual pressure drop across
dry filters, or visual continuity and water
flow rate for waterwash systems,
recorded once each shift that depainting
occurred. Log also must indicate
acceptable limit(s) for the recorded
parameters.
x'
C. Option 3: (§63.746(c)) Organic HAP chemical strippers
(Emissions reduced by use of control device)
Check "Yes" or "No" for each item in the table when using organic HAP chemical
strippers.
D
Citation
Compliance
§63.746(c)
Requirement
Use a control system that reduces
organic HAP and VOC emissions with
at least:
1 . 8 1 % overall efficiency (= capture
efficiency x. removal efficiency) or mass
balance calculations for existing
sources, or
2. 95% overall efficiency for new
sources or mass balance calculation.
Measurement,
Calculation, or
Observation
Yes
No
5-32
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G - DEPAINTING
Citation
Monitoring
§63.75 l(b)(3)(iii) and
(b)(iv)
Monitoring
§63.75 l(b)(6)(iii)(A)
Monitoring
§63.75 l(b)(6)(ii)
Monitoring
§63.75 l(b)(6)(iii)(D)
Monitoring
§63.751(b)(8)
Monitoring
,§63.75 l(b)(9)
Monitoring
§63.75 l(b)(10)
Recordkeeping
§63.752(e)(2)
Requirement
Conduct monitoring of capture and
operating parameters established by plan
and calculate site specific operating
parameter value(s) that demonstrate
compliance.
Install, calibrate, operate, and maintain a
continuous emission monitor to measure
total organic HAP or VOC
concentration exhausted from control
device (portable monitor allowed for
nonregenerative carbon adsorbers).
Perform a quarterly audit of the
continuous emission monitor.
For nonregenerative carbon adsorption
systems, replace the carbon at a regular
predetermined time interval.
For incinerators, install, calibrate,
maintain, and operate temperature
monitoring equipment according to
manufacturer's specifications. Every
3 months, replace or recalibrate
temperature sensors (or use a CEMS to
verify destruction efficiency).
For noncatalytic incinerators, install
thermocouples with continuous
recorders immediately downstream of
the firebox.
For catalytic incinerators, install
thermocouples with continuous
recorders immediately before and after
the catalyst bed.
Records for carbon adsorbers, as
appropriate for the type of system:
1 . Overall control efficiency, with all
data and calculations used to calculate
efficiency;
For mass balance calculation:
2. Length of rolling material balance
period, with all data and calculations;
and
3. Certification of accuracy for the
device that measures recovered HAP or
VOC.
For nonregenerative carbon adsorbers:
4. Record of carbon replacement time
Measurement,
Calculation, or
Observation
-
Yes
No
5-33
-------
G - DEPARTING
Citation
Recordkeeping
§63.752(e)(3)
Requirement
Records for other control devices, as
appropriate:
1 . Overall control efficiency and
supporting calculations.
Measurement,
Calculation, or
Observation
Yes
No
4. INSPECTOR COMMENTS:
END OF CHECKLIST G
5-34
-------
CHECKLIST H
CHEMICAL MILLING MASKANT OPERATIONS
Aerospace Manufacturing and Rework NESHAP
. NOTE: Chemical milling maskant is defined as a coating that is applied directly to aluminum
components to protect surface areas when chemical milling the component with a Type I or
Type n etchant. This does not include bonding maskants and critical use and line sealer
maskants, and seal coat maskants. Additionally, maskants that must be used with a combination
of Type I or n etchant and any of the above types of maskants are also exempt from the chemical
milling maskant requirements.
1. GENERAL INFORMATION
A. Source Location (if applicable):
B. Installation Date (if applicable):
2. EXEMPT OPERATIONS
The following maskants are exempt from the rule requirements. The cited regulatory NESHAP
provision and §63.742 Definitions should be consulted for more details and for any qualifications
on the exemptions.
Citation
§63.742
Chemical milling
maskant
§63.747(c)
Exempt Maskant
1 . Bonding maskants
2. Critical use and line sealer maskants
3. Seal coat maskants
4. Maskants used with a combination of
Type I or II etchant and any of the
maskant types in 1, 2, or 3 above.
Maskants used for touchup of scratched
surfaces, damaged maskant, or trimmed
edges
Measurement,
Calculation, or
(Observation
Does Facility Use
the Maskant?
Yes
No
5-35
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H - MASKANT
3. COMPLIANCE OPTIONS
Check off the compliance option selected by the owner/operator and check "Yes" or "No"
for each item in the table(s) for that option. If a requirement is not applicable, write "N/A"
across the "Yes" or "No" portion of the applicable column.
Citation
Option 1
§63.747(c)
Option 2
§63.747(d)
Option 3
§63.741(i)
Requirement
Chemical milling maskant meets organic
HAP/VOC limits
Add-on controls
Use of waterborne coatings
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
A. Option 1: (§63.747(c)) Organic HAP and VOC content limits
I. (§63.747(e)(l)) Each maskant meets limit
D
D
Citation
Compliance
§63.747(b)
Compliance
§63.747(c) and
(e)(l)
Recordkeeping
§63.752(0(1)
Requirement
Handle and transfer maskant between
containers in a manner that minimizes
spills.
Each maskant in use meets the following
content limits for both HAP and VOC:a
1. 5.2 Ib/gal (622 g/liter) - Type I
2. 1.3 Ib/gal (160 g/liter) - Type II
Keep monthly records of mass of organic
HAP and VOC emitted per unit volume
of maskant as applied, all documentation
for these emission values, and the
monthly volume usage for each maskant
formulation.
Measurement,
Calculation, or
Observation
Yes
No
Different content limits apply to maskants used with Type I or Type n etchants, as shown.
OR
5-36
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H. (§63.747(e)(2)) Weighted average content
H - MASKANT
D
Citation
Compliance
§63.747(b)
Compliance
§63.743(d) and
§63.747(c) and
(e)(2)
Recordkeeping
§63.752(0(2)
Requirement
Handle and transfer maskant between
containers in a manner that minimizes
spills.
The monthly volume-weighted average
organic HAP and VOC contents meet
the following limits:
1. 5.2 Ib/gal (622 g/liter) - Type I
2. 1.3 Ib/gal (160 g/liter) - Type II
Keep records of monthly volume-
weighted average mass of organic HAP
and VOC for all maskants, and all
documentation for these calculations.
Measurement,
Calculation, or
Observation
Yes
No
B. Option 2: (§63.747(d)) Add-on control system
D
Citation
Compliance
§63.747(b)
Compliance
§63.747(d)
Monitoring
§63.75 l(b)(3)(iii),
(b)(iv)
Monitoring
§63.75 l(b)(6)(iii)(A)
Monitoring
§63.75 l(b)(6)(ii)
Requirement
Handle and transfer maskant between
containers in a manner that minimizes
spills.
Use a control system that reduces
organic HAP and VOC emissions with
at least 81% overall efficiency
(= capture efficiency x removal
efficiency or mass balance calculation).
See required Records below for
verification of efficiency.
Conduct monitoring of capture and
operating parameters established by plan
and calculate site specific operating
parameter value(s) that demonstrate
compliance.
Install, calibrate, operate, and maintain a
continuous emission monitor to measure
total HAP or VOC concentration
exhausted from control device (portable
monitor allowed for nonregenerative
carbon adsorbers).
Perform a quarterly audit of the
continuous emission monitor.
Measurement,
Calculation, or
Observation
s*
Yes
No
5-37
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H - MASKANT
Citation
Monitoring
§63.75 l(b)(6)(iii)(D)
Monitoring
§63.75 l(b)(8)
Monitoring
§63.75 l(b)(9)
Monitoring
§63.75 l(b)( 10)
Recordkeeping
§63.752(f)(3) and (4)
Requirement
For nonregenerative carbon adsorption
systems, replace the carbon at a regular
predetermined time interval.
For incinerators, install, calibrate,
maintain, and operate temperature
monitoring equipment according to
manufacturer's specifications. Every
3 months, replace or recalibrate
temperature sensors (or use a CEMS to
verify destruction efficiency).
For noncatalytic incinerators, install
thermocouples with continuous
recorders immediately downstream of
the firebox.
For catalytic incinerators, install
thermocouples with continuous
recorders immediately before and after
the catalyst bed.
Records for carbon adsorbers, as
appropriate for the type of system:
1 . Overall control efficiency, with all
data and calculations used to calculate
efficiency;
For mass balance calculation:
2. Length of rolling material balance
period, with all data and calculations;
3. Certification of accuracy for the
device that measures recovered HAP or
VOC; and
For nonregenerative carbon adsorbers:
4. Record of carbon replacement time.
Records for other control devices, as
appropriate:
1 . Overall control efficiency and
supporting calculations;
For noncatalytic incinerators:
2. Continuous records of firebox
temperature and calculated 3-hour
averages;
For catalytic incinerators:
3. Continuous records of temperature
before and after the catalyst bed and all
calculated 3-hour averages of such
temperatures.
Measurement,
Calculation, or
Observation
x-
Yes
No
5-38
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C. Option 3: (§63.741(1)) Use waterborne maskants
H - MASKANT
D
Citation
Compliance
§63.741(i)
Compliance
§63.747(b)
Recordkeeping
§63.741(i)
Requirement
Maskant contains more than 5% water
by weight as applied in its volatile
fraction and meet applicable HAP and
VOC limits. Exemptions from several
rule requirements are specified.
Handle and transfer maskants between
containers in a manner that minimizes
spills.
Keep manufacturer's supplied data and
annual purchase records for each
exempt waterborne maskant for
5 years.
Measurement,
Calculation, or
Observation
Yes
No
4. INSPECTOR COMMENTS:
END OF CHECKLIST H
5-39
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6.0 QUESTIONS AND ANSWERS
Below is a compilation of questions that an inspector may be asked about implementation
of the standard. An answer approved by the U. S. Environmental Protection Agency follows
each question. Most of the questions listed came from two sources: (1) general inquiries, and
(2) the Applicability Determination Index (ADI) found on the TTN. Section 7.0 describes the
ADI. Additional public comments and questions on the NESHAP, as well as EPA responses, are
presented in the EPA document, EPA/R-97-003b, "National Emission Standard for Hazardous
Air Pollutants (NESHAP) for the Aerospace Industry - Background Information for Promulgated
Standards," July 1995. While these questions and answers constitute the best available guidance
at this time, the EPA recommends that the EPA Regional office and/or the State or local
authority be consulted for any final determinations. State and local air pollution authorities are
allowed to implement provisions that are more stringent than those contained in the NESHAP.
