United States
               Environmental Protection
               Agency
Enforcement And
Compliance Assurance
(2223A)
               Profile Of The
               Areospace Industry
EPA 310-R-98-001
November 1998

                EPA Office of Compliance Sector Notebook Project
NOTEBOOKS

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                 WASHINGTON, D.C. 20460
XPR0^
                                       NOV  f  8 1997
                                                                           THE ADMINISTRATOR
  Message from the Administrator

  Since EPA's founding over 25 years ago, our nation has made tremendous progress in protecting
  public health and our environment while promoting economic prosperity. Businesses as large as
  iron and steel plants and those as small as the dry cleaner on the corner have worked with EPA to
  find ways to operate cleaner, cheaper and smarter. As a result, we no longer have rivers catching
  fire.  Our skies are clearer.  American environmental technology and expertise are in demand
  around the world.

  The Clinton Administration recognizes that to continue this progress, we must move beyond the
  pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
  future. Industry by industry and community by community, we must build a new generation of
  environmental  protection.

  The Environmental Protection Agency has undertaken its Sector Notebook Project to compile,
  for major industries, information about environmental problems and solutions, case studies and
  tips about complying with regulations.  We called on industry leaders, state regulators, and EPA
  staff with many years of experience in these industries and with their unique environmental issues.
  Together with an extensive series covering other industries, the notebook you hold in your hand is.
  the result.

  These notebooks will help business managers to understand better their regulatory requirements,
  and learn more about how Others in the.ir industry have achieved regulatory compliance and, the
  innovative methods some have foimd to prevent pollution in the first instance. These notebooks
  will give useful information to state regulatory agencies moving toward industry-based programs.
  Across EPA we will use this manual to better integrate our programs and improve our compliancy
  assistance efforts.

  I encourage you to use this notebook to evaluate and improve the way that we together achieve
  our important environmental protection goals. I am confident that these notebooks will help us to
  move forward in  ensuring that ~ in industry after industry, community after community  —
  environmental protection and economic prosperity go ha»4 in hand.
                                                  Carol M. Browner
               FUcyeled/Recyclabl* • Printed with Vegetable OH Based Inks on 100% Recycled Paper (40% Postconsumer)

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             For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
                       ISBN 0-16-049968-2

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Aerospace Industry
Sector Notebook Project
                                                            EPA/310-R-98-001.
             EPA Office of Compliance Sector Notebook Project

                   Profile of the Aerospace Industry
                                November 1998
                             Office of Compliance
                  Office of Enforcement and Compliance Assurance
                       U.S. Environmental Protection Agency
                           401 M St., SW (MC 2221-A)
                             Washington, DC 20460

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Aerospace Industry
Sector Notebook Project
This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors.   The documents were developed under contract by Abt Associates
(Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-Allen
& Hamilton, Inc. (McLean, VA). This publication may be purchased from the Superintendent of
Documents,  U.S.  Government Printing  Office. [A listing of available Sector Notebooks and
document numbers is included on the following page.]
All telephone orders should be directed to:

       Superintendent of Documents
       U.S. Government Printing Office
       Washington, DC 20402
       (202) 512-1800
       FAX (202) 512-2250
       8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be directed to:

       U.S. Government Printing Office
       P.O. Box 371954
       Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and
academic libraries, Federal, State, and local governments, and the media from EPA's National
Center for Environmental Publications and Information at (800) 490-9198. For further
information, and for answers to questions pertaining to these documents, please refer to the
contact names and numbers provided within this volume.
Electronic versions of all Sector Notebooks are available via Internet on the Enviro$en$e World
Wide Web at http://www.epa.gov/oeca/sector/index.html.  Enviro$ense is a free, public,
environmental exchange system operated by EPA's Office of Enforcement and Compliance
Assurance and Office of Research and Development. The Network allows regulators, the
regulated community, technical experts, and the general public to share information regarding:
pollution prevention and innovative technologies; environmental enforcement and compliance
assistance; laws, executive orders, regulations, and policies; points of contact for services and
equipment; and other related topics. The Network welcomes receipt of environmental messages,
information, and data from any public or private person or organization. Direct technical
questions to the "Feedback" button on the bottom of the web page.

Cover photograph courtesy of The Boeing Company.
 Sector Notebook Project
         November

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 Aerospace Industry
                                                                       Sector Notebook Project
                                   Sector Notebook Contacts

 The Sector Notebooks were developed by the EPA's Office of Compliance.  Direct general
 questions about the Sector Notebook Project to:

        Seth Heminway, Coordinator, Sector Notebook Project
        US EPA Office of Compliance
        401 M St., SW (2223-A)
        Washington, DC  20460
        (202) 564-7017

 Questions and comments regarding the individual documents should be directed to the specialists
 listed below.  See the Notebook web page at: www.epa.gov/oeca/sector for the most recent
 titles and staff contacts.
 Document Number              Industry
 EPA/310-R-95-001.    Profile of the Dry Cleaning Industry
                     Profile of the Electronics and Computer Industry*
                     Profile of the Wood Furniture and Fixtures Industry
                     Profile of the Inorganic Chemical Industry*
                     Profile of the Iron and Steel Industry
                     Profile of the Lumber and Wood Products Industry
                     Profile of the Fabricated Metal Products Industry*
                     Profile of the Metal Mining Industry
                     Profile of the Motor Vehicle Assembly Industry
                     Profile of the Nonferrous Metals Industry
                     Profile of the Non-Fuel, Non-Metal Mining Industry
                     Profile of the Organic Chemical Industry*
                     Profile of the Petroleum Refining Industry
                     Profile of the Printing Industry
                     Profile of the Pulp and Paper Industry
                     Profile of the Rubber and Plastic Industry
                     Profile of the Stone, Clay, Glass, and Concrete Ind.
                     Profile of the Transportation Equipment Cleaning Ind. Virginia Lathrop
                     Profile of the Air Transportation Industry           Virginia Lathrop
                     Profile of the Ground Transportation Industry       Virginia Lathrop
                     Profile of the Water Transportation Industry         Virginia Lathrop
                     Profile of the Metal Casting Industry               Steve Hoover
                     Profile of the Pharmaceuticals Industry            Emily Chow
                     Profile of the Plastic Resin and Man-made Fiber Ind.  Sally Sasnett
                     Profile of the Fossil Fuel Electric Power Generation Industry
                                                                 Rafael Sanchez
                     Profile of the Shipbuilding and Repair Industry
                     Profile of the Textile Industry
                     Sector Notebook Data Refresh-1997
                     Profile of the Aerospace Industry
EPA/310-R-95-002.
EPA/310-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/310-R-95-010.
EPA/310-R-95-011.
EPA/310-R-95-012.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-95-015.
EPA/310-R-95-016.
EPA/310-R-95-017.
EPA/310-R-95-018.
EPA/3 IO-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006.
EPA/310-R-97-007.

EPA/310-R-97-008.
EPA/310-R-97-009.
EPA/310-R-97-010.
EPA/310-R-98-001.
  Contact
  Joyce Chandler
  Steve Hoover
  Bob Marshall
  Walter DeRieux
  Maria Malave
  Seth Heminway
  Scott Throwe
  Maria Malave
  Anthony Raia
  Debbie Thomas
  Rob Lischinsky
  Walter DeRieux
  Tom Ripp
  Ginger Gotliffe
  Seth Heminway
  Robert Tolpa
  Scott Throwe
 Anthony Raia
Belinda Breidenbach
 Seth Heminway
 Anthony Raia
Phone (202)
  564-7073
  564-7007
  564-7021
  564-7067
  564-7027
  564-7017
  564-7013
  564-5027
  564-6045
  564-5041
  564-2628
  564-7067
  564-7003
  564-7072
  564-7017
  564-2337
  564-7013
  564-7057
  564-7057
  564-7057
  564-7057
  564-7007
  564-7071
  564-7074

  564-7028
  564-6045
  564-7022
  564-7017
  564-6045
                                     Government Series
EPA/310-R-99-001.    Profile of Local Government Operations
*Spanish translations available.
                                                                 John Dombrowski  564-7036
Sector Notebook Project
                                                                               November 1998

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Aerospace Industry
Sector Notebook Project
                         AEROSPACE INDUSTRY
                          TABLE OF CONTENTS
LIST OF FIGURES	m

LIST OF TABLES	i"

LIST OF ACRONYMS	iv

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	1
      A. Summary of the Sector Notebook Project	1
      B. Additional Information	2

II. INTRODUCTION TO THE AEROSPACE INDUSTRY	3
      A. Introduction, Background, and Scope of the Notebook	3
      B. Characterization of the Aerospace Industry	4
            1.  Product Characterization	5
            2.  Industry Size and Geographic Distribution	11
            3.  Economic Trends  	14

III. INDUSTRIAL PROCESS DESCRIPTION  ..;	17.
      A. Aircraft Engines and Parts Industry	18
            1.  Materials	18
            2.  Metal Shaping	19
            3.  Metal Finishing	23
      B. Aircraft Assembly 	30
      C. Repair/Rework Operations	33
      D. Space Vehicles and Guided Missiles	34
      E. Raw Materials Inputs and Pollution Outputs	34
      F. Management of Chemicals in Wastestream	39

IV. CHEMICAL RELEASE AND TRANSFER PROFILE	41
      A. EPA Toxic Release Inventory for the Aerospace Industry	 44
      B. Summary of Selected Chemicals Released  	50
      C. Other Data Sources .,.	53
      D. Comparison of Toxic Release Inventory Between Selected Industries	56

V.  POLLUTION PREVENTION OPPORTUNITIES	59
      A. Machining and Metalworking	60
      B. Surface Preparation 	-61
      C. Solvent Cleaning and Degreasing	62
      D. Metal Plating and Surface Finishing	68
      E. Painting and Coating 	68

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS	75
 Sector Notebook Project
        November 1998

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 Aerospace Industry
                    Sector Notebook Proiect
       A. General Description of Major Statutes	75
       B. Industry Specific Requirements	86
       C. Pending and Proposed Regulatory Requirements  	91

 VII. COMPLIANCE AND ENFORCEMENT HISTORY	92
       A. Aerospace Industry Compliance History	96
       B. Comparison of Enforcement Activity Between Selected Industries 	98
       C. Review of Major Legal Actions	103
              1. Review of Major Cases 	103
              2. Supplementary Environmental Projects (SEPs)	103

 VIU. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES	104
       A. Sector-related Environmental Programs and Activities	104
              1. Federal Activities  	104
       B. EPA Voluntary Programs	105
       C. Trade Association/Industry Sponsored Activity	113
              1. Industry Research Programs	113
             2. Trade Associations	115

 DC CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS  	118
fcector Notebook Project
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November 1998

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Aerospace Industry
                   Sector Notebook Project
                                LIST OF FIGURES

Figure 1: Structure of the Aerospace Industry 	5
Figure 2: Number of Establishments and Value of Shipments for the Aerospace Industry	8
Figure 3: Value of Shipments and Number of Establishments for the Aircraft Industry	9
Figure 4: Value of Shipments and Number of Establishments for the Space Vehicles and
       Guided Missiles Industry	1°
Figure 5: Geographic Distribution of Aerospace Manufacturing Facilities	11
Figure 6: The Aerospace Manufacturing Process	17
Figure 7: Summary of TRI Releases and Transfers by Industry	57


                                LIST OF TABLES

Table 1:  Products Included in the Aerospace Industry	6
Table 2:  Facility Size Distribution for the Aerospace Industry	12
Table 3:  States with the Largest Number of Aerospace Manufacturing Facilities	13
Table 4:  Top U.S. Aerospace Companies	13
Table 5:  Primary and Secondary Shaping Operations  	20
Table 6:  Material Input and Pollutant Outputs	38
Table 7:  Source Reduction and Recycling Activity for Aerospace Manufacturers Facilities
       (SICs 372 or 376) as Reported within TRI 	40
Table 8:  1996 TRI Releases for Aerospace Chemicals Facilities	46
Table 9:  1996 TRI Transfers for Aerospace Chemicals Facilities 	47
Table  10: Top 10 TRI Releasing Facilities Reporting Only 372 or 376 SIC Codes to TRI	48
Table  11: Top 10 TRI Releasing Facilities Reporting Aerospace SIC Codes to TRI	49
Table  12: Air Pollutant Releases by Industry Sector (tons/year)	55
Table  13: 1995 Toxics Release Inventory Data for Selected Industries	57
Table  14: Five-Year Enforcement and Compliance Summary for the Aerospace Industry	97
Table  15: Five-Year Enforcement and Compliance Summary for Selected Industries  	99
Table  16: One-Year Enforcement and Compliance Summary for Selected Industries	100
Table  17: Five-Year Inspection and Enforcement Summary by Statute for Selected
       Industries
Table  18: One-Year Inspection and Enforcement Summary by Statute for Selected
       Industries
Table 19: Aerospace Industry Participation in the 33/50 Program	107
 Sector Notebook Project
in
                                                                        November 1998

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 Aerospace Industry
                     Sector Notebook Project
                             LIST OF ACRONYMS

 AIA-        Aerospace Industries Association
 AFS -        AIRS Facility Subsystem (CAA database)
 AIRS -       Aerometric Information Retrieval System (CAA database)
 BIFs -        Boilers and Industrial Furnaces (RCRA)
 BOD -        Biochemical Oxygen Demand
 CAA -        Clean Air Act
 CAAA -      Clean Air Act Amendments of 1990
 CARB-       California Air Resources Board
 CERCLA -    Comprehensive Environmental Response, Compensation and Liability Act
 CERCLIS -    CERCLA Information System
 CFCs -        Chlorofluorocarbons
 CO -         Carbon Monoxide
 COD -        Chemical Oxygen Demand
 CSI -         Common Sense Initiative
 CWA-        Clean Water Act
 D&B -        Dun and Bradstreet Marketing Index
 DOC-        Department of Commerce
 DOD-       Department of Defense
 DOE-       Department of Energy
 ELP -       Environmental Leadership Program
 EPA -       United States Environmental Protection Agency
 EPCRA -     Emergency Planning and Community Right-to-Know Act
 FIFRA -      Federal Insecticide, Fungicide, and Rodenticide Act
 FINDS -      Facility Indexing System
 GPS-        Global Positioning System
 HAPs -       Hazardous Air Pollutants (CAA)
 HSDB -      Hazardous Substances Data Bank
 HVLP-       High Volume/Low Pressure
 IDEA -       Integrated Data for Enforcement Analysis
 LDR -       Land Disposal Restrictions (RCRA)
 LEPCs -      Local Emergency Planning Committees
 MACT -      Maximum Achievable Control Technology (CAA)
 MCLGs -     Maximum Contaminant Level Goals
 MCLs -       Maximum Contaminant Levels
 MEK -       Methyl Ethyl Ketone
 MSDSs -     Material Safety Data Sheets
NAAQS -     National Ambient Air Quality Standards (CAA)
NAFTA -     North American Free Trade Agreement
NAICS-      North American Industrial Classification System
NCDB -      National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP -        National Oil and Hazardous Substances Pollution Contingency Plan
NEC-        Not Elsewhere Classified
NEIC -       National Enforcement Investigation Center
Sector Notebook Project
IV
November 1998

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Aerospace Industry
                                                            Sector Notebook Project
NESHAP -    National Emission Standards for Hazardous Air Pollutants
NO2-        Nitrogen Dioxide
NOV - Notice of Violation
             Nitrogen Oxide
             National Pollution Discharge Elimination System (CWA)
             National Priorities List
             National Response Center
             National Risk Management Research Laboratory
             New Source Performance Standards (CAA)
             Office of Air Quality Planning and Standards
             Office of Air and Radiation
             Office of Enforcement and Compliance Assurance
             Original Equipment Manufacturer
             Office of Management and Budget
             Oil Pollution Act
             Office of Prevention, Pesticides, and Toxic Substances
             Occupational Safety and Health Administration
             Office of Solid Waste
             Office of Solid Waste and Emergency Response
             Office of Water
             Pollution Prevention
             Permit Compliance System (CWA Database)
             Publicly Owned Treatments Works
             Resource Conservation and Recovery Act
             RCRA Information System
             Superfund Amendments and Reauthorization Act
             Safe Drinking Water Act
             Supplementary Environmental Projects
             State Emergency Response Commissions
             Standard Industrial Classification
             Sulfur Dioxide
             Sulfur Oxides
             Total Organic Carbon
             Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS -      Toxic Chemical Release Inventory System
             Toxic Substances Control Act
             Total Suspended Solids
             Underground Injection Control (SDWA)
             Underground Storage Tanks (RCRA)
             Volatile Organic Compounds
NOX-
NPDES-
NPL-
NRC-
NRMRL-
NSPS-
OAQPS-
OAR-
OECA-
OEM-
OMB-
OPA-
OPPTS-
OSHA-
OSW-
OSWER-
OW-
P2-
PCS-
POTW-
RCRA-
RCRIS-
SARA-
SDWA-
SEPs-
SERCs -
SIC-
SO2-
SOX-
TOC-
TRI-
TSCA-
TSS-
UIC-
UST-
VOCs-
 Sector Notebook Project
                                                                    November 1998

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Aerospace Industry
                     Sector Notebook Project
I.  INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

LA. Summary of the Sector Notebook Project

                    Environmental policies based upon comprehensive analysis of air, water and
                    land pollution (such as economic sector, and community-based approaches)
                    are becoming an important supplement to traditional single-media approaches
                    to environmental protection.   Environmental  regulatory agencies  are
                    beginning to embrace  comprehensive, multi-statute solutions to facility
                    permitting,  compliance  assurance,  education/outreach, research,  and
                    regulatory development issues. The central concepts driving the new policy
                    direction are that pollutant releases to each environmental medium (air, water
                    and land) affect each other, and that environmental strategies must actively
                    identify and address these interrelationships by designing policies for the
                    "whole" facility.  One way to achieve a whole facility focus is to design
                    environmental  policies for similar industrial  facilities.  By doing  so,
                    environmental concerns that are common to the manufacturing of similar
                    products can be addressed in a comprehensive manner. Recognition of the
                    need to develop the industrial "sector-based" approach within the EPA Office
                    of Compliance led to the creation of this document.

                    The Sector Notebook Project was initiated by the Office of  Compliance
                    within the Office of Enforcement and Compliance Assurance (OECA) to
                    provide its staff  and managers with summary  information for eighteen
                    specific industrial sectors.  As other EPA offices,  states, the  regulated
                    community, environmental groups, and the public became interested in this
                    project, the scope of the original project was expanded. The ability to design
                    comprehensive, common sense environmental  protection measures  for
                    specific industries is dependent on knowledge of several interrelated topics.
                    For the purposes of this project, the key elements chosen for inclusion are:
                    general industry information (economic and geographic); a description of
                    industrial processes; pollution outputs; pollution prevention opportunities;
                    Federal statutory and regulatory framework;  compliance history; and a
                    description of partnerships that have been formed between regulatory
                    agencies, the regulated community and the public.

                    For any given industry, each topic listed above could alone be the subject of
                    a lengthy volume. However, in order to produce a manageable document,
                    this project focuses on providing summary information for each topic. This
                    format provides the reader with a synopsis of each issue, and references
                    where more in-depth information is available. Text within each profile was
                    researched from a variety of sources, and was usually condensed from more
                    detailed sources pertaining to specific topics. This approach allows for a
                    wide  coverage of activities that can  be further  explored based upon  the
                    references listed at the end of this profile. As a check on the information
                    included, each notebook went through an external document review process.
Sector Notebook Project
1
November 1998

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Aerospace Industry
Sector Notebook Project
                    The Office of Compliance appreciates the efforts of all those that participated
                    in this process and enabled us to develop more complete, accurate and up-to-
                    date summaries. Many of those who reviewed this notebook are listed as
                    contacts in Section IX and may be sources of additional information. The
                    individuals and groups  on this list do not necessarily concur with  all
                    statements within this notebook.

I.B.  Additional Information
Providing Comments
                    OECA's Office of Compliance plans to periodically review and update the
                    notebooks and will make these  updates available both in hard copy and
                    electronically. If you have any comments on the existing notebook, or if you
                    would like to provide additional information, please send a hard copy and
                    computer disk to the EPA Office of Compliance, Sector Notebook Project
                    (2223-A), 401 M St., SW, Washington, DC 20460. Comments can also be
                    sent via the web page or to notebook@epamail.epa.gov.
Adapting Notebooks to Particular Needs
                    The scope of the industry sector described in this notebook approximates the
                    national occurrence of facility types within the sector. In many instances,
                    industries within specific geographic regions or states may have unique
                    characteristics that are not fully captured in these profiles. The Office of
                    Compliance encourages state and local environmental agencies and other
                    groups to supplement or re-package the information included hi this notebook
                    to include more specific industrial and regulatory information that may be
                    available.  Additionally,  interested  states may  want to supplement the
                    "Summary of Applicable Federal Statutes and Regulations" section with state
                    and local requirements. Compliance or technical assistance providers may
                    also want to develop the "Pollution Prevention" section in more detail.
                    Please contact the appropriate specialist listed on the opening page of this
                    notebook if your office is interested in assisting us in the further development
                    of the information or policies addressed within  this volume. If you are
                    interested in assisting hi the development of new notebooks, please contact
                    the Office of Compliance at 202-564-2395.
Sector Notebook Project
         November 1998

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Aerospace Industry
                Introduction, Background, and Scope
II. INTRODUCTION TO THE AEROSPACE INDUSTRY
                    This section  provides background information on the  size,  geographic
                    distribution, employment, production, sales, and economic condition of the
                    aerospace industry. Facilities described within this document are described
                    hi terms of their Standard Industrial Classification (SIC) codes.
II. A.  Introduction, Background, and Scope of the Notebook
                    This industry sector profile provides an overview of the aerospace industry
                    as listed under SIC industry groups 372 and 376. Establishments listed under
                    these codes primarily manufacture and assemble aircraft, space vehicles,
                    guided missiles, and all the associated parts.

                    Within the industry groups 372, Aircraft and Parts, and 3 76, Guided Missiles
                    and Space Vehicles and Parts, are the following SIC codes:
                           •3721-
                           •3724-
                           •3728-

                           •3761-
                           •3764-

                           •3769-
Aircraft
Aircraft Engines and Engine Parts
Aircraft Parts and Auxiliary Equipment, Not Elsewhere
Classified
Guided Missiles and Space Vehicles
Guided Missile and Space Vehicle Propulsion Units and
Propulsion Unit Parts
Guided Missile and Space  Vehicle Parts and Auxiliary
Equipment, Not Elsewhere Classified
                    While this notebook covers all of the SIC codes listed above, the large
                    number and variability of the products will not allow a detailed description
                    of each. Instead, commonalities in the industrial processes, pollutant outputs,
                    and pollution prevention opportunities will be identified and described in
                    more general terms. An overview of general manufacturing processes within
                    the industry will be presented, along with descriptions of the actual products
                    and information on the state of the industry.  Although certain products
                    covered under these SIC codes may not be specifically mentioned, the
                    economic, pollutant output, and enforcement and compliance data in this
                    notebook covers all establishments producing aerospace products.

                    SIC codes were established by the Office of Management and Budget (OMB)
                    to track the flow of goods and services within the economy. OMB is hi the
                    process of changing the  SIC code system to a system based on similar
                    production processes called the North American Industrial  Classification
                    System (NAICS). In the NAICS, the SIC codes for the aerospace industry
                    correspond to the following NAICS codes:
Sector Notebook Project
                                     November 1998

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Aerospace Industry
Introduction, Background, and Scope
                      SIC    Industry Sector
                NAICS
                      3721   Aircraft                               336411

                      3724   Aircraft Engines                       336412

                      3728   Aircraft Parts                          336413

                      3761   Guided Missiles and Space Vehicles      336414

                      3764   Space Vehicle Propulsion Units          336415

                      3769   Guided Missile and Space Vehicle Parts  336419
II.B.  Characterization of the Aerospace Industry
                    There  are  many different  aerospace  products classified under the six
                    aerospace SIC codes. The products produced, geographical distribution, and
                    economic trends of the aerospace industry are discussed below. Figure 1
                    represents the general structure of the aerospace industry. The aerospace
                    industry operations are often classified as either military or commercial and
                    as either original equipment manufacturers (OEM) or rework.   Most
                    aerospace facilities specialize in either military or commercial and either
                    rework or OEM.  OEM facilities might do both military and commercial
                    work, and likewise for rework facilities. Some facilities might even work in
                    all areas of the industry, as indicated by the dotted circle in Figure 1.
Sector Notebook Project
                     November 1998

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Aerospace Industry
Introduction, Background, and Scope
        Figure 1:  Structure of the Aerospace Industry
                                  Aerospace Industry
                            Military
        Commercial
                                   OEM
  OEM
                              Rework
      Rework
       Soyrce: NESH^P $ID, USEPA/OAQPS, May 1994.
       II.B.l. Product Characterization
                    The aerospace industry consists of manufacturers of aircraft, aircraft engines,
                    aircraft parts, guided missiles and space vehicles, and guided missile and
                    space vehicle propulsion units and parts. Table 1 lists the products included
                    in aircraft, aircraft engines, and space vehicle and missile categories. One
                    source of manufacturer and model information is The Aerospace Sourcebook,
                    published by Aviation Week & Space Technology.
 Sector Notebook Project
                     November 1998

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 Aerospace Industry
Introduction, Background, and Scone
                        Table 1; Products Included in the Aerospace Industry
                        Category
 I Products
                        Military Fixed-Wing Aircraft
  Attack
  Bombers
  Cargo/Transport/Refueling
  Early Warning
  Electronic Warfare
  Fighters
  Observation
  Patrol ASW
  Reconnaissance
  Research/Test Bed
  Training
  Utility
                        Commercial Fixed-Wing Aircraft
  Narrow Body Turbofans
  Wide Body Turbofans
  Turboprops
                        Rotary-Wing Aircraft
  Naval
  Scout/Attack
  Tiltrotor
  Training
  Transport
  Utility
                        Business & General Aviation Aircraft
 Turbofan
 Turboprop
 Reciprocating Engine-Powered
                        Gas Turbine Engines
                        Unmanned Aerial Vehicles and Drones
                        Space/Launch Vehicles
 Manned Systems
 Unmanned Systems
                        Missiles
 Air-to-Air
 Air-to-Surface
 Anti-Armor
 Anti-Ballistic
 Anti-Ship
 Anti-Submarine
 Surface-to-Air
 Surface-to-Surface
                        Source: Aerospace Source Book. Aviation Week & Space Technoloev. 1/12/98
                      These manufacturing facilities are classified under SIC codes 372 and 376 as
                      listed above. In order to discuss the production of these parts in a sequential
                      manner, Sections II and III of this profile are divided into four categories:
                      aircraft parts, aircraft assembly, aircraft rework and repair, and space vehicles
                      and guided missiles.

                      The diverse nature of parts needed to produce these products requires the
                      support of many other major U.S. industries.  Many of the parts utilized by
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Aerospace Industry
Introduction, Background, and Scope
                    aerospace manufacturers are made by other industry sectors such as the
                    plastics and rubber industry, the fabricated metal industry, the metal casting
                    industry,  the  glass  industry, the textile  industry,  and  the  electronic
                    components industry. Manufacturing and assembling of complete units in the
                    aerospace industry typically involves prime contractors and several tiers of
                    subcontractors, as follows:
                        •Prime Contractors-
                         •First Tier Subcontractors-
 Design (develop) and assemble or
 manufacture complete units.

 Do major assembly and/or manufacture
 of sections of air/space craft  without
 designing or assembling complete units.
                         •Second Tier Subcontractors- Make various subassemblies and
                                                    sections.
                         •Third Tier Subcontractors-
                         •FourthTier Subcontractors-
 Produce machined components and sub-
 assemblies.

 Specialize in the production of particular
 components and in specific processes.
                    Typically, those facilities designated as "prime contractors" are included hi
                    SIC codes  3721, 3724, 3761 and  3764.  Both first and second tier
                    subcontractors correspond to SIC codes 3728 and 3769. Third and fourth tier
                    subcontractors  may be  included  in a variety  of industry SIC  codes
                    (EPA/OAQPS, 1994).

                    Figure 2 illustrates the distribution of manufacturing facilities and value of
                    shipments within the aerospace industry. These figures show that while the
                    aircraft parts sector of the aerospace industry is by far the largest in terms of
                    number of establishments, the finished aircraft sector has the largest value of
                    shipments.

                    The aircraft-related portion of the aerospace industry is much larger than the
                    space vehicle and missile portion. The aircraft portion comprises 93 percent
                    of the establishments and 79 percent of the value of shipments. However,
                    considering the small percentage of facilities engaged in guided missile and
                    space vehicle manufacturing (2 percent), the value of shipments is relatively
                    high (15 percent). In general, facilities which are responsible for assembling
                    the final aerospace products are few and their production rates are low, but
                    the value of each of their products  greatly  surpasses that of the supporting
                    industries.
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 Aerospace Industry
         Introduction, Background, and Scope
                     Figure 2:  Number of Establishments and Value of Shipments for the
                     Aerospace Industry
                             (number of establishments)
                   (millions of dollars)
                                        442
                                                                        $62.98
                                                          $21.97
                            1121
                            Aircraft
                            Aircraft Parts
                            Space Propulsion Units and Parts
                                                                                $2.07
                                                                                $5.33
                                                                             $19.68
                                                                 $19.83
               Aircraft Engines and Engine Parts
               Guided Missiles and Space Vehicles
               Space Vehicle Equipment
                     Source: 1992 Census of Manufacturers, USDOC, 1995.
       Aircraft Engines and Engine Parts and Air craft Parts and Equipment

                     The aircraft engines, engine parts, and aircraft parts industry is classified
                     under SIC 3724 and 3728. Facilities producing these parts employ processes
                     similar to many other metal casting, fabricating, and finishing facilities, as
                     well as processes from a wide range of other industries. Typical products
                     manufactured by these facilities include: engines, exhaust systems, motors,
                     brakes, landing gear, wing assemblies, propellers,  and many other related
                     products. The primary customers for these industries are the establishments
                     involved in the assembly of aircraft, classified under SIC 3721.

       Aircraft Assembly

                     The aircraft industry is made up of establishments primarily engaged in
                     manufacturing or assembling complete aircraft and is classified under SIC
                     3721.    This  industry  also includes establishments owned  by aircraft
                     manufacturers and primarily  engaged in research and development on
                     aircraft, whether from enterprise funds or on a contract or fee basis (Census,
                     1995).  There are many different types of aircraft included in this industry,
                     from airplanes and helicopters to blimps and balloons.  However, this profile
                     focuses primarily on the production of airplanes since they represent the
                     largest portion of the industry.  Typical products include fixed wing aircraft,
                     helicopters, gliders, balloons, and research and development on aircraft.

                     The major customers of the aircraft  industry are commercial airlines and
                     transport companies arid the military.  Figure 3 shows the distribution within
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Aerospace Industry
  Introduction, Background, and Scope
                     the industry of value of shipments and number of establishments.  Civilian
                     aircraft represents the largest percentages in value of shipments and number
                     of establishments. Approximately one-third of the establishments in this
                     industry are involved in the repair and rework of aircraft. These facilities will
                     be discussed in Section III.
                     Figure 3: Value of Shipments and Number of
                     Establishments for the Aircraft Industry
                             (millions of dollars)
(number of establishments)
                                      Military Aircraft
                                      Civilian Aircraft
                                      Modification, Conversion, and Overhaul
                                      Other Aeronautical Services
                     Source: 1992 Census of Manufacturers, USDOC, 1995.
        Guided Missiles and Space Vehicles and Associated Parts

                      The guided missiles and space vehicles industry includes establishments
                      primarily engaged in manufacturing and research and development on guided
                      missiles and space vehicles, propulsion units, and parts. Typical products
                      covered under  SIC 3761,  3764,  and 3769 include guided and  ballistic
                      missiles, space  and military rockets, space vehicles, propulsion units and
                      engines for missiles and space vehicles, airframe assemblies, and research
                      and development on these products.  The primary customer for this industry
                      is the military, however space vehicles are also used by commercial entities
                      for releasing communications satellites.

                      Figure 4 illustrates the specialization within the guided missile and space
                      vehicle industry. The Census of Manufacturers identifies only 31 facilities
                      in this sector. Value of shipment data is not available for facilities providing
                      R&D and other services to protect individual facility confidentiality.  Only
                      six facilities, or less than  a quarter of the facilities in this industry, are
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 Aerospace Industry
          Introduction, Background, and Scope
                      producing complete space vehicles.   The value of shipments  for these
                      facilities, however, comprised more than three-quarters of the total value of
                      shipments for the industry.
                     Figure 4: Value of Shipments and Number of Establishments
                     for the Space Vehicles and Guided Missiles Industry
                                (millions of dollars)
        (number of establishments)
                                       • Complete Missiles
                                       Q Complete Space Vehicles
                                       IH R&D-Missiles
                                       • R&D-Space Vehicles
                                       EB Other Services-Missiles
                                       § Other Services- Space Vehicles
                     Source: 1992 Census of Manufacturers, USDOC, 1995.
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Aerospace Industry
        Introduction, Background, and Scope
       II.B.2. Industry Size and Geographic Distribution

                     Figure 5 shows the U.S. distribution of aerospace facilities. Generally, the
                     geographic distribution of aerospace facilities is determined by the location
                     of industrialized areas of the  country.  As with many manufacturing
                     industries, the ease of transportation  of materials, products, and skilled
                     workers influence facility location.
 Figure 5:  Geographic Distribution of Aerospace Manufacturing Facilities
   Source: 1992 Census of Manufacturers, USDOC, 1995.
                     Table 2 lists the facility size distribution within the aerospace sectors. As
                     previously mentioned, the aircraft and aircraft parts industry (1,745 facilities)
                     is more than ten times larger than the space vehicles, guided missiles, and
                     parts industry (140 facilities).   Aircraft and aircraft part manufacturing
                     generally employs less people per facility than space vehicle and guided
                     missile manufacturing.  However, the number of employees in the aircraft
                     industries still overshadows that of the missile and space vehicle industries,
                     645.9 thousand and 149.6 thousand respectively.
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 Aerospace Industry
        Introduction, Background, and Scope
Table 2: Facility Size Distribution for the Aerospace Industry
Employees
per Facility
1-9
10-49
50-249
250-2499
2500 +
Total
Employees
per Facility
1-9
10-49
50-249
250-2499
2500 +
Total
Aircraft and Aircraft
Engines and Parts
(SIC 372)
Number of
Facilities
652
543
340
173
37
1,745
Percentage of
Facilities
37%
31%
19%
10%
2%
100%
Space Vehicles, Guided
Missiles, and Parts
(SIC 376)
Number of
Facilities
26
27
31
37
19
140
Percentage of
Facilities
19%
19%
22%
26%
14%
100%
Aircraft (SIC 3721)
Number of
Facilities
60
42
29
32
19
182
Percentage
of Facilities
33%
23%
16%
18%
10%
100%
Space Vehicles and
Guided Missiles
(SIC 3761)
Number of
Facilities
4
5
5
12
12
38
Percentage
of Facilities
10%
13%
13%
32%
32%
100%
Aircraft Engines and
Engine Parts (SIC 3724)
Number of
Facilities
112
130
129
63
8
442
Percentage of
Facilities
26%
29%
29%
14%
2%
100%
Space Propulsion Units
and Parts
(SIC 3764)
Number of
Facilities
6
8
8
15
5
42
Percentage of
Facilities
14%
19%
19%
36%
12%
100%
Aircraft Parts and
Equipment (SIC 3728)
Number of
Facilities
480
371
182
78
10
1,121
Percentage of
Facilities
43%
33%
16%
7%
1%
100%
Space Vehicle and Guided
Missiles Parts (SIC 3769)
Number of
Facilities
16
14
18
10
2
60
Percentage of
Facilities
27%
23%
30%
17%
3%
100%
Source: 1992 Census of Manufacturers, Industry Series: Aerospace Equipment, Including Parts, US Department of Commerce, Bureau of the
Census, 1995.
Mote: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location, and employment figures
since 1 992 arc not reflected in these data.
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Aerospace Industry
                                                   Introduction, Background, and Scope
                    Table 3 further divides the geographic distribution of aerospace facilities.
                    The top states in which the aerospace industries are concentrated are given
                    along with their respective number of establishments.
Table 3: States with the Larg<
— ^^-=^g^^=
States in which industry is
concentrated, based on number of
establishments
Percent of Total
jst Number of Aerospace Manufacturing Facilities
Aircraft and Aircraft Parts
(SIC 372)
Top States
California
Texas
Washington
Connecticut
Establishments
393
140
136
126
45%
Space Vehicles, Guided Missiles
and Associated Parts
(SIC 376)
Top States
California
Arizona
Texas
Alabama
Establishments
49
9
8
7
52%
Source: 1992 Census of Manufacturers, Industry Series: Aerospace Equipment, Including Parts, US
                                      Million Dollar Directory, compiles financial data on U.S.
                     companies including those operating within the aerospace industry. Dun &
                     Bradstreet ranks U.S. companies,  whether they are  a parent  company,
                     subsidiary or division, by sales volume within their assigned 4-digit SIC
                     code. Table 4 lists the top 10 aerospace companies by sales.

iank
1
2
3
4
5
6
7
8
9
10
Company
General Electric Co.- Fairfield, CT
Lockheed Martin Co.- Bethesda, MD
United Technologies Corp.- Hartford, CT
The Boeing Co.- Seattle, WA
Hughes Electronics Corp.- Los Angeles, CA
Allied Signal Inc.- Morristown, NJ
McDonnell Douglas Corp*-Saint Louis, MO
Textron Inc.- Providence, RI
Northrop Grumman Corp.- Los Angeles, CA
The BF Goodrich Co.- Richfield, OH
1997 Sales
(millions of
dollars)
79,179
26,875
23,273
22,681
14,772
13,971
13,834
9,274
8,071
2,238
SIC Code(s) Reported
3724, 3511, 3612, 3641, 3632, 4833
3721, 3761, 3663, 3764. 3812, 3728
3724, 3585, 3534, 3721, 3842, 3714
3721, 3663, 3761, 3764, 3812, 3728
3761, 3812, 3714, 3651, 3663, 3699
3724, 3812, 3728, 3761, 3714, 2824,
2821
3721,3761,3764,3812,6159
3721, 3714, 3452, 3711, 6141, 6159
3721, 3761, 3728, 3812, 3825, 4581
3728, 3724, 7699, 2821, 2843
Source: Dunn & Bradstreet's Million Dollar Directory, 1997.
Note: Not all sales can be attributed to the companies' aerospace operations.
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  Aerospace Industry
          Introduction, Background, and Scope
                      Readers should note that: (1) companies are assigned a 4-digit SIC code that
                      resembles their principal industry most closely; and (2) sales figures include
                      total company sales, including subsidiaries and operations (possibly not
                      related to aerospace).  Additional sources  of company specific financial
                      information include Standard &  Poor's Stock Report Service, Ward's
                      Business Directory of U.S.  Public and Private  Companies,  Moody's
                      Manuals, and company annual reports.

                      The Bureau of the Census publishes concentration ratios, which measure the
                      degree of competition in a market. They compute the percentage of the value
                      of products shipped by establishments classified within an industry of the
                      total value of these products shipped from any establishment.  Within the
                      aerospace industry, the aircraft industry and the space  vehicle and guided
                      missile industry had the greatest coverage ratios in 1992: 97 percent each.
                      The aircraft engine, aircraft parts, propulsion units, and  auxiliary space
                      vehicle equipment coverage ratios  were 95,  74, 86, and 40  percent
                      respectively.

        II.B.3. Economic Trends

                      Growth in the U.S. aerospace industry will be influenced by several key
                      factors, including constrained defense spending by the U.S. and foreign
                      governments, increased productivity and technological innovation, foreign
                      competition, continuing expansion  of the global economy, investment in
                     research and development, offsets and outsourcing, and support by foreign
                     governments for their industries.

       Domestic Trends

                     In recent years  there has been considerable consolidation of aerospace
                     companies, especially those supplying the military. This has resulted in some
                     reductions in labor force and closing of some aerospace facilities in the U.S.
                     However, in constant 1992 dollars, the value of U.S. shipments in 1996 of
                     complete aircraft (all types, civil and military) rose by about six percent over
                     the value of shipments in 1995. The value of those shipments was expected
                     to rise further by about thirty percent in 1997 and about five percent in 1998.

                     Military
                     In September 1996, Congress passed a DOD budget for F Y1997 that, for the
                     first tune in more than a decade, did not reduce spending from the previous
                     year.  In addition, the legislation provided more funding for procurement of
                     aircraft and missiles than DOD had requested. Also, DOD reduced funding
                     for R&D, which means that private  companies will have to increase their
                     share of the total amount spent on R&D if the overall level of technology
                     investment and advancement is to be maintained.
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Aerospace Industry
       Introduction, Background, and Scope
                    In the missiles sector, air-to-surface weapons should experience the most
                    growth relative to other types of missiles. Strong focus will be placed on
                    improving guidance capabilities, mainly through the use of the U.S. Global
                    Positioning System (GPS) (USDOC, 1998).

                    Commercial
                    Of all the aerospace  sectors, the large civil transport aircraft sector  is
                    expected to experience the fastest rate of growth from 1997 through 2001.
                    With the significant increase in production rates undertaken by Boeing in
                    1996, the value of shipments in 1997 of large civil transports could be  as
                    much as sixty percent higher than that of 1996, with another increase of about
                    ten percent expected in 1998 (USDOC, 1998).

                    Even as U.S. aerospace workers are being laid off because of consolidation
                    in some companies, workers are  being hired by other firms because  of
                    increasing orders. Sales of large transport aircraft are expected to come from
                    the retirement and replacement of aircraft plus additional aircraft to allow for
                    air traffic growth (USDOC, 1998).

                    The aircraft engines  and parts sectors also should  see production and
                    shipments increase as suppliers respond to increased production rates by the
                    manufacturers of commercial transports.   The market for commercial
                    transport engines alone is expected to total from $ 150 billion to $ 175 billion
                    between 1996 and 2005 (USDOC, 1998).

       International Trends

                    The internationalization of aerospace programs is increasing, and the U.S.
                    aerospace industry is dependent on exports for athird of its market. The U.S.
                    aerospace industry is affected significantly by the economies of foreign
                    countries. The average annual increase in world GDP is expected to be three
                    percent  from  1996  through 2005.    The main barriers  facing U.S.
                    manufacturers are foreign government support for their aerospace industries
                    through direct and indirect subsidies, tariffs, and  difficult and expensive
                    licensing procedures.  Additional access could be  guaranteed if efforts
                    succeed to expand membership and broaden  the disciplines of several
                    aircraft-related trade agreements (USDOC, 1998).

                    Military
                    The situation for firms  in the defense industry is  mixed.   While some
                     governments, such as those of North America and Europe (with the largest
                     defense budgets), continue to seek ways to reduce their military expenditures,
                     governments in South America (with relatively small defense budgets)  are
                     maintaining or increasing  their defense spending.   However, current
                     economic crises in Asia may reduce exports to some countries. The pace of
                     consolidation in Europe of aerospace and defense companies, which began
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 Aerospace Industry
         Introduction, Background, and Scope
                     later than in the U.S., is escalating just as the merger rate in the U.S. appears
                     to be slowing (USDOC, 1998).

                     Commercial
                     Overall improvement in the global economy has buoyed the fortunes of the
                     world's airlines.  World air passenger traffic rose each year from 1994 to
                     1996, and increased traffic by airlines all  over the world produced  a
                     significant turnaround in the large transport aircraft market, the largest part
                     of the aircraft industry. The civil aircraft sector exports 60 percent of its total
                     production and represents about 20 percent of the overall U.S. aerospace
                     industry (USDOC, 1998).

                     Asian economic problems have not had serious widespread impacts on the
                     aerospace industry to date. Companies such as Lockheed Martin and Boeing
                     estimate that about five percent of their contracts for the next five years are
                     tied to that region. It is possible that, considering the strength of the industry
                     and the economy outside of Asia, other customers may step in and eliminate
                     lower production rates (Smith, 1998).

                     Commercial space launch providers also are benefiting from the improved
                     economic situation. Consumer demand for direct-to-home television, voice
                     and data transmission, and other satellite services is increasing the demand
                     for satellites and therefore for space launch vehicles to place them in orbit
                     (USDOC, 1998).
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Aerospace Industry
               Industrial Process Description
III. INDUSTRIAL PROCESS DESCRIPTION
                     This section describes the major industrial processes within the aerospace
                     industry, including the materials and equipment used, and the processes
                     employed. The section is designed for those interested in gaining a general
                     understanding of the industry, and for those interested in the inter-relationship
                     between the industrial process and the topics described in subsequent sections
                     of this profile -- pollutant outputs, pollution prevention opportunities, and
                     Federal  regulations. This section does not attempt to replicate published
                     engineering information that is available for this industry. Refer to Section
                     IX for a list of resource materials and contacts that are available.

                     It is important to note that the  FAA places very strict  "airworthiness"
                     guidelines on manufacturing and rework facilities for safety and quality
                     control purposes, thus new pollution prevention alternatives may require a
                     full evaluation and permitting process before they may be used.

                     This section contains a description of commonly used production processes,
                     associated raw materials, by-products produced or released, and materials
                     either recycled or transferred off-site.   This discussion, coupled with
                     schematic drawings of the identified processes, provide a concise description
                     of where wastes may be produced in the process. This section also describes
                     the potential fate (via air, water, and soil pathways) of these waste products.
                     Figure 6 shows a general aerospace manufacturing process diagram.
  Figure 6: The Aerospace Manufacturing Process
Raw Materials
Aluminum and alloys
Ferrous alloys
Copper and alloys
Titanium and alloys
1
Metal Working
Machining
Shaping
Heat Treating
^
-^



Surface Finishing
Degreasing
Descaling
De-oxidizing
Etching
Anodizing
Plating
Passivating


•


Component
Assembly
Cleaning
Painting
Bonding
Sealing
Touch-up

Final Assembly
™ Cleaning ^
Painting
I
Product
Aircraft
rviissne






Maintenance
> f*. >
Stripping
Cleaning
Rework
and Repair
u

Rocket ~^~ Field Operations
Engine

  Source: Aerospace Industries Association Newsletter, October 1994.
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 Aerospace Industry
                Industrial Process Descrintion
 III.A. Aircraft Engines and Parts Industry
                     Manufacturing processes for aircraft engines and parts may consist of the
                     following basic operations: materials receiving, metal fabricating, machining
                     and mechanical processing, coating  application, chemical  milling, heat
                     treating,  cleaning,  metal  processing  and  finishing,  coating removal
                     (depainting), composite processing, and testing. Many facilities employ all
                     of these processes in their operations, however, a facility may also employ
                     only a subset of these operations, as with a facility that produces a single
                     component  or  a  facility  that provides a service  such  as painting
                     (EPA/OAQPS, 1997).

                     In addition, there are a number of operations that may be used at aircraft
                     engine and  parts facilities  but are  not typical and are performed in
                     conjunction  with a variety of industries, such as foundry operations  and
                     manufacturing of electronic components.  For more information on foundry
                     operations, see the Profile of the Metal Casting Industry, EPA, 1997.  For
                     more  information on  electronics and computers, see the Profile  of the
                     Electronics and Computer Industry, EPA, 1995.
       HI.A.I. Materials
                     There are many different materials involved in the production of engines and
                     parts. The most common materials are alloys of aluminum, which are used
                     primarily for aircraft structural components and exterior skin sections. Other
                     materials are titanium, stainless steel, magnesium, and non-metallics such as
                     plastics, fabrics, and composite materials. Typical forms of materials are
                     honeycomb, wire mesh, plate, sheet stock, bar cast, and forged materials.
       Metallic Alloys
                     Aluminum is used as a primary structural material in the aerospace industry
                     because of its light weight, and because its alloys can equal the strength of
                     steel.  The  ability to resist atmospheric corrosion also favors the use of
                     aluminum.   The type  of alloy  metal used  depends  on  the  desired
                     characteristics of the finished product such as strength, corrosion resistance,
                     machinability, ductility, or weldability (Home, 1986).

                     High strength alloys typically contain copper, magnesium, silicon, and zinc
                     as their alloying elements.  Other alloying agents that may be used are:
                     lithium for lightness; nickel for strength and ductility; chromium for tensile
                     strength and elastic limit; molybdenum for strength and toughness; vanadium
                     for tensile strength, ductility, and elastic limit; silicon as a deoxidizer; and
                     powder metallurgy alloys for strength, toughness, and corrosion resistance
                     (Home, 1986).
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Aerospace Industry
                Industrial Process Description
                    The development of the gas turbine and the evolution of engines required
                    materials with great resistance to temperature, stress, arid oxidation. Nickel-
                    based alloys have a high resistance to oxidation and are used for compressor
                    blades and guide vanes, discs, turbine blades, shafts, casings, combustion
                    chambers, and exhaust systems.  Titanium alloys have excellent toughness,
                    fatigue strength, corrosion resistance, temperature resistance, and a lower
                    density than steel.  Titanium alloys are frequently used to make hot-end
                    turbine components and turbine rotor blades (Home, 1986).

       Non-Metallic Materials

                    Plastics,  carbon and glass fibers, and synthetic resins and polymers are all
                    used in aerospace  manufacturing.  There are two types of plastics used,
                    thermoplastics and thermosetting materials.  Thermoplastic materials are
                    softened by heating and will harden on cooling and can be extruded (material
                    is pressure forced through a shaped hole), injection molded (soft material is
                    forced into a mold through a screw injector and pressure), or thermoformed
                    (material is cast in a mold with heat and pressure). Thermosetting plastics are
                    hardened by heating and form rigid three dimensional structures through
                    chemical reactions. They are typically compression molded (Home, 1986).
                    For more information on non-metallic materials, refer to the Profile of the
                    Rubber and Plastic Industry, EPA, 1995.

                    Carbon and glass fibre strands are used to reinforce plastics for strength and
                    stiffness while remaining lightweight. Synthetic resins and polymers are used
                    as adhesives which produce smooth  bonds and  a stiff structure which
                    propagates cracks more slowly than in a riveted structure (Home, 1986).

       III.A.2. Metal Shaping

                    Another major process in the manufacturing of aircraft and other aerospace
                    equipment is metal shaping. Shaping operations take raw materials and alter
                    their form to make the intermediate and final product shapes. There are two
                    phases of shaping operations: primary and secondary.   Primary shaping
                    consists of forming the metal from its raw form into a sheet, bar, plate, or
                    some other preliminary form.   Secondary shaping consists of taking the
                    preliminary form and further altering its shape to an intermediate or final
                    version of the product. Examples of primary and secondary shaping are listed
                    in Table 5 below. Brief descriptions of the most common operations follow
                    the table.
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Aerospace Industry
                Industrial Process Description
Table 5: Primary and Secondary Shaping Operations
Primary Shaping Operations
Abrasive Jet Machining
Casting
Drawing
Electrochemical Machining
Electron Beam Machining
Extruding
Forging
Impact Deformation
LASER Beam Machining
Plasma Arc Machining
Pressure Deformation
Sand Blasting
Ultrasonic Machining
Secondary Shaping Operations
Stamping
Turning
Drilling
Cutting and Shaping
Milling
Reaming
Threading
Broaching
Grinding
Polishing
Planing
Deburring

Source: Pollution Prevention Options in Metal Fabricated Products, USEPA,
January 1992.

       Primary Shaping Operations
                    The most common primary shaping operations include casting, forging,
                    extruding, rolling, cutting, coining, shearing, drawing, and spinning. Each of
                    these operations is briefly described below.

                    Metal casting involves the introduction of molten metal into a mold or die
                    having the external shape  of the desired cast part.  The mold or die is
                    removed when the metal has cooled and solidified. Metal casting operations
                    can be classified as either foundries or diecasters. The primary difference is
                    that foundries pour molten metal relying on gravity to fill the mold and die
                    casters use machines to inject molten metal under pressure into the mold.
                    Foundry molds are typically used only once for each part.  They are often
                    made of sand grains bound together with chemicals or clay. Die casting
                    molds are often reused thousands of times  and are part of a larger diecasting
                    machine that can achieve very high production rates. Foundries typically
                    produce larger airplane parts such as engine blocks, turbine and compressor
                    parts, and other mechanical parts from both ferrous and non-ferrous metals.
                    Die casters typically produce smaller intricate parts from non-ferrous metals
                    (EPA/OECA, 1995).  For a more detailed discussion  of metal  casting
                    operations see the Profile of the Metal Casting Industry, USEPA, 1997.

                    Once the molten metal is formed into a workable shape, shearing and forming
                    operations are usually performed.  Shearing operations cut materials into a
                    desired shape and size, while forming operations bend or form materials into
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AerosDace Industry
Industrial Process Description
                     specified shapes.  Shearing operations include punching, piercing, blanking,
                     cutoff, parting, and trimming. These operations produce holes, openings,
                     blanks, or parts.  Forming operations shape parts by forcing them into a
                     specific configuration, and include bending, extruding, drawing, spinning,
                     coining, and forging.  Bending is the simplest forming operation; the part is
                     simply bent to a specific angle or shape and normally produce flat-shapes
                     (EPA/OECA, 1995).

                     Extruding is the process of forming a specific shape from a solid blank by
                     forcing the  blank through  a die of the desired shape.  Complicated and
                     intricate cross-sectional shapes can be produced by extruding. Rolling is a
                     type of extruding that passes the material through a set or sqries of rollers that
                     bend and form the  part into the desired shape. Coining, another type of
                     extruding, alters the form of the part by changing its thickness, producing a
                     three-dimensional relief on one or both sides of the part, as found on coins
                     (EPA/OECA, 1995).

                     Drawing and spinning form  sheet stock into  three-dimensional shapes.
                     Drawing uses a punch to force the sheet stock into a die, where the desired
                     part shape is formed in the space between the punch and die. In spinning,
                     pressure is applied to the sheet while it spins on a rotating form so that the
                     sheet acquires the shape of the form (EPA/OECA, 1995).

                     Forging operations produce, a specific part shape, much like casting.  The
                     forging process is used in the aerospace industry when manufacturing parts
                     such as pistons, connecting rods, and  the aluminum and steel portion of
                     wheels. However, rather than using molten materials, forging uses externally
                     applied pressure that either strikes or squeezes a heated blank into a die of the
                     required shape. Forging operationsuse machines that apply repeated hammer
                     blows to a red-hot blank to force the material to conform to the shape of the
                     die opening. Squeezing acts in much the same way, except it uses pressure
                     to squeeze rather than strike the blank. Forging typically uses a series of die
                     cavities to change the shape of the blank in increments. Depending on the
                     shape, a forging die can have from one to over a dozen individual cavities
                     (EPA/OECA, 1995).

       Secondary Shaping Operations

                     Shearing (or cutting) operations include punching, piercing, blanking, cutoff,
                     parting, shearing, and trimming.  Basically, these are operations that produce
                     holes or openings, or that produce blanks or parts. The most common hole-
                     making operation is punching. Piercing is similar to punching, but produces
                     a raised-edge hole rather than a cut hole. Cutoff, parting, and shearing are
                     similar operations with different applications: parting produces both a part
                     and scrap pieces; cutoff and shearing produce parts with no scrap; shearing
                     is  used where the cut edge is straight; and cutoff produces an edge shape

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                     rather than a straight edge.  Trimming is performed to shape or remove
                     excess material from the edges of parts (EPA/OECA, 1995).

                     Turning, drilling, and reaming processes typically use a lathe, which holds
                     and spins the workpiece against the edge of a cutting tool. Drilling machines
                     are designed for making holes and for reaming, or  enlarging or finishing
                     existing holes. Milling machines use multiple edge cutters to cut unusual or
                     irregular shapes into the workpiece (EPA/ORD, 1990).

                     Broaching is a process whereby internal surfaces such as holes of circular,
                     square or irregular shapes, or external surfaces like keyways are finished. A
                     many-toothed cutting tool called a broach is  used  in this process.  The
                     broach's teeth are graded in size in such a way that each one cuts a small chip
                     from the workpiece as the tool is pushed or pulled either past the workpiece
                     surface, or through a leader hole.  Broaching  of round holes often gives
                     greater accuracy and better finish than reaming  (EPA/ORD, 1990).

                     Deburring involves removing metal shavings and burrs clinging to the cut
                     edges of parts after machining has been completed.  Deburring is typically
                     done by one of two processes. Small parts can be deburred in a tumbler
                     where the burrs are smoothed  off the part by the constant friction with the
                     tumbling media. This process, however, is  not appropriate for long parts.
                     Instead, long parts are scrubbed with an abrasive pad by hand or buffed with
                     a power tool. The buffing operation can be performed either by hand or in an
                     automatic operation (EPA/OAQPS, 1994).

                     Parts may also be honed and buffed to smooth their surfaces; spray-washed
                     with an alkaline cleaner; and blown dry using compressed air. A protective
                     coating of oil may be applied to parts that are stored on-site or shipped off-
                     site to a heat-treating facility (EPA/NRMRL, 1995).

                     The metal working process creates much heat and friction.  If the heat and
                     friction are not reduced, the tools used in the process are quickly damaged
                     and/or destroyed.  Also, the quality of the products made is diminished
                     because  of inefficient tools and damage to the product while it is being
                     manufactured.  Coolants reduce friction at the tool/substrate interface and
                     transfer heat away from the tools and the material being processed, reducing
                     the time to process the metal, increasing the quality of the workmanship, and
                     increasing tool life.  The ability to transfer  the heat away from the metal
                     working process is why metal working fluids are often called coolants (Ohio
                     EPA, 1993).

                     Oils are natural lubricants and provide this quality to coolants that are
                     petroleum-based.  Other coolants'  ability to reduce friction comes from
                     lubricating additives. During the metal working process, heat diffuses into
                     the coolant. The heated coolant flows off the work  area into a collection
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                     container or sump, where it cools off and then enters the cycle again. Water
                     has excellent cooling characteristics and many coolants contain water or are
                     primarily water. Soluble oils and semi-synthetic oils have both water and oil
                     components.  Coolants containing both oil and water require surfactants to
                     form and maintain emulsions, a mixture of the oil and water,  so that both
                     properties can work together (Ohio EPA, 1993).
       Heat Treating
                     Heat treating is the modification of the material's or part's metallurgical
                     properties through the application of controlled heating and cooling cycles.
                     For example, aluminum outer skin panels undergo a low temperature oven
                     bake after forming to provide greater stress tolerance. Heat treating can be
                     performed either before  or after machining and includes carburizing
                     (impregnating the surface with carbon), annealing (softening), stress relief,
                     tempering, air furnace treating, and salt pot treating. Chemicals, such as
                     methanol, are often used in heat treating ovens to maintain a chemically
                     reducing atmosphere in order to obtain the proper metallurgical properties on
                     the surface of the part being treated. After heat treating, the parts can either
                     be cooled in ambient air or placed in a liquid quenching bath.  The quench
                     bath  is typically  a  glycol  solution,  a  chromate  solution, or  an oil
                     (EPA/OAQPS, 1994).