Topic Question Numbers Page Topic Starts
Applicability
Compliance
Cleaning Provisions
Primer/Topcoat Provisions
Depainting Provisions
Chemical Milling Maskant
Test Methods and Monitoring
Applicability Determinations from ADI
1-7
^
8-10
11-27
28-37
38-43
44-45
46-48
49-51
6-2
6-3
6-3
6-6
6-8
6-9
6-10
6-11
6-1
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Applicability
1.
2. .
3.
4.
5.
6.
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
If the emissions from my aerospace activities alone do not constitute a major source, but the
total emissions from my facility cause me to be a major source, does the Aerospace
NESHAP apply?
If the facility as a whole qualifies as a major source, then the Aerospace NESHAP requirements
apply to the aerospace related activities as defined in §63.741.
Consider an aerospace facility at which the major emitting activity is hand-wipe cleaning.
How would potential to emit (PTE) for this activity be determined in making an
applicability determination? In this case, past higher cleaner usage (and higher production
rates) are not likely to be repeated in the future.
This PTE determination involves making a reasonable worst-case judgment as to how much wipe
cleaning could occur per unit of production, and in addition a worst-case judgment as to the
physical capacity to produce. If there is a large amount of uncertainty in making these estimates,
it may be prudent for the facility owner to obtain enforceable limits on the amount of hand-wipe
cleaning solvent that may be used. When it is unclear whether a source will be in the major
category due to PTE, the facility should always contact the authorized State or local agency for an
applicability determination.
How does a facility designate which activities/processes are exempt?
The facility should determine" which activities/processes it believes are exempt, and it is
recommended that the facility be prepared to document how they reached those conclusions. This
might include records of materials used or other documentation such as why the coating qualifies
as a specialty coating, etc. Records of materials used for some exempt activities are required to be
kept, and are subject to review by the inspector.
Since R&D labs are not covered (§63.741(0), how does an inspector determine which
activities are R&D?
Section 63.742 of the NESHAP defines Research and Development as "an operation whose
primary purpose is for research and development of new processes and products, that is conducted
under the close supervision of technically trained personnel, and is not involved in the
manufacture of final or intermediate products for commercial purposes, except in a de minimis
manner." The facility should be able to document that the activities conducted fit the above
definition. Section 1 12(c)(7) of the Clean Air Act requires the EPA to "establish a separate
category covering research or laboratory facilities, as necessary to assure the equitable treatment
of such facilities." The EPA is now initiating the process of defining that category.
How is the operational area defined?
The term is not defined. Best judgment would indicate that sources have the flexibility to define
their operational areas in a way that makes sense with regard to recordkeeping and the most
efficient way of tracking volume usages of cleaner, paint, etc.
Under §63.741(g), the rule provides for a 50/200 gallon exemption for low volume use
coatings. Does the 200-gallon cumulative limit apply to all low volume topcoats, primers,
and maskants? Or does the 200-gallon limit apply to each coating category (i.e., 200 gal for
topcoats, 200 gal for primers, and 200 gal for maskants)? If a facility uses more than the
200-gallon limit for nonexempt low volume coatings as allowed under §63.741(g), can they
still exempt 200 gallons? For example, if a facility uses 400 gallons (8 formulations, 50
gallons each), can four of the formulations be exempt?
Under §63.741(g), the low volume coating limit applies to all topcoats, primers, and maskants for
which the annual total of each separate formulation used at the facility does not exceed 50 gallons
and the combined annual total of all such primers, topcoats, and maskants used does not exceed
200 gallons. The 200-gallon low volume exemption is a cumulative total. The exemption under
§63.741(g) would not be allowed if the low volume usage limits were exceeded. The facility must
comply with applicable sections of the rule.
6-2
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7.
Q:
A:
Section 63.741(f) states that the requirements of this rule do not apply to parts/assemblies
not critical to the vehicle's structural integrity or flight performance. In light of this, are
armament (weapons) systems on the aircraft exempt?
This question was raised previously in the July 1995 background information document for the
Aerospace NESHAP. The EPA considers weapons systems that attach to, or install in, any
aerospace vehicle designed to operate within the earth's atmosphere to be aerospace components
and thus subject to the requirements of the final rule. Of course, the low coating usage, specialty
coating, and other exemptions provided in the rule will apply to these systems in the same way
they apply to aerospace vehicles and components generally.
Compliance
8.
9.
10.
Q:
A:
Q:
A:
Q:
A:
What is the required submittal date for the initial notification of compliance status for
facilities that are not subject to any initial compliance testing requirements (i.e., those
without add-on control systems)?
Semiannual compliance reports are due every 6 months after the date of compliance (September 1,
1998) for existing sources, and every 6 months after the date of initial startup for new sources.
Annual compliance reports need to be submitted every 12 months after the date of compliance for
existing sources, and every 12 months after the date of initial startup for new sources. Existing
sources must submit the Notification of Compliance Status (NOCS) by May 1, 1999 or 60 days
after the performance test (if one is performed), whichever is earlier. New sources are given 240
days after initial startup or 60 days after the performance test in which to submit the NOCS.
Are any of the compliance deadlines for items addressed in the supplemental rule
amendments expected to be different from the current deadlines?
Compliance with all requirements will be required by September 1, 1998.
Throughout the Aerospace rule, several options for compliance are given. Can the source
use more than one compliance option at a single facility?
More than one compliance option may be used by a single facility. However, any alternative
compliance procedures must be approved and the facility should identify which compliance option
or options are to be used to comply with the rule in the Title V operating permit.
Cleaning Provisions
11.
12.
13.
Q:
A:
Q:
A:
Q:
A:
What does "still in use" mean for wipe cleaning?
The term "still in use" is not found in the rule. This question may^refer to the housekeeping
measures (§63.744(a) in the promulgated rule) which required placing solvent-laden cloth, paper,
or any other absorbent applicators used for cleaning in bags or other closed containers
immediately after use. The term "immediately" was considered vague and has been removed in
the amended version of the rule which now reads "upon completing their use." The term is
subject to best professional judgement as to when the use of the applicator is completed.
What is the definition of "closed container" in the cleaning provisions?
The rule does not provide a definition for "closed container," but does say (§63.744(a)(l)) that
bags and containers should be kept closed at all times except when depositing or removing
materials from the container. Also, bags or containers should be designed so as to contain the
vapors of the cleaning solvent. This is not interpreted to mean that the container should be tested
to be emission-free. Common sense would indicate that a close-fitting lid or closure device
should be on the container, and that the container should be kept shut when not in use.
Do the hand-wipe cleaning requirements apply to all activities (e.g., desk, window, toilet
cleaning) or just to aerospace activities?
The rule has been clarified to indicate that the applicability of the final rule is limited only to the
manufacture or rework of aerospace vehicles or components. Other nonaerospace activities at
affected facilities are not subject to the rule.
6-3
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14.
15.
16.
17.
18.
19.
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
How will cleaning solvent vapor pressure be determined? What evidence will the source
owner have to supply to the inspector?
Under §63.750(b), Test Methods and Procedures, Vapor Pressure Determination, the text
indicates the necessary procedures for calculating the solvent vapor pressure. The source owner
should have a record of what information was used to calculate the vapor pressure, be it material
safety data sheets, engineering reference texts, or other methods. Recordkeeping (§63.7S2(b)(3))
requires data and calculations to be kept.
In §63.741(c), it states that "all hand-wipe cleaning operations" constitute an affected
source. Therefore, if an Air Force base has 10 different operations that perform hand-wipe
cleaning of aerospace parts, do all 10 operations combined constitute one affected source?
If they do, then would the future addition of another hand-wipe cleaning operation on base
simply be a modification to an existing affected source (i.e., does it mean the additional
operation would not be considered a new source)?
If the facility has conducted wipe-cleaning operations prior to September 1,
1995, any additional wipe-cleaning operations would be considered an existing source. Under
§63.753(b)(l)(ii), the facility would be required to report any new cleaning solvent used but
would not have to specifically identify the added source separately.
Section 63.744(b) of the rule states that if hand-wipe cleaning solvents do not meet certain
composition requirements, then the volume used must be reduced by at least 60 percent
from a baseline adjusted for production. We have two questions pertaining to this:
1) Has the EPA established a specific year (or years) for the baseline?
2) Exactly how do you adjust for production (can you give an example)?
The EPA realized that as written §63.744(b) would be difficult to implement. Therefore, the EPA
is proposing new language as follows: "The baseline shall be calculated using data from 1996 and
1997, or as otherwise agreed upon by the Administrator or delegated State Authority. The
baseline shall be approved by the Administrator or delegated State Authority and shall be included
as part of the facility's title V or part 70 permit."
The EPA will be soliciting comments on the proposed changes. Each facility will need to
demonstrate the 60 percent reduction adjusted for productjpn. This will need to be approved by
the permitting authority. In adjusting for production, the Administrator may want to look at the
production rates for 1996 and 1997 and determine if these were high, low, or standard production
years. It might be that at some facilities the production for these years did not accurately reflect
future or typical production rates. For example, at least one facility indicated that their workers
had been on strike in 1996 and, therefore, production was nonexistent for that year.
What latitude will the inspector have in determining the adequacy of monitoring and
recordkeeping for hand-wipe cleaning?
Recordkeeping requirements for cleaning operations are detailed in §63.752(b). There are no
monitoring requirements for hand-wipe cleaning. The rule does not detail the responsibilities of
inspectors; they will need to use their best professional judgment in determining if a facility has
kept adequate records of the cleaners in use. Records are adequate if they contain all of the
information required in the relevant portion(s) of the rule.
What compliance options are there involving flush cleaning for spray guns?
The NESHAP provides four options for cleaning spray guns (§63.744(c)): enclosed system,
nonatomized cleaning, disassembled gun cleaning, and atomized cleaning. Equivalent methods
are also acceptable upon approval by the Administrator. A separate provision (§63.744(d))
addresses flush cleaning of aerospace parts or assemblies, as well as components of a coating unit
(except for spray guns). Options for cleaning spray guns are discussed in §63.744(c).
The exemptions in §63.744(e) pertain to hand-wipe cleaning only. Do the flush cleaning
requirements apply to the operations exempted from wipe cleaning? In other words, is the
flush cleaning of oxygen breathing systems, hydraulic systems, fuel and engine systems, etc.
subject to this rule if nonexempt solvents are used?
Yes. Flush cleaning operations would be subject to §63.744(d).
6-4
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20.
21.
22.
23.
24.
25.
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
When does a rag used for wipe cleaning become a RCRA waste?
The answer to this question is not as straightforward as it may appear. First, it needs to be
determined whether the wiper and solvent is a hazardous waste, which will depend on several
things: (1) whether the solvent was applied first to the item to be cleaned or to the wiper first;
(2) the type of solvent; (3) whether the wiper also exhibits the characteristics of a hazardous
waste; and (4) when and if the wiper is to be laundered or simply discarded. Several articles on
this topic appear on the EPA Homepage in the RCRA Permit Policy Compendium. You may also
want to consult 40 CFR Sections 26 1 .2 and 26 1 .3 for more information on when something
becomes a solid or hazardous waste. In addition, you may want to discuss this with your State
RCRA contact.
What are acceptable solvent disposal procedures?
It would be best to contact your State and local agencies for the best disposal methods. Solvents
are often recyclable and there are companies which offer this service. Disposal is not addressed
under the Aerospace NESHAP. If the solvent is a hazardous waste then it should be handled and
disposed of as such. Disposal requirements may also be dependent on other Federal, State, or
local requirements.
Table 1 of section 63.744, gives the composition requirements for approved cleaning
solvents. The definition for "hydrocarbon-based" approved cleaning solvents is as follows:
"Cleaners that are composed of a mixture of photochemically*reactive hydrocarbons and
oxygenated hydrocarbons and have a maximum vapor pressure of 7mm Hg at 20 °C (3.75 in.
fi^O at 68 °F). These cleaners also contain no HAP or depleting compounds." We've come
across some cleaners in the Air Force which meet this "hydrocarbon-based" definition with
the exception that they do not contain any oxygenated hydrocarbons. Would these cleaners
still be considered "approved cleaning solvents".
No, they would not be considered "approved cleaning solvents" since the rule specifically requires
that all four criteria be met (i.e., photochemically reactive hydrocarbons and oxygenated
hydrocarbons and maximum vapor pressure and contain no HAP). Depending on the type of
cleaning operation performed, the source would be required to comply with another option in the
rule (i.e., hand wipe cleaning: use a solvent with a composite vapor pressure of 45 mm Hg or less
or show a reduction of at least 60% in the volume of solvent used).
If water (or another non-HAP, non-VOC material) is used for spray gun cleaning, is it
regulated by the Aerospace NESHAP?
No, §63.741(f) specifically states that the requirements of the Aerospace NESHAP do not apply to
cleaning solvents containing HAP and VOC at concentrations <©.!% for carcinogens or <1% for
noncarcinogens.
The installation uses a number of different solvent for hand wipe cleaning, some of which
have high vapor pressures. We would like to generate a composite VOC for shop based on
all the solvents used. For example: shop A uses MEK (VP = 83 mm Hg & s.g. = 0.81 ) and
denatured alcohol (VP = 25 nun Hg & s.g. = 0.793) at a rate of 3 gal/yr (203 Ib/yr) and
60 gal/yr (397 Ib/yr) generating a composite vapor pressure of 27.8 mm Hg. This would be
less than the composite vapor pressure in section 63.743(b)(2). Is this allowed under the
rule?
There are no provisions in the final rule that allow averaging between hand wipe cleaning
solvents. Therefore, your facility would be in violation of the rule unless each hand wipe cleaning
solvent met the one of the options in §63.744.
In section 63.744(b)(3), it specifies a 60% reduction in hand wipe solvents. Is reduction just
of solvents over the 45 nun Hg (24.1 in H2O) limit, or does include those solvents that meet
63.743(b)(2) and/or 63.743(b)(l)?
The 60% reduction should include all solvents.
6-5
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26.
27.
Q:
A:
Q:
A:
Under hand-wipe cleaning operations, if we have a multiple component product, do we need
to use the vapor pressure calculations in 63.750? Why can't we use the MSDS info?
If the manufacturer of the multiple component product does not provide a vapor pressure for the
product, you must use the vapor pressure calculations. The composite vapor pressure determina-
tion for a blended hand-wipe solvent has to be determined using manufacturer supplied data (or a
gas chromatographic analysis) and then using the equation in §63.750(b)(2). Many of the MSDSs
that EPA is familiar with do not provide the needed specificity for each of the organic compounds
in the blended solvent. That is why specific manufacturer's data (e.g., product data sheets) are
required to quantify each compound in the blended solvent.
If we have a gun cleaner that has a lid, but, we lift the lid to perform atomized cleaning (and
then close the lid), is this in compliance? What is an enclosed system?
No. In accordance with 63.744(c)(4), you must "direct the resulting atomized spray into a waste
container that is fitted with a device designed to capture the atomized cleaning solvent."
Primer/Topcoat Provisions
28.
29.
30.
Q:
A:
Q:
A:
Q:
A:
What is a primer? What is a topcoat? Which coatings are actually regulated and how
should they be defined in a Title V permit?
Coating: a material that is applied to the surface of an aerospace vehicle or component to form a
decorative or functional solid film, or the solid film itself. Primer: the first layer and any
subsequent layers of identically formulated coating applied to the surface of an aerospace vehicle
or component. Primers are typically used for corrosion prevention, protection from the
environment, functional fluid resistance, and/or adhesion of subsequent coatings.
Topcoat: a coating that is applied over a primer (or may be a self-priming topcoat) on an
aerospace vehicle or component for appearance, identification, camouflage, or protection.
Under the Aerospace NESHAP, the HAP and VOC emissions from the application of primers and
topcoats are regulated for major facilities. Specialty coatings (as defined in Appendix A of the
NESHAP) are exempt from the NESHAP; however, the aerospace control techniques guideline
document (CTG) includes guidance for regulating specialty coatings which may be adopted by the
States.
The definitions used in the rule have been agreed upon during industry/EPA Round Table
discussions, and may be used in a Title V permit.
How will the VOC content of coatings be determined by inspectors? What evidence is
adequate from the source owner's perspective?
Recordkeeping requirements are specified in §63.752 (c) and (d) for primer and topcoat
application operations, and in §63.752(f) for maskant operations.
Which primer/topcoat activities are exempted from high transfer efficiency requirements
(i.e., when are HVLP spray guns not required)?
Acceptable application equipment is listed in §63.745(0(1), which includes high volume low
pressure (HVLP) spray equipment. Exempted activities are listed under (f)(3) as follows:
(a) Situations that require the use of an airbrush or an extension on the spray gun to reach a
limited access space;
(b) The application of coatings that contain fillers that adversely affect atomization with HVLP
spray guns and that cannot be applied by any of the application methods specified in (0(1);
(c) The application of coatings that normally have a dried film thickness of less than 0.0005 in.
(0.0013 cm) and that the permitting agency has determined cannot be applied by any of the
application methods specified in §63.745(0(1);
(d) The use of airbrush application methods for stenciling, lettering, and other identification
markings;
(e) The use of hand-held spray can application methods; and
(0 Touchup and repair operations.
6-6
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31.
Section 63.745(e)(2) states that a monthly volume-weighted average can be used for primers
and topcoats to demonstrate compliance with the applicable organic HAP and VOC content
limits (note: we realize that primers and topcoats may not be added together). We have the
following two questions pertaining to this:
1) Can the averaging be conducted within each individual operation or does the averaging
have to be done for all operations combined? Note: most Air Force bases have several
individual shops that perform coating operations. These shops are usually independent
of one another and located in different parts of the base. Therefore, performing the
averaging base-wide (i.e., for all operations combined) would be extremely difficult.
2) If averaging is conducted and results show that the VOC and/or the organic HAP
content is above the applicable limit, do ail the coatings have to be controlled or just
those that are above the limits?
Section 63.745(e)(2) specifies that the "combination of primers and topcoats comply with the
specified content limits..." The term "combination" is referring to the averaged primers or
topcoats, and not the facility. The facility has the option to average any primer and topcoat, at any
location(s) where aerospace priming and coating operations occur, as long as you do not average
primers and topcoats together .
Only those applications above the limits would require controls, since the remaining primers and
topcoats are already in compliance with the rule.
32.
Q:
A:
How will compliance be determined for spray booth filters? Will records of specific filter
manufacturers be adequate?
Compliance requirements for inorganic HAP emissions are detailed in §63.750(o). Dry
paniculate filters used to comply with §63.745(g)(2) or §63.746(b)(4) must be certified by the
filter manufacturer or distributor, paint/depainting booth supplier, and/or the facility owner or
operator using Method 319 in appendix A of subpart A of the NESHAP, to meet or exceed the
efficiency data points found in Tables 1 and 2, or 3 and 4, of §63.745 for existing and new
sources, respectively. Although you are not required to do so, you will probably want to keep a
copy of the certification record.
33.
If you are using coatings containing inorganic HAP, do you have to use the certified filters?
Section 63.745(g) provides several options for controlling emissions of inorganic HAP. The
available options vary based on whether a source is considered to be existing or new. If filters are
used to comply, they must be certified to meet the applicable requirements in § 63.745.
34.
Q:
A:
What is acceptable monitoring for pressure drop in paint spray booths, especially in large
booths with multiple filter banks?
Monitoring requirements in §63.751 for dry paniculate filter or waterwash systems indicate that
the owner or operator must continuously monitor the pressure drop across the system, and read
and record the pressure drop once per shift following the recordkeeping requirements of
§63.752(d). Depending on the size of the system, multiple points may need to be monitored.
Recordkeeping would be required for each of those points.
35.
Under what circumstances is a painting operation considered "new"?
A painting operation is considered new if the source is a major source and constructs a primer or
topcoat operation where there was not previously one after September 1, 1995, or if an owner or
operator reconstructs such that the cost of the replaced components exceeds 50 percent of the
fixed capital cost that would be required to construct a comparable new source.
Adding a new organic HAP spray line does not constitute a new painting operation because the
affected operation is the total of all the topcoat or primer applications at the facility. However, an
added spray booth or hangar at a facility with existing primer or topcoat operations that will be
used for applying primer or topcoat containing inorganic HAP would be considered a new source
for purposes of compliance with inorganic HAP requirements only.
6-7
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36.
37.
Q:
A:
Q:
A:
Section 63.745(g) lists nine exemptions to the inorganic HAP emissions requirements for
primers and topcoats. Three of these nine exemptions involve touchup of certain parts. It is
our understanding that all touchup operations are exempt from the Aerospace NESHAP
because touchup is considered a specialty coating. For this reason, what is the purpose of
listing these three types of touchup as exemptions to the inorganic HAP requirements?
Section 63.742 defines specialty coating as coating type and not coating quantities. Touchup is
defined as "... a portion of a coating operation that is the incidental application of coating used
to cover minor imperfections in the coating finish..." Touchup applications meeting this
definition are exempt from only §63.745(0(1), application techniques. All other requirements,
such as HAP/VOC content, are applicable to touchup painting operations. Touchup operations
which are spray applied and specifically identified in §63.745(g)(4) are exempt from the
inorganic control requirements (dry paniculate filter/waterwash system). However, using a
specialty coating, as identified in Appendix A, in any quantity (touchup or other), would be
exempt from §63.745.