                     Heat-treated parts can also be machined, honed, and deburred after they are
                     returned to the plant. After machining, the parts are typically sprayed with
                     a protective oil coating that controls corrosion until they are further processed
                     (EPA/NRMRL, 1995).
       III.A.3. Metal Finishing
                     Metal finishing and electroplating activities are performed on a number of
                     metals and serve a variety of purposes; the primary purpose being protection
                     against corrosion.  Without metal finishing, products made  from metals
                     would last only a fraction of their unfinished life-span. Metal finishing alters
                     the surface of metal products to  enhance  properties such as corrosion
                     resistance, wear resistance, electrical  conductivity, electrical resistance,
                     reflectivity, appearance, torque tolerance, solderability, tarnish resistance,
                     chemical resistance, ability to bond to rubber (vulcanizing), and a number of
                     other special properties (e.g.  electropolishing  sterilizes stainless steel)
                     (EPA/ORD, 1994).

                     These plating processes involve immersing the article to be coated or plated
                     into a series of baths consisting of acids, bases, salts, etc. A wide variety of
                     materials, processes, and products are used to clean, etch, and plate metallic
                     and non-metallic surfaces. Typically, metal parts or work pieces undergo one
                     or more physical, chemical, and  electrochemical  processes.  Physical
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                 Industrial Process Description
                     processes include buffing, grinding, polishing, and blasting.   Chemical
                     processes include degreasing, cleaning, pickling, milling, etching, polishing,
                     and electroless  plating.    Electrochemical  processes  include plating,
                     electropolishing, and anodizing (EPA/ORD, 1994).

        Cleaning/Preparing

                     Cleaning
                     Aerospace  components are cleaned frequently during manufacturing to
                     remove contaminants such as dirt, grease,  and oil, and to prepare the
                     components for the next operation. Cleaning is important in order to ensure
                     the successful application of later surface treatments. There are three main
                     types of cleaning: aqueous, organic solvent, and abrasive. Aqueous cleaning
                     covers a wide variety of cleaning methods such as detergents,  acids, and
                     alkaline compounds to displace soil rather than dissolving it as  in organic
                     solvent cleaning.  Aqueous cleaners are either sprayed or used in cleaning
                     baths,  ultrasonic  baths, and in steam cleaning.  Three types of aqueous
                     cleaning favored by the aerospace industry are:

                            •emulsification cleaning-  emulsification  cleaning  uses  water-
                            immiscible solvents, surfactants, and emulsifiers.
                            •acid cleaning- sulfuric acid or hydrochloric acid is used  to remove
                            scale from metal; acid cleaning is sometimes known as pickling
                            baths.
                            •alkaline cleaning- alkaline cleaning solutions (usually hot) contain
                            builders (sodium salts of phosphate, carbonate, and hydroxide) and
                            surfactants (detergents and soap) (GARB, 1997).

                     Abrasive cleaning is mechanical cleaning using abrasives such as rough
                     fabric scrubbing pads,  sandpaper, tumbling barrels, buffing wheels, and
                     blasting equipment. Abrasives may be added to acid or alkaline cleaning
                     solutions to improve cleaning action (CARS, 1997).

                     Masking
                     Maskants are coatings that are applied to a part to protect the surface from
                     chemical milling and surface treatment processes such as anodizing, plating,
                     and bonding. Maskants are typically rubber- or polymeric-based substances
                     applied to an entire part or subassembly by brushing, dipping, spraying, or
                     flow coating. Two major types of maskants are used: solvent-based and
                     waterborne. After an adequate thickness of maskant has been applied to the
                     part, the maskant is cured in a bake oven. The maskant is then cut following
                     a specific pattern and manually stripped away from selected areas of the part
                     where metal is to be removed. The maskant remaining on the part protects
                     those areas from the etching solution.

                     Chemical Milling
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                     Chemical milling is used to reduce the thickness of selected areas of metal
                     parts in order to reduce weight.  The process is typically used when the size
                     or shape of parts precludes mechanical milling or when chemical milling is
                     advantageous due to shorter processing time or its batch capability. Chemical
                     milling is accomplished by submerging the component in an appropriate
                     etchant.  Commonly used etchants are sodium hydroxide for aluminum, nitric
                     acid and hydrofluoric acid for titanium, dilute sulfuric acid for magnesium,
                     and aqua regia (a mixture of nitric and hydrochloric acids) for stainless steel.
                      The depth of the cut is closely  controlled  by the  length of time  the
                     component is in the etchant and the concentration of the etchant.  When the
                     milling has been completed, the part is removed from the etchant and rinsed
                     with water.  Some metals may develop a smutty discoloration during the
                     chemical milling process. A brightening solution, such as dilute nitric acid,
                     is typically used as a final step in the process to remove the discoloration.
                     After desmutting,  the part either goes back to chemical milling for further
                     metal removal or to the stripping area to have the maskant removed.  The
                     maskant may be softened in a solvent solution and then stripped off by hand
                     (EPA/OAQPS, 1994).

                     Anodizing
                     Anodizing uses the piece to be coated, generally with an aluminum surface,
                     as an anode in an electrolytic cell. Anodizing provides aluminum parts with
                     a hard abrasion-  and corrosion-resistant film.  This coating is porous,
                     allowing it to be dyed or to absorb lubricants.  This method is used both in
                     decorative application and in engineering applications such as aircraft landing
                     gear struts.  Anodizing is usually performed  using either sulfuric, boric-
                     sulfuric, or chromic acid often followed by a hot water bath, though nickel
                     acetate or sodium potassium dichromate seal may also be used (EPA/OECA,
                     1995).

                     Passivation
                     Passivation is a chemical process in which parts are immersed in a solution
                     containing a strong oxidizing agent. This forms a thin oxide layer on the part
                     surface, providing corrosion protection and increasing adhesion of subsequent
                     coatings. It is often used before maskant application in the chemical milling
                     process (EPA/OAQPS, 1994).

                     Pickling
                     Pickling is a process of chemical abrasion/etching which prepares surfaces
                     for good paint adhesion.  The pickling process is used mainly for preparing
                     pipe systems and small parts for paint.  However, the process and qualities
                     will vary by facility.  The process involves a system of dip tanks.  In pickling
                      steel parts, The first tank is used to remove any oil, grease, flux, and other
                      contaminants on the  surface being pickled. The part is then immersed into
                      a 5-8% caustic soda and water mixture (pH 8-13) maintained at temperatures
                      of between 180°-200°F. Next, the steel is dipped into a 6-10% acid/water
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                     mixture maintained between 140°-160°F(EPA/OECA, 1997). Most carbon
                     steel is pickled with sulfuric or hydrochloric acid, while stainless steel is
                     pickled with hydrochloric, nitric, and hydrofluoric acids (EPA/OECA, 1995).
                     The fourth tank contains an acid rinse tank that is maintained at a pH of 5-7.
                     Finally, the steel part is immersed in a rust preventative 5% phosphoric
                     mixture.   The part is then allowed to fully dry prior to paint application
                     (EPA/OECA, 1997).

                     Polishing
                     Polishing is used at some facilities to clean and finish the outer skin of the
                     aircraft. The polish is a lightly abrasive metal cleaner that is buffed on the
                     metal surface, then wiped off.  The polish gives a mirror-like surface finish
                     and is usually applied instead of paint. Polishing can also be used on other
                     metal parts as a cleaning step.

                     Conversion Coatings
                     Conversion  coating  is the  process  of  changing  a  metal's  surface
                     characteristics by applying a reactive chemical to the metal's surface or by
                     reacting the metal in a chemical bath. The desired result is improved coating
                     adhesion, increased corrosion resistance, or both (EPA/OAQPS, 1994).

                     Aluminum surfaces are treated with various conversion coatings depending
                     upon the anticipated environmental conditions or performance requirements
                     such as corrosion, electrochemical insulation, and abrasion.  Conversion
                     coatings are also used to  enhance bond and  paint  adhesion.   Typical
                     treatments include chromate phosphates, chromate oxides, anodizing, and
                     non-chromate formulations (GARB, 1997).

                     Cadmium  surfaces  require either a phosphate or  a chromate conversion
                     coating prior to painting.  The phosphate  conversion is designed to be
                     painted; the chromate conversion is designed to add corrosion resistance to
                     the cadmium and it may also be painted (GARB, 1997).

                     Magnesium must be treated with a conversion coating or anodized before
                     painting to prevent corrosion and to  prevent environmental damage by
                     abrasion. Magnesium coatings utilize sodium dichromate solutions (CARB
                     1997).

                     Titanium must be treated with a conversion coating or anodized to protect it
                     from corrosion and to improve adhesion bonding strength. Emersion baths
                     for applying a conversion coating to titanium typically contain sodium
                     phosphate, potassium fluoride, and hydrofluoric acid (CARB, 1997).

       Coating/Painting

                     A coating is a material  that  is applied to the surface  of a part to form a

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                     decorative or functional  solid film.  Coatings  are used for corrosion
                     resistance, aircraft identification  and improved visibility, and  friction
                     reduction. The most common coatings are nonspecialized primers and
                     topcoats, however there are also many specialized primers that  provide
                     characteristics such as fire resistance, flexibility, substrate compatibility,
                     antireflection,  sealing,  adhesion,  and  enhanced  corrosion protection
                     (EPA/OAQPS, 1997).

                     Coatings are applied by spraying, brushing, rolling, flow coating, and dipping
                     using a variety of application equipment including conventional air spray,
                     high volume low pressure (HVLP) spray, and electrostatic spray. Many of
                     the  conventional methods such as rolling, flow coating, dip coating, and
                     brushing are limited to the size and configuration of the part being painted
                     (CARD, 1997).

                     Painting involves the application of predominantly organic coatings to a work
                     piece for protective and/or  decorative purposes.  It is applied in various
                     forms, including dry powder, solvent-diluted formulations, and water-borne
                     formulations. Various methods of application are used,  the most common
                     being spray painting and electrodeposition. Electrodeposition is the process
                     of coating a work piece by either making it anodic or cathodic in a bath that
                     is generally an aqueous emulsion of the coating material. When applying the
                     paint as a dry powder, some  form of heating or baking is necessary to ensure
                     that the powder adheres to the metal. These processes may result in solvent
                     waste  (and  associated  still bottom  wastes  generated  during   solvent
                     distillation), paint sludge wastes, paint-bearing wastewaters, and paint solvent
                     emissions (EPA/OECA, 1995).

                     Spray painting is a process by which paint is placed into a pressurized cup or
                     pot and is atomized into a spray pattern when it is released from the vessel
                     and forced through an orifice. Differences in spray-painting equipment are
                     based on how the equipment atomizes paint. The more highly atomized the
                     paint, the more likely transfer efficiency is to decrease.  Transfer efficiency
                     is the amount of paint applied to the object being painted, divided by the
                     amount of paint used. Highly atomized paint spray can more readily drift
                     away from the painting surface due to forces such as air currents and gravity
                     (Ohio EPA, 1994).  Cleaning solvent can only be sprayed through  a gun for
                     nonatomized and atomized cleaning using specific equipment as specified in
                     theNESHAP.

                     The viscosity of paint may need adjustment before it can be sprayed. This is
                     accomplished by reduction with organic solvents, or with water for certain
                     water-based coatings. Using solvents for reduction requires the purchase of
                     additional materials and increases air emissions.  An alternative method of
                     reducing the viscosity  is to use heat.  Benefits from the purchase of paint
                     heaters include lower solvent usage, lower solvent emissions, more consistent
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                 Industrial Process Descriotion
                     viscosities, and faster curing rates (Ohio EPA, 1994).

                     The following types of spray application equipment may be used in the
                     aerospace industry:

                            •Conventional Spray
                            •High-Volume/Low-Pressure (HVLP)
                            •Airless
                            •Air-Assisted
                            •Electrostatics
                            •Rotary Atomization
                            •Spray Booths
       Electroplating
                     The metals used in electroplating operations (both common and precious
                     metal plating) include cadmium, lead, chromium, copper, nickel, zinc, gold,
                     and silver. Cyanides are also used extensively in electroplating solutions and
                     in some stripping and cleaning solutions (EPA/OECA, 1995).

                     Electroless plating is the chemical deposition of a metal coating onto a metal
                     object, by immersion of the object in an appropriate plating solution.  In
                     electroless nickel plating, the source of nickel is a salt, and a reducer is used
                     to hold the metal ion in the solution. Immersion plating produces a metal
                     deposit by chemical displacement.  Immersion plating baths  are usually
                     formulations of metal  salts,  alkalies,  and complexing agents (typically
                     cyanide or ammonia) (EPA/OECA, 1995).

                     Occasionally, touch-up plating is done on an in-house plating  line that
                     consists of six separate tanks for cleaning, rinsing, and plating. Following
                     touch-up plating, the parts are typically cleaned in a cold solvent-cleaning
                     tank (EPA/NRMRL, 1995).
       Equipment/Line Cleaning
                     Spray guns and coating lines used to apply the various coatings used at
                     aerospace facilities must be cleaned when switching from one coating to
                     another and when they are not going to be immediately reused. Spray guns
                     can be cleaned either manually or with enclosed spray gun cleaners.  Manual
                     cleaning involves disassembling  the gun  and placing the parts in a  vat
                     containing an appropriate cleaning solvent. The residual paint is brushed or
                     wiped off the parts.  After reassembling, the cleaning solvent may be sprayed
                     through the gun for a final cleaning. Paint hoses/coating lines are cleaned by
                     passing the  cleaning solvent through the lines until all coating residue is
                     removed. Enclosed spray gun cleaners are self-contained units that pump the
                     cleaning solvent through the gun within a closed chamber. After the cleaning
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                     cycle is complete, the guns are removed from the chamber and typically
                     undergo some manual cleaning to remove coating residue from areas not
                     exposed to the cleaning solvent, such as the seals under the atomizing cap
                     (EPA/OAQPS, 1997).

       III.A.4. Composites Processing

                     The aerospace industry is increasingly substituting composites for metals in
                     aircraft and space vehicles due to the  superior strength-to-weight ratio,
                     corrosion resistance, and  fatigue life of composites.   Composites are
                     comprised of a resin matrix that bonds together layers of reinforcing material.
                     The resultant structure has mechanical properties superior to each individual
                     component. The resin matrix is usually a polymeric material such as epoxy,
                     polyester, nylon, or phenolic.  The reinforcing material or fiber is usually
                     carbon (graphite), fiberglass, or Kevlar.  The fibers are oriented at specific
                     angles within the matrix to achieve desired strength characteristics. Methods
                     of forming composites include: injection molding, compression molding, and
                     hand lay-up (or wet lay-up). Hand lay-up can involve applying resin on pre-
                     woven fibers or can involve stacking thin sheets of pre-impregnated (prepreg)
                     fiber material. Steps in hand lay-up are typically: lay-up, debulking, curing,
                     and tear-down (break-out).

                     Injection molding is the process of shaping a material by applying heat and
                     utilizing the  pressure created by injecting a resin into  a closed mold.
                     Compression molding is  the process  of  filling  a mold with molding
                     compound, closing  the mold, and applying heat and pressure until the
                     material has cured. Lay-up is the process of assembling composite parts by
                     positioning reinforcing material in amold and impregnating the material with
                     resin. With hand lay-up, reinforcing material with resin or prepreg can be
                     added to an open mold until the design thickness and contours are achieved.
                     Debulking is the simultaneous application of low-level heat and pressure to
                     composite materials to force out excess resin, trapped air, vapor, and volatiles
                     from between the layers of the composite, thus removing voids within the
                     composite.

                     Curing is the process of changing the resin into a solid material so that the
                     composite part holds its shape. This is accomplished by heating the lay-up
                     assembly in order to initiate a polymerization reaction within the resin. Once
                     the reaction  is  complete,  the resin solidifies and bonds the layers  of
                     composite materials together.  The curing process is typically performed in
                     an autoclave  (a pressurized oven), with the composite lay-up enclosed in a
                     bag so that  a vacuum can be  applied.  The vacuum  removes  air and
                     volatilized  components of the resin from within the composite structure
                     which may otherwise be trapped and create voids. Key parameters for curing
                     are time, pressure, vacuum, temperature, and heating and  cooling rates.
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                     Break-out is the removal of the composite materials from the molds or curing
                     fixtures (includes the application of release agents prior to filling the mold).
 III.B. Aircraft Assembly

                     Aircraft assembly requires the coordination of thousands of parts coming
                     together to form one large final product. The total assembly process of a
                     complete aircraft can be close to two years.  The relatively small number of
                     finished products  does not allow for a great deal of automation  in the
                     assembly process. Considerable coordination is needed between materials
                     delivery and the production schedule in order to achieve efficient assembly.

       Assembly Equipment

                     Typical materials handling equipment includes conveyors, cranes, industrial
                     vehicles (e.g., forklifts, flatbeds, carts,  special  lift  vehicles, etc.),  and
                     containers (EPA/OECA, 1997). Assembly facilities may also use jigs to aid
                     in lining up or joining pieces.

                     Assembly jigs are  essential for the successful  assembly or large aerospace
                     products. Their main function is to identify the precise location of fittings for
                     attachment of one  component  to another.  Assembly  jigs should be
                     constructed hi a manner which allows them to be removed upon completion
                     of the work without breaking down the entire jig structure.  They require
                     materials which will not bend or distort over a period of time or during
                     assembly operations. They must also provide easy access to locations where
                     manual joining operations are needed (Home, 1986).

                     Pin jigs are used to assemble the curved sheets that form the outside of the
                     fuselage's curved surface.  The pin jig is simply a series of vertical screw
                    jacks that support  curved pieces during construction.  A pin jig is set up
                     specifically for the curved piece under construction.  The jig heights are
                     determined from the  engineering drawings and plans (EPA/OECA, 1997).

                     Specially designed locating jigs are required for skins to which stiffeners are
                     to be riveted, such as airplane wings. Stiffeners are first placed in the jigs and
                     then locked in the required position on the completed wings. Wing skins are
                     then placed on the jig and held to a contoured shape with metal bands in
                     order to make contact with the stringers. Holes are drilled through the skin
                     and stringers by using templates to locate hole positions.  When all  of the
                     holes have been drilled, they are filled with clamping bolts and the metal
                     bands are released. The skin is taken out of the jig and the clamping bolts
                     hold the skin in the desired shape until it  is riveted together (Home, 1986).
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                    Fuselage assembly operations may follow these steps:

                           •bond stringers to fuselage skin
                           •fit formers to assembly jig
                           •assemble skin, drill flanges, and fit riveting clamps
                           •replace clamps with rivets and remove panel from the jig
                           •assemble panels and formers on  fuselage assembly jig (Home,
                           1986).

       Welding/Riveting

                    Fusion Welding
                    Fusion welding is performed with a metal arc in the presence of an inert gas
                    which prevents the oxidation of the metals to be welded. An alternating or
                    direct current, depending on the type and thickness of the metal, is typically
                    applied through an electrode. The ideal current and pulse duration is selected
                    according to the wire composition, shielding gas, welding position, and wire
                    size (Home, 1986).

                    Resistance Welding
                    Resistance welding requires: a primary electrical circuit from a transformer;
                    a secondary circuit and electrodes to conduct the current to the desired spot;
                    a mechanical system to  hold the components and apply force; and control
                    equipment to measure duration  and  magnitude of the  electrical current.
                    Press-type machines have a moveable welding head and force is applied by
                    air through hydraulic cylinders. Seam  welding is performed by power-driven
                    roller electrodes instead of the pointed electrodes used for spot welding.
                    Leak-proof and pressure-tight welds are formed by the seam welding process,
                    where each weld overlaps the previous one (Home, 1986).

                    Pre-pressure jig welding uses a jig to clamp  the components together to
                    relieve the electrodes from clamping stress. This ensures that the desired
                    electrode pressure is available (Home, 1986).

                    Electron Beam Welding
                    Electron beam welding is achieved by concentrating a beam of high velocity
                    electrons onto the surfaces to be joined.  The electrons are produced and
                    accelerated by an electron beam gun which consists of a filament emitter, a
                    bias electrode, and a positively charged anode.  The electrons are generated
                    by thermionic emission from  a filament. Their attraction to an anode gives
                    them speed and direction, and a bias  electrode cup surrounding the emitter
                    electrostatically shapes  ejected electrons into a beam. An electromagnetic
                    lens system reconverges the beam once its left the anode and focusses it on
                    the work piece (Home, 1986).

                    Riveting
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                     Riveted joints are usually in sheet metal parts where the rivets take a shearing
                     load.  Riveted joints may be in single, double, triple, or quadruple rows and
                     either chain or zigzag (Home, 1986).
       Sealing/Bonding

                     Sealants, predominantly composed of poly sulfide, are applied throughout the
                     aerospace vehicle structure primarily to seal out moisture and contaminants.
                     This helps prevent corrosion, particularly on faying (i.e., closely or tightly
                     fitting) surfaces, inside holes  and slots, and around installed fasteners.
                     Sealants are also used to seal fuel tanks and pressurized components. They
                     are applied using tubes, spatulas, brushes, rollers, or spray guns. Sealants are
                     often stored frozen and thawed before use, and many are two-component
                     mixtures that cure after mixing.  Typically,  a  sealant is applied before
                     assembly or fastener installation, and the excess is squeezed out or extruded
                     from between the  parts as the assembly is completed.  This ensures a
                     moisture-tight seal  between the parts (EPA/OAQPS, 1997).

                     Adhesive bonding involves joining together two or more metal or nonmetal
                     components.  This process is typically performed when the joints being
                     formed are  essential to the structural integrity of the aerospace vehicle or
                     component.  Bonding surfaces are typically roughened mechanically or
                     etched chemically to provide increased surface area for bonding and then
                     treated chemically to provide a stable corrosion-resistant oxide layer. The
                     surfaces are then thinly coated with an adhesive bonding primer to promote
                     adhesion and protect from subsequent corrosion.  Structural adhesives are
                     applied as either a thin film or as a paste. The parts are joined together and
                     cured either at ambient temperature, in an oven, or in an autoclave to cure the
                     adhesive and  provide  a permanent  bond  between  the components
                     (EPA/OAQPS, 1997).

                     Nonstructural adhesives are used to bond materials that are not critical to the
                     structural integrity  of the aerospace vehicle or component, such as gaskets
                     around windows and carpeting or to nonstructurally joined components.
                     These adhesives are  applied using  tubes,  brushes,  and  spray guns
                     (EPA/OAQPS, 1997).

       Testing

                     A wide variety of tests are performed by the aerospace industry to verify that
                     parts meet  manufacturing specifications.  Leak tests are performed on
                     assemblies such as  wing fuel tanks. These parts are filled with an aqueous
                     solution or a gas to  check seams and seals. Dye penetrant is used following
                     chemical milling and other operations to check for cracks,  flaws, and

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Aerospace Industry
Industrial Process Description
                     fractures. Many different kinds of penetrants, fluids, dyes, and etchants can
                     be applied to the surface of metal parts to aid in the detection of defects.
                     Hydraulic and fuel system checks are other typical testing operations. Weight
                     checks are performed to verify the balance of certain structures, such as
                     propeller blades and vertical tail rudders.   Some critical areas on the
                     assembled components are checked for flaws, imperfections, and proper
                     alignment of parts by X-ray (EPA/OAQPS,  1994).

III.C.  Repair/Rework Operations

                     Repair operations generally include all conversions, overhauls, maintenance
                     programs, major damage repairs, and minor equipment repairs.  Although
                     specific repair methods vary from job to job, many of the operations are
                     identical to new construction operations.  Repair operations, however, are
                     typically on a smaller scale and are performed at a faster pace. Jobs can last
                     anywhere from one day to over a year.  Repair jobs often have severe time
                     constraints requiring work to be completed as quickly as possible in order to
                     get the aircraft, missile, or space vehicle back in service. In many cases,
                     piping, ventilation, electrical, and other machinery are prefabricated prior to
                     the major product's arrival.   Typical maintenance and  repair operations
                     include:

                            •Cleaning and repainting the aircraft's surfaces, superstructure, and
                            interior areas
                            •Major rebuilding and installation of equipment such as turbines,
                            generators, etc.
                            •Systems overhauls, maintenance, and installation
                            •System replacement and new installation of  systems such as
                            navigational systems, combat systems, communication systems, etc.
                            •Propeller   and rudder  repairs,  modification,  and  alignment
                            (EPA/OECA, 1997)

                     The depainting operation involves the removal of coatings from the outer
                     surface of the aircraft. The two basic types are chemical depainting and blast
                     depainting.  Methylene chloride  is the most common chemical stripper
                     solvent; however, the particular solvent used is highly dependent on the type
                     of coating to be removed. Chemical depainting agents are applied to the
                     aircraft, allowed to degrade the coating, and then scraped or washed off with
                     the coating residue. Blast depainting methods utilize a media such as plastic,
                     wheat starch, carbon dioxide (dry ice), or high pressure water to remove
                     coatings by physically abrading the coatings from the surface of the aircraft.
                     Grit blasting and sand/glass blasting are also included in this category. High
                     intensity ultraviolet light stripping has been developed for use in conjunction
                     with carbon dioxide methods and is under development at several facilities
                     (EPA/OAQPS, 1994).  However, FAA has strict guidelines for safety and
                     quality control purposes which dictate the types of solvents and materials that
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Aerospace Industry                                         Industrial Process Description

                     may be used in aerospace operations. Thus, any alternative must go through
                     a comprehensive study before it is approved for use. (See Section V- Pollution
                     Prevention Opportunities)
                     In addition, some larger facilities are capable of large repair and conversion
                     projects that could include: converting passenger planes to cargo planes,
                     replacing  segments of  an aircraft that has been damaged, structural
                     reconfiguration and outfitting of combat systems, major remodeling of
                     interiors or exteriors (EPA/OECA, 1997).

III.D.  Space Vehicles and Guided Missiles

                     Many of the industrial processes involved in the production of space vehicles
                     and guided missiles are similar to those discussed above in the production of
                     aircraft parts and assembly. Because the number of establishments involved
                     in the production of space vehicles, guided missiles, and their associated parts
                     is less than 10 percent of the total industry, no additional information on
                     industrial processes will be presented here.  Also, due to  the confidential
                     nature of some of these products, there is little information available on
                     production technologies.

III.E.  Raw Materials Inputs and Pollution Outputs

                     The Aerospace Industries Association estimates  that there are 15,000 to
                     30,000 different materials used in manufacturing, many of which may be
                     potentially toxic, highly volatile, flammable, contain chloroflourocarbons, or
                     contribute to global warming (AIA, 1994).  Material inputs for aerospace
                     manufacturing include metals, solvents, paints and coatings, and  plastics,
                     rubbers, and fabrics. Metals used in manufacturing include steel, aluminum,
                     titanium, and many specialty alloys. There is also a wide variety of paints,
                     solvents, and coatings available to the aerospace industry.  Many of these
                     materials are specifically required by FAA guidelines.

                     Pollutants  from metal fabricating processes are dependant on the metal and
                     machining techniques being used.  Larger pieces of scrap metal are usually
                     recovered  and reintroduced to the process, while smaller shavings may be
                     sent off-site for disposal or recovery.

                     Surface preparation operations generate wastes contaminated with solvents
                     and/or metals depending on the type of cleaning operation. Degreasing
                     operations may result in solvent-bearing wastewaters, air emissions,  and
                     materials in solid form. Chemical surface treatment operations can result in
                     wastes containing metals. Alkaline, acid, mechanical, and abrasive cleaning
                     methods can generate  waste streams  such as spent cleaning media,
                     wastewaters, and rinse waters. Such wastes consist primarily of the metal

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Aerospace Industry
               Industrial Process Description
                    complexes or particles, the cleaning compound, contaminants from the metal
                    surface, and water. In many cases, chemical treatment operations are used in
                    conjunction with organic solvent cleaning systems. As such, many of these
                    wastes may be cross-contaminated with solvents (EPA/OECA, 1995).

                    Surface finishing and related washing operations account for a large volume
                    of wastes associated with aerospace metal finishing. Metal plating and
                    related waste account for the largest volumes of metal  (e.g., cadmium,
                    chromium, copper, lead, mercury, and nickel) and cyanide bearing wastes
                    (EPA/OECA, 1995).
       Air Emissions
       Wastewater

                    Air emissions, primarily volatile organic compounds (VOCs), result mainly
                    from  the  sealing, painting, depainting, bonding,  finishing  application
                    processes  including material  storage, mixing,  applications, drying,  and
                    cleaning. These emissions are composed mainly of organic solvents which
                    are used as carriers for the paint or sealant and as chemical coating removers.
                    Most  aerospace coatings  are  solvent-based, which contain a mixture of
                    organic solvents,  many of which are VOC's.  The most  common VOC
                    solvents used in coatings are trichloroethylene, 1,1,1 -trichloroethane, toluene,
                    xylene, methyl ethyl ketone, and methyl isobutyl ketone. The most common
                    VOC  solvent used for coating removal is methylene chloride.  The VOC
                    content ranges differ for the various coating categories.  Air  emissions from
                    cleaning and degreasing operations may result through volatilization during
                    storage, fugitive losses during use, and direct ventilation of fumes. Releases
                    to the air from metal shaping processes contain products of combustion (such
                    as fly ash, carbon, metallic dusts) and metals and abrasives (such as sand and
                    metallic particulates).
                    Wastewater is produced by almost every stage of the manufacturing process.
                    Metalworking fluids, used in machining and shaping metal parts, are a
                    common source of wastewater contamination. Metalworking fluids can be
                    petroleum-based, oil-water emulsions, or synthetic emulsions that are applied
                    to either the tool or the metal being tooled to facilitate the shaping operation.
                    Waste cooling waters  can be  contaminated with metalworking  fluids
                    (EPA/OECA, 1995).