Under §63.752(c), it lists several recordkeeping requirements applicable to topcoats and
primers as-applied. However, paragraph (c)(l) requires name and VOC content for both
as-received and as-applied coatings. Why is as-received required under paragraph (c)(l)
and not other items under §63.752(c)7 Also, does paragraph (c)(l) apply if control devices
are used?
Section 63.752(c) indicates that records should be maintained as appropriate.
Section 63.752(c)(l) would be appropriate information for any operation that used primers and
topcoats and therefore would be information that everyone would have to maintain. Since
everyone should maintain records for each primer and topcoat on the VOC content as-received,
this is only included once. The EPA is aware that thinner is added to many primers and topcoats
for a variety of reasons. To ensure that thinner are adequately accounted for, the "as-received"
and "as-applied" requirements were added to the rule. If your facility uses §63.745(c) to meet
compliance, you will be responsible for documenting all information found in §63.752(c)(l)
through (c)(6).
Depainting Provisions
38.
39.
40.
41.
Q:
A:
Q:
A:
Q:
A:
Q:
A:
How is the applicability of the depainting part of the regulation determined (i.e., is rolling
12 months or calendar year used, what is exempted in counting, etc.)?
Section 63.746 indicates that an aerospace manufacturing facility that depaints six or fewer
completed aerospace vehicles in a calendar year is exempt from this section of the rule. The rule
does not specify any particular aerospace vehicle size associated with this exemption.
If a source uses "other" technologies to remove paint such as high pressure water, laser
depainting, etc., which option in §63.746 do these types of operations fall under?
The source should comply with §63.746(b)(l), the non-HAP chemical strippers and technologies
section of the regulation.
What records are needed to demonstrate that the source is not subject to the depainting
provisions?
There are no recordkeeping requirements in the rule that address this issue. However, a facility
should be able to substantiate why they are exempt, and this may require some recordkeeping. A
facility may also need to demonstrate why they did not consider depainting certain parts of the
aircraft to fall under the rule.
What is a RCRA waste with respect to depainting waste material?
RCRA hazardous waste is defined in 40 CFR Section 261.3 and solid waste is defined in 40 CFR
Section 261.2. If you are unsure whether or not your waste is hazardous you should contact the
State RCRA office. Information provided on your MSDS should help you in that determination.
6-8
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42.
Under depainting, nonchemical based equipment, you require that a dry media blasting
system have their filter efficiencies tested. They are two primary types of filters in blasting
systems. The baghouse and the particulate filter. Are they both covered?
The baghouse is exempt from Method 319 testing, however, you will be required to use
Method 319 type particulate filters for your blasting operation.
43.
If our facility operated 50 aircraft (number of aircraft on our property listing), however, we
also perform "extra" depainting on wing stabilizers for aircraft that are not officially ours.
What do I use to count the # of aircraft?
Under 63.746(b)(3), you shall not, on an annual average basis, use more than 50 gallons of
organic HAP stripper per military aircraft depainted for spot stripping and decal removal. This
means that you would count your planes (not parts). If you had 50 planes x 50 gallons per plane,
you would be able to use annually 2,500 gallons of organic HAP stripper at your facility. This
amount is limited to spot stripping and decal removal only. It does not give you the authority to
perform nonspot stripping with any amounts you may have "left over" from your annual total.
Chemical Milling Maskant
44.
We have a facility applying chemical processing maskant where the booth, fiashoff area,
and oven are all vented to a carbon adsorber. Due to the amount of emissions from the
maskant operation, we are subject to the NESHAP, although the only operations .affected
are hand-wipe solvent use and spray gun cleaning. The spray gun cleaning is what is giving
us some concern. The guns are automatic reciprocators that are equipped with cleaning
brushes so that the operator can turn off the maskant, direct solvent through the gun, and
have the brushes automatically scrub the nozzle of the gun without having to shut down the
operation. The atomized solvent spray is of course captured and sent to the carbon
adsorber. Unfortunately, this process does not meet the NESHAP requirement in that there
is no "waste container." The carbon adsorber is a highly efficient capture device that is
better than what was probably envisioned for this type of cleaning. How do I comply?
Section 63.744(c) describes four methods for spray gun cleaning and allows an owner or operator
to use a method equivalent to those described in §63.744. Owners and operators should consult
with the Regional Office or the State or local agency for equivalency determinations.
45.
I have an aerospace facility which uses the same maskant for aluminum chemical milling
(type I) and titanium chemical milling (critical use). Applications are not used on the same
part or subassembly. The maskant does not meet the HAP/VOC limits in 63.747(c) or
63.747(e)(l) since low VOC/HAP maskants do not work effectively in the corrosive solution
used for the titanium etching (nitric acid or hydrofluoric acid). We understand that the
titanium process is not regulated under this subpart, but believe that the type I process is
also exempt based on the proposed definition of chemical milling maskant in 63.742. Is our
maskant process exempt from 63.742 and 63.747?
The proposed 63.742 states "Additionally, maskants that must be used with a combination
of Type I or II etchants and any of the above types of maskants (e.g., bonding, critical use
and line sealer, and seal coat) are also exempt from this subpart."
Yes, in this particular instance, your maskant would be exempt since you are using a maskant for a
type I and critical use applications.
6-9
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Test Methods and Monitoring
46.
Q:
Under §63.75 l(b)(6)(ii)(D), it requires that the carbon in the carbon adsorber system be
replaced at a regular predetermined time interval. What if a source uses the operation so
sporadically that they would be repeatedly replacing clean carbon? Could they instead use
a usage interval?
A:
Under §63.75 l(b)(2), the owner or operator may establish a site-specific operating parameter to
determine the carbon replacement time interval as determined by the maximum design flow rate
and organic concentration in the gas stream vented to the carbon adsorption system. The carbon
replacement time interval must be established either as part of the design evaluation to
demonstrate initial compliance or during the initial performance test conducted according to
procedures in §62.750(g)(l), (2), (3), or (4).
47.
Under §63.75 l(b)(6)(iii)(A)(2), it states that for nonregenerative carbon adsorbers a
portable monitoring device can be used in lieu of continuous emission monitors. If a
portable monitoring device is used, what is the minimum duration of each monitoring test
and how frequently must a test be performed?
Section 63.75l(b)(6)(iii)(A) indicates how the monitoring test should be operated. The frequency
of the test is not indicated, although §63.75 l(b)(6)(iii)(D) indicates that the carbon must be
replaced at a regular predetermined time interval as determined in §63.751(b)(2). The frequency
of the test would be established by the permitting authority or at a minimum once for each carbon
unit depending on replacement intervals.
48.
Section 63.750(g)(9) states that either EPA Method 18 or EPA Method 25A shall be used to
determine VOC and HAP concentrations of air exhaust streams. Does this mean that just
Method 25A can be used even if the coatings being applied contain HAP? Method 25A is
much easier and cheaper than Method 18; therefore, if given the choice most people will
choose Method 25A. Can you give an example (or examples) of a situation in which
Method 18 should be used instead of Method 25A?
The section cited, §63.750(g)(9), indicates to use the method that is appropriate to the conditions
at the site. Method selection should be based on consideration of the diversity of organic species
present and their total concentration and on consideration <5f the potential presence of interfering
gases. The biggest difference in the methods is that Method 18 can provide speciated results,
while Method 25A only provides total VOC results measured as propane. If a source is looking
for specific HAP or if they have exempt organic compounds that they want to subtract out of their
total results, then they will need to have speciated data. If all they are looking for is total VOC,
then Method 25A can provide those results in most situations.
6-10
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Applicability Determinations from the ADI (as of 11/97)
49.
A facility manufactures components, known as wingskins, that are used as the outer shell of
an airplane wing. The components undergo machining and mechanical processing that
involves cutting the aluminum plates into the required shapes, machining the wingskins to
the required thickness, debarring, and cleaning. The wingskin then undergoes final
trimming, forming, and coating by other contractors before it is used in the final assembly
of an airplane wing. Are these preliminary wingskin manufacturing operations subject to
the Aerospace NESHAP requirements?
The Aerospace NESHAP applies to major source facilities that are engaged, either in part of in
whole, in the manufacture or rework of commercial, civil, or military aerospace vehicles or
components. An aerospace vehicle or component is defined as any fabricated part, processed
part, assembly of parts, or completed unit, with the exception of electronic components, of any
aircraft including but not limited to airplanes, helicopters, missiles, rockets, and space vehicles.
Wingskins, while not a completed aerospace component, are a fabricated or processed part of an
aircraft wing. Review of the rule and the background documents indicate that the intent of the
rule is to cover all basic operations that are involved in the manufacturing of an aerospace vehicle
or component, including those conducted by subcontractors as well as by the original
manufacturer. This includes subcontractors that merely offer a service rather than a part or
component (e.g., subcontractors who perform chemical milling operations on provided
substrates). The wingskin manufacturer does not produce the final product (a completed wing),
but does conduct the initial operations necessary for the production of the wing. Based on these
considerations, the determination was made that wingskin manufacturing operations (and similar
operations that perform manufacturing steps toward producing an aerospace vehicle or
component) are subject to the applicable requirements of the NESHAP (subject to major source
determination and consideration of allowable exemptions, etc.).
50.
Is the production of components of a nuclear weapon at a Department of Energy facility
subject to Subpart GG?
As discussed in the previous answer, the intent of Subpart GG is to regulate emissions from
facilities that are engaged, either in part or in whole, in the manufacture or rework of commercial,
civil, or military aerospace vehicles or components, and that are major sources as defined in
40 CFR §63.2. Therefore, while the regulation applies to the production of missiles or missile
components used in nuclear weapon delivery systems, it is not applicable to the production of the
nuclear weapons or components that are carried on missiles produced at other facilities.
51.
Is landing gear exempt under "parts and assemblies not critical to the vehicle's structural
integrity or flight performance? What about aircraft engines?
No, such components are considered critical and would therefore not be exempted from the hand
wipe requirements.
6-11
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7.0 OTHER IMPLEMENTATION MATERIALS
The EPA has not officially reviewed or sanctioned the materials in the following table.
However, listed below are additional materials dealing with the Aerospace Manufacturing and
Rework Facilities NESHAP that may be helpful. These documents may be obtained by getting in
touch with the contact person associated with the document.
Document
Author/Agency
Contact
Aerospace Coating Operations Manual.
January 1997
Compliance Division, California
EPA, Air Resources Board.
Sacramento, CA
Gary Hunter
(916)324-6972
NESHAP Fact Sheet for Aerospace
NESHAP & South Coast Air Quality
Management District Rules 1124 and
1171.
February 11,1997
South Coast Air Quality
Management District.
Diamond Bar, CA
Stacey Ebiner, Senior Air Quality Engineer.
(909) 396-2504
Amir Dejbakhsh, Air Quality Engineer II.