                    Surface preparation, cleaning, and coating removal often involves the use of
                    solvents which can also contribute to wastewater pollution. The nature of the
                    waste will depend upon the specific cleaning application and manufacturing
                    operation. Solvents may be rinsed into wash waters and/or spilled into floor
                    drains (EPA/OECA, 1995).
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Aerospace Industry	Industrial Process Description

                     Wastewater may also be generated in operations such as quenching and
                     deburring.  Such wastewater can be high in oil  and suspended  solids.
                     Wastewater from metal casting and shaping mainly consists of cooling water
                     and wet scrubber effluent.  The scrubber water is typically highly alkaline
                     (EPA/OECA, 1997).

                     Wastewater contaminated with paints and solvents may be generated during
                     equipment cleaning operations; however,  water  is typically only used in
                     cleaning water-based paints.  Wastewater is also  generated when water
                     curtains (water wash spray booths) are used during painting.  Wastewater
                     from painting water curtains commonly contains organic pollutants as well
                     as certain metals (EPA/OECA, 1997).

                     Electroplating operations can result in solid and  liquid waste streams that
                     contain toxic constituents. Aqueous wastes result from work piece rinses and
                     process cleanup waters.  In addition to these wastes, spent process solutions
                     and quench baths are discarded periodically  when the concentrations of
                     contaminants inhibit proper function of the solution or bath. When discarded,
                     process baths usually consist of solid-phase and liquid-phase wastes that may
                     contain high concentrations of toxic constituents, especially cyanide. Rinse
                     water from the electroplating process may  contain zinc, lead, cadmium, or
                     chromium (EPA/OECA, 1995).

       Solid/Hazardous/Residual Waste

                     Solid,   hazardous,  and residual  wastes  generated  during  aerospace
                     manufacturing include contaminated metalworking fluids, scrap metal, waste
                     containers, and spent equipment or materials.  Scrap metal is produced by
                     metal shaping operations and may consist of metal removed from the original
                     piece (e.g., steel or aluminum). Scrap may  be reintroduced into the process
                     as a feedstock or recycled off-site.

                     Various solid and liquid wastes, including waste solvents, blast media, paint
                     chips,  and spent equipment may be generated  throughout painting and
                     depainting operations. These solid and liquid wastes are usually the result of
                     the following operations:

                           •Paint applications- paint overspray caught by emissions control
                           devices (e.g., paint booth collection systems, ventilation filters, etc.)
                           •Depainting- spent blast media, chips, and paint and solvent sludges
                           •Cleanup operations- cleaning of equipment and paint booth area
                           •Disposal- discarding  of leftover  and unused paint as well as
                           containers used to hold paints, paint materials, and overspray

                     Solvents are also used during cleanup processes to clean spray equipment
                     between color changes, and to clean portions of the spray booth. The solvent

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Aerospace Industry
               Industrial Process Description
                    utilized during cleaning is generally referred as "purge solvent" and is often
                    composed of a mixture of dimethyl-benzene, 2-propanone (acetone),  4-
                    methyl-2-pentanone, butyl ester acetic acid, light aromatic solvent naphtha,
                    ethyl benzene,  hydrotreated heavy naphtha,  2-butanone, toluene, and  1-
                    butanol (EPA/OECA, 1995).

                    Metalworking fluids typically become contaminated and spent with extended
                    use and reuse.  When disposed, these oils may contain toxics, including
                    metals (cadmium, chromium, and lead), and therefore must be tested to
                    determine if they are considered a RCRA hazardous waste.  Many fluids may
                    contain chemical additives such as chlorine, sulfur, phosphorous compounds,
                    phenols, cresols, and alkalines. In the past, such oils have commonly been
                    mixed with used cleaning fluids and solvents (including chlorinated solvents)
                    (EPA/OECA, 1995).

                    If metal coating operations use large quantities of molding sand, spent sand
                    may  be generated.   The largest waste by  volume from metal casting
                    operations is waste sand. Other residual wastes may include dust from dust
                    collection systems, slag, arid off-spec products. Dust collected in baghouses
                    may inclu'de zinc, lead,  nickel, cadmium, arid chromium.  Slag' is a glassy
                    mass composed of metal oxides from the melting process, incitedrefractories,
                    sand, and other materials (EPA/OECA, 1997).

                    Centralized wastewater treatfherit system's are eotrmiori arid can result in
                    solid-phase wastewater treatment Sludges. Any solid wastes (e.g., wastdwa'ie'r
                    treatment sludges, still  bottoihSj cleaning" tank  residues,' machining fluid
                    residues, etc.) generated by the manufacturing  process  ttiay  also  be
                    contaminated with solvents (EPA/OECA, 199'5).

                    Table 6 su'rrifnarizds the ffiatefial ifip'ttts and ^llutdrit outputs frorh the
                    vafidiiS aerosp'ace rrianufacturirig operations.
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 Aerospace Industry
               Industrial Process Descrintion
Table 6: Material Input and Pollutant Outputs
Process
Metal
Shaping
Grinding/
Polishing
Plating
Painting
Cleaning,
depainting,
and vapor
degreasing
Material Input
Cutting oils,
degreasing and
cleaning
solvents, acids,
metals
Metals, abrasive
materials,
machining oils
Acid/alkaline
solutions, metal
bearing and
cyanide bearing
solutions
Solvent based
or water based
paints
Acid/alkaline
cleaners and
solvents
Air Emissions
Solvent wastes
(e.g., 1,1,1-
trichloroethane,
acetone, xylene,
toluene, etc.)
Metal shavings/
particulates,
dust from
abrasive
materials
Volatized
solvents and
cleaners
Paint overspray,
solvents
Solvent wastes,
acid aerosols,
paint chips and
particulates
Wastewater
Acid/alkaline wastes
(e.g., hydrochloric,
sulfuric, and nitric acids),
waste coolant water with
oils, grease, and metals
Wastewaters with oil,
grease, and metal from
machining
Waste rinse water
containing
acids/alkalines cyanides,
and solvents
Cleaning water
containing paint and
stripping solutions
Wastewater containing
acids/alkalines, spent
solvents
Solid/Hazardous/
Residual Wastes
Scrap metal, waste
solvents
Abrasive waste
(e.g., aluminum
oxide, silica,
metal), metal
shavings, dust
Metal wastes,
solvent wastes,
filter sludges
(silica, carbides)
wasted plating
material (copper,
chromium, and
cadmium)
Waste paint, empty
containers, spent
paint application
equipment
Spent solvents,
paint/solvent
sludges, equipment
and abrasive
materials, paint
chips
Source: Pollution Prevention Assessment for a Manufacturer of Aircraft Landing Gear, EPA, August 1 995 and
Guides to Pollution Prevention. The Fabricated Metal Products Industry EPA Julv 1990
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Aerospace Industry
                                                           Industrial Process Description
III.F. Management of Chemicals in Wastestream
                    The Pollution Prevention Act of 1990 (PPA) requires facilities to report
                    information about  the management of Toxic  Release Inventory (TRI)
                    chemicals in waste and efforts made to eliminate or reduce those quantities.
                    These data have been collected annually in Section 8 of the TRI reporting
                    Form R beginning with the 1991 reporting year. The data summarized below
                    cover the years 1994-1997 and are meant to provide a basic understanding of
                    the quantities of waste handled by the industry, the methods typically used to
                    manage  this waste, and recent trends in these methods.  TRI waste
                    management data can be used to assess trends in source reduction within
                    individual industries and facilities, and for specific TRI chemicals.  This
                    information could then be used as a tool in identifying opportunities for
                    pollution prevention and compliance assistance activities.

                    While the quantities reported for 1995 and 1996 are estimates of quantities
                    already managed, the quantities listed by facilities for 1997 and 1998 are
                    projections only. The PPA requires these projections to encourage facilities
                    to consider future source reduction, not to establish any mandatory limits,
                     Future-year estimates are not commitments that facilities reporting under TRI
                     are required to meet

                     Table 7 shows that the TRI reporting aerospace facilities managed about 37
                     million pounds of production related wastes (total quantity of TRI chemicals
                     in the waste from routine production operations in column  B) in  1996.
                     Production related wastes were projected to continue to decrease slightly in
                     1997 and 1998. Note that the effects of production increases and decreases
                     on the quantities of wastes generated are not evaluated here, but production
                     has generally been increasing hi recent years.

                     In 1995, about 34 percent of the industry's TRI wastes were managed on-site
                     through recycling, energy recovery, or treatment as shown in columns C, D,
                     and E, respectively. This decreased to 25 percent hi 1996 and was expected
                     to slightly increase to over 30 percent in 1998. The majority of these on-site
                     managed wastes were recycled on-site in 1995.  About 39 percent  of the
                     industry's TRI wastes were transferred off-site for recycling, energy recovery,
                     or treatment as shown in columns F, G, and H. This increased to 50 percent
                     in 1996. Most of the off-site managed wastes were recycled as well.  The
                     remaining portion of the production related wastes, shown in column I, (31
                     percent in 1995 and 27 percent in 1996) is either released to the environment
                     through direct discharges to air, land, water, and underground injection, or is
                     transferred off-site for disposal.
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  Aerospace Industry
                Industrial Process Description
Table 7: Source Reduction and Recycling Activity for Aerospace Manufacturers
Facilities (SICs 372 or 376) as Reported within TRI

Year
1995
1996
1997
1998

Quantity of
Production-
Related
Waste
( 10s Ibs.V
40.6
36.5
35.2
33.3

C
%
Recycled
22%
14%
14%
19%
On-Site
D
% Energy
Recovery
0%
0%
0%
0%
E
% Treated
12%
11%
12%
12%
Off-Site
F
%
26%
36%
36%
33%
G
% Energy
3%
4%
4%

H

10%
10%
10%

1 I
%
Released
and
Disposed'
Off-site
31%
27%
24%
21%
Source: 1996 Toxics Release Inventory Database.
' Within this industry sector, non-production related waste < 1% of production related wastes for 1995.
b Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production
related wastes.
e Percentage of production related waste released to the environment and transferred off-site for
disposal.
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Aerospace Industry
                                                       Chemical Releases and Transfers
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
                    This section is designed to provide background information on the pollutant
                    releases that are reported by this industry. For industries that are required to
                    report, the best source of comparative pollutant release information is the
                    Toxic Release Inventory (TRI).  A component of the Emergency Planning
                    and Community Right-to-Know Act, TRI includes self-reported facility
                    release and transfer data for over 600 toxic chemicals. Facilities within SIC
                    Codes 20 through 39 (manufacturing industries) that have more than 10
                    employees, and that are above weight-based reporting thresholds are required
                    to  report TRI on-site  releases  and off-site  transfers.  The  information
                    presented within the sector notebooks is derived from the most recently
                    available (1996) TRI reporting year (which includes over 600 chemicals), and
                    focuses primarily on the on-site releases reported by each sector.  Because
                    TRI requires consistent reporting regardless of sector, it is an excellent tool
                    for drawing comparisons across industries. TRI data provide the type, amount
                    and media receptor of each chemical released or transferred.

                    Although this  sector notebook does not  present  historical  information
                    regarding TRI chemical releases over time, please note that in general, toxic
                    chemical releases have been declining. In fact, according to the 1996 Toxic
                    Release Inventory Public Data Release, reported onsite  releases of toxic
                    chemicals to the environment decreased by 5 percent (111.6 million pounds)
                    between 1995 and 1996 (not including chemicals added and removed from
                    the TRI chemical list during this period). Reported releases dropped by 48
                     percent between 1988 and 1996. Reported transfers of TRI chemicals to off-
                     site locations increased by 5 percent(14.3 million pounds) between 1995 and
                     1996. More detailed information can be obtained from EPA's annual Toxics
                     Release Inventory Public Data Release book (which is  available through the
                     EPCRA Hotline at 800-535-0202),  or directly from the Toxic Release
                     Inventory System database (for user support call 202-260-1531).

                     Wherever possible, the sector notebooks present TRI data as the primary
                     indicator of chemical release within each industrial  category.   TRI data
                     provide the  type, amount and media  receptor of each chemical released or
                     transferred.  When other sources of pollutant release data have been obtained,
                     these data have been included to augment the TRI information.
 TRI Data Limitations
                      Certain limitations exist regarding TRI data. Within some sectors, (e.g. dry
                      cleaning, printing and transportation equipment cleaning) the majority  of
                      facilities are not subject to TRI reporting because they are not considered
                      manufacturing industries, or because they are below TRI reporting thresholds.
                      For these sectors, release information from other sources has been included.
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 Aerospace Industry
              Chemical Releases and Transfers
                      Reported chemicals are limited to the approximately 600 TRI chemicals. A
                      portion of the emissions from aerospace facilities, therefore, are not captured
                      by TRI.

                      In addition, many facilities report more than one SIC code reflecting the
                      multiple operations carried out on-site.  Therefore, reported releases and
                      transfers may or may not all be associated with the industrial operations
                      described in this notebook.

                      The reader should also be aware that TRI "pounds released" data presented
                      within the notebooks is not equivalent to a "risk" ranking for each industry.
                      Weighting  each pound of release equally  does not factor in the relative
                      toxicity of each chemical that is released or the potential exposure  to
                      surrounding populations. The Agency is in the process of developing  an
                      approach to assign toxicological weightings to each chemical released so that
                      one can  differentiate between pollutants with significant differences  in
                     toxicity.  As a preliminary indicator of the environmental impact of the
                     industry's most commonly released chemicals,  the  notebook briefly
                     summarizes the toxicological properties of the top five chemicals (by weight)
                     reported by the industry.

 Definitions Associated With Section IV Data Tables

       General Definitions

                     SIC Code - is the Standard Industrial Classification (SIC) code, a statistical
                     classification standard used for all establishment-based Federal economic
                     statistics. The SIC codes facilitate comparisons between facility and industry
                     data.

                     TRI Facilities - are manufacturing facilities that have 10 or more full-time
                     employees  and are above established  chemical throughput thresholds.
                     Manufacturing facilities  are  defined as facilities in Standard Industrial
                     Classification primary codes 20-39. Facilities must submit estimates for all
                     chemicals that are  on the  EPA's defined list and are above throughput
                     thresholds.

       Data Table Column Heading Definitions

                     The following definitions are based upon standard definitions developed by
                     EPA's Toxic Release Inventory Program.  The categories below represent the
                     possible pollutant destinations that can be reported.
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Aerospace Industry
                                                        Chemical Releases and Transfers
                    Releases — are on-site discharges of a toxic chemical to the environment.
                    This includes emissions to the air, discharges to bodies of water, releases at
                    the facility to land, as well as contained disposal into underground injection
                    wells.

                    Releases to Air (Point  and Fugitive Air Emissions) - include all air
                    emissions from industry activity. Point emissions occur through confined air
                    streams as found in stacks, vents, ducts, or pipes. Fugitive emissions include
                    equipment leaks, evaporative losses from surface impoundments and spills,
                    and releases from building ventilation systems.

                    Releases to Water (Surface Water Discharges) - encompass any releases
                    going directly to streams, rivers, lakes, oceans, or other bodies of water.
                    Releases due to runoff, including storm water runoff, are also reportable to
                    TRI.

                    Releases to Land -- occur within the boundaries of the reporting facility.
                     Releases to land include disposal of toxic chemicals in landfills,  land
                     treatment/application farming, surface impoundments, and other disposal on
                     land (such as spills, leaks, or waste piles).

                     Underground Injection ~ is a contained release of a fluid into a subsurface
                     well for the purpose of waste disposal. Wastes containing TRI chemicals are
                     injected into either Class I wells or Class V wells. Class I wells are used to
                     inject liquid hazardous wastes or dispose of  industrial and municipal
                     wastewaters beneath the lowermost underground source of drinking water.
                     Class V wells are generally used to inject non-hazardous fluid into or above
                     an underground source of drinking water.  TRI reporting does not currently
                     distinguish between these two types of wells, although there are important
                     differences in environmental impact between these two methods of injection.

                     Transfers -- are transfers of toxic chemicals in  wastes to a facility that  is
                     geographically or physically separate from the facility reporting under TRI.
                     Chemicals reported to TRI as transferred are sent to off-site facilities for the
                     purpose of recycling, energy recovery, treatment, or disposal. The quantities
                     reported represent a movement of the chemical away from the reporting
                     facility. Except for off-site transfers for disposal, the reported quantities do
                     not necessarily represent entry of the chemical into the  environment.

                     Transfers to POTWs ~ are wastewater transferred through pipes or sewers
                     to a publicly owned treatments works (POTW).  Treatment or removal of a
                      chemical from the wastewater depends on the nature of the chemical, as well
                      as the treatment methods present at the POTW.  Not all TRI chemicals can
                      be treated or removed by a POTW. Some chemicals, such as metals, may be
                      removed but not destroyed and may be disposed of in landfills or discharged
                      to receiving waters.
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 Aerospace Industry	Chemical Releases and Transfers

                      Transfers to Recycling - are wastes sent off-site for the purposes of
                      regenerating or recovery by a variety of recycling methods, including solvent
                      recovery, metals recovery, and acid regeneration. Once these chemicals have
                      been recycled,  they may be returned to the originating facility or sold
                      commercially.

                      Transfers to Energy Recovery - are wastes combusted off-site in industrial
                      furnaces for energy recovery. Treatment of a chemical by incineration is not
                      considered to be energy recovery.

                      Transfers to Treatment ~ are wastes moved off-site to be treated through
                      a variety of methods, including neutralization, incineration,  biological
                      destruction, or physical separation.  In some cases, the chemicals are not
                      destroyed but prepared for further waste management.

                      Transfers to Disposal ~ are wastes taken to another facility for disposal,
                      generally as a release to land or as an injection underground.

 IV.A. EPA Toxic Release Inventory for the Aerospace Industry

                      This section summarizes TRI data of aerospace facilities reporting SIC codes
                      within 372 and 376 as the primary SIC code for the facility.

                      According to the 1996 Toxics Release Inventory (TRI) data, 199 aerospace
                      facilities released (to the air, water, or land) and transferred (shipped off-site
                      or discharged to sewers) a total of approximately 27 million pounds of 65
                      different toxic chemicals during calendar year  1996.   This represents
                      approximately one half of one percent of the 5.6 billion pounds of releases
                     and transfers from all manufacturers (SICs 20-39) reporting to TRI that year.
                     Facilities released an average of 43,862 pounds per facility and transferred
                     and average of 93,503 pounds per facility. The top four chemicals released
                     by  weight are  solvents- methyl  ethyl ketone,  1,1,1-trichloroethane,
                     trichloroethylene, and toluene. These four account for about 66 percent (5.8
                     million pounds) of the industry's total releases. Nickel, chromium, sulfuric
                     acid, and methyl ethyl ketone were the four top chemicals transferred by
                     weight. These four account for 55 percent (10.2 million pounds) of the total
                     TRI chemicals transferred by the aerospace industry. Only 22 percent of the
                     65 chemicals reported to TRI as releases or transfers were reported by more
                     than 10 facilities, evidence of the many different materials used by the
                     industry and the variance between facilities on choice of these materials.

       Releases

                     Table 8 presents the number and weights of chemicals released by aerospace
                     facilities reporting SIC 372 and 376.  The total quantity of releases was 8.7
                     million pounds or 32 percent of the total weight of chemicals released and

Sector Notebook Project                     44                             November 1998

-------
Aerospace Industry
                                                         Chemical Releases and Transfers
                     transferred.  The vast majority of air releases were solvents. Air emissions
                     account for 98 percent of total releases, 44 percent as fugitive air emissions
                     and 54 percent as point air  releases.  Methyl ethyl  ketone was the top
                     chemical released by the aerospace industry, accounting for 25 percent of
                     total releases. Releases of 1,1,1-trichloroethane were the second greatest,
                     representing 20 percent of the total.  Twenty-four percent of fugitive air
                     emissions were of 1,1,1-trichloroethane, and 32  percent of the point air
                     releases were methyl ethyl ketone. Nitrate compounds accounted for 74
                     percent of water discharges.
       Transfers
                     Table 9 presents the number and weights of chemicals transferred off-site by
                     aerospace facilities reporting SIC 372 or 376 in 1996.  The total amount of
                     transfers was  18.6 million pounds or 68 percent of the total releases and
                     transfers reported to the 1996 TRI by aerospace facilities.  Transfers to
                     recycling facilities accounted for the largest percentage,  70 percent, of
                     transfers. The next greatest percentage was 17 percent to treatment facilities.
                     The majority  of transfers consisted of metals, spent acids, and solvents.
                     Sixty-six percent (12.3 million pounds) of the total transfers were metals.
                     Nickel represented the largest quantity of transfers, 5.3 million pounds or 29
                     percent of the total. Chromium composed the second largest quantity of
                     transfers with 12 percent of the total. The chemical with the largest quantity
                     of releases, methyl ethyl ketone, accounted for about  6 percent of the total
                     transfers.
 Sector Notebook Project
45
                                                                            November 1998

-------
Aerospace Industry
Chemical Releases and Transfers
Table 8: 1996 TRI Releases for Aerospace Chemicals Facilities (SICs 372
or 376),

By Number of Facilities Reporting (Releases Reported in Pounds/year) 1
# Reporting
Chemical Name
Methyl Ethyl Ketone
Nitric Acid
Nickel
Chromium
1,1,1-trichloroc thane
Trichlorocthylene
Chromium Compounds
Toluene
Tetrachloroethylene
Dkhloromc thane
Cobalt
ilydrogen Fluoride
Ammonia
Copper
titrate Compounds
Kylcnc (Mixed Isomers)
Nickel Compounds
Phosphoric Acid
Mcthanol
Aluminum (Fume or Dust)
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Hydrochloric Acid (1995 and after "Acid
Aerosols" Only)
Misocyanates
Certain Glycol Ethers
'reon 113
Methyl Isobutyl Ketone
'hcnol
»cad
vfanganese
Copper Compounds
Cobalt Compounds
Rankle Compounds
.cad Compounds
krucnc
Naphthalene
Aluminum Oxide (Fibrous Forms)
Chlorine
vfanganese Compounds
Zinc Compounds
rlcthyl Methacrylate
Ityrene
intimony
anc (Fume or Dust)
Antimony Compounds
larium Compounds
'olyehlorinated Alkanes
'ormaldchyde
sopropyl Alcohol (Manufacturing,
Strong-acid Process Only, No Supplies)
N.n-dimcthylformamide
N-butyl Alcohol
romotrifluoromcthane
'richlorofluorome thane
Sec-butyl Alcohol
PkricAcM
iphcnyl
,2-dtehlorobenzene
ithylbenzene
ithylcne Glycol
Jyclohexane
vlethyl Tert-butyl Ether
, 1-dkhloro-l-fluoroe thane
Mercury
ilver
odium Nitrite
Aluminum Phosphide

Chemical
67
58
48
39
36
29
25
23
21
20
18
16
14
12
10
10
9
9
8
8
8

7

6
6
6
6
6
6
5
4
3
3
3
3
3
3
3
2
2
2
2
2
2
1
1
1
1
1

1
1
1
1
1
1
1









199**
Fugitive
Air
704,499
7,530
15,778
12,829
938,383
671,880
1,685
129,305
237,547
591,048
740
2,841
3,166
311
145
15,356
265
923
13,247
282
16

190,257

390
11,170
114,487
26,191
118
0
15
0
0
0
65
16,997
65,993
290
0
15
0
2,951
11,488
0
5
5
0
0
0
90

250
0
1,641
3,500
14,000
0
0
0
0
0
0
1,200
22,000
0
0
250
0
3.831.144
Point
Air
1,484,499
57,219
8,421
2,813
769,346
268,358
9,815
776,295
388,663
99,403
1,905
14,889
205,300
255
499
211,057
616
1,301
32,566
112
331

54,062

230
10,785
34,782
78,205
2,997
200
11
281
250
0
96
119,768
250
784
0
45
250
1,400
16,500
0
5
4
1
0
0
2,172

250
15,233
0
430
8,800
0
0
1,400
0
0
904
0
0
0
0
4,200
0
4 687 Q5R
Water
Discharges
505
165
972
1,322
5
11
422
260
34
18
476
0
21,646
26
77,000
55
58
0
0
0
0

0

0
0
0
0
0
4
250
543
0
0
0
0
.0
0
98
0
0
0
0
0
18
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
103.888
Underground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
o
0

0
0
o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
A
**Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
Sector Notebook Project


46
Land
Disposal
0
0
20,557
3,343
11,280
2,640
15,866
4,128
0
0
2,774
0
0
0
0
0
0
0
0
0
0

0

0
0
0
0
0
0
o
0
0
0
0
0
0
45,000
o
0
0
0
0
o
0
0
0
o
o
0

0
0
o
o
0
o
o
0
o
0
o
0
0
0
o
0
0
105.588

Total
Releases
2,189,503
64,914
45,728
20,307
1,719,014
942,889
27,788
909,988
626,244
690,469
5,895
17,730
230,112
592
77,644
226,468
939
2,224
45,813
394
347

244,319

620
21,955
149,269
104,396
3,115
204
276
824
250
0
161
136,765
66,243
46,074
98
60
250
4,351
27,988
o
28
9
1
o
o
2,262

500
15,233
1 641
3^930
22,800
0
0
1,400
o
0
904
1,200
22,000
0
o
4,450
0
8 728 578

Avg. Reli
Per Fa j
32l
l]

1
47,1
321
1\
39,]
29 5
*'"f>'\
34,4

1,1
16,4

7,7
22 6
4r.£
-------
      Aerospace Industry
            Chemical Releases and Transfers
         Table 9: 1996 TRI Transfers for Aerospace Chemicals Facilities
               By Number of Facilities Reporting (Transfers Reported in
                      (SICs372or376),
                     Pounds/year)
Chemical Name # Reporting
Chemical
Methyl Ethyl Ketone
Nitric Acid
Nickel
Chromium
1 , 1 , 1 -trichloroethane
Trichloroethylene
Chromium Compounds
Toluene
Tetrachloroethylene
Dichloromethane
Cobalt
Hydrogen Fluoride
Ammonia
Copper
Mitrate Compounds
Xylene (Mixed Isomers)
Nickel Compounds
Phosphoric Acid
vlethartol
Aluminum (Fume or Dust)
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Hydrochloric Acid (1995 and after
"Acid Aerosols" Only)
Diisocyanates
Certain Glycol Ethers
Freon 113
Methyl Isobutyl Ketone
Phenol
Lead
Manganese
Copper Compounds
Cobalt Compounds
Cyanide Compounds
Lead Compounds
Benzene
Naphthalene
Aluminum Oxide (Fibrous Forms)
Chlorine
Manganese Compounds
Zinc Compounds
Methyl Methacrylate
Styrene
Antimony
Zinc (Fume or Dust)
Antimony Compounds
Jarium Compounds
?olychlorinated Alkanes
formaldehyde
isopropyl Alcohol (Manufacturing,
Strong-acid Process Only, No Supplies)
^,n-dimethylformamide
M-butyl Alcohol
Bromotrifluoromethane
Trichlorofluoromethane
Sec-butyl Alcohol
Picric Acid
Biphenyl
1 ,2-dichlorobenzene
Ethylbenzene
Ethylene Glycol
Cyclohexane
Methyl Tert-butyl Ether
1 , 1-dichloro-l-fluoroethane
Mercury
Silver
Sodium Nitrite
Aluminum Phosphide

67
58
48
39
36
29
25
23
21
20
18
16
14
12
10
10
9
9
8
8
8

7

6
6
6
6
6
6
5
4
3
3
3
3
3
3
3
2
2
2
2
2
2
1
1
1
1
1

1
1
1
1
1
1
1







199**
Potw
10,350
50,018
1,201
906
13
10
3,140
25
16
30
564
534
5
406
357,214
0
325
2,291
0
0
250

250

0
23,200
0
6
15
250
10
98
268
12
42
0
0
0
0
0
250
0
0
0
251
0
0
0
0
0

0
0
0
0
0
0
0
0
0
30,613
0
0
0
0
0
0
0
482,563
Disposal
Transfers
2,368
13,963
59,938
23,073 ,
19,879
215
50,811
5,244
88
3,684
11,683
0
0
39,121
106,700
160
30,566
20,725
2
10,401
55,261

77

0
505
0
561
939
2,543
255
13,642
0
4,603
941
0
0
127,153
27
3,600
0
0
0
5
90
6,700
0
0
0
0