(909)396-2618
PRO-ACT Fact Sheet for the
Aerospace NESHAP
HQ Air Force Center for
Environmental Excellence
PRO-ACT
1 (800) 233-4356
Web Site:
http://www.afcee.brooks.af.mil/PRO-ACT
Fact Sheets for Air Toxics Rule:
Cleaning Operations
(Available November 1997)
U.S. EPA, Office of
Enforcement and Compliance
Assurance
Transportation Environmental Compliance
Assistance Center
Web Site:
http://es.inel.gov/oeca/tcac/tcac.html
Fact Sheets for Air Toxics Rule:
Depainting and Painting
(Available November 1997)
U.S. EPA, Office of
Enforcement and Compliance
Assurance
Transportation Environmental Compliance
Assistance Center
Web Site:
http://es.inel.gov/oeca/tcac/tcac.html
U.S. EPA Information Pamphlet: New
Regulation Controlling Air Emissions
from Aerospace Manufacturing and
Rework Facilities, 40 CFR 63, Subpart
GG
U.S. EPA, Office of Air Quality
Planning and Standards.
Research Triangle Park, NC
U.S. EPA
Unified Air. Toxics Website,
http://www.epa.gov/ttn/uatw
Also, the EPA's Office of Enforcement and Compliance Assurance (OECA) maintains a
data base called the Applicability Determination Index (ADI), which contains memoranda issued
by the EPA on applicability and compliance issues associated with the New Source Performance
Standards (NSPS), NESHAP (Part 61 and MACT, Part 63), and chlorofluorocarbons. Deter-
minations recently issued are added to the data base on a quarterly basis. Also available are
determinations for Subpart T. They can be accessed on the TTN Web at
http://ttnwww.rtpnc.epa.gov/html/sscd/compli.htm.
7-1
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8.0 EXAMPLE CALCULATIONS
This section includes example calculations and spreadsheets to demonstrate compliance with the
surface coating requirements involving primers and topcoats in § 63.745 of the rule. The
example data was derived from actual facilities' data in response to information collection
requests conducted during the aerospace project. Example 1 is a monthly spreadsheet using
individual coating compliance for primers and topcoats. Example 2 demonstrates compliance
using emissions averaging for primers and topcoats. Example 3 demonstrates compliance using
rolling average calculations for primers and topcoats.
Acronyms (column headings) used in example calculation spreadsheets.
Column
A
B
C
D
E
F
G
H
I
J
K
L
M
Heading
Paint E)
Type of coating
Usage
VW
ww
vx
Dc
MH
WH
H
My
wv
G
Description, units
Coating identification by the supplier or manufacturer
Applicable coating category (i.e., primer or topcoat)
Monthly usage in gallons, (gal/mo)
Volume of water in 1 gal of coating, in gal
Weight fraction of water in coating, in percent (%)
Volume of exempt solvents in 1 gal of coating, in gal
Density of coating, in pounds of coating per gal of coating
(lb/gal)
Mass of organic HAP in 1 gal on coating, in Ib
Weight fraction of organic HAP in coating, in %
Mass of organic HAP emitted per volume of coating (lb/gal)
less water as applied
Mass of VOC in 1 gal of coating, in Ib
Weight fraction of VOC in coating, in %
Mass of VOC emitted per volume of coating (lb/gal) less
water and exempt solvents as applied
8-1
-------
Example 1. Monthly spreadsheet for demonstrating compliance using individual coating compliance for primers and topcoats.
Paint ID
515X368
BR127
AR022
AR030
AR150
822X450
DA0001
DA0002
DA0003
Type of
coating
Primer
Primer
Primer
Primer
Primer
Topcoat
Topcoat
Topcoat
Topcoat
Usage,
gal/mo
35
234
43
78
81
34
250
125
50
Vw, gal
0
0
0
0
0.32
0
0
0
0
0.21
ww,%
0
0
0
0
0.3
0
0
0
0
0.2
Vx, gal
0
0
0
0
0
0
0
0
0
0
Dc, Ib/gal
8.9
7.3
9.9
9.3
9
9.3
9.9
10.3
10.6
8.8
MH, Ib
1.96
2.19
2.67
0.00
0.54
2.05
3.27
2.58
1.59
0.88
WH, %
22
30
27
0
6
22
33
25
15
10
H, Ib/gal
1.96
2.19
2.67
0.00
0.79
2.05
3.27
2.58
1.59
1.11
My.lb
2.85
2.85
2.67
2.33
0.99
3.16
3.37
2.58
2.65
0.88
wv,%
32
39
27
25
11
34
34
25
25
10
G, Ib/gal
2.85
2.85
2.67
2.33
1.46
3.16
3.37
2.58
2.65
1.11
\
oo
HAP and VOC content limit(s):
Compliance demonstration:
Compliance demonstration:
2.9 Ib/gal for primers and 2.5 Ib/gal for topcoats
Each primer (as applied) has HAP and VOC contents <2.9 Ib/gal
Each topcoat (as applied) has HAP and VOC contents <2.5 Ib/gal
-------
Example 2. Monthly spreadsheet for demonstrating compliance using emissions averaging for primers and for topcoats.
Paint ID
515X368
BR127
DLP001
DLP002
DLP003
DLP004
DLP004
822X450
DA0001
DA002
DA003
DA003
DA004
DA005
DA006
DA007
DA008
Type of coating
Primer
Primer
Primer
Primer
Primer
Primer
Primer
SUBTOTAL
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
SUBTOTAL
Usage,
gal/mo
35
234
140
10
45
26
42
532
34
250
18
32
35
17
38
102
4
138
668
VW-
gal
0.0
0.0
0.0
0.0
0.1
0.1
0.0
0.0
0.0
0.1
0.3
0.0
0.0
0.0
0.1
0.0
0.0
ww,%
0
0
0
0
10
6
0
0
0
5
25
0
0
0
10
0
0
Vx, gal
0
0
0
0
0
0
0
0
0
0
0
\o
0
0
0
0
0
Dc-
Ib/gal
8.9
7.3
8.38
8.3
12.45
8.76
10.79
9.3
9.9
9.85
9.96
8.3
6.64
7.47
8.33
9.5
9.94
MH, Ib
1.96
2.77
0.00
4.57
1.25
2.89
2.16
3.07
3.66
3.45
1.00
4.15
2.79
4.48
1.67
1.43
1.49
WH, %
22
38
0
55
10
33
20
H,
Ib/gal
1.96
2.77
0.00
4.57
1.46
3.09
2.16
"avg= 1-88
33
37
35
10
50
42
60
20
15
15
3.07
3.66
3.66
1.42
4.15
2.79
4.48
1.85
1.43
1.49
Hava= 2.84
My.lb
2.76
2.77
2.85
4.57
3.11
3.50
2.16
3.07
3.66
3.94
3.69
4.15
4.65
4.48
1.67
2.19
3.48
wv,%
31
38
34
55
25
40
20
Gavg =
33
37
40
37
50
70
60
20
23
35
G,
Ib/gal
2.76
2.77
2.85
4.57
3.66
3.74
2.16
2.90
3.07
3.66
4.19
5.26
4.15
4.65
4.48
1.85
2.19
3.48
G.vaz. 3.50
Monthly primer use = 532 Monthly average limit(s) = 2.9 Ib/gal for primers and 3.5 Ib/gal for topcoats
Monthly topcoat use = 668 Compliance demonstration: monthly primer (as applied) averages: Hav~ and Gavg <2.9 Ib/gal
TOTAL (combined) = 1 ,200 Compliance demonstration: monthly topcoat (as applied) averages: Havg and Gavg <3.5 Ib/gal
00
OJ
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Example 3. Rolling average calculations
These rolling calculations are intended to be used to demonstrate compliance with the
§ 63.745(d) primers and topcoats, § 63.746(c) depainting (chemical strippers), or § 63.747(d)
chemical milling maskants using Equation 9 which is located in § 63.750(g). These calculations
are also to be used "to demonstrate initial and continuous compliance when emissions are
controlled by a dedicated solvent recovery device."
Mr
R = x 100 Equation 9
Sum of [(Woi)(Md) - Rs,)] Aquation y
where:
R = overall HAP or VOC emission reduction, %;
Mf = the total mass in kilograms of HAP or VOC recovered for a 7 to 30 day period;
MCJ = the total mass in kilograms of each batch of coating (i) applied, or of each coating
applied at an affected coating operation during a 7- to 30-day period, as appropriate,
as determined from
WQj = the weight fraction of HAP or VOC in each batch of coating (i) applied, or of each
coating applied at an affected coating operation during a 7- to 30-day period, as
appropriate, as determined by EPA Method 24 or formulation data; and
Rsj = the total mass in kilograms of HAP or VOC retained in the coating after drying.
(The value of Rs^ is zero unless additional documentation is submitted showing that
the measured value of Rs; exceeds zero.)
i ./»
8-4
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Example VOC data for a 10 day period using eight different coatings (A through H).
Day
1
2
3
4
5
6
7
8
9
10
Coating (wt fraction;
wt of coating)
A (55%; 10. lib)
B(51%,9.91b)
C(48%; ll.Olb)
Volume
applied, gal
22
45
33
Total
weight, Ib
122.2
227.2
174.2
Mass of VOC
recovered, Ib
No coating applied
D (40%; 9.5 Ib)
E (55%; 12.2 Ib)
B(51%;9.91b)
C(48%; ll.Olb)
F (57%; 10.9 Ib)
15
69
46
7
46
57.0
463.0
232.3
37.0
285.8
325
No coating applied
No coating applied
B(51%;9.91b)
C(48%; ll.Olb)
F (57%; 10.9 Ib)
22
56
41
111.1
295.7
254.7
1,748
No coating applied.
G (45%; 10.5 Ib)
H (55%; 12.0 Ib)
B(51%;9.91b)
C(48%; ll.Olb)
F (57%; 10.9 Ib)
82
4
43
24
21
387.5
26.4
s*
217.1
126.7
130.5
For each coating used on each day, (Woi)(Mci) is represented as "TOTAL WEIGHT" and for
Day 1, coating A, the total weight (or mass) of coating A was calculated to be the weight fraction
(55%) multiplied by the weight of the coating (10.1 Ib/gal) multiplied by volume applied (22 gal)
= (0.55) x (10.1) x (22) = 122.2 Ib.
Using Equation 9, the overall VOC reduction, R, for the first week (days 1 through 7) is
calculated as follows (and assuming Rsj = 0):
R = (325 + 1.748)
(122.2 + 227.2 + 174.2 + 57 + 463 + 232.3 + 37 + 285.8 + 111.1 + 295.7 + 254.7)
R = 2-073 = 0.917 x 100% = 91.7%
2,260.2
8-5
-------
On day 10, the rolling average would be calculated for days 4 through 10 as follows:
R= 0.748)
(232.3 + 37 + 285.8 + 111.1 + 295.7 + 254.7 + 387.5 + 26.4 + 217.1 + 126.7 + 130.5)
R = 1-748 = 0.830 x 100% = 83.0%
2,104.8
Since the overall reduction has to be greater than or equal to 81%, both of these rolling average
calculations demonstrate compliance for those coating operations being controlled with a
dedicated solvent recovery device.
NOTE: All of the English units used in this example can be converted to metric as defined in the
aerospace final rule and the final result will be the same since we are dealing with ratios.
8-6
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9.0 LIST OF CLEANING SOLVENT SUBSTITUTIONS
This section includes a listing of substitution products that were identified in aerospace industry
responses to a Section 114 information collection request involving cleaning operations. The
comments section reflects industry's associated comments, not EPA's.
Substitution product
97% water, 2% surfactant,
1%MEK
Jettacin
RIMS- 1029
Type 1 Cleaner:
Water 96.8%
MEK 0.8%
Triton X-l 00 1.8%
Triton X-45 0.6%
d-Limonene
Solvent 64
Citri-Kleen
Emulsion cleaners
Alkaline cleaner: diethylene
glycol monobutyl ether
(0.01 mmHg) and water
mixture
Blend of low vapor pressure
solvents
d-Limonene based
hydrocarbon solution
Envirosolv KN 12000:
mixture of wood
blend terpenes
vapor press = 0.28 mmHg
Product substituted for
MEK/MIBK blend
MEK
MEK/MIBK blend
7
MEK
MEK
Carbon remover with large
percent of the methylene
chloride
Vapor degreasers with
trichloroethylene
MEK mixture
85wt%CFC-113
15 wt% MEK or organic
solvent blend
Naphtha, methylene
chloride, and
perchloroethylene
MEK and MIBK blend
Vapor press = 43 mmHg
and 1,1,1-TCAvapor
press =100 mmHg
Comments
Cleaning of noncritical components
Reduce VOC emissions by 10,000 Ib.
Reduce MEK usage by 25%.
Use in 80-90% of cleaning applications for final
aircraft cleaning.
Reduce VOC and HAP emissions by 98%.
Reduced MEK usage by 99%.
Eliminated MIBK usage.
Used in tool cleaning operations, general shop
cleaning, and other noncritical aerospace
applicationsgeneral purpose hand-wipe
cleaning.
Eliminated MEK usage.
Batch cleaning of coating equipment and
fabrication of tools.
Wipe solvent.
Used in propeller shop disassembly and
cleaning ^reas
Used in metal parts cleaning
Estimated reduction of VOC emissions by
5-10 tons per yepr.
Used in exterior cleaning of wings.
Reduced VOC emissions by 8,000 Ib.
Reduced HAP emissions by 37,500 Ib.
Reduced solvent usage by 308,000 Ib.
General purpose cleaner.
Reduced HAP emissions by 31,000 Ib.
Reduced solvent usage by 27,000 Ib-solution is
recyclable.
Machine shop cleaner.
General purpose wipe cleaner and cold
degreasing activities
9-1
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Substitution product
Ardrox 5523
Bio-T Mex:
Terpene, coors
Diethylene glycol
monobutyl ether (0.01 mmHg)
Diethylene glycol monobutyl
ether (0.01 mmHg) and Citra
Safe
Alkaline cleaner
Bio-T Max
Aqueous cleaners <100 gal/L
MU-C-383334A type 1 (metal
conditioner) no VOC content
Orange all
Aqueous cleaning solutions,
vapor press. = <26 mmHg
Solvents vapor press. =
<45 mmHg at 20°C:
Turco 6754
Androx5515
Desoclean 20
Diethylene glycol monobutyl
ether (0.01 mmHg)
Diethylene glycol monobutyl
ether (0.01 mmHg)
Citra-Safe
d-Limonene
Biogenic
Toluene
Diethylene glycol monobutyl
ether (0.01 mmHg)
Product substituted for
50/50 blend of 1,1,1 -TC A
and methylene chloride
MEK, TCA
MEK
MEK
Freon TES
MEK
TCA
Mil-C-54 10 376 gal/L
MEK, TCA methylene
chloride
MEK
MEK and acetone
MEK, acetone, toluene
MEK, acetone
MEK
MEK
Comments
Reduced usage of 1,1,1 -TCA and methylene
chloride by 30,000 Ib.
Used for spray gun cleaning.
Wiping solvents in machine shop and machinery
repair.
Wipe cleaning
Solvent usage reduced by 50%.
Cleaning in assembly and sheet metal areas.
Parts washer in the machine shop.
Cleaning processes.
Remove grease and oils from machinery prior to
paint
Cleaner
Removal of contaminants from noncritical items
Wipe solvents
Solvent wiping operations needed for aircraft
parts.
Turco 6754 and Ardrox 5515:
s"
Cleaning parts prior to adhesive bonding
primer application
All phases of production and factory support,
clean spray guns, lines and related equipment
Reduced solvent usage by 12,000 Ib/yr.
Used in metal cleaning operations.
Reduced MEK and acetone usage by 600 gal.
Used in cleaning machine parts and tool
grindings.
Paint gun cleaning.
General purpose cleaning and replacement for
solvent cleaning.
Used to remove aircraft corrosion inhibiting
contamination.
Hand wipes.
9-2
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APPENDIX A - GLOSSARY
GLOSSARY
Aerospace facility means any facility that produces, reworks, or repairs in any amount
any commercial, civil, or military aerospace vehicle or component.
Aerospace vehicle or component means any fabricated part, processed part, assembly of
parts, or completed unit, with the exception of electronic components, of any aircraft including
but not limited to airplanes, helicopters, missiles, rockets, and space vehicles.
Aircraft fluid systems means those systems that handle hydraulic fluids, fuel, cooling
fluids, or oils.
Aircraft transparency means the aircraft windshield, canopy, passenger windows,
lenses, and other components which are constructed of transparent materials.
Antique aerospace vehicle or component means an antique aircraft as defined by
14 CFR part 45, or components thereof. An antique aerospace vehicle would not routinely be in
commercial or military service in the capacity for which it was designed.
Carbon adsorber means one vessel in a series of vessels in a carbon adsorption system
that contains carbon and is used to remove gaseous pollutants from a gaseous emission source.
Carbon adsorber control efficiency means the total efficiency of the control system,
^'determined by the product of the capture efficiency and the control device efficiency.
Chemical milling maskant means a coating that is applied directly to aluminum
components to protect surface areas when chemical milling the component with a Type I or
Type n etchant. This does not include bonding maskants, and critical use and line sealer
nnaskants, and seal coat maskants. Additionally, maskants that must be used with a combination
of Type I or n etchants and any of the above types of maskants (e.g., bonding, critical use and
line sealer, and seal coat) are also exempt from this subpart. (See also Type n etchant
definition.)
Chemical milling maskant application operation means application of chemical
milling maskant for use with Type I or Type n chemical milling etchants.
Cleaning operation means collectively spray gun, hand-wipe, and flush cleaning
operations.
Cleaning solvent means a liquid material used for hand-wipe, spray gun, or flush
cleaning. This definition does not include solutions that contain HAP and VOC below the
de minimis levels specified in § 63.741(f).
Closed-cycle depainting system means a dust-free, automated process that removes
permanent coating in small sections at a time, and maintains a continuous vacuum around the
area(s) being depainted to capture emissions.
A-l
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Coating means a material that is applied to the surface of an aerospace vehicle or
component to form a decorative, protective, or functional solid film, or the solid film itself.
Coating operation means the use of a spray booth, tank, or other enclosure or any area,
such as a hangar, for the application of a single type of coating (e.g., primer); the use of the same
spray booth for the application of another type of coating (e.g., topcoat) constitutes a separate
coating operation for which compliance determinations are performed separately.
Coating unit means a series of one or more coating applicators and any associated drying
area and/or oven wherein a coating is applied, dried, and/or cured. A coating unit ends at the
point where the coating is dried or cured, or prior to any subsequent application of a different
coating. It is not necessary to have an oven or flashoff area in order to be included in this
definition.
Confined space means a space that: (1) is large enough and so configured that an
employee can bodily enter and perform assigned work; (2) has limited or restricted means for
entry or exit (for example, fuel tanks, fuel vessels, and other spaces that have limited means of
entry); and (3) is not .suitable for continuous employee occupancy.
Control device means destruction and/or recovery equipment used to destroy or recover
HAP or VOC emissions generated by a regulated operation.
Control system means a combination of pollutant capture system(s) and control device(s)
used to reduce discharge to the atmosphere of HAP or VOC emissions generated by a regulated
operation.
Depainting means the removal of a permanent coating from the outer surface of an
aerospace vehicle or component, whether by chemical or nonch&nical means. For nonchemical
means, this definition excludes hand and mechanical sanding, and any other nonchemical
removal processes that do not involve blast media or other mechanisms that would result in
airborne particle movement at high velocity.
Depainting operation means the use of a chemical agent, media blasting, or any other
technique to remove permanent coatings from the outer surface of an aerospace vehicle or
component. The depainting operation includes washing of the aerospace vehicle or component
to remove residual stripper, media, or coating residue.
Electrodeposition of paint means the application of a coating using a water-based
electrochemical bath process. The component being coated is immersed in a bath of the coating.
An electric potential is applied between the component and an oppositely charged electrode
hanging in the bath. The electric potential causes the ionized coating to be electrically attracted,
migrated, and deposited on the component being coated.
Electrostatic spray means a method of applying a spray coating in which an electrical
charge is applied to the coating and the substrate is grounded. The coating is attracted to the
substrate by the electrostatic potential between them.
Exempt solvent means specified organic compounds that have been determined by the
EPA to have negligible photochemical reactivity and are listed in 40 CFR 51.100.
A-2
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Flush cleaning means the removal of contaminants such as dirt, grease, and coatings
from an aerospace vehicle or component or coating equipment by passing solvent over, into, or
through the item being cleaned. The solvent may simply be poured into the item being cleaned
and then drained, or be assisted by air or hydraulic pressure, or by pumping. Hand-wipe
cleaning operations where wiping, scrubbing, mopping, or other hand action are used are not
included.
Hand-wipe cleaning operation means the removal of contaminants such as dirt, grease,
oil, and coatings from an aerospace vehicle or component by physically rubbing with a material
such as a rag, paper, or cotton swab that has been moistened with a cleaning solvent.
Hazardous air pollutant (HAP) means any ah- pollutant listed in or pursuant to
section 112(b) of the Act.
High efficiency particulate air (HEPA) filter means a dry paniculate filter system that
has a 99.97 percent reduction efficiency for 0.3 micron aerosol.