820
209
0
0
0
0
0
0
0
0
0
0
0
0
0
17,600
0
634,152
Recycling
Transfers
85,457
122,824
5,220,398
2,130,107
188,170
154,717
540,602
13,660
224,131
4,932
716,388
41,234
7,475
770,166
112
7,420
481,291
20,304
24
80,089
0

0

51,000
2,505
2,224
56
0
942,255
107,855
290,391
86,360
0
252,145
0
5
0
0
170,481
24,000
16,000
0
135,000
14,000
35,000
550
0
0
0

250
0
0
8,300
0
0
0
0
0
0
0
0
0
0
0
0
0
12.947.878
Treatment
Transfers
98,407
741,790
66,968
46,840
45,743
55,071
145,257
18,302
4,397
50,424
4,103
89,974
1,355
332
92,382
27,148
5,703
1,100
295
8,950
1,490,000

250

15,050
925
5,900
11,709
16,859
3,550
0
122
5
6,380
50,094
0
0
0
0
6,550
0
0
0
1,958
0
2
0
23,495
0
0

0
460
0
0
0
0
0
9,200
0
0
0
0
460
0
0
0
0
3.147,510 .
Energy
Recovery
905,400
0
0
423
39,549
5,542
6,560
153,115
14,438
90,028
0
0
0
0
0
26,723
0
0
25,192
0
0

0

0
15,113
690
25,774
16,487
5
0
0
0
0
0
0
250
0
146
0
0
0
1,553
0
0
0
0
15,079
0
0

0
5,025
0
0
0
0
0
0
0
0
40,268
0
0
0
0
0
0
1,387,360
Total Avg Transfers
Transfers Per Facility
1,101,982
928,595
5,348,505
2,201,349
293,354
215,555
746,370
190,346
243,070
149,098
732,738
131,742
8,835
810,025
556,408
61,451
525,531
44,420
25,513
99,440
1,545,511

577

66,050
42,248
8,814
38,106
34,300
948,603
108,120
304,253
86,633
10,995
303,222
0
255
.127,153
173
180,631
24,250
16,000
1,553
136,963
14,341
41,702
550
38,574
0
0

1,070
5,694
0
8,300
0
0
0
9,200
0
30,613
40,268
0
460
0
0
17,600
0
18.607.109
16,447
16,010
111,427
56,445
8,149
7,433
29,855
8,276
11,575
7,455
40,708
8,234
631
67,502
55,641
6,145
58,392
4,936
3,189
12,430
193,189

82

11,008
7,041
1,469
6,351
5,717
158,101
21,624
76,063
28,878
3,665
101,074

85
42,384
5?
90,316
12,125
8,000
777
68,482
7,171
41,702
550
38,574
0,
i
(

1,070
5,694
(
8,300
0

1
9,200
(
30,613
40,268
i
Af-i
4&
1
17,60

93.503
**Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
       Sector Notebook Project
47
November 1998

-------
Aerospace Industry
              Chemical Releases and Transfers
                     The TRI database contains a detailed compilation of self-reported, facility-
                     specific chemical releases only and not transfers. The top reporting facilities
                     for the aerospace industry are listed below in Tables 10 and 11. Facilities that
                     have reported the primary SIC codes covered under this notebook appear on
                     the first list. Table 11 contains additional facilities that have reported the SIC
                     codes covered within this report, and one or more SIC codes that are not
                     within  the scope  of this notebook.  Therefore, the second list includes
                     facilities that conduct multiple operations — some that are under the scope of
                     this notebook, and some that are not.  However, only one additional facility
                     appears on the second list, implying that the processes directly relating to the
                     production of aerospace equipment is responsible for releases and transfers
                     reported by aerospace facilities. Currently, the facility-level data do not allow
                     pollutant releases to be broken apart by  industrial process.
Table 10: Largest Quantity TRI Releasing Facilities Reporting Only 372 or
376 SIC Codes to TRI1
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Boeing Commercial Airplane, Everett, WA
Chem-fab Corp., Hot Springs, AR
Raytheon Aircraft Co., Wichita, KS
Douglas Aircraft Co.*, Long Beach, CA
Pemco Aeroplex Inc., Birmingham, AL
Thiokol Propulsion Group, Promontory,
U.S. Air Force Plant 06 GA, Marietta, GA
Cessna Aircraft, Wichita, KS
Aerostructures Corp., Nashville, TN
Menasco, Euless, TX
SIC Codes Reported in
TRI
3721
3728
3721
3721
3721
3764
3721
3721
3728, 3769
3728
TOTAL
Total TRI
Releases
in Pounds
784,581
433,630
393,324
347,420
330,130
330,000
305,149
266,709
252,299
240,000
3,683,242
              Source: US EPA Toxics Release Inventory Database, 1996.
              *Douglas Aircraft Co. is now part ofThe Boeing Company.
1  Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.
Sector Notebook Project
48
November 1998

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Aerospace Industry
             Chemical Releases and Transfers
Table 11: Largest Quantity TRI Releasing Facilities Reporting Aerospace
SIC Codes to TRI2
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Boeing Wichita, Wichita, KS
Boeing Commercial Airplane, Everett, WA
Chem-fab Corp., Hot Springs, AR
Raytheon Aircraft Co., Wichita, KS
Douglas Aircraft Co., Long Beach, CA
Pemco Aeroplex Inc., Birmingham, AL
Thiokol Propulsion Group, Promontory,
U.S. Air Force Plant 06 GA, Marietta, GA
Cessna Aircraft, Wichita, KS
Aerostructures Corp., Nashville, TN
SIC Codes Reported in
TRI
3728,3679,3721,3724
3721
3728
3721
3721
3721
3764
3721
3721
3728, 3769
TOTAL
Total TRI
Releases
in Pounds
1,254,080
784,581
433,630
393,324
347,420
330,130
330,000
305,149
266,709
252,299
4,697,322
               Source: US EPA Toxics Release Inventory Database, 1996.
               *Douglas Aircraft Co. is now part ofThe Boeing Company.
 2 Being included on this list does not mean that the release is associated with non-compliance with environmental
 laws.
 Sector Notebook Project
49
November 1998

-------
Aerospace Industry
             Chemical Releases and Transfers
IV.B.  Summary of Selected Chemicals Released
                     The following is a synopsis of current scientific toxicity and fate information
                     for the top chemicals (by weight) that facilities within this sector self-reported
                     as released to the environment based upon 1995 TRI data.  Because this
                     section is based upon self-reported release data, it does not attempt to provide
                     information on management practices employed by the sector to reduce the
                     release of these chemicals. Information regarding pollutant release reduction
                     over time may be available from EPA's TRI and 33/50 programs, or directly
                     from the industrial trade associations that are  listed in Section IX of this
                     document. Since these descriptions are cursory, please consult these sources
                     for a more detailed description  of both  the chemicals described  in this
                     section, and the chemicals that appear on the full list of TRI chemicals
                     appearing in Section IV.A.

                     The brief  descriptions provided below were  taken  from the Hazardous
                     Substances Data Bank (HSDB) and the Integrated Risk Information System
                     (IRIS).  The discussions of toxicity describe the range of possible adverse
                     health effects that have been found to be associated with exposure to these
                     chemicals. These adverse effects may or may not occur at the levels released
                     to the environment. Individuals interested in a more detailed picture of the
                     chemical concentrations associated with these adverse effects should consult
                     a toxicologist or the toxicity  literature for the chemical to obtain more
                     information. The effects listed below  must be taken in context of these
                     exposure assumptions that are explained more fully within the full chemical
                     profiles in HSDB.  For more information on TOXNET3  , contact the
                     TOXNET help line at 1-800-231-3766.
                     1.1.1-Trichloroethane CCAS: 71-55-6)

                     Sources.  1,1,1 -Trichloroethane is used as an equipment and parts cleaning
                     and degreasing solvent in aerospace manufacturing and is also used as a paint
                     solvent.
3 TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological
databases managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and
Health. For more information on TOXNET, contact the TOXNET help line at 800-231-3766. Databases included in
TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART (Developmental and
Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources), EMICBACK
(Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous
Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical
Substances), and TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and use, chemical and physical properties, safety and handling, toxicity and biomedical effects,
pharmacology, environmental fate and exposure potential, exposure standards and regulations, monitoring and
analysis methods, and additional references.
Sector Notebook Project
50
November 1998

-------
Aerospace Industry
                 Chemical Releases and Transfers
                    Toxicity. Repeated contact of 1,1,1-Trichloroethane (TCA) with skin may
                    cause serious skin cracking and infection. Vapors cause a slight smarting of
                    the eyes or respiratory system if present in high concentrations.

                    Exposure to high concentrations of TCA causes reversible mild liver and
                    kidney dysfunction, central nervous system depression, gait disturbances,
                    stupor, coma, respiratory depression, and even death.  Exposure to lower
                    concentrations of TCA leads to light-headedness, throat irritation, headache,
                    disequilibrium,  unpaired coordination, drowsiness, convulsion and mild
                    changes hi perception.

                    Carcinogenicity.  There  is  currently no evidence to suggest that this
                    chemical is carcinogenic.

                    Environmental Fate. Releases of TCA to surface water or land will almost
                    entirely volatilize. Releases of TCA to air may be transported long distances
                    and may partially return to earth in rain. In the lower atmosphere, TCA
                    degrades very slowly by photo oxidation and slowly diffuses to the upper
                    atmosphere where photodegradation is rapid.

                    Any TCA  that does not evaporate from soils leaches to groundwater.
                    Degradation in soils and water is slow. TCA does not hydrolyze in water, nor
                    does it significantly bioconcentrate in aquatic organisms.

                    Physical Properties.  TCA  is  a clear,  colorless  liquid with  a mild,
                    chloroform-like odor and slight solubility.
                    Methvl Ethvl Ketone (CAS: 78-93-3)

                    Sources. Methyl ethyl ketone (MEK) is used as an equipment and parts
                    cleaning and degreasing solvent and as a paint solvent.

                    Toxicity.  Breathing moderate amounts of methyl ethyl ketone for short
                    periods of time can cause adverse effects on the nervous system ranging from
                    headaches,  dizziness, nausea, and numbness in the fingers and toes to
                    unconsciousness.  Its vapors are irritating to the skin, eyes, nose, and throat
                    and can damage the eyes.  Repeated exposure to moderate to high amounts
                    may cause liver and kidney effects.
                    Carcinogenicity.
                    carcinogen.
EPA does not consider methyl ethyl ketone to be a
                    Environmental Fate. Most of the MEK released to the environment will
                    end up in the atmosphere.  MEK can contribute to the formation of air
Sector Notebook Project
     51
November 1998

-------
Aerospace Industry
             Chemical Releases and Transfers
                    pollutants in the lower atmosphere. It can be degraded by microorganisms
                    living in water and soil.

                    Physical Properties. Methyl ethyl ketone is a clear, colorless, flammable
                    liquid which decomposes explosively at 230°F.  It has a fragrant mint-like
                    odor detectable at 2 to 85 parts per million.
                     Trichloroethvlene (CAS: 79-01-6)

                     Sources.  Trichloroethylene is used extensively as an equipment and parts
                     cleaning and degreasing solvent and as a paint solvent.

                     Toxicity.  Trichloroethylene was once used as an anesthetic, though its use
                     caused several fatalities due to liver failure. Short term inhalation exposure
                     to high levels  of trichloroethylene may cause rapid coma  followed by
                     eventual death from liver, kidney, or heart failure.  Short-term exposure to
                     lower concentrations of trichloroethylene causes eye, skin, and respiratory
                     tract irritation.  Ingestion causes a burning sensation in the mouth, nausea,
                     vomiting   and  abdominal  pain.    Delayed  effects  from  short-tern
                     trichlorethylene poisoning include liver and kidney lesions, reversible nerve
                     degeneration, and psychic disturbances.  Long-term exposure can produce
                     headache,  dizziness, weight  loss, nerve  damage, heart damage, nausea,
                     fatigue, insomnia, visual impairment, mood perturbation, sexual problems,
                     dermatitis, and rarely jaundice. Degradation products of trichloroethylene
                     (particularly phosgene) may cause rapid death due to respiratory collapse.

                     Carcinogenicity. Trichloroethylene is considered by EPA to be a probable
                     human carcinogen via both oral and inhalation exposure, based on limited
                     human evidence and sufficient animal evidence.

                     Environmental Fate. Trichloroethylene breaks down slowly in water in the
                     presence of sunlight and bioconcentrates moderately in aquatic organisms.
                     The main removal of trichloroethylene from water is via rapid evaporation.
                     Trichloroethylene does not photodegrade in the atmosphere, though it breaks
                     down quickly under  smog conditions, forming other pollutants such as
                     phosgene, dichloroacetyl chloride,  and  formyl  chloride.  In addition,
                     trichloroethylene vapors may be decomposed to toxic levels of phosgene in
                     the presence of an intense heat source such as an open arc welder.  When
                     spilled on land, trichloroethylene rapidly volatilizes from surface soils. Some
                     of the remaining chemical may leach through the soil to groundwater.

                     Physical  Properties.  Trichloroethylene is  a  colorless liquid with a
                     chloroform-like odor.  It is a combustible liquid, but burns with difficulty,
                     and it has a very low solubility.
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            Chemical Releases and Transfers
                     Toluene (CAS: 108-88-3)

                     Sources. Toluene is used as an equipment and parts cleaning and degreasing
                     solvent and as a paint solvent.

                     Toxicity. Inhalation or ingestion of toluene can cause headaches, confusion,
                     weakness, and memory loss. Toluene may also effect the way the kidneys
                     and liver function.

                     Reactions of toluene (see environmental fate) in the atmosphere contribute
                     to the formation of ozone in the lower  atmosphere.  Ozone can affect the
                     respiratory system, especially in sensitive individuals such as asthma or
                     allergy  sufferers.

                     Some studies have shown that unborn animals were harmed when high levels
                     of toluene were inhaled by their mothers, although the same effects were not
                     seen when the mothers were fed large quantities 6f toluene. Note that these
                     results may reflect similar difficulties in humans.

                     Carcinogehlcfiy.  There is  currently  ho evidence to suggest  that this
                     chemical is carcinogenic.

                     Environmental Fate. The majority of releases of toluene to land and water
                     will evaporate. Toluene may also'be degraded by microorganisms. Once
                     volatized, toluene in the lower atmosphere will react with bthef atmospheric
                     components contributing to the fbrmatibri of ground-level 'ozone and other air
                     pollutants.

                     Physical Prdpertifes. Toluene^ a* volatile brgahlc ehendibal (VOC); is a
                     colorless liquid with a sweet, benzene-like bdof.  It is a Class IB fiarnitiable
                     liquid.
IV.C. Other Data Sources

                     The toxic chemical release data obtained from TRI captures only about 237
                     of the facilities  in  the aerospace industry.   However,  it allows for a
                     comparison across years and industry sectors. Reported chemicals are limited
                     to the approximately 600  TRI chemicals.  A significant portion of the
                     emissions from aerospace facilities, therefore, are not captured by TRI.  The
                     EPA Office of Air Quality Planning and Standards has compiled air pollutant
                     emission factors for determining the total air emissions of priority pollutants
                     (e.g., total hydrocarbons, SOx, NOx, CO, particulates, etc.) from many
                     manufacturing sources.
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Aerospace Industry
             Chemical Releases and Transfers
                    The Aerometric Information Retrieval System (AIRS) contains a wide range
                    of information related to stationary sources of air pollution, including the
                    emissions of a number of air pollutants which may be of concern within a
                    particular industry.  With  the exception of volatile organic compounds
                    (VOCs), there is little overlap with the TRI chemicals reported above. Table
                    12  summarizes annual  releases (from the industries for which a Sector
                    Notebook Profile was prepared) of carbon monoxide (CO), nitrogen dioxide
                    (NO2), particulate matter of 10 microns or less (PM10), total particulates
                    (PT), sulfur dioxide (SO2), and volatile organic compounds (VOCs).
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Aerospace Industry
           Chemical Releases and Transfers
Table 12: Air Pollutant Releases by Industry Sector (tons/year)
Industry Sector
Metal Mining
Oil and Gas Extraction
Non-Fuel, Non-Metal Mining
Textiles
Lumber and Wood Products
Wood Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Plastic Resins and Man-made Fibers
Pharmaceuticals
Organic Chemicals
Agricultural Chemicals
Petroleum Refining
Rubber and Plastic
Stone, Clay, Glass and Concrete
Iron and Steel
Metal Castings
Nonferrous Metals
Fabricated Metal Products
Electronics and Computers
Motor Vehicle Assembly
Aerospace
Shipbuilding and Repair
Ground Transportation
Water Transportation
Air Transportation
Fossil Fuel Electric Power
Dry Cleaning
CO
4,951
132,747
31,008
8,164
139,175
3,659
584,817
8,847
242,834
15,022
6,389
112,999
12,906
299,546
2,463
92,463
982,410
115,269
311,733
7,135
27,702
19,700
4,261
109
153,631
179
1,244
399,585
145
NO2
49,252
389,686
21,660
33,053
45,533
3,267
365,901
3,629
93,763
36,424
17,091
177,094
38,102
334,795
10,977
335,290
158,020
10,435
31,121
11,729
7,223
31,127
5,705
866
594,672
476
960
5,661,468
781
PM10
21,732
4,576
44,305
1,819
30,818
2,950
37,869
539
6,984
2,027
1,623
13,245
4,733
25,271
3,391
58,398
36,973
14,667
12,545
2,811
1,230
3,900
890
762
2,338
676
133
221,787
10
PT
9,478
3,441
16,433
38,505
18,461
3,042
535,712
1,772
150,971
65,875
24,506
129,144
14,426
592,117
24,366
290,017
241,436
4,881
303,599
17,535
8,568
29,766
757
2,862
9,555
712
147
13,477,367
725
SO2
1,202
238,872
9,183
26,326
95,228
84,036
177,937
88,788
52,973
71,416
31,645
162,488
62,848
292,167
110,739
21,092
67,682
17,301
7,882
108,228
46,444
125,755
3,705
4,345
101,775
3,514
1,815
42,726
7,920
voc
119,761
114,601
138,684
7,113
74,028
5,895
107,676
1,291
34,885
7,580
4,733
17,765
8,312
36,421
6,302
198,404
85,608
21,554
23,811
5,043
3,464
6,212
10,804
707
5,542
3,775
144
719,644
40
Source- TJS FPA Office of Air and Radiation AIRS Database 1997.
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Aerospace Industry
             Chemical Releases and Transfers
IV.D. Comparison of Toxic Release Inventory Between Selected Industries

                     The following information is presented as a comparison of pollutant release
                     and transfer data across industrial categories. It is provided to give a general
                     sense as to the relative scale of TRI releases and transfers within each sector
                     profiled under this project. Please note that the following figures and tables
                     do not contain releases and transfers for industrial categories that are not
                     included in this project, and thus cannot be used to  draw conclusions
                     regarding the total release and transfer amounts that are reported  to TRI.
                     Similar information is available within the annual TRI Public Data  Release
                     Book.

                     Figure 7 is  a graphical representation of a summary of the TRI data for the
                     aerospace industry and the other sectors profiled in separate notebooks. The
                     bar graph presents the total TRI releases and total transfers on the  vertical
                     axis. Industry sectors are presented in the order of increasing SIC code. The
                     graph is based on the data shown in Table  13 and is meant to facilitate
                     comparisons between the relative amounts of releases and transfers both
                     within and between these sectors. Table 13 also presents the average releases
                     per facility  in each industry. The reader should note that differences in the
                     proportion of facilities captured by TRI exist between industry sectors. This
                     can be a factor of poor SIC matching and relative differences in the  number
                     of facilities reporting to TRI from the various sectors.  In the case of the
                     aerospace industry, the 1995 TRI data presented here covers 237 facilities.
                     These facilities listed SIC 3721,3724,3728,3761,3764, or 3769 (aerospace
                     industry) as a primary SIC code(s).
Sector Notebook Project
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Aerospace Industry
           Chemical Releases and Transfers
             Figure 7; Summary of TRI Releases and Transfers by Industry
500 .
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Key to Standard Industrial Classification Codes

22
24
25
2611-2631
2711-2789
2812-2819
2821, 2823,
2824

Textiles
Lumber and Wood
Products
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemical
Manufacturing
Resins and Plastics
SIC Range
2833,2834
2861-2869
2911
30
32
331
332, 336
Industry Sector
Pharmaceuticals
Organic Chem. Mfg.
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay, and Concrete
Iron and Steel
Metal Casting

SIC Range
333, 334
34
36
371
372, 376
3731


Nonferrous Metals
Fabricated Metals
Electronic Equip, and
Comp.
Motor Vehicles, Bodies,
Parts, and Accessories
Aerospace
Shipbuilding and Repair

 Sector Notebook Project
57
                                                                        November 1998

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Aerospace Industry
            Chemical Releases and Transfers
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Aerospace Industry
Pollution Prevention Opportunities
V. POLLUTION PREVENTION OPPORTUNITIES
                    The best way to reduce pollution is to prevent it in the first place.  Some
                    companies have creatively implemented pollution prevention techniques that
                    improve efficiency and increase profits while at the same time minimizing
                    environmental impacts.  This can be done in many ways such as reducing
                    material inputs, re-engineering processes to reuse by-products, improving
                    management practices, and employing substitution of toxic chemicals. Some
                    smaller facilities are able to actually get below regulatory thresholds just by
                    reducing pollutant releases through aggressive pollution prevention policies.

                    The Pollution Prevention Act  of 1990 established a national policy of
                    managing waste  through  source  reduction, which means preventing  the
                    generation of waste.  The Pollution Prevention Act also established as
                    national policy a hierarchy of waste management options for situations in
                    which source reduction cannot be implemented feasibly.  In the waste
                    management hierarchy, if source reduction is not feasible the next alternative
                    is recycling of wastes, followed by energy recovery, and waste treatment as
                    a last alternative.

                    In order to encourage these approaches, this section provides both general and
                    company-specific descriptions of some pollution prevention advances that
                    have been implemented within the aerospace industry. While the list is  not
                    exhaustive, it does provide core information that can be used as the starting
                    point for facilities interested in beginning their own pollution prevention
                    proj ects. This section provides summary information from activities that may
                    be, or are being implemented by this sector. When possible, information is
                    provided that gives  the  context in  which the  technique can be used
                    effectively. Please note that the activities described in this  section do  not
                    necessarily apply to all facilities that fall within this sector. Facility-specific
                    conditions must be carefully considered when pollution prevention options
                     are evaluated, and the full impacts of the change must examine how each
                     option affects air, land and water pollutant releases.
 Pollution Prevention Techniques
                     This section lists many pollution prevention techniques geared toward the
                     aerospace industry and its related processes.  Some techniques may be
                     applicable to a number of different processes such as materials substitution
                     of low-solvent and less hazardous materials exist, while others are specific
                     to a single phase of aerospace manufacturing.  Many of the techniques
                     discussed below were obtained from the Profile of the Shipbuilding and
                     Repair Industry, EPA, 1997. It is important to note that the FAA places very
                     strict "airworthiness" guidelines on manufacturing and rework facilities for
                     safety  and  quality  control  purposes,  thus new pollution prevention
                     alternatives may require a full evaluation and permitting process before they
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           Pollution Prevention Opportunities
                     may be used. Because military facilities are not subject to FAA guidelines,
                     they have a greater opportunity to implement P2 alternatives.  As a result,
                     studies have been conducted at various Air Force, Coast Guard, and Naval
                     facilities which are referenced in Section IX.   Excellent information on
                     military facility P2 activities can be found at web sites of the Air Force
                     Center for Environmental Excellence (http://www.afcee.brooks.af.milX and
                     at the Navy's P2 Library web site (http://enviro.nfesc.navy.mil/p21ibrary).

V.A. Machining and Metalworking

                     Coolant, or metalworking, fluids  account for  the  largest waste stream
                     generated by machining operations.  Waste metalworking fluids are created
                     when the fluids are no longer usable due to contamination by oils or chemical
                     additives. If the contamination rate of the metalworking fluids is reduced, the
                     need to replace them will be less  frequent.  This will reduce the waste
                     generated.

       Preventing Fluid Contamination

                     Fluid can become hazardous waste if it is contaminated.  Although it is not
                     possible to eliminate contamination, it is possible to reduce the  rate of
                     contamination and thereby prolong its use.

                     The primary contaminant in these waste fluids is tramp  oil.  One way to
                     postpone contamination is to promote better maintenance of the wipers and
                     seals. A preventative maintenance program should be installed and enforced
                     in the machine shop.  Scheduled sump and machine cleaning as well as
                     periodic inspections of the wipers and oil seals should be carried out. The
                     responsibility for this should be assigned to some person or group in a
                     position of authority to ensure its success.
       Synthetic Fluids
                     Synthetic fluids have many advantages over their non-synthetic counterparts.
                     Usually the synthetic varieties do not lubricate as effectively, but they are less
                     susceptible to contamination and highly resistant to biological breakdown.
                     Most synthetic fluids have superior longevity and can operate over a large
                     temperature range without adverse side effects.  Straight oils should be
                     replaced with synthetic ones when possible.
       Recycling Fluids
                     Once all of the source reduction options have been considered, it is time to
                     explore the possibilities of reuse. It should be noted that in many cases, after
                     the majority of the contaminants have been removed, further treatment with
                     chemicals or concentrated fluid is necessary before the fluids can be
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Aerospace Industry                          	Pollution Prevention Opportunities

                    recirculated through the machines.
                     Filtration Filtration is a common way to remove particles from the fluid as
                     well as tramp oils or other contaminants. Many different types of filters can
                     be used depending on the medium to be filtered and the amount of filtration
                     desired.  Contaminated cutting fluids can be passed through a bag, disc, or
                     cartridge filter or separated in a centrifuge.

                     Skimming and  Flotation  Although it is  a  slow process,  skimming  of
                     contaminants is inexpensive and can be very effective. The principle is to let
                     the fluid sit motionless in a sump or a tank, and after a predetermined amount
                     of time, the unwanted oils are skimmed off the surface and the heavier
                     particulate matter is collected off the bottom. A similar technique, flotation,
                     injects high pressure air into contaminated cutting fluid. As the air comes out
                     of solution and bubbles  to the  surface, it attaches itself to suspended
                     contaminants and carries them up to the surface. The resulting sludge is
                     skimmed off the surface and the clean fluid is reused.

                     Centrifugation Centrifugation uses the same settling principles as flotation,
                     but the  effects  of gravity are multiplied thousands of times due to the
                     spinning action of the centrifuge.  This will increase the volume of fluids
                     which can be cleaned in a given amount of time.

                     Pasteurization Pasteurization uses heat treatment to kill microorganisms in
                     the fluid and reduce the rate at which rancidity (biological breakdown) will
                     occur. Unfortunately,, heat can alter the properties of the fluid and render it
                     less effective. Properties lost in this way are usually impossible to recover.

                     Downgrading Sometimes it is possible to use high quality hydraulic oils as
                     cutting fluids. After the oils have reached their normal usable life, they no
                     longer meet the high standards necessary for hydraulic components. At this
                     time they are still good enough to be used for the less demanding jobs. It may
                     be necessary to treat the fluid before it can be reused, but changing fluid's
                     functions in this manner has proven successful in the past.

 V.B. Surface Preparation

                     The majority of wastes  generated during surface preparation are  spent
                     abrasives and solvents mixed with paint chips. One way the volume of waste
                     generated can be reduced is by using blast media that is relatively easy to
                     reuse.

          Improving Readability of Abrasive Blasting Media

                     Often, air powered cleaning equipment is used to screen abrasive to separate

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 Aerospace Industry
            Pollution Prevention Opportunities
                     it from large paint particles.  These systems may also remove lighter dust
                     from the heavy abrasive.  This media separation can be especially important
                     when the paint being removed contains heavy metals. An alternative to on-
                     site reclamation is to send it for processing off-site. It is very important that
                     waste streams, especially hazardous waste, are not mixed with used blasting
                     media. Outside debris and other waste could render the media unfit for reuse.

          Plastic Media Blasting

                     As  a substitute for other blast media, the military has experimented
                     extensively with plastic media stripping. This process is particularly good for
                     stripping coatings from  parts with fragile  substrates often found in the
                     aerospace industry such  as zinc, aluminum, and fiberglass.  It can be a
                     lengthy process because it strips paint layer by layer. The same types and
                     quantities of waste are generated as with grit blasting, but the plastic medium
                     is more recyclable with the use of pneumatic media classifiers that are part
                     of the stripping equipment. The only waste requiring disposal is the paint
                     waste itself.  However, the use of plastic media is fairly limited.  Plastic
                     blasting media do not work well on epoxy paints. In addition, the blasting
                     equipment is expensive and requires trained operators.