High volume low pressure (HVLP) spray equipment means spray equipment that is
used to apply coating by means of a spray gun that operates at 10.0 psig of atomizing air pressure
*or less at the air cap.
Inorganic hazardous air pollutant (HAP) means any HAP that is not organic.
Leak means any visible leakage, including misting and clouding.
Limited access space means internal surfaces or passages of an aerospace vehicle or
^component that cannot be reached without the aid of an airbrush or a spray gun extension for the
-.application of coatings. ^
Mechanical sanding means aerospace vehicle or component surface conditioning which
uses directional and random orbital abrasive tools and aluminum oxide or nylon abrasive pads for
the purpose of corrosion rework, substrate repair, prepaint surface preparation, and other
maintenance activities.
Natural draft opening means any opening in a room, building, or total enclosure that
remains open during operation of the facility and that is not connected to a duct in which a fan is
installed. The rate and direction of the natural draft through such an opening is a consequence of
the difference in pressures on either side of the wall containing the opening.
Nonchemical based depainting equipment means any depainting equipment or
technique, including, but not limited to, media blasting equipment, that can depaint an aerospace
vehicle or component in the absence of a chemical stripper. This definition does not include
mechanical sanding or hand sanding.
Nonregenerative carbon adsorber means a carbon adsorber vessel in which the spent
carbon bed does not undergo carbon regeneration in the adsorption vessel.
Operating parameter value means a minimum or maximum value established for a
control device or process parameter which, if achieved by itself or in combination with one or
A-3
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more other operating parameter values, determines that an owner or operator has complied with
an applicable emission limitation.
Organic hazardous air pollutant (HAP) means any HAP that is organic.
Primer means the first layer and any subsequent layers of identically formulated coating
applied to the surface of an aerospace vehicle or component. Primers are typically used for
corrosion prevention, protection from the environment, functional fluid resistance, and adhesion
of subsequent coatings. Coatings that are defined as specialty coatings are not included under
this definition.
Radome means the nonmetallic protective housing for electromagnetic transmitters and
receivers (e.g., radar, electronic countermeasures, etc.).
Recovery device means an individual unit of equipment capable of and normally used for
the purpose of recovering chemicals for fuel value (i.e., the recovered stream must have a net
positive heating value), use, reuse, or for sale for fuel value, use, or reuse. Examples of
equipment that may be recovery devices include absorbers, carbon adsorbers, condensers, oil-
water separators, or organic-water separators or organic removal devices such as decanters,
strippers, or thin-film evaporation units. For purposes of the monitoring, recordkeeping, and
reporting requirements of this subpart, recapture devices are considered recovery devices.
Research and Development means an operation whose primary purpose is for research
and development of new processes and products, that is conducted under the close supervision of
technically trained personnel, and is not involved in the manufacture of final or intermediate
products for commercial purposes, except in a de minimis manner.
Self-priming topcoat means a topcoat that is applied difectly to an uncoated aerospace
vehicle or component for purposes of corrosion prevention, environmental protection, and
functional fluid resistance. More than one layer of identical coating formulation may be applied
to the vehicle or component.
Semiaqueous cleaning solvent means a solution in which water is a primary ingredient
(> 60 percent of the solvent solution as applied must be water.)
Softener means a liquid that is applied to an aerospace vehicle or component to degrade
coatings such as primers and topcoats specifically as a preparatory step to subsequent depainting
by nonchemical based depainting equipment. Softeners may contain VOC but shall not contain
any HAP as determined from MSDS's or manufacturer supplied information.
Solids means the nonvolatile portion of the coating which after drying makes up the dry
film.
Space vehicle means a man-made device, either manned or unmanned, designed for
operation beyond earth's atmosphere. This definition includes integral equipment such as
models, mock-ups, prototypes, molds, jigs, tooling, hardware jackets, and test coupons. Also
included is auxiliary equipment associated with test, transport, and storage, which through
contamination can compromise the space vehicle performance.
A-4
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Specialty coating means a coating that, even though it meets the definition of a primer,
topcoat, or self-priming topcoat, has additional performance criteria beyond those of primers,
topcoats, and self-priming topcoats for specific applications. These performance criteria may
include, but are not limited to, temperature or fire resistance, substrate compatibility,
antireflection, temporary protection or marking, sealing, adhesively joining substrates, or
enhanced corrosion protection. Individual specialty coatings are defined in appendix A to
subpart GG and in the CTG for Aerospace Manufacturing and Rework Operations
(EPA453/R-97-004).
Spot stripping means the depainting of an area where it is not technically feasible to use
a nonchemical depainting technique.
Spray gun means a device that atomizes a coating or other material and projects the
particulates or other material onto a substrate.
Stripper means a liquid that is applied to an aerospace vehicle or component to remove
permanent coatings such as primers and topcoats.
Surface preparation means the removal of contaminants from the surface of an
aerospace vehicle or component, or the activation or reactivation of the surface in preparation for
-the application of a coating.
Temporary total enclosure means a total enclosure that is constructed for the sole
purpose of measuring the emissions from an affected source that are not delivered to an emission
control device. A temporary total enclosure must be constructed and ventilated (through stacks
^Suitable for testing) so that it has minimal impact on the performance of the permanent emission
capture system. A temporary total enclosure will be assumed to, achieve total capture of fugitive
emissions if it conforms to the requirements found in § 63.750(g)(4) of the rule and if all natural
draft openings are at least four duct or hood equivalent diameters away from each exhaust duct or
hood. Alternatively, the owner or operator may apply to the Administrator for approval of a
temporary enclosure on a case-by-case basis.
Topcoat means a coating that is applied over a primer on an aerospace vehicle or
component for appearance, identification, camouflage, or protection. Coatings that are defined as
specialty coatings are not included under this definition.
Total enclosure means a permanent structure that is constructed around a gaseous
emission source so that all gaseous pollutants emitted from the source are collected and ducted
through a control device, such that 100 percent capture efficiency is achieved. There are no
- fugitive emissions from a total enclosure. The only openings in a total enclosure are forced
. makeup air and exhaust ducts and any natural draft openings such as those that allow raw
materials to enter and exit the enclosure for processing. All access doors or windows are closed
during routine operation of the enclosed source. Brief, occasional openings of such doors or
windows to accommodate process equipment adjustments are acceptable, but if such openings
are routine or if an access door remains open during the entire operation, the access door must be
considered a natural draft opening. The average inward face velocity across the natural draft
openings of the enclosure must be calculated including the area of such access doors. The drying
A-5
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oven itself may be part of the total enclosure. An enclosure that meets the requirements found in
§ 63.750(g)(4) of the rule is a permanent total enclosure.
Touchup and repair operation means that portion of the coating operation that is the
incidental application of coating used to cover minor imperfections in the coating finish or to
achieve complete coverage. This definition includes out-of-sequence or out-of-cycle coating.
Two-stage filter system means a dry paniculate filter system using two layers of filter
media to remove paniculate. The first stage is designed to remove the bulk of the paniculate and
a higher efficiency second stage is designed to remove smaller paniculate.
Type II etchant means a chemical milling etchant that is a strong sodium hydroxide
solution containing amines (Type I etchants contain varying amounts of dissolved sulfur and do
not contain amines).
Volatile organic compound (VOC) means any compound defined as VOC in 40 CFR
51.100. This includes any organic compound other than those determined by the EPA to be an
exempt solvent. For purposes of determining compliance with emission limits, VOC will be
measured by the approved test methods. Where such a method also inadvertently measures
compounds that are exempt solvent, an owner or operator may exclude these exempt solvents
when determining compliance with an emission standard.
Waterborne (water-reducible) coating means any coating which contains more than
5 percent water by weight as applied in its volatile fraction.
Waterwash system means a control system that utilizes flowing water to remove
paniculate emissions from the exhaust air stream in spray coating application or dry media blast
depainting operations.
A-6
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APPENDIX B - INITIAL NOTIFICATION FORM
INITIAL NOTIFICATION REPORT1
THIS IS A SAMPLE NOTIFICATION FORM WHICH CAN BE USED BY FACILITIES AT THEIR
DISCRETION TO MEET COMPLIANCE WITH 40 CFR 63.753(a)
Applicable Rule: 40 CFR Part 63, Subpart GG - National Emission Standards for Aerospace
Manufacturing and Rework Facilities. Initial Notification is being made in accordance
with §63.753(a)(1) and §63.9(b)(2).
1. Print or type the following information for each plant in which aerospace manufacturing and rework
operations are performed (§63.9(b)(2)(i)- (ii)):
Owner/Operator/Title.
Street Address
City State Zip Code:
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional)
Plant Address (if different than owner/operator's)
Street Address
City State Zip Code:
2. Indicate your anticipated compliance date (§63.9(b)(2)(iii)):
D 1 September1998
n Upon startup Anticipated startup date ^
3. Check which affected source(s) (as defined by 40 CFR 63.741 (c)) are performed at your plant:3
n Hand wipe cleaning4 D Waste handling and storage
n Flush cleaning4 n Topcoat application
D Spray gun cleaning4 n Primer application
D Chemical milling maskant applications n n Depainting operations
11nitial notification forms should be sent to the EPA Regional Office servicing your area and to
your State or local Air Pollution Control Agency by September 1,1997. Part 70 permits can be used in lieu
of an initial notification provided: (1) the same information is contained in the permit application as
required by this rule; (2) the State has an approved Title V program under Part 70; (3) the State has
received delegation of authority by the EPA; and (4) Title V permits are submitted by September 1,1997.
^Sources may use the application for approval and construction or reconstruction to fulfill the
initial notification requirement.
Operations regulated under 40 CFR 63 Subpart GG include: hand-wipe cleaning, spray gun
cleaning, flush cleaning, primer application, topcoat application, depainting operations, chemical milling
maskant and waste handling/storage.
4Proposed changes to the final rule were published on October 29,1996 (61 FR 55853) which
proposes limiting the definition of an affected source to those activities subject to the manufacture or
rework of aerospace vehicles or components. Until these amendments are finalized, all cleaning
operations at the facility are subject to Subpart GG.
B-l
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Briefly describe the nature, size, design and method of operation of the source, including its operating
design capacity. (§63.9(b)(2)(iv)):
EXAMPLE RESPONSE: Plant #4 is responsible for the maintenance, repair and rework of military and
commercial aircraft. The plant occupies approximately 1500 acres and contains 12 maintenance shops and
one aircraft hangar where aircraft cleaning, topcoating, priming, depainting and chemical milling maskant
operations are performed.
All topcoating, priming and milling maskant operations, except for minor touchup operations, are performed
in enclosed areas where dry paniculate filters are utilized. Depainting of aircraft parts is performed using
plastic media blasting where emissions are controlled by the use of HEPA filters. Depainting of parts not
normally removed from the aircraft are performed using mechanical or hand sanding. Minor amounts of
chemical stripping may be performed in areas where mechanical or hand sanding is not feasible.
Approximately 65% of HAP emissions from this plant come from painting and priming operations; 5% from
chemical milling maskant operations; 25% from cleaning operations and 5% from depainting operations.
Plant #4 is capable of operating 24 hours per day, 365 days per year but currently operates 16 hours per
day (two 8 hour shifts). Approximately 181 aircraft are maintained per year, however, the plant can
accommodate up to 300 aircraft per year for maintenance and repair. Approximately 60% of the work
performed is at this location involves minor maintenance and repair of internal and external aircraft parts.
Approximately 40% involve major rework of the aircraft exterior.
4. Identify each point of emission for each hazardous air pollutant, or if a definitive identification is
not yet possible, a preliminary identification of each point of emission for each hazardous air
pollutant. If additional lines are needed, make copies of this .page (§63.9(b)(2)(iv)).
Please indicate if the information below is:
D Actual
n Preliminary
NOTE: 40 CFR 63.741 (c)(ii) identifies each spray gun cleaning operation as an affected source. Each
spray gun cleaning operation should be identified separately.
Source ID
Source Location
Source Description
Operation Performed
B-2
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EXAMPLE RESPONSE:
Source ID
N/A
CLEAN- 1
and 2
CLEAN-3
and 4
PAINT- 1
PAINT-2
PAINT-3
STRIP-1
STRIP-2
MILL-1
N/A
Source Location*
Bldg 510, 550, Hangar 1,
Hangar 2, Flight Line
Bldg 5 10, Paint Shop (all
sources located in Room 220)
Hangar 2
Bldg 510, PaintShop
(Room 220)
Hangar 2
Flight Line
Bldg 510, Depaint Shop
(Room 300)
Bldg 550, Hangar 1 , Flight
Line
Hangar 2
Bldg 51 0,550, Hangar 1,
Hangar 2, Flight Line
Source Description
Wipe-clean aircraft after sanding
operations and prior to topcoating,
priming and maskant application
One paint gun cleaner (enclosed
system). One disassembled spray
gun cleaning area
One paint gun cleaner (enclosed
system). One disassembled spray
gun cleaning area
One walk-in paint booth
One corrosion control facility large
enough to contain a 747
Flight Line operations are "touch-up"
only
Plastic media blasting using a walk-
in contained booth
Mechanical and hand sanding; minor
chemical stripping
Apply Type I and II maskant
Store and handle waste
Operation(s) Performed
Hand-Wipe Cleaning
Spray Gun Cleaning
Spray Gun Cleaning
Primer and Topcoat
Application
Primer and Topcoat
Application
Primer and Topcoat
Application
Depainting Operations
Depainting Operations
Milling Maskant
Waste Handling and
Storage
* The following information is available at Plant #4 as of the date of this suEJmittal and may change prior to the
compliance date of Subpart GG. Building 510 contains five maintenance shops and Bldg. 550 contains seven
shops for parts assembly and minor repair.
5. Check the box that applies (§63.9(b)(2)(v)):
o My plant is a major source of Hazardous Air Pollutants (HAP's)
n My plant is a minor source of HAP's
NOTE: A major source is a facility that emits greater than 10 tons per year of any one hazardous air
pollutant (HAP) or 25 tons per year of multiple HAP's. All other sources are area sources. The
major/area source determination is based on all HAP emission points inside the plant fenceline, not
just the aerospace manufacture and rework facilities.
B-3
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APPENDIX C - GENERAL PROVISIONS APPLICABILITY TO SUBPART GG
TABLE C-l. GENERAL PROVISIONS APPLICABILITY TO SUBPART GG
Reference
63.1(a)(l)
63.1(a)(2)
63.1(a)(3)
63.1(a)(4)
63.1(a)(5)
63.1(a)(6)
63.1(a)(7)
63.1(a)(8)
63.1(a)(9)
63.1(a)(10)
63.1(a)(ll)
63.1(a)(12)
63.1(a)(13)
63.1(a)(14)
63.1(b)(l)
63.1(b)(2)
63.1(b)(3)
63.1(c)(l)
63.1(c)(2)
63.1(c)(3)
63.1(c)(4)
63.1(c)(5)
63.1(d)
63.1(e)
63.2
63.3
63.4(a)(l)
63.4(a)(2)
63.4(a)(3)
63.4(a)(4)
63.4(a)(5)
63.4(b)
Applies to affected
sources in Subpart
GG
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Comment
Reserved
Reserved
'
Subpart GG does not apply to area sources
Reserved
Reserved
Reserved
C-l
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TABLE C-l. (continued)
Reference
63.4(c)
63.5(a)
63.5(b)(l)
63.5(b)(2)
63.5(b)(3)
63.5(b)(4)
63.5(b)(5)
63.5(b)(6)
63.5(c)
63.5(d)(l)(i)
63.5(d)(l)(ii)(A)-(H)
63.5(d)(l)(ii)(I)
63.5(d)(l)(ii)(J)
63.5(d)(l)(iii)
63.5(d)(2)-(4)
63.5(e)
63.5(f)
63.6(a)
63.6(b)(l)-(5)
63.6(b)(6)
63.6(b)(7)
63.6(c)(l)
63.6(c)(2)
63.6(c)(3)-(4)
63.6(c)(5)
63.6(d)
63.6(e)
63.6(f)
63.6(g)
63.6(h)
63.6(i)(l)-(3)
63.6(i)(4)(i)(A)
Applies to affected
sources in Subpart
GG
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
No
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Comment
leserved
leserved
Reserved
§ 63.749(a) specifies compliance dates for new sources
Reserved
The standards in Subpart GG are promulgated under section 1 12(d)
of the Clean Air Act (Act)
Reserved
Reserved
§ 63.743(b) includes additional provisions for the startup, shutdown,
and malfunction plan
The standards in Subpart GG do not include opacity standards
C-2
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TABLE C-1. (continued)
Reference
63.6(i)(4)(i)(B)
63.6(i)(4)(ii)
63.6(i)(5)-(12)
63.6(i)(13)
63.6(i)(14)
63.6(i)(15)
63.6(i)(16)
63.60)
63.7(a)(l)
63.7(a)(2)(i)-(vi)
63.7(a)(2)(vii)-(viii)
63.7(a)(2)(ix)
63.7(a)(3)
63.7(b)
63.7(c)
63.7(d)
63.7(e)
63.7(f)
63.7(g)(l)
63.7(g)(2)
63.7(g)(3)
63.7(h)
63.8(a)(l)-(2)
63.8(a)(3)
63.8(a)(4)
63.8(b)
63.8(c)
63.8(d)
63.8(e)(l)-(4)
63.8(e)(5)(i)
63.8(e)(5)(ii)
Applies to affected
sources in Subpart
GG
No
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
No
Comment
§ 63.743(a)(4) specifies that requests for extension of compliance
must be submitted no later than 120 days before an affected source's
compliance date
The standards in Subpart GG are promulgated under section 1 12(d)
of the Act
Reserved
Reserved
s-
Reserved
Reserved
The standards in Subpart GG do not include opacity standards
C-3
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TABLE C-l. (continued)
Reference
63.8(f)(l)
63.8(f)(2)(i)-(vii)
63.8(f)(2)(viii)
63.8(f)(2)(ix)
63.8(f)(3)-(6)
63.8(g)
63.9(a)
63.9(b)(l)
63.9(b)(2)
63.9(b)(3)
63.9(b)(4)
63.9(b)(5)
63.9(c)
63.9(d)
63.9(e)
63.9(f)
63.9(g)(l)
63.9(g)(2)
63.9(g)(3)
63.9(h)(l)-(3)
63.9(h)(4)
63.9(h)(5)-(6)
63.9(i)
63.9(j)
63.10(a)
63.10(b)
63.10(c)(l)
63.10(c)(2)-(4)
63.10(c)(5)-(8)
63.10(c)(9)
63.10(c)(10)-(13)
Applies to affected
sources in Subpart
GO
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Yes
No
No
No
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
Comment
Tie standards in Subpart GG do not include opacity standards
}63.753(a)(l) requires submittal of the initial notification at least
1 year prior to the compliance date; § 63.753(a)(2) allows a Title V
or Part 70 permit application to be substituted for the initial
notification in certain circumstances
-------
TABLE C-l. (continued)
Reference
63.10(c)(14)
63.10(c)(15)
63.10(d)(l)-(2)
63.10(d)(3)
63.10(d)(4)
63.10(d)(5)
63.(10)(e)(l)
63.10(e)(2)(i)
63.10(e)(2)(ii)
63.10(e)(3)
63.10(e)(4)
63.10(f)
63.11
63.12
63.13
63.14
63.15
Applies to affected
sources in Subpart
GG
No
No
Yes
No
Yes
Yes
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Comment
§ 63.8(d) does not apply to this subpart
The standards in Subpart GG do not include opacity standards
The standards in Subpart GG do not include opacity standards
The standards in Subpart GG do not include opacity standards
^"
C-5
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TECHNICAL REPORT DATA
1. REPORT NO.
EPA-456/R-97-006
2.
4. TITLE AND SUBTITLE
National Emission Standards for Aerospace Manufacturing and Rework
Facilities: Summary of Requirements for Implementing the NESHAP
7. AUTHOR(S)
Gregory A. LaFlam (PES) Dave Reeves (MRI)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Pacific Environmental Services, Inc. Revised and Updated by:
5001 South Miami Boulevard, Suite 300 Midwest Research Institute
Research Triangle Park, NC 27709 5520 Dillard Road, Suite 100
Cary.NC 27511
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
March 1998
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D3-0032, WA 111-93 & IV- 1 (PES)
68-D6-0012, TO No. 12 (MRI)
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
Project Officer is Mary Wilkins, Mail Drop 12, (919) 541-5229
Work Assignment Manager is Ingrid Ward, Mail Drop 12, (919) 541-0300
16. ABSTRACT '
National emission standards to control emissions of HAP from existing and new aerospace manufacturing and rework facilities were promulgated in 1995.
This document contains information to assist State and local air pollution control agencies as well as the regulated community in the implementation of
these standards. This document provides a common sense summary of the NESHAP requirements and provides answers to commonly asked questions
on the NESHAP. Sample inspection sheets are also provided along with a bibliography of Federal, State, and local agency sources of additional
information related to these standards.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air pollution
Air pollution control
National emission standards
Hazardous air pollutants
Aerospace industry
Implementation guidance
18. DISTRIBUTION STATEMENT
Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS
Air pollution control
Aerospace manufacturing
Stationary sources
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (This page)
Unclassified
c. COAST! Field/Group
-13B
21. NO. OF PAGES
124
22. PRICE ' '
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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