          Water Jet Stripping (Hydroblasting)

                     Hydroblasting is a cavitating high pressure water jet stripping system that can
                     remove most paints. These system may use pressures as high as 50,000 psig.
                     Hydroblasting is an excellent method for removing even hard coatings from
                     metal substrates.  Some systems automatically remove the paint chips or
                     stripped material from the water and reuse the water for further blasting. By
                     recirculating the water in this manner, the amount of waste is greatly reduced.
                     Wastewater from this process is usually suitable for sewer disposal after the
                     paint particles are removed. Although this process produces very little waste,
                     it is not always as efficient as other blasting methods, has relatively high
                     capital and maintenance costs, and may not be adequate for fragile substrates.
V.C.  Solvent Cleaning and Degreasing
                     Aerospace manufacturers often use large quantities of solvents in a variety of
                     cleaning  and  degreasing  operations  including  parts  cleaning,  process
                     equipment cleaning, and surface preparation for coating applications. The
                     final cost of solvent used for various cleanup operations is nearly twice the
                     original purchase price of the virgin solvent. The additional cost is primarily
                     due to the fact that for each drum purchased, extra disposal cost, hazardous
                     materials transportation cost, and manifesting time and expense are incurred.
                     With the rising cost of solvents and waste disposal services, combined with
                     continuously developing regulation, reducing the quantities of solvents used
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Aerospace Industry
          Pollution Prevention Opportunities
                    and solvent wastes generated can be extremely cost effective.
         Eliminating the Use of Solvents
                     Eliminating the use of solvents avoids any waste generation associated with
                     spent solvent.  Elimination can be achieved by utilization of non-solvent
                     cleaning agents or eliminating the need for cleaning altogether.  Solvent
                     elimination applications include the use of water-soluble cutting fluids,
                     protective peel coatings, aqueous cleaners, and mechanical cleaning systems
                     (USEPA/OECA, 1997).

                     Water-soluble Cutting Fluids  Water-soluble cutting fluids can often be used
                     in place of oil-based fluids. The cutting oils usually consist of an oil-in-water
                     emulsion used to reduce friction and dissipate heat. If these fluids need to be
                     removed after the macMning process is complete, solvents may be needed.

                     In efforts to eliminate solvent degreasing and its subsequent waste, special
                     water-soluble cutting fluids have been developed. Systems are available that
                     can clean the cutting fluid and  recycle the material back to the cutting
                     operation. Obstacles to implementing this method are: cost (water-soluble
                     fluids are generally more expensive), procurement (there are only a few
                     suppliers available), and the inability to quickly switch between fluid types
                     without thoroughly cleaning the equipment (USEPA/OECA, 1997).

                     Aqueous Cleaners Aqueous cleaners, such as alkali, citric, and caustic base,
                     are often useful substitutes for solvents. There are many formulations that are
                     suited for a variety of cleaning requirements. Many aqueous cleaners have
                     been found to be as effective as the halogenated solvents that are commonly
                     employed.

                     Aqueous stripping agents, such as caustic soda (NaOH), are often employed
                     in place of methylene chloride based strippers.  Caustic solutions have the
                     advantage of eliminating solvent vapor emissions. A typical caustic bath
                     consists of about 40 percent caustic solution heated to about 200 degrees
                     Fahrenheit.  Caustic stripping is generally effective on alkyl  resins and oil
                     paints (EPA, March 1997).

                     The Douglas Aircraft Division of McDonnell Douglas used a chromic acid
                     solution to clean aluminum parts. However, the solution began to corrode the
                     steel cleaning equipment parts. A scientist at McDonnell Douglas developed
                     a sodium hydroxide-based process which cleaned parts sufficiently to detect
                     cracks in the aluminum parts during testing.   The new process saves an
                     estimated $28,000 per year in chemical costs (Boeing, 1998).
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                     In 1990, the Martin Marietta Astronautics Group (now Lockheed Martin)
                     eliminated the use of 1,1,1-trichloroethane (TCA) and methyl ethyl ketone
                     (MEK) for vapor degreasing. Six alternative aqueous cleaners were subjected
                     to  a screening process that evaluated health hazards, treatability of
                     wastewater,  corrosion potential, degreasing performance,  and  salt fog
                     corrosion resistance. From this study, Lockheed Martin selected a nontoxic
                     aqueous terpene cleaner.  The substitution of this cleaner saves hundreds of
                     thousands of dollars every year in material cost savings and ozone depletion
                     taxes (Dykema, 1993).

                     Lockheed Martin Tactical Aircraft Systems in Fort Worth, Texas, has
                     substituted low vapor pressure solvent and aqueous cleaning for  CFC-113
                     in all aspects of aircraft manufacturing.  The low vapor pressure solvent is a
                     blend of propylene glycol methyl ether acetate, isoparaffins, and butyl acetate.
                     The solvent is effective on a variety of organic soils and is used for wiping
                     the surfaces of aircraft components and assemblies. The  substitution of this
                     cleaner completely eliminated CFC  emissions and reduced solvent use,
                     solvent cost, VOC emissions, and total air emissions (Evanoff, 1993).

                     The advantages of substituting aqueous cleaners include minimizing worker's
                     exposure  to solvent  vapors,  reducing liability and disposal  problems
                     associated with solvent use, and cost.  Aqueous cleaners do not volatilize as
                     quickly as other solvents, thereby reducing losses due to evaporation. Since
                     most aqueous cleaners are biodegradable, disposal is not a problem once the
                     organic or inorganic contaminants are removed (USEPA, March 1997).

                     The use of aqueous cleaners can also result in cost savings. Although some
                     aqueous cleaners may cost less than an equivalent amount of solvent, the
                     purchase price of each is  about the same.  The cost of disposal, loss due to
                     evaporation, and associated liabilities, however, favor aqueous cleaners.

                     The disadvantages  of aqueous cleaners in place of solvents  may include:
                     possible incompatibilities with FAA guidelines, possible inability of the
                     aqueous cleaners to provide the degree of cleaning required, incompatibility
                     between the parts being cleaned and the cleaning solution, need to modify or
                     replace existing equipment,  longer required cleaning time, and problems
                     associated with moisture left on parts being cleaned.  Oils removed from the
                     parts during cleaning  may float on the surface of the cleaning solution and
                     may interfere with  subsequent cleaning. Oil skimming  is usually required
                     (USEPA/OECA, 1997).

                     Mechanical Cleaning Systems Utilizing mechanical cleaning systems can
                     also replace solvents in degreasing and cleaning operations. In many cases,
                     a high pressure steam gun or high pressure parts washer can clean parts and
                     surfaces quicker and to the same degree of cleanliness as that of the solvents
                     they replace. Light detergents can be added to the water supply for improved

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Aerospace Industry
Pollution Prevention Opportunities
                    cleaning. The waste produced by these systems is usually oily wastewater.
                    This wastewater can be sent through an oil/water separator, the removed
                    water discharged to the sewer, and the oil residue sent to a petroleum
                    recycler. Some hot water wash and steam systems can be supplemented by
                    emulsifying solutions to speed the process. Although these additives speed
                    the cleaning process, they can make separation of the oil from the water very
                    difficult and create problems with disposal of the waste.

                    Cryogenic stripping utilizes liquid nitrogen and non-abrasive plastic beads as
                    blasting shot.  This method relies on the freezing effect of the liquid nitrogen
                    and the impact of the plastic shot.  Subjecting the surface to extremely low
                    temperatures creates stress between the coating and the substrate causing the
                    coating to become brittle.  When the plastic shot hits the  brittle coating,
                    debonding occurs. The process is non-abrasive,  and will not damage the
                    substrate, but  effects  of the  metal shrinkage, due  to extremely  low
                    temperatures, should be monitored.  The process does not produce liquid
                    wastes, and nitrogen, chemically inert, is already present in the atmosphere
                    (USEPA/OECA, 1997).

                    Thermal stripping methods can be useful for objects that cannot be immersed.
                    In this process,  superheated air is directed against the surface of the object.
                    The high temperatures cause some paints to flake off.  The removal results
                    from the drying effects of the air and the uneven expansion of the paint and
                    the substrate.  Some paints will melt at high temperatures, allowing the paint
                    to be scraped off manually or with abrasives. Hand-held units are available
                    that produce a jet of hot air.  Electric units and open flame or torch units are
                    also used. While this system is easy to implement, it is limited to items that
                    are not heat sensitive and to coatings that  are  affected by the heat
                    (USEPA/OECA, 1997).

                    McDonnell Douglas has developed two thermal stripping techniques.  The
                    first one, known as FLASHJET™, uses a high-intensity xenon lamp to heat
                    the surface paint and disintegrate it.  A stream  of dry ice  pellets follows to
                    carry away the paint chips. FLASHJET™ was developed for use and tested
                    on helicopters at the McDonnell Douglas Helicopter Systems plant in Mesa,
                    Arizona.  FLASHJET™ reduced the manual work required by 10 to 15
                    percent (Boeing, 1998).

                    The second technique was adapted from a technique to remove hydrocarbons
                    from engines.  The Hot Gaseous Nitrogen (GN2) Purge heats the critical
                    engine surfaces, driving off the volatile hydrocarbons, which then leave the
                    engine through the flow of nitrogen. This method eliminates the use of 1,1,1 -
                    trichloroethane for this type of engine cleaning  (Boeing, 1998).

                    Hughes Aircraft Company developed a supercritical carbon dioxide (SCCO2)
                    cleaning system to be used in many cleaning applications in the aerospace
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                     industry. At temperatures and pressures close to or above its critical point
                     (88 °F and 1,073 psia), CO2 acts as an ideal solvent.  It is also inexpensive
                     and inert, non-combustible, naturally occurring, and does not contribute to
                     smog.  Efficient removal of oils, greases, fingerprints, solder flux residues
                     have been achieved by the SUPERSCRUB™ unit at Hughes (Chao).

         Reducing the Use of Solvent

                     By eliminating the use or need for solvent cleaning, the problems associated
                     with disposal of spent solvent  are also eliminated.  In cases where the
                     elimination of solvent use is not possible or practical, utilization of various
                     solvent waste reduction techniques can lead to a substantial savings in solvent
                     waste.

                     Methods of reducing  solvent usage can be divided into three categories:
                     source  control of air emissions, efficient use of solvent and equipment, and
                     mamtaining solvent quality. Source control of air emissions addresses ways
                     in which more of the solvent can be kept inside a container or cleaning tank
                     by reducing the chances for evaporation loss.  Efficient use of solvent and
                     equipment through better operating procedures can reduce the amount of
                     solvent required for cleaning. Maintaining the quality of solvent will extend
                     the life cycle effectiveness of the solvent.

                     Source Control of Air Emissions  Source control of air emissions can be
                     achieved through equipment modification and proper operation of equipment.
                     Some simple control measures include installation and use of lids, an increase
                     of freeboard height of cleaning tanks, installation of freeboard chillers, and
                     taking steps to reduce solvent drag-out.

                     All cleaning units, including cold cleaning tanks and dip tanks, should have
                     some type of lid installed. When viewed from the standpoint of reducing air
                     emissions, the roll-type cover is preferable to the hinge type. Lids that swing
                     down can cause a piston effect and force the escape of solvent vapor.  In
                     operations such as vapor degreasing, use of lids can reduce solvent loss from
                     24 percent to 50 percent. For tanks that are continuously in use, covers have
                     been designed that allow the work pieces to enter and leave the tank while the
                     lid remains  closed.

                     In an open top vapor degreaser, freeboard is defined as the distance from the
                     top of the vapor zone to the top of the tank. Increasing the freeboard will
                     substantially reduce the amount of solvent loss. A freeboard chiller may also
                     be installed above the primary condenser coil.  This refrigerated coil, much
                     like the cooling jacket, chills the air above the vapor zone and creates a
                     secondary barrier to vapor loss.  Reduction in solvent usage, by use of
                     freeboard chillers, can be as high as 60 percent. The major drawback with a
                     freeboard chiller is that it can introduce water (due to condensation from air)

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                    into the tank.

                    In  addition to measures that reduce air  emissions  through equipment
                    modification,  it is also possible  to  reduce emissions through proper
                    equipment layout, operation, and maintenance. Cleaning tanks should be
                    located in areas where air turbulence and temperature do not promote vapor
                    loss.

                    Maximize the Dedication of the Process Equipment In addition to reduction
                    in vapor loss, reducing the amount of solvent used can be achieved through
                    better operating practices that increase the efficiency of solvent cleaning
                    operations. Maximizing the dedication of the process equipment reduces the
                    need for frequent cleaning.  By using a mix tank consistently for the same
                    formulation, the need to clean equipment between batches is eliminated.

                    Avoid Unnecessary Cleaning  Avoiding unnecessary cleaning also offers
                    potential for waste reduction. For example, paint mixing tanks for two-part
                    paints are  often cleaned between batches of the same product. The effect of
                    cross-contamination between batches should be examined  from a product
                    quality control viewpoint to see if the cleaning step is always necessary.

                    Proper Production Scheduling Proper production scheduling can reduce
                    cleaning  frequency by eliminating the need for cleaning between the
                    conclusion of one task  and the start of the next. A simple example of this
                    procedure is to have a small overlap between shifts that perform the same
                    operation  with the same equipment. This allows the equipment that would
                    normally be cleaned and put away at the end of each shift, such as painting
                    equipment, to be taken over directly by the relief.

                    Clean Equipment Immediately Cleaning equipment immediately after use
                    prevents deposits from  hardening and avoids the need for consuming extra
                    solvent. Letting dirty equipment accumulate and be cleaned later can also
                    increase the time required for cleaning.

                    Better Operating Procedures  Better operating procedures can minimize
                    equipment clean-up waste.   Some  of the methods already discussed are
                    examples  of better operating procedures. Better operator training, education,
                    closer supervision, improved equipment maintenance, and increasing the use
                    of automation are very effective in waste minimization.

                    Reuse Solvent Waste Reuse of solvent waste can reduce or eliminate waste
                    and result in a cost  savings associated with  a decrease in raw material
                    consumption.  The solvent from cleaning operations can be reused in other
                    cleaning processes in which the degree of cleanliness required is much less.
                    This will be discussed in more detail in the next section.
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         Solvent Recycling
                     Although not as preferable as source reduction, solvent recycling may be a
                     viable alternative for some facilities.  The goal of recycling is to recover from
                     the waste solvent, a solvent of a similar purity to that of the virgin solvent for
                     eventual reuse in the same operation, or of a sufficient purity to be used in
                     another application.  Recycling can also include the direct use of solvent
                     waste from one waste stream in another operation. There are a number of
                     techniques  that  facilities can  use onsite to separate solvents  from
                     contaminants including distillation, evaporation, sedimentation, decanting,
                     centrifugation, filtering, and membrane separation.
V.D.  Metal Plating and Surface Finishing
                    Pollution prevention opportunities in metal plating and surface finishing
                    operations are discussed in the Profile of the Fabricated Metal Products
                    Industry Sector Notebook. Readers are encouraged to consult this document
                    for pollution prevention information relating to metal plating and surface
                    finishing.  An additional resource for pollution prevention information
                    regarding metal finishing can be found at the National Metal Finishing
                    Resource Center (http://www.nmfrc.org).
V.E. Painting and Coating
                    Painting and coating operations are typically the largest single source of VOC
                    emissions from aerospace manufacturing and rework facilities.  In addition,
                    paint waste can account for more than half of the total hazardous waste
                    generated.  Paint waste may include leftover paint in containers, overspray,
                    paint that is no longer usable (Non-spec paint), and rags and other materials
                    contaminated with paint. In many cases, the amount of paint waste generated
                    can be reduced through the use of improved equipment, alternative coatings,
                    and good operating practices. An additional resource for pollution prevention
                    information regarding painting and coating can be found at the Paint and
                    Coatings Resource Center flittp://www.paintcenter.orgX
         Application Equipment
                    In order to effectively reduce paint waste and produce a quality coating,
                    proper  application techniques should  be supplemented with efficient
                    application equipment.  Through the use of equipment with high transfer
                    efficiencies, the amount of paint lost to overspray is minimized.

                    High Volume Low Pressure CHVLP) Spray Guns  The HVLP spray gun is
                    basically a conventional air spray gun with modifications and special nozzles
                    that atomize the paint at very low air pressures. The atomizing pressure of
                    HVLP systems is often below 10 psi. The design of this gun allows better
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                    transfer efficiency and reduced overspray than that of conventional air guns.
                    The low application pressure decreases excessive bounceback and allows
                    better adhesion of the coating to the substrate.

                    Although improvements  are  consistently  being made to  overcome its
                    limitations, most HVLP systems have some definite drawbacks, including
                    difficulty atomizing viscous coatings, sensitivity to variations in incoming
                    pressure, sensitivity to wind, and slow application rates.

                    Airless Spray Guns Instead of air passing through the spray gun, an airless
                    system applies static pressure to the liquid paint. As the paint passes through
                    the nozzle, the sudden drop in pressure atomizes the paint and it is carried to
                    the substrate by its own momentum.  Pressure is applied to the paint by a
                    pump located at a remote supply. These systems have become favorable over
                    conventional air-spray systems for three main reasons:

                           1) reduced overspray and rebound,
                           2) high application rates and transfer efficiency,
                           3) permits the use of high-build coatings with the result that fewer
                           coats are required to achieve specific film thickness.

                    One major disadvantage  of some airless spray systems is  the difficulty
                    applying very thin coats. If coatings with less than a millimeter in thickness
                    are required, such as primers applied to objects that require weldability, it
                    may be difficult to use an airless system.

                    Electrostatic Spray Electrostatic spray systems utilize paint droplets that are
                    giveri a negative charge in the vicinity of a positively charged  substrate. The
                    droplets are attracted to the substrate and a uniform coating is formed. This
                    system works well on  cylindrical and rounded objects  due  to  its "wrap-
                    around" effect that nearly allows the object to be coated from one side. Very
                    little paint is  lost to overspray, and it has beefi noted to  have a transfer
                    efficiency of over 95%.

                    In order for an electrostatic system to operate properly, the correct solvent
                    balance is needed. The evaporation rate must be slow enough for the charged
                    droplets to reach the substrate in a fluid condition to flow out into a smooth
                    film, but fast enough to avoid sagging. The resistivity of the paint must also
                    be low enough to enable the paint droplets to acquire the  maximum charge.

                    Although the operating costs of electrostatic spray systems are relatively low,
                    the initial capital investment can be high.  This system has been found to
                    work extremely well in small parts painting applications. Sometimes the
                    installation of an electrostatic powder coating system can replace a water
                    curtain spray paint booth.
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                    Heated Spray When paint is heated, its viscosity is reduced allowing it to be
                    applied with a higher solids content, thus requiring less solvent.  When the
                    paint is heated in a special container and supplied to the gun at 140° to
                    160 °F, coatings of 2 to 4 millimeters dry-film thickness can be applied in one
                    operation, resulting in considerable savings hi labor cost.  In addition,  much
                    of the associated solvent emissions are eliminated.

                    Heating the coating prior to application can be used with both conventional
                    and airless spray applications. An in-line heater is used to heat the coating
                    before it reaches the gun. As the coating is propelled through the air, it cools
                    rapidly and increases viscosity after it hits the surface, allowing for  better
                    adhesion to the substrate.

                    Plural Component Systems A common problem that facilities face  when
                    working with two-part coatings is overmixing. Once the component parts of
                    a catalyst coating are mixed, the coating must be applied. Otherwise, the
                    excess unused coating will cure and require disposal.  Additionally, the
                    coating equipment must be cleaned immediately after use.

                    One large advantage of plural component technology is the elimination of
                    paint waste generated by mixing an excess amount of a two part coating.
                    This is achieved through the use of a special mixing chamber that mixes the
                    pigment and catalyst seconds before the coating is applied. Each component
                    is pumped through a device that controls the mixing  ratio  and then is
                    combined in a mixing chamber.  From the mixing  chamber, the mixed
                    coating travels directly to the spray guns. The only cleaning that is required
                    is the mixing chamber, gun, and the length of supply hose connecting  them.

                    Wet Booth Generally, small-volume painting operations will find the lower
                    purchase cost  of a dry filter booth will meet their requirements.   One
                    disadvantage in the use of a dry-filter booth is in the disposal of the waste.
                    Typically the majority of this waste is the filter media itself which has been
                    contaminated by a relatively small amount of paint.  Reusable filters may
                    decrease waste volume and reduce disposal cost. In some applications,
                    overspray can be collected for reuse.

                    If overall painting volume can justify the investment, a wet booth eliminates
                    disposal of filter media and allows waste to be reduced in weight and volume.
                    This is achieved by separating the paint from the water through settling,
                    drying, or using a centrifuge or cyclone (Ohio EPA, 1994).

                    Recycle Paint Booth Water  Various methods and equipment are used to
                    reduce or eliminate the discharge  of the water used in water-wash booths
                    (water curtain). These methods and equipment prevent the continuous
                    discharge of booth waters by conditioning (i.e., adding detacifiers and paint-
                    dispersing polymers) and removing paint solids.  The most basic form of
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                    water maintenance is the removal of paint solids by manual skimming and/or
                    raking. This can be performed without water conditioning since some portion
                    of solvent-based paints usually float and/or sink. With the use of detacifiers
                    and paint-dispersing polymer treatments, more advanced methods of solids
                    removal can be implemented. Some common methods are discussed below.
                    Wet- Vacuum Filtration Wet-vacuum filtration units consist of an industrial
                    wet-vacuum head on a steel drum containing a filter bag. The unit is used to
                    vacuum paint sludge from the booth. The solids are filtered by the bag and
                    the water is returned to the booth. Large vacuum units are also commercially
                    available that can be moved from booth to booth by forklift or permanently
                    installed near a large booth.

                    Tank-Side Weir A weir can be attached to the side of a side-draft booth tank,
                    allowing floating material to overflow from the booth and be pumped to a
                    filtering tank for dewatering.

                    Consolidator  A consolidator is a separate tank into which booth water is
                    pumped. The water is then conditioned by the introduction of chemicals.
                    Detacified paint floats to the surface of the tank, where it is skimmed by a
                    continuously moving blade. The clean water is recycled to the booth.

                    Filtration Various types of filtration units  are used to remove paint solids
                    from booth water. This is accomplished by pumping the booth water to the
                    unit where the solids are separated and returning the water to the booth. The
                    simplest filtration unit consists of a gravity filter bed utilizing paper or cloth
                    media. Vacuum filters are also employed, some of which require precoating
                    with diatomaceous earth.

                    Centrifuge Methods Two common types of centrifugal separators are the
                    hydrocyclone  and the centrifuge.  The hydrocyclone is used to concentrate
                    solids. The paint booth water enters a cone-shaped unit under pressure and
                    spins around the inside surface.  The spinning imparts an increased force of
                    gravity, which causes most of the solid particles to be pulled outward to the
                    walls of the cone. Treated water exits the top of the unit and the solids exit
                    from the bottom. Some systems have secondary filtration devices to further
                    process the solids. The centrifuge works in a similar manner, except that the
                    booth water enters  a  spinning drum, which imparts the  centrifugal force
                    needed for separating the water and solids.  Efficient centrifugation requires
                    close control of the booth water chemistry to ensure a uniform feed. Also,
                    auxiliary equipment such as booth water agitation equipment may be needed
                    (EPA, 1995).

         Alternative Coatings
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                     The use of solvent-based coatings can lead to high costs to meet air and water
                     quality regulations. In efforts to reduce the quantity and toxicity of waste
                     paint disposal, alternative coatings have been developed that do not require
                     the use of solvents and thinners. FAA guidelines may prohibit use of such
                     coatings.
                     Powder Coatings  Metal substrates can be coated with certain resins by
                     applying the powdered resin to the surface, followed by application of heat.
                     The heat melts the resin, causing it to flow and form a uniform coating. The
                     three main methods in use for applying the powder coating are fluidized bed,
                     electrostatic spray, and flame spraying.

                     In flame spraying, the resin powder is blown through the gun by compressed
                     air. The particles are melted in a high temperature  flame and propelled
                     against the substrate. This process is used widely with epoxy powders for
                     aluminum surfaces.

                     The electrostatic application method uses  the same principles as the
                     electrostatic spray.   The resin powder  is  applied to  the  surface
                     electrostatically.  Heat is applied to the covered surface and the powder melts
                     to form the coating. The transfer efficiency and recyclability of this method
                     is very high.

                     The elimination  of environmental problems associated with many liquid
                     based systems is  one of the major advantages of powder coatings. The use
                     of powder  coatings eliminates the need for  solvents and thereby emits
                     negligible volatile organic compounds (VOCs). Powder coatings also reduce
                     the waste associated with unused two-part coatings that have already been
                     mixed. Since powder overspray can be recycled, material utilization is high
                     and solid waste generation is  low.  Recent case studies demonstrate that
                     powder  coating  systems  can  be cleaner,  more  efficient,  and more
                     environmentally  acceptable, while producing  a higher quality finish than
                     many other coating systems.

                     Water-Based Paints Water-based coatings are paints containing a substantial
                     amount of water instead of volatile solvents. Alkyd, polyester, acrylic, and
                     epoxy polymers can be dissolved and dispersed by water.  In addition to
                     reduction hi environmental hazards due to substantially lower air emissions,
                     a decrease in the amount of hazardous paint sludge generated can reduce
                     disposal cost.

                     UV  / EB Coatings Powder coatings require high temperatures for their cure
                     and hence are not applicable to temperature sensitive substrates, such as
                     paper, wood or plastics.  For such materials, the use of coatings systems
                     curable by  ultra violate  light or electron beams (UV/EB) have been
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                    developed. The resins used in these coatings are basically the saime as those
                    used in conventional high performance coatings which have been modified
                    to make them polymerizable by UV or EB energy. Thus they are liquids that
                    can be applied by conventional techniques such as spraying, roller coating,
                    curtain coating, etc. (in contrast to powder coating which requires specialized
                    application techniques). When exposed to the low level radiant energy, they
                    are instantly and completely cured with no heat application. Because of the
                    diversity  of raw  materials that can be adapted  to this technology, a
                    tremendous range of performance characteristics can be achieved. In addition,
                    because no solvents are used in the coating formulations, there are virtually
                    no volatile organic compounds (VOCs) emitted, making them ecologically
                    preferred.  Other advantages include the elimination of curing  ovens and
                    incinerators which further aid the cleansing of the air as well as substantial
                    savings of space and fuel costs. The rapid curing cycle without the need of
                    a cool-down cycle allows for higher production rates and therefore lower
                    costs. LTV7EB coatings can be used on metals, and are especially useful when
                    coating complex metal products that might contain paper, plastic or wood
                    parts, because of the low temperature curing required by UV/EB. In addition,
                    these, and other advantages which UV/EB provides,  have led to rapid
                    increase in their use in the manufacture of electronic components.

          Good Operating Practices

                    In many cases, simply altering a painting process can reduce wastes through
                    better management.

                    A good manual coating application technique is very important  in reducing
                    waste. If not properly executed, spraying techniques have a high potential for
                    creating waste; therefore, proper application techniques are very important.

                     Reducing Oversprav One of the most common means of producing paint
                     waste at  facilities is overspray. Overspray not only wastes some of the
                     coating, it also presents environmental and health hazards.  It is important
                     that facilities try to reduce the amount  of overspray as much as possible.
                     Techniques for reducing overspray include:

                            1) triggering the paint gun at the end of each pass instead of carry ing
                            the gun past the edge of the surface before reversing directions,
                            2) avoiding excessive air pressure,
                            3) keeping the  gun perpendicular to the surface being coated.

                     Uniform Finish Application of a good uniform finish provides the  surface
                     with quality coating with a higher performance than an uneven finish. An
                     uneven coating does not dry evenly and commonly results in using excess
                     paint.
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                     Overlap An overlap of 50 percent can reduce the amount of waste by
                     increasing the production rate and overall application efficiency.  Overlap of
                     50 percent means that for every pass that the operator makes with the spray
                     gun, 50 percent of the area covered by the previous pass is also sprayed.  If
                     less than a 50 percent overlap is used,  the  coated  surface may appear
                     streaked. If more than a 50 percent overlap is used, the coating is wasted and
                     more passes are required to coat the surface.
                     Paint Proportioning Mixing batches of paint on an as-needed basis, whether
                     through the use of a paint proportioning machine or otherwise, can reduce the
                     amount of paint wasted. Recordkeeping requirements to track the amount of
                     paint and thinner used can also help conserve materials and prevent waste.

                     General Housekeeping Small quantities of paint and solvents are frequently
                     lost due to poor housekeeping techniques. There are a variety of ways that
                     can be implemented to control and minimize spills and leaks.  Specific
                     approaches  to  product  transfer  methods and container handling  can
                     effectively reduce product loss.

                     The potential for accidents and spills is at the highest point when thinners and
                     paints are being transferred from bulk drum storage to the process equipment.
                     Spigots, pumps, and funnels should be used whenever possible.

                     Evaporation can be controlled by using tight fitting lids, spigots, and other
                     equipment.  The reduction in evaporation will increase the amount of
                     available material and result in lower solvent purchase cost.

                     Paint Containers A significant portion of paint waste is the paint that remains
                     inside a container after the container is emptied, and paint that is placed in
                     storage, not used, and becomes outdated or non-spec. By consolidating paint
                     use and purchasing paint in bulk, large bulk containers have less surface area
                     than an equivalent volume of small cans, and the amount of drag-on paint
                     waste is reduced. Large bulk containers can sometimes be returned to the
                     paint supplier to be cleaned for reuse.

                     If the purchase of paint in bulk containers is not practical, the paint should be
                     purchased in the smallest amount required to minimize outdated or non-spec
                     paint waste. Workers should not have to open a gallon can when only a quart
                     is required. Usually, any paint that is left  in the can will require disposal as
                     hazardous waste.
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           Federal Statutes and Regulations
VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS

                    This section discusses the Federal regulations that may apply to this sector.
                    The purpose of this section is to highlight and briefly describe the applicable
                    Federal requirements, and to provide citations for more detailed information.
                    The three following sections are included:

                    •Section VI. A. contains a general overview of major statutes
                    •Section VLB. contains a list of regulations specific to this industry
                    •Section VI.C. contains a list of pending and proposed regulations

                    The descriptions  within Section  VI  are  intended solely  for  general.
                    information.   Depending upon the nature or scope of the activities at a
                    particular facility, these summaries may or may not necessarily describe all
                    applicable  environmental requirements.  Moreover, they do not constitute
                    formal interpretations or clarifications of the statutes and regulations. For
                    further information, readers should consult the Code of Federal Regulations
                    and other state or local regulatory agencies.  EPA Hotline contacts are also
                    provided for each major statute.

 VI. A. General Description of Major Statutes

          Resource Conservation and Recovery Act

                     The Resource Conservation And Recovery Act (RCRA) of 1976 which
                     amended the  Solid Waste Disposal Act, addresses solid (Subtitle D) and
                     hazardous  (Subtitle C) waste management activities.  The Hazardous and
                     Solid  Waste Amendments  (HSWA) of 1984 strengthened RCRA's waste
                     management provisions and added Subtitle  I, which governs underground
                     storage tanks  (USTs).

                     Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
                     260-299) establish a "cradle-to-grave"  system governing hazardous waste
                     from the point of generation to disposal. RCRA hazardous wastes include the
                     specific materials listed in the regulations (commercial chemical products,
                     designated with the  code "P" or "U";  hazardous  wastes from specific
                     industries/sources, designated with the code "K"; or hazardous wastes from
                     non-specific  sources,  designated with the  code "F") or materials which
                     exhibit a hazardous waste characteristic (ignitability, corrosivity, reactivity,
                     or toxicity and designated with the code "D").

                     Regulated entities that  generate hazardous waste are  subject to waste
                     accumulation, manifesting, and record keeping  standards.  Facilities must
                     obtain a permit either from EPA or from a State agency which  EPA  has
                     authorized to implement the permitting program if they store hazardous
                     wastes  for more than  90 days before treatment or disposal. Facilities may
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              Federal Statutes and Regulations
                     treat hazardous wastes stored in less-than-ninety-day tanks or containers
                     without a permit.  Subtitle C permits contain general facility standards such
                     as contingency plans, emergency procedures, record keeping and reporting
                     requirements, financial assurance mechanisms, and unit-specific standards.
                     RCRA also contains provisions (40 CFR Part 264 Subpart S and §264.10) for
                     conducting corrective actions which govern the cleanup of releases of
                     hazardous waste  or  constituents from solid waste management units at
                     RCRA-regulated facilities.

                     Although RCRA  is a Federal statute, many States implement the RCRA
                     program. Currently, EPA has delegated its authority to implement various
                     provisions of  RCRA to  47 of the 50 States and two U.S. territories.
                     Delegation has not been given to Alaska, Hawaii, or Iowa.

                     Most RCRA requirements are not industry specific but apply to any company
                     that generates, transports, treats, stores, or disposes of hazardous waste. Here
                     are some important RCRA regulatory requirements:

                     •Identification of Solid and Hazardous Wastes (40 CFR Part 261) lays out
                     the procedure every generator must follow to determine whether the material
                     in question is considered a hazardous waste, solid waste, or is exempted from
                     regulation.

                     •Standards for Generators of Hazardous Waste  (40 CFR Part 262)
                     establishes the responsibilities of hazardous waste generators including
                     obtaining an EPA ID number, preparing  a manifest,  ensuring  proper
                     packaging and labeling, meeting standards for waste accumulation units, and
                     recordkeeping  and reporting requirements.  Generators can accumulate
                     hazardous waste for up to 90 days (or 180 days depending on the amount of
                     waste generated) without obtaining a permit.

                     •Land  Disposal Restrictions (LDRs) (40 CFR Part 268) are regulations
                     prohibiting the disposal of hazardous waste on land without prior treatment.
                     Under the LDRs program, materials must meet LDR treatment standards
                     prior to placement in a RCRA land disposal unit (landfill, land treatment unit,
                     waste pile, or surface impoundment). Generators of waste  subject to the
                     LDRs must provide notification of such to the designated TSD facility to
                     ensure proper treatment prior to disposal.

                     •Used Oil Management Standards (40 CFR Part 279) impose management
                     requirements affecting the storage, transportation, burning, processing, and
                     re-refining of the  used oil.   For parties  that merely  generate used oil,
                     regulations establish storage standards.  For a party considered a used  oil
                     processor, re-refiner,  burner, or marketer (one who generates and sells
                     off-specification used  oil directly to a used oil burner), additional tracking
                     and paperwork requirements must be satisfied.
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                    •RCRA contains unit-specific standards for all units used to store, treat, or
                    dispose of hazardous waste, including Tanks and Containers. Tanks and
                    containers used to store hazardous waste with a high volatile organic
                    concentration must meet emission standards under RCRA. Regulations (40
                    CFR Part 264-265, Subpart CC) require generators  to test the waste to
                    determine the concentration of the waste, to satisfy tank and  container
                    emissions standards, and to inspect and monitor regulated units. These
                    regulations  apply  to all facilities that store such  waste, including large
                    quantity generators accumulating waste prior to shipment off-site.

                    •Underground Storage Tanks (USTs) containing petroleum and hazardous
                    substances are regulated under Subtitle I of RCRA. Subtitle I regulations (40
                    CFR Part 280) contain tank design and release detection requirements, as
                    well as financial responsibility and corrective action standards for USTs. The
                    UST program also includes upgrade requirements for existing tanks that must
                    be met by December 22,1998.

                    •Boilers and Industrial Furnaces (BIFs) that use or burn fuel containing
                    hazardous waste must comply with design and operating standards. BIF
                    regulations (40 CFR Part 266, Subpart H) address  unit design, provide
                    performance standards, require emissions monitoring, and restrict the type of
                    waste that may be burned.

                    EPA'sRCRA,SuperfundandEPCRAHotline,at(800) 424-9346, responds
                    to questions and distributes guidance regarding all RCRA regulations. The
                    RCRA Hotline operates weekdays from 9:00a.m. to 6:00p.m., ET, excluding
                    Federal holidays.

          Comprehensive Environmental Response, Compensation, and Liability Act

                    The Comprehensive Environmental Response, Compensation, and Liability
                    Act (CERCLA), a 1980 law known commonly as Superfund, authorizes EPA
                    to respond to releases, or threatened releases, of hazardous substances that
                    may endanger public health, welfare, or the environment. CERCLA also
                    enables EPA to force parties responsible for environmental contamination to
                    clean it up or to reimburse the Superfund for response costs incurred by EPA.
                    The Superfund Amendments and Reauthorization Act (SARA) of 1986
                    revised various sections of CERCLA, extended the taxing authority for the
                     Superfund, and created a free-standing law, SARA Title III, also known as
                    the Emergency Planning and Community Right-to-Know Act (EPCRA).

                     The CERCLA hazardous substance release reporting regulations (40 CFR
                     Part 302) direct the person in charge of a facility to  report to the National
                     Response Center (NRC) any environmental release of a hazardous substance
                     which equals or exceeds a reportable quantity.  Reportable quantities are
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                     listed in 40 CFR §302.4. A release report may trigger a response by EPA, or
                     by one or more Federal or State emergency response authorities.

                     EPA implements hazardous substance responses according to procedures
                     outlined in the National Oil and Hazardous Substances Pollution Contingency
                     Plan (NCP) (40 CFR Part 300). The NCP includes provisions for permanent
                     cleanups, known as remedial  actions, and other cleanups referred to as
                     removals. EPA generally takes remedial actions only at sites on the National
                     Priorities List (NPL), which currently includes approximately 1300 sites.
                     Both EPA and states can act at sites; however,  EPA provides responsible
                     parties  the opportunity to conduct removal and remedial  actions and
                     encourages community involvement throughout the Superfund response
                     process.

                     EPA's RCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers
                     questionsand references guidance per taming to the Superfund program. The
                     CERCLA Hotline operates -weekdays from 9:00 a.m. to 6:00 p.m., ET,
                     excluding Federal holidays.

         Emergency Planning And Community Right-To-Know Act

                     The  Superfund Amendments and Reauthorization Act  (SARA) of 1986
                     created  the Emergency Planning and Community Right-to-Know Act
                     (EPCRA, also known as SARA Title III), a statute designed to improve
                    community access to information about chemical hazards and to facilitate the
                    development of chemical  emergency response  plans by State and local
                    governments.   EPCRA required the establishment of State emergency
                    response commissions  (SERCs), responsible  for coordinating  certain
                    emergency response activities and for appointing local emergency planning
                    committees (LEPCs).

                    EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
                    types of reporting obligations for facilities which store or manage specified
                    chemicals:

                    •EPCRA §302 requires facilities to notify the  SERC and LEPC of the
                    presence of any extremely hazardous  substance (the list of such substances
                    is in 40 CFR Part 355, Appendices A and B) if it has such substance in excess
                    of the substance's threshold planning quantity, and directs the facility to
                    appoint an emergency response coordinator.

                    •EPCRA §304 requires the facility to notify the SERC and the LEPC in the
                    event of a  release  equaling or exceeding the  reportable  quantity  of a
                    CERCLA hazardous substance or an EPCRA extremely hazardous substance.

                    •EPCRA §311 and §312 require a facility at which a hazardous chemical,

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                    as defined by the Occupational Safety and Health Act, is present in an amount
                    exceeding a specified threshold to submit to the SERC, LEPC and local fire
                    department material safety data sheets (MSDSs) or  lists of MSDS's and
                    hazardous chemical inventory forms (also known as  Tier I and II forms).
                    This information helps the local government respond in the event of a spill
                    or release of the chemical.

                    •EPCRA §313 requires manufacturing facilities included in SIC codes 20
                    through 39, which have ten or more employees, and which manufacture,
                    process,  or use specified chemicals  in amounts  greater  than threshold
                    quantities, to submit an annual toxic chemical release report.  This report,
                    known commonly as the Form R, covers releases and transfers of toxic
                    chemicals to various facilities and environmental media, and allows EPA to
                    compile the national Toxic Release Inventory (TRI) database.

                    AH information submitted pursuant  to EPCRA  regulations  is publicly
                    accessible, unless protected by a trade secret claim.

                    EPA's RCRA, Superfimd and EPCRA Hotline, at (800) 424-9346, answers
                    questions and distributes guidance regarding the emergency planning and
                    community  right-to-know regulations.   The EPCRA Hotline operates
                    weekdays from 9:00 a.m. to 6:00 p.m., ET, excluding Federal holidays.

         Clean Water Act

                    The primary objective of the Federal Water Pollution Control Act, commonly
                    referred to as the Clean Water Act (CWA), is to restore and maintain the
                    chemical, physical, and biological integrity of the nation's surface waters.
                    Pollutants regulated under the CWA include "priority" pollutants, including
                    various toxic pollutants; "conventional" pollutants,  such as biochemical
                    oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and
                     grease, and pH; and "non-conventional" pollutants, including any pollutant
                     not identified as either  conventional or priority.

                     The CWA regulates both direct  and indirect  discharges.   The National
                     Pollutant Discharge Elimination System (NPDES) program (CWA §502)
                     controls direct discharges into navigable waters. Direct discharges or "point
                     source"  discharges are from sources such as pipes and sewers. NPDES
                     permits, issued by either EPA or an authorized State (EPA has authorized 42
                     States to  administer  the NPDES program), contain industry-specific,
                     technology-based and/or water quality-based limits, and establish pollutant
                     monitoring requirements. A facility that intends to discharge into the nation's
                     waters must obtain a  permit prior to initiating its  discharge. A permit
                     applicant must provide quantitative analytical data identifying the types of
                     pollutants present in the facility's effluent.  The permit will then set the
                     conditions and effluent limitations on the facility discharges.
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                      A NPDES permit may also include discharge limits based on Federal or State
                      water quality criteria or standards, that were designed to protect designated
                      uses of surface waters, such as supporting aquatic life or recreation. These
                      standards, unlike the technological standards, generally do not take into
                      account technological feasibility or costs.   Water quality criteria and
                      standards vary from State to State, and site to site,  depending on the use
                      classification of the receiving body of water.  Most  States follow EPA
                      guidelines which propose aquatic life and human health criteria for many of
                      the 126 priority pollutants.

                      Storm Water Discharges

                      In 1987 the CWA was amended to require EPA to establish a program to
                      address storm water discharges.  In response, EPA promulgated the NPDES
                      storm water permit application regulations. These regulations require that
                      facilities with the following storm water discharges  apply for an NPDES
                      permit: (1) a discharge associated with industrial activity; (2)  a discharge
                      from a large or medium municipal storm sewer system; or (3)  a discharge
                      which EPA or the State determines to contribute to a violation of a water
                      quality standard or is a significant contributor of pollutants to waters of the
                      United States.

                      The term "storm water discharge associated with industrial activity" means
                      a storm water discharge from one of 11 categories  of industrial activity
                      defined at 40 CFR 122.26.  Six of the categories are defined by SIC codes
                      while the other five  are identified through narrative descriptions of the
                      regulated industrial activity.  If the primary SIC code of the facility is one of
                      those identified in the regulations, the facility is subject to the storm water
                     permit application requirements.  If any activity at a facility is covered by one
                      of the  five narrative categories,  storm  water  discharges from those areas
                      where  the activities occur are subject to storm  water discharge permit
                      application requirements.
                     Those facilities/activities that are subject to storm water discharge permit
                     application requirements are identified below. To determine whether a
                     particular facility falls within one of these categories, consult the regulation.

                     Category i: Facilities subject to storm water effluent guidelines, new source
                     performance standards, or toxic pollutant effluent standards.

                     Category ii: Facilities classified as SIC 24-lumber and wood products
                     (except wood kitchen cabinets);  SIC 26-paper and allied products (except
                     paperboard containers and products); SIC 28-chemicals and allied products
                     (except drugs and paints); SIC 291 -petroleum refining; and SIC 311 -leather
                     tanning and finishing.

                     Category  iii:  Facilities  classified as SIC 10-metal  mining; SIC 12-coal

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                     mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
                     mining.

                     Category iv:  Hazardous waste treatment, storage, or disposal facilities.

                     Category v: Landfills, land application sites, and open dumps that receive
                     or have received industrial wastes.

                     Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
                     SIC 5093-automotive scrap  and waste material recycling facilities.

                     Category vii:  Steam electric power generating facilities.

                     Category viii:  Facilities classified as SIC 40-railroad transportation; SIC 41 -
                     local passenger transportation; SIC 42-trucking and warehousing (except
                     public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
                     transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
                     storage stations and terminals.

                     Category ix: Sewage treatment works.

                     Category x:   Construction activities except operations that result in the
                     disturbance of less than five acres of total land area.

                     Category xi: Facilities classified as SIC 20-food and kindred products; SIC
                     21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
                     products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-fumiture
                     and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
                     paper and paperboard products; SIC 27-printing, publishing, and allied
                     industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
                     allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
                     products (except leather and tanning and finishing); SIC 323-glass products;
                     SIC 34-fabricated metal products (except fabricated structural metal); SIC
                     35-industrial and commercial machinery and computer equipment; SIC 36-
                     electronic  and other  electrical equipment and  components; SIC 37-
                     transportation equipment (except ship and boat building and repairing); SIC
                     38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
                     manufacturing industries;  and SIC  4221-4225-public warehousing and
                     storage.

                     Pretreatment Program

                     Another type of discharge that is regulated by the CWA is one that goes to
                     a publicly-owned treatment works  (POTWs). The national pretreatment
                     program (CWA §307(b)) controls the indirect discharge of pollutants to
                     POTWs by "industrial users." Facilities regulated under §307(b) must meet
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                     certain pretreatment standards.  The goal of the pretreatment program is to
                     protect municipal wastewater treatment plants from damage that may occur
                     when hazardous, toxic, or other wastes are discharged into a sewer system
                     and to protect the quality of sludge generated by these plants.  Discharges to
                     a POTW are regulated primarily by the POTW itself, rather than the State or
                     EPA.

                     EPA  has developed technology-based standards  for industrial  users  of
                     POTWs. Different standards apply to existing and new sources within each
                     category. "Categorical" pretreatment standards applicable to an industry on
                     a nationwide  basis are developed by  EPA.  In addition, another land of
                     pretreatment standard, "local limits," are developed by the POTW in order to
                     assist the POTW in achieving the effluent limitations in its NPDES permit.

                     Regardless of whether a State is authorized to implement either the NPDES
                     or the pretreatment program, if it develops its own program, it may enforce
                     requirements more stringent than Federal standards.

       Spill Prevention, Control and Countermeasure Plans

                     The 1990 Oil Pollution Act requires that facilities that could reasonably be
                     expected to discharge oil in harmful quantities prepare and implement more
                     rigorous Spill Prevention Control and Countermeasure (SPCC) Plan required
                     under the CWA (40 CFR § 112.7). There are also criminal and civil penalties
                     for deliberate or negligent spills of oil. Regulations covering response to oil
                     discharges and contingency plans (40 CFR Part 300), and Facility Response
                     Plans to oil discharges (40 CFR §112,20) and for  PCS transformers and
                     PCB-containmg items were revised and finalized in 1995.

                     EPA's Office of Water, at (202) 260-5700, will direct callers -with questions
                     about the CWA  to the appropriate EPA office.  EPA also maintains  a
                     bibliographic  database of Office of Water publications  -which  can be
                     accessed through the Ground Water and Drinking Water resource center, at
                     (202) 260-7786.

       Safe Drinking Water Act

                     The Safe Drinking Water Act (SDWA) mandates that EPA establish
                     regulations to protect human health from contaminants in drinking water.
                     The law authorizes EPA to develop national drinking water standards and to
                     create a j oint Federal-State system to ensure compliance with these standards.
                    The SDWA also directs EPA to protect underground sources of drinking
                    water through the control of underground injection of liquid wastes.

                    EPA has developed primary and secondary drinking water standards under
                    its SDWA authority.  EPA and authorized  States enforce  the  primary

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                    drinking water standards, which are, contaminant-specific concentration
                    limits that apply to certain public drinking water supplies. Primary drinking
                    water standards consist of maximum contaminant level goals (MCLGs),
                    which are non-enforceable health-based goals, and maximum contaminant
                    levels (MCLs), which are enforceable  limits set as close to MCLGs as
                    possible, considering cost and feasibility of attainment.

                    The SDWA Underground Injection Control (UIC) program (40 CFR Parts
                    144-148) is a permit program which protects underground  sources of
                    drinking water by regulating five classes of injection wells.  UIC permits
                    include design, operating, inspection, and monitoring requirements.  Wells
                    used to inject hazardous wastes must also comply with RCRA corrective
                    action standards  hi order to be granted a RCRA permit, and must meet
                    applicable RCRA land disposal restrictions  standards.  The UIC permit
                    program is primarily State-enforced, since EPA has authorized all but a few
                    States to administer the program.

                    The SDWA also provides for a Federally-implemented Sole Source Aquifer
                    program, which prohibits Federal funds from being expended on proj ects that
                    may contaminate the sole or principal source of drinking water for a given
                    area, and for a State-implemented Wellhead Protection program, designed to
                    protect drinking water wells and drinking water recharge areas.

                    EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
                    and  distributes guidance pertaining to SDWA standards.  The Hotline
                    operatesfrom 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays.

       Toxic Substances Control Act

                    The Toxic Substances Control Act (TSCA) granted EPA authority to create
                    a regulatory framework to collect data on chemicals in order to evaluate,
                    assess, mitigate, and control risks which may be posed by their manufacture,
                    processing, and use. TSCA provides a variety of control methods to prevent
                    chemicals from posing unreasonable risk.

                    TSCA standards may apply at any point during a chemical's life  cycle.
                    Under TSCA §5, EPA has established an inventory of chemical substances.
                    If a chemical is not already on the inventory, and has not been excluded by
                    TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to
                    manufacture or import.  The PMN must identify the chemical and provide
                    available information on health and environmental effects.  If available data
                    are  not  sufficient to evaluate the chemicals effects, EPA can impose
                    restrictions pending  the development of information on its health and
                    environmental effects.  EPA  can  also restrict significant new uses of
                    chemicals based upon factors such  as the projected volume and use of the
                    chemical.
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                     Under TSCA §6, EPA can ban the manufacture or distribution in commerce,
                     limit the use, require labeling, or place other restrictions on chemicals that
                     pose unreasonable risks.  Among the chemicals EPA regulates under §6
                     authority are asbestos, chlorofluorocarbons (CFCs), and polychlorinated
                     biphenyls (PCBs).

                     EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
                     questions and distributes guidance pertaining to Toxic Substances Control
                     Act standards.  The Service operates from 8:30 am. through 4:30 p.m., ET,
                     excluding Federal holidays.

       Clean Air Act

                     The Clean Air Act (CAA) and its amendments, including the Clean Air Act
                     Amendments (CAAA) of 1990, are designed to "protect and enhance the
                     nation's air resources so as to promote the public health and welfare and the
                     productive capacity of the population." The CAA consists of six sections,
                     known as Titles, which direct EPA to establish national standards for ambient
                     air quality and for EPA and the States to implement, maintain, and enforce
                     these standards through a variety of mechanisms.  Under the CAAA, many
                     facilities will be required to obtain permits for the first time. State and local
                     governments oversee, manage, and enforce many of the requirements of the
                     CAAA. CAA regulations appear at 40 CFR Parts 50-99.

                     Pursuant to Title I of the CAA, EPA has established national ambient air
                     quality standards (NAAQSs) to limit levels of "criteria pollutants," including
                     carbon monoxide, lead, nitrogen dioxide, particulate matter, VOCs, ozone,
                     and sulfur dioxide.   Geographic areas that meet NAAQSs  for a  given
                     pollutant are classified as attainment areas; those that do not meet NAAQSs
                     are classified as non-attainment areas. Under section 110 of the CAA, each
                     State must develop a State Implementation Plan (SIP) to identify sources of
                     air pollution and to determine what reductions are required to meet Federal
                     air quality standards.  Revised NAAQSs for particulates and ozone were
                     proposed in 1996 and will become effective in 2001.

                     Title I also authorizes EPA to establish New Source Performance Standards
                     (NSPSs), which are nationally uniform emission standards for new stationary
                     sources falling within particular industrial categories. NSPSs are based on
                     the pollution control technology available to that category of industrial source
                     (see 40 CFR 60).

                     Under Title I, EPA establishes and enforces National Emission Standards for
                     Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
                     towards controlling particular hazardous air pollutants (HAPs).  Title I,
                     section 112(c) of the CAA further directed EPA to develop a list of sources
                     that emit any of 189 HAPs, and to develop regulations for these categories

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                    of sources. To date EPA has listed 174 categories and developed a schedule
                    for the establishment of emission standards. The emission standards will be
                    developed for both new and existing sources based on "maximum achievable
                    control  technology"  (MACT).   The MACT is  defined as  the  control
                    technology achieving the maximum degree of reduction in the emission of
                    the HAPs, taking into account cost and other factors.

                    Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
                    and planes.  Reformulated gasoline, automobile pollution control devices,
                    and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
                    uses to regulate mobile air emission sources.

                    Title IV of the CAA establishes  a sulfur dioxide nitrous oxide emissions
                    program designed to reduce the formation of acid rain. Reduction of sulfur
                    dioxide releases will be obtained by granting to certain sources  limited
                    emissions allowances, which, beginning in 1995, will be set below previous
                    levels of sulfur dioxide releases.

                    Title V of the CAA of 1990 created a permit program for all "major sources"
                    (and certain other sources) regulated under the CAA. One purpose of the
                    operating  permit is to Include in a single  document all  air emissions
                    requirements that apply to a given facility.  States are developing the permit
                    programs in accordance with guidance and regulations from EPA.  Once a
                    State program is approved by EPA, permits will be issued and monitored by
                    that State.

                    Title VI of the CAA is intended to protect stratospheric ozone by phasing out
                    the manufacture of ozone-depleting chemicals and restrict meir use and
                    distribution.   Production of Class I substances, including 15 kinds of
                    chlorofluorocarbons (CFCs) and chloroform,  were phased out (except for
                    essential uses) in 1996.

                    EPA's Control Technology Center, at (919)  541-0800, provides general
                    assistance and information on CAA standards.  The Stratospheric Ozone
                    Information Hotline, at (800) 296-1996, provides general information about
                    regulations promulgated under Title VI of the CAA, and EPA's EPCRA
                    Hotline, at (800) 535-0202, answers questions about accidental release
                    prevention under  CAA §112(r).  In addition, the Technology Transfer
                    Network Bulletin Board System (modem access (919) 541-5742)) includes
                    recent CAA rules, EPA guidance documents, and updates of EPA activities.
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 VLB. Industry Specific Requirements
                     The aerospace industry is affected by several major federal environmental
                     statutes. A summary of the major federal regulations affecting the aerospace
                     industry follows. Other resources which are useful in understanding industry
                     specific requirements are:

                            1.  The Paint and Coatings Resource Center web page
                            (http://www.paintcenter.org^
                            2.  The  Self Audit & Inspection Guide: For Facilities Conducting
                            Cleaning. Preparation, and Organic Coating of Metal Parts, published
                            by the EPA (call NCEPI at 800-490-9198, EPA Doc.  #305-B-95-
                            002).
                            3.  California EPA Air Resources Board Web Pages;
                                  Compliance Handbooks and Pamphlets
                                  •   http://www.arb.ca.gov/cd/cap/handbks.htm
                                  Compliance Training Courses
                                  •   http://www.arb.ca.gov/cd/training.htm
                                  •   http://www.arb.ca.gov/html/all.htm
       Resource Conservation and Recovery Act (RCRA)

                     The Resource Conservation and Recovery Act (RCRA) was enacted in 1976
                     to address problems related to hazardous and solid waste management.
                     RCRA gives EPA the authority to establish a list of solid and hazardous
                     wastes and to establish standards and regulations for the treatment, storage,
                     and disposal of these wastes. Regulations in Subtitle C of RCRA address the
                     identification, generation, transportation, treatment, storage, and disposal of
                     hazardous wastes.  These regulations are found in 40 CFR Part 124 and 40
                     CFR Parts 260-279.  Under RCRA, persons who  generate waste must
                     determine whether the waste is defined as solid waste or hazardous waste.
                     Solid wastes are considered hazardous wastes if they are listed by EPA as
                     hazardous or if they exhibit characteristics of a hazardous waste: toxicity,
                     ignitability, corrosivity, or reactivity.

                     Some wastes potentially generated at aerospace facilities that are considered
                     hazardous wastes are listed in 40 CFR Part 261. Some of the handling and
                     treatment requirements for RCRA hazardous waste generators are covered
                     under  40 CFR Part 262 and include the  following: determining what
                     constitutes a RCRA hazardous waste (Subpart A); manifesting (Subpart B);
                     packaging, labeling, and accumulation time limits (Subpart C); and record
                     keeping and reporting (Subpart D).

                     Several common aerospace manufacturing operations have the potential to
                     generate  RCRA  hazardous wastes.   Some of these  wastes are identified
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                    below by process.

                    Machining and Other Metalworking
                    •Metalworking fluids contaminated with oils, phenols, creosol, alkalies,
                    phosphorus compounds, and chlorine

                    Cleaning and Degreasing
                    •Solvents (F001, F002, F003, F004, F005)
                    •Alkaline and Acid Cleaning Solutions (D002)
                    •Cleaning filter sludges with toxic metal concentrations

                    Metal Plating and Surface Finishing and Preparation
                    •Wastewater treatment sludges from electroplating operations (F006)
                    •Spent cyanide plating bath solutions (F007)
                    •Plating bath residues from the bottom of cyanide plating baths (F008)
                    •Spent stripping and cleaning bath solutions from cyanide plating operations
                    (F009)

                    Surface Preparation. Painting and Coating
                    •Paint and paint containers containing paint sludges with solvents or toxic
                    metals concentrations
                    •Solvents (F002, F003)
                    •Paint chips with toxic metal concentrations
                    •Blasting media contaminated with paint chips

                    Aerospace manufacturing and rework facilities  may also generate used
                    lubricating oils which are regulated under RCRA but may or may not be
                    considered a hazardous waste (40 CFR 266).

                    Many aerospace facilities store some hazardous  wastes at the facility for
                    more than 90 days, and are therefore, a storage facility under RCRA. Storage
                    facilities are required to  have a RCRA treatment, storage, and disposal
                    facility (TSDF) permit (40 CFR Part 262.34). Some aerospace facilities are
                    considered TSDF facilities and therefore may be subject to the following
                    regulations  covered under  40  CFR Part  264: contingency plans and
                    emergency procedures (40 CFR Part 264 Subpart D); manifesting, record
                    keeping, and reporting (40 CFR Part 264 Subpart E); use and management
                    of containers (40 CFR Part 264 Subpart I); tank systems (40 CFR Part 264
                    Subpart  J); surface impoundments (40 CFR Part  264 Subpart K); land
                    treatment (40 CFR Part 264 Subpart M); corrective action of hazardous waste
                    releases  (40 CFR Part 264 Subpart S); air emissions standards for process
                    vents of processes that process or generate hazardous wastes (40 CFR Part
                    264 Subpart AA); emissions standards for leaks in hazardous waste handling
                    equipment (40 CFR Part 264 Subpart BB); and emissions standards for
                    containers, tanks, and surface impoundments that contain hazardous wastes
                    (40 CFR Part 264 Subpart CC).
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                     Many aerospace manufacturing and rework facilities are also subject to the
                     underground storage tank (UST) program (40 CFR Part 280).  The UST
                     regulations  apply  to  facilities that  store either petroleum products or
                     hazardous substances  (except  hazardous  waste)  identified  under the
                     Comprehensive Environmental Response, Compensation, and Liability Act.
                     UST regulations address design standards, leak detection, operating practices,
                     response  to releases, financial responsibility for  releases, and  closure
                     standards.

                     A number of RCRA wastes have been prohibited from land disposal unless
                     treated to meet specific standards under the RCRA Land Disposal Restriction
                     (LDR) program. The wastes covered by the RCRA LDRs are listed in 40
                     CFR Part 268  Subpart  C and include a number  of wastes that could
                     potentially be generated at aerospace manufacturing facilities. Standards for
                     the treatment and storage of restricted wastes are described in Subparts D and
                     E, respectively.

       Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

                     The  Comprehensive Environmental Response, Compensation, and Liability
                     Act (CERCLA) and the Superfund Amendments and Reauthorization Act of
                     1986 (SARA) provide the basic legal framework for the federal "Superfund"
                     program to clean up abandoned hazardous waste sites (40 CFR Part 305).
                     Metals and metal compounds often found in the aerospace industry's air
                     emissions, water discharges, or waste shipments for off-site disposal include
                     chromium, manganese, aluminum, nickel, copper, zinc, and lead. Metals are
                     frequently found at CERCLA's problem sites. When Congress ordered EPA
                     and the Public Health Service's Agency for Toxic Substances and Disease
                     Registry (ATSDR) to list the hazardous substances most commonly found at
                    problem sites and that pose the greatest threat to human health, lead, nickel,
                     and aluminum were all included.

                    Title III  of the  1986 SARA amendments (also known as Emergency
                    Response  and Community  Right-to-Know Act, EPCRA)  requires all
                    manufacturing facilities,  including aerospace  facilities, to report  annual
                    information to the public about over 600 toxic substances as well as release
                    of these substances  into the environment (42 U.S.C. 9601). This is known
                    as the Toxic Release Inventory (TRI). EPCRA also establishes requirements
                    for Federal, State, and local governments regarding emergency planning.

       Clean Air Act (CAA)

                    Under Title III of the 1990 Clean Air Act Amendments (CAAA), EPA is
                    required to develop national emission  standards for  189 hazardous air
                    pollutants  (NESHAP). EPA is developing maximum achievable control
                    technology (MACT) standards for all new and existing sources. The National
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Aerospace Industry
            Federal Statutes and Regulations
                    Emission Standards for Aerospace Manufacturing and Rework Facilities (40
                    CFR Part 63 Subpart GG) were finalized in 1996 and apply to major source
                    aerospace manufacturing and rework facilities.  Facilities that emit ten or
                    more tons of any one HAP or 25 or more tons of two or more HAPs
                    combined  are major  sources,  and therefore are subject to  the MACT
                    (NESHAP) requirements.  The MACT  requirements  apply  to solvent
                    cleaning operations, primer and topcoat application  operations, depainting
                    operations, chemical milling maskant application operations, and handling
                    and storage of waste.  The standards set VOC emissions and content limits
                    for different types of solvents, chemical strippers and coatings. In addition,
                    performance standards are set to reduce spills, leaks, and fugitive emissions.
                    Aerospace facilities may also be subject to National Emissions Standards for:
                    Chromium Emissions From Hard and Decorative Chromium Electroplating
                    and Chromium Anodizing Tanks (40 CFR Part 63 Subpart N) if they perform
                    chromium electroplating or anodizing; and Halogenated Solvent Cleaning if
                    they operate a solvent cleaning machine using a halogenated HAP solvent.
                    These NESHAPs require emission limits, work practice standards, record
                    keeping, and reporting.

                    Under Title V of the CAAA 1990 (40 CFR Parts 70-72) all of the applicable
                    requirements of the Amendments are integrated into one federal renewable
                    operating permit. Facilities defined as "major sources" under the Act must
                    apply for permits within one year from when EPA approves the state permit
                    programs.  Since most state programs  were not approved until  after
                    November 1994, Title V permit applications, for the most part, began to be
                    due  in  late  1995.   Due dates  for  filing complete  applications  vary
                    significantly from state to state, based on the status of review and approval
                    of the state's Title V program by EPA.

                     A facility  is designated as a major source  for Title V if it releases a certain
                     amount of any one of the CAAA regulated pollutants (SOx, NOx, CO, VOC,
                     PM10, hazardous air  pollutants, extremely hazardous substances, ozone
                     depleting  substances, and pollutants covered by NSPSs) depending on the
                     region's air quality category. Title V permits may set limits on the amounts
                     of pollutant emissions; require emissions monitoring, and record keeping and
                     reporting. Facilities are required to pay an annual fee based on the magnitude
                     of the facility's potential emissions. It is estimated that as many as 2,869
                     aerospace facilities will be designated as major sources and therefore must
                     apply for a Title V permit.

                     Under section 112(r) of CAA, owners and operators  of stationary sources
                     who produce, process, handle, or store substances listed under CAA section
                     112(r)(3)  or any other extremely hazardous substance have a "general duty"
                     to  initiate specific activities to prevent  and mitigate accidental releases.
                     Since the  general duty requirements apply to stationary sources regardless of
                     the quantity of substances  managed at  the  facility, many  aerospace
  Sector Notebook Project
89
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 Aerospace Industry	Federal Statutes and Regulations

                     manufacturing and reworking facilities are subject. Activities such as
                     identifying hazards  which may result from  accidental  releases using
                     appropriate hazard assessment techniques; designing,  maintaining  and
                     operating a safe facility; and minimizing the consequences of accidental
                     releases if they occur are considered essential activities to satisfy the general
                     duty requirements. These statutory requirements have been in affect since the
                     passage of the Clean Air Act Amendments in 1990. Although there is no list
                     of  "extremely hazardous  substances,"  EPA's  Chemical  Emergency
                     Preparedness and Prevention Office provides some guidance at its website:
                     http://www.epa.gov/swercepp.html.

                     Also under section 112(r), EPA was required to develop a list of at least 100
                     substances that, in the event of an accidental release, could cause death,
                     injury, or serious adverse effects to human health or the environment. The
                     list promulgated by EPA is contained in 40 CFR 68.130 and includes acutely
                     toxic  chemicals, flammable gases and volatile flammable liquids,  and
                     Division 1.1 high explosive substances as listed by DOT in 49 CFR 172.101.
                     Under section 112(r)(7), facilities handling more than a threshold quantity
                     (ranging from  500 to 20,000 pounds) of these substances are subject to
                     chemical accident prevention provisions including the development and
                     implementation of a risk management program (40 CFR 68.150-68.220).
                     The requirements in 40 CFR Part 68  begin to go into effect in June 1999.
                     Some  of the chemicals on the 112(r) list could be handled by aerospace
                     manufacturers and reworkers in quantities greater than the  threshold values.

       Clean Water Act

                     Aerospace manufacturing and rework facility waste water released to surface
                     waters is  regulated  under  the CWA.   National Pollutant Discharge
                     Elimination System (NPDES) permits must  be obtained to  discharge
                     wastewater into navigable waters (40 Part 122). Facilities that discharge to
                     a POTW may be required to meet National Pretreatment Standards for some
                     contaminants. General pretreatment standards applying to most industries
                     discharging to a POTW are described in 40 CFR Part 403.  In addition,
                     effluent  limitation  guidelines, new  source  performance  standards,
                     pretreatment  standards for new sources, and pretreatment standards  for
                     existing  sources may apply to some aerospace manufacturing and rework
                     facilities that carry out electroplating  or metal finishing operations.
                     Requirements for the Electroplating Point Source Category and the Metal
                     Finishing Point Source Category are listed under 40 CFR Part 413 and 40
                     CFR Part 433, respectively.

                     Storm  water rules require certain facilities with storm water discharge from
                     any one of 11 categories of industrial activity defined in 40 CFR 122.26 be
                     subject to  the storm water permit application requirements  (see Section
                     VI.A). Many aerospace facilities fall within these categories. To determine

Sector Notebook Project                     90                            November 1998

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Aerospace Industry
           Federal Statutes and Regulations
                    whether a particular facility falls within one of these categories,  the
                    regulation should be consulted.

VI-.C. Pending and Proposed Regulatory Requirements
       Clean Water Act
                    Effluent limitation guidelines for wastewater discharges from metal products
                    and machinery (MP&M) industries are being developed. MP&M industries
                    have been divided into two groups that originally were to be covered under
                    two separate phases of the rulemaking. Effluent guidelines for Phase I
                    industries and Phase II industries (which includes the aerospace industry) will
                    now be covered under a single regulation to be proposed in October 2000 and
                    finalized in December 2002.   (Steven Geil, U.S. EPA, Office of Water,
                    Engineering  and  Analysis  Division,   (202)260-9817,   email:
                    geil.steve@epamail.epa.gov)
       Clean Air Act
                    In December 1997, EPA published Control Technique Guidelines (CTG) for
                    the control  of VOC  emissions from coating  operations at aerospace
                    manufacturing and rework operations.  The CTG was issued to assist states
                    in analyzing and determining reasonably  available  control technology
                    (RACT) standards  for major sources of  VOCs  in  the  aerospace
                    manufacturing  and  rework operations  located  within  ozone NAAQS
                    nonattainment areas.  EPA estimates  that there are approximately 2,869
                    facilities that could fall within this category.  Within  one  year of the
                    publication of the CTG, states must adopt a RACT regulation at least as
                    stringent as the limits recommended in the CTG. Under Section 183(b)(3) of
                    the Clean Air Act, EPA is required to issue the CTG for aerospace coating
                    and solvent application operations based on "best available control measures"
                    (BACM) for emissions of VOCs. (Barbara Driscoll, U.S. EPA, Office of Air
                    Quality Planning and Standards, (919) 541-0164)

                    Several National Emission  Standards  for  Hazardous  Air Pollutants
                    (NESHAPs) relating to the aerospace industry are being developed for
                    promulgation by November of 2000.  They include: Rocket Engine Test
                    Firing, Engine Test Facilities, Miscellaneous Metal Parts and Products, and
                    Plastic Parts and Products. (Contact: In the U.S. EPA Office of Air Quality
                    Planning and Standards, George Smith for information  pertaining to the
                    former two, (919)541-1549; and Bruce Moore for the latter two, (919)541-
                     5460)
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 Aerospace Industry
          Compliance and Enforcement History
 VII. COMPLIANCE AND ENFORCEMENT HISTORY

        Background

                     Until recently, EPA has  focused much of its attention on measuring
                     compliance with specific environmental statutes. This approach allows the
                     Agency  to  track  compliance with the  Clean Air Act, the Resource
                     Conservation  and  Recovery  Act,  the  Clean Water Act,  and  other
                     environmental statutes.  Within the last several years, the Agency has begun
                     to supplement single-media compliance indicators with facility-specific,
                     multimedia indicators of compliance. In doing so, EPA is in a better position
                     to track compliance with all statutes at the facility level, and within specific
                     industrial sectors.

                     A major step  in building the capacity to compile multimedia data for
                     industrial sectors was the creation of EPA's Integrated Data for Enforcement
                     Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's
                     single-media databases, extract compliance records, and match the records
                     to individual facilities.  The IDEA system can  match Air, Water,  Waste,
                     Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
                     facility, and generate a list of historical permit, inspection, and enforcement
                     activity. IDEA also has the capability to analyze data by geographic area and
                     corporate holder. As the capacity to generate multimedia compliance data
                     improves, EPA  will make available more in-depth compliance and
                     enforcement information. Additionally, sector-specific measures of success
                     for compliance assistance efforts are under development.

       Compliance and Enforcement Profile Description

                     Using inspection, violation and enforcement data from the IDEA system, this
                     section provides information regarding  the historical compliance and
                     enforcement activity of this sector. In order to mirror the facility universe
                     reported in the Toxic Chemical Profile, the data reported within this section
                     consists of records only from the TRI reporting universe. With this decision,
                     the selection criteria are consistent across sectors with certain exceptions.
                     For the sectors that do not normally report to the TRI program, data have
                     been provided from EPA's Facility Indexing System (FINDS) which tracks
                     facilities in all media databases. Please note,  in this section, EPA does not
                     attempt to define the actual number of facilities that fall within each sector.
                     Instead, the section portrays the records of a subset of facilities within the
                     sector that are well defined within EPA databases.

                     As a check on the relative size of the full sector  universe, most notebooks
                     contain an estimated number of facilities within the sector according to the
                     Bureau of Census (See Section II).   With  sectors dominated by  small
                     businesses, such as metal finishers and printers, the reporting universe within
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Aerosnace Industry
       Compiiance and Enforcement History
                    the EPA databases may be small in comparison to Census data. However,
                    the group selected for inclusion in this data analysis section should be
                    consistent with this sector's general make-up.

                    Following this introduction is a list defining each data column presented
                  .  within this section.  These values represent a retrospective summary of
                    inspections and enforcement actions, and reflect solely EPA, State, and local
                    compliance assurance activities that have been entered into EPA databases.
                    To identify any changes in trends, the EPA ran two data queries, one for the
                    past five calendar years (April 1,1992 to March 31,1997) and the other for
                    the most recent twelve-month period (April 1,1996 to March 31,1997). The
                    five-year analysis gives an  average level of activity for that period for
                    comparison to the more recent activity.

                    Because most inspections focus on single-media requirements, the data
                    queries presented in this section are taken from single media databases.
                    These databases do not provide data on whether inspections are state/local or
                    EPA-led. However, the table breaking down the universe of violations does
                    give the reader a crude measurement of the EPA's and states' efforts within
                    each media program. The presented data illustrate the variations across EPA
                    Regions for certain sectors.4 This variation may be attributable to state/local
                    data entry variations, specific geographic concentrations, proximity to
                    population centers, sensitive ecosystems, highly toxic chemicals used in
                    production, or historical noncompliance. Hence, the exhibited data do not
                    rank regional performance or necessarily reflect which regions may have the
                    most compliance problems.

Compliance and Enforcement Data Definitions

       General Definitions

                    Facility Indexing System (FINDS) - assigns a common facility number to
                    EPA single-media permit records.  The FINDS identification number allows
                    EPA to compile and review  all permit,  compliance, enforcement and
                    pollutant release data for any given regulated facility.

                     Integrated Data for Enforcement Analysis (IDEA) ~ is a data integration
                     system that can retrieve information from the major EPA program office
                     databases. IDEA uses the FINDS identification number to link separate data
                     records from EPA's databases.  This allows retrieval of records from across
                     media or statutes for any given  facility, thus creating a "master list" of
 4 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD,
 PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK,
 TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X
 (AK, ID, OR, WA).
 Sector Notebook Project
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 Aerospace Industry
         Compliance and Enforcement History
                     records for that facility. Some of the data systems accessible through IDEA
                     are:  AFS (Air Facility Indexing and Retrieval System, Office of Air and
                     Radiation),  PCS (Permit Compliance System, Office of Water), RCRIS
                     (Resource Conservation and Recovery Information System, Office of Solid
                     Waste), NCDB (National Compliance Data Base, Office of Prevention,
                     Pesticides,   and  Toxic  Substances),   CERCLIS  (Comprehensive
                     Environmental and Liability Information System, Superfund), and TRIS
                     (Toxic Release Inventory System). IDEA also contains information from
                     outside sources such as Dun and Bradstreet and the Occupational Safety and
                     Health Administration (OSHA).  Most data queries displayed in notebook
                     sections IV and VII were conducted using IDEA.

       Data Table Column Heading Definitions

                     Facilities in Search -- are based on the universe of TRI reporters within the
                     listed SIC code range.  For industries not covered under TRI reporting
                     requirements (metal mining, nonmetallic mineral mining, electric power
                     generation, ground transportation, water transportation, and dry cleaning), or
                     industries in which only a very small fraction of facilities report to TRI (e.g.,
                     printing), the notebook uses the FINDS universe for executing data queries.
                     The SIC code range selected for each search is defined by each notebook's
                     selected SIC code coverage described in Section II.

                     Facilities Inspected  — indicates the level of EPA and state agency
                     inspections for the facilities in  this data search. These values show what
                     percentage of the facility universe is inspected in a one-year or five-year
                     period.

                     Number of Inspections ~ measures the total  number of  inspections
                     conducted in this  sector.  An inspection event is  counted each time it is
                     entered into a single media database.

                     Average Time Between Inspections ~ provides an average length of time,
                     expressed in months, between compliance inspections at a facility within the
                     defined universe.
                    Facilities with One or More Enforcement Actions — expresses the number
                    of facilities that were the subject of at least one enforcement action within the
                    defined time period. This category is broken down further into federal and
                    state actions.  Data are  obtained for administrative, civil/judicial, and
                    criminal enforcement actions. A facility with multiple enforcement actions
                    is only counted once in this column, e.g.,  a facility with 3 enforcement
                    actions counts as 1 facility.

                    Total Enforcement Actions ~ describes the total number of enforcement
                    actions identified for an industrial sector across all environmental statutes.
Sector Notebook Project
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November 1998

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Aerospace Industry                               Compliance and Enforcement History

                    A facility with multiple enforcement actions is counted multiple times, e.g.,
                    a facility with 3 enforcement actions counts as 3.

                    State Lead Actions — shows what percentage of the total enforcement
                    actions are taken by state and local environmental agencies. Varying levels
                    of use  by states of EPA data systems may limit the volume  of actions
                    recorded as state enforcement activity.  Some  states extensively  report
                    enforcement activities into EPA data systems, while other states may use
                    their own data systems.

                    Federal Lead Actions — shows what percentage of the total enforcement
                    actions are taken by the United States Environmental Protection Agency.
                    This value includes referrals from state agencies. Many of these actions
                    result from coordinated or joint state/federal efforts.

                    Enforcement to Inspection Rate — is a ratio of enforcement actions to
                    inspections, and is presented for comparative purposes only. This ratio is a
                    rough indicator of the relationship between inspections and enforcement. It
                    relates the number of enforcement actions and the number of inspections that
                    occurred within the one-year or five-year period. This ratio includes the
                    inspections and enforcement actions reported under the  Clean Water Act
                    (CWA), the Clean Air Act (CAA) and the Resource  Conservation and
                    Recovery Act (RCRA).  Inspections and actions from the TSCA/FIFRA/
                    EPCRA database are not factored into this ratio because most of the actions
                    taken under these programs are not the result of facility inspections.  Also,
                    this  ratio does  not account  for enforcement actions arising from non-
                    inspection  compliance  monitoring activities (e.g., self-reported  water
                    discharges) that can result in enforcement action within the CAA, CWA, and
                    RCRA.

                    Facilities with One or More Violations Identified   — indicates the
                    percentage of inspected facilities having a violation identified in one of the
                    following data categories:   In Violation or Significant Violation  Status
                    (CAA);  Reportable  Noncompliance,   Current Year  Noncompliance,
                    Significant Noncompliance  (CWA);  Noncompliance   and  Significant
                    Noncompliance (FIFRA, TSCA, and EPCRA); Unresolved Violation and
                    Unresolved High Priority Violation (RCRA). The values presented for this
                    column reflect the extent of noncompliance within the measured time  frame,
                    but do  not distinguish between the severity of the noncompliance. Violation
                    status may be a precursor to an enforcement action, but does not necessarily
                    indicate that an enforcement action will occur.

                    Media Breakdown of Enforcement Actions  and Inspections  — four
                    columns identify the proportion of total inspections and enforcement actions
                    within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
                    column is a percentage of either the "Total Inspections," or the  "Total

 Sector Notebook Project                   95                            November 1998

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 Aerospace Industry
         Compliance and Enforcement History
                     Actions" column.
 VILA. Aerospace Industry Compliance History
                     Table 14 provides an overview of the reported compliance and enforcement
                     data for the aerospace industry over the past five years (April 1992 to April
                     1997). These data are also broken out by EPA Regions thereby permitting
                     geographical comparisons.  A few points evident from the data are listed
                     below.

                     • Region IX and Region I had the most enforcement actions (43 and 36
                     respectively), accounting for 62 percent of the total enforcement actions and
                     only 29 percent of the total inspections.  Thus, these two Regions had the
                     highest enforcement/inspection ratios (0.26 and 0.19).

                     • Region IV had significantly more inspections (325) than the other Regions,
                     27 percent of the total, but only 13 percent of enforcement actions.

                     • Enforcement actions were primarily state-lead (75 percent), especially in
                     Regions with the greatest number of enforcement actions.

                     • Region V had the highest average time  between inspections (23 months),
                     which means that fewer inspections, in relation to the number of facilities,
                     were done in Region V than in other Regions.
Sector Notebook Project
96
November 1998

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Aerospace Industry
       Compliance and Enforcement History





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 Aerospace Industry
         Compliance and Enforcement History
 VII.B. Comparison of Enforcement Activity Between Selected Industries

                     Tables 15 and 16 allow the compliance history of the aerospace sector to be
                     compared to the other industries covered by the industry sector notebooks.
                     Comparisons between Tables 15 and 16 permit the identification of trends in
                     compliance and enforcement records of the various industries by comparing
                     data covering the last five years (April 1992 to April 1997) to that of the past
                     year (April 1996 to April 1997).  Some points evident from the data are listed
                     below.

                     • The one-year enforcement/inspection ratio (0.05) is only half of the five-
                     year ratio (0.10).

                     • The aerospace industry data approximate the averages of the industries
                     shown for  enforcement/inspection ratios, state-lead versus  federal-lead
                     actions, and facilities with one or more violations and enforcement actions.

                     Tables 17 and 18 provide a more in-depth comparison between the aerospace
                     industry and other sectors by breaking out the compliance and enforcement
                     data by environmental statute. As in the previous Tables (Tables 15 and 16),
                     the data cover the last five years (Table 17) and the last one year (Table 18)
                     to facilitate the identification of recent trends. A few points evident from the
                     data are listed below.

                     • The aerospace industry has the highest percentage of RCRA inspections (54
                    percent of total) of any industry.

                     • The one-year versus  five-year breakdowns in  terms of percent of total
                    inspections do not differ significantly.  However, the percent of total actions
                    pertaining to RCRA increased from 42 percent to 55 percent in the past year.
                    CWA actions decreased from 11 percent to zero percent in the last year.
Sector Notebook Project
98
November 1998

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Aerospace Industry
       Compliance and Enforcement History












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100
November 1998

-------
Aerospace Industry
       Compliance and Enforcement History
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 Sector Notebook Project
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                                                                   November 1998

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 Aerospace Industry
         Compliance and Enforcement History
Sector Notebook Project
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Aerospace Industry
        Compliance and Enforcement History
VII.C. Review of Major Legal Actions

       Major Cases/Supplemental Environmental Projects

                    This section provides summary information about major cases that have
                    affected this  sector,  and a list of Supplemental Environmental Projects
                    (SEPs).

       VII.C.1. Review of Major Cases

                    As indicated in EPA's Enforcement Accomplishments Report, FY1995 and
                    FY1996 publications, one  significant enforcement action was resolved
                    between 1995 and 1996 for the aerospace industry.

                    U.S. v. General Electric Company General Electric (GE) operates a facility
                    in Lynn, MA at which the company tests and manufactures aircraft.  The
                    enforcement  issues  arose  from GE's failure to obtain  prevention of
                    significant deterioration (PSD) permits for one boiler and for four test cells
                    used for the testing of jet engines. The boiler and the test cells emit NOx in
                    quantities that trigger the PSD new source review requirements of the Clean
                    Air Act. GE  installed/constructed two new test cells in the early 1980s and
                    modified two test cells in the late 1980s, without obtaining required permits.
                    GE installed/constructed the boiler without obtaining an adequate permit.
                    The boiler also emitted NOx in excess of the levels permissible in EPA's
                    New Source Performance Standards (NSPS).

       VII.C.2. Supplementary Environmental Projects (SEPs)

                    SEPs are compliance agreements that reduce a facility's non-compliance
                    penalty in return for  an environmental project that exceeds the value of the
                    reduction. Often, these projects fund pollution prevention activities that can
                    reduce the future pollutant loadings of a facility. Information on SEP cases
                    can be accessed via  the  internet at the  SEP  National  Database,
                    http://es.epa.gov/oeca/sep/sepdb.

                    Aerospace Techniques, Inc., in Cromwell, Connecticut, performed a SEP in
                    return for failing to  submit a Toxic Release Inventory Form R for 1,1,1-
                    trichloroethane. Aerospace Techniques achieved a 4,500 pound reduction in
                     1,1,1-trichloroethane releases by replacing the larger of its two vapor
                     degreasers with jet washing machines using heated  aqueous cleaning
                     solution.  They also  plan to scale back degreasing operations to final rinses
                     and replace six interim part-rinsing stations that utilize aqueous cleaner. The
                     cost of this project was $9,766.
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November 1998

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 Aerospace Industry
                      Activities and Initiatives
 VIII.  COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

                    This section highlights the activities undertaken by this industry sector and
                    public  agencies  to  voluntarily   improve the  sector's  environmental
                    performance.  These activities include those initiated independently by
                    industrial trade associations.  In this section, the notebook also contains a
                    listing and description of national and regional trade associations.

 VIILA.  Sector-related Environmental Programs and Activities

       Vm.A.1.  Federal Activities

       Propulsion Environmental Working Group

                    The Propulsion Environmental Working Group  (PEWG) was formally
                    chartered in 1994 by the Joint Propulsion Coordinating Committee (JPCC),
                    a consortium of industry and Department of Defense participants. PEWG is
                    composed of members from the Army, Navy, and Air Force, and of
                    companies such as Allied Signal, GE Aircraft Engines, Allison Engine,
                    Williams Intl., P&W UTC, Teledyne, Continental, and Sundstrand.

                    PEWG's chartered objectives include:
                          •providing an open forum for information exchange on possible
                          technologies to eliminate HAZMATs,
                          •assisting team members with decisions  regarding HAZMATs,
                          identifying HAZMATs, and assisting in prevention and control of
                          HAZMATs,
                          •assisting engine manufacturers and reworkers with compliance of
                          state and federal regulations,
                          •ensuring and assisting in the completion of required environmental
                          documentation such as EAs or EIAs,
                          •establishing committees to  address topics  of interest for the team
                          members.

       Propulsion Product Group

                    The Air Force Propulsion Product Group (PPG) works to incorporate
                    environmental, safety, and occupational  health concerns into multiple
                    weapon systems.  The PPG is a participant in the Propulsion Environmental
                    Working Group discussed above. Some of the accomplishment of the PPG
                    are:
                          •eliminating the use of Class I Ozone Depleting Substances (ODS)
                          •reducing the use of EPA-17 materials
                          •facilitating the annual reduction of EPA-17 materials and Class I
                          ODS's used by OEM's.
Sector Notebook Project
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November 1998

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Aerospace Industry
                                                                Activities and Initiatives
       Airworthiness Assurance Center of Excellence

                    The FAA created the Airworthiness Assurance Center of Excellence (AACE)
                    in September 1997 in an effort to "make a significant contribution to the
                    reduction of accident rates over the next five years." AACE is based at Iowa
                    State University and Ohio State University.  The five principal areas of
                    research are maintenance, inspection and repair, propulsion and fuel systems
                    safety,  crashworthiness, advanced  materials, and landing gear systems
                    performance and safety. A focus of the work is to develop crack detection
                    methods for particularly small cracks which may be under several layers of
                    skin. Major airlines are also pushing for inspection techniques which do not
                    require disassembly,  thus  preserving  sealants  and  coatings  (AW&ST,
                    3/30/98).

       Joint EPA/NASA/USAF Inter agency Depainting Study

                    NASA is conducting a technical assessment of alternative technologies for
                    aerospace depainting operations on behalf of the EPA and the US Air Force.
                    Such technologies are to be used as paint stripping processes which do not
                    adversely affect the environment and which specifically do not involve the
                    use of methylene chloride. The nine techniques subdivided into five removal
                    method categories (abrasive, impact, cyrogenic, thermal, and molecular
                    bonding disassociation).

       Thai Airways/Government ofThailand/USEPA Solvent Elimination Project

                    The  Government of  Thailand, Thai Airways, and the USEPA Solvent
                    Elimination Project studied methods of eliminating CFC-113 and methyl
                    chloroform use.  This project was undertaken as part of the World Bank
                    Global Solvents Project under  the Multilateral Fund of the Montreal
                    Protocol. The manual developed under this project describes a step-by-step
                    approach for characterizing the use of  ozone-depleting solvents  and
                    identifying and evaluating alternatives.  For case studies on this topic, see
                    Eliminating CFC-113 and Methyl Chloroform  in Aircraft Maintenance
                    Procedures, published by the Office of Air and Radiation of the USEPA in
                     October 1993.

 VIII.B.  EPA Voluntary Programs

       33/50 Program

                     The 33/50 Program  is a groundbreaking program that has focused  on
                     reducing pollution from seventeen high-priority chemicals through voluntary
                     partnerships with industry. The program's name stems from its goals: a 33%
                     reduction in toxic releases by 1992, and a 50% reduction by 1995, against a
 Sector Notebook Project
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                                                                         November 1998

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 Aerospace Industry
                       Activities and Initiatives
                     baseline of 1.5 billion pounds of releases and transfers in 1988. The results
                     have been impressive:   1,300  companies  joined the 33/50  Program
                     (representing over 6,000 facilities) and reached the national targets a year
                     ahead of schedule. The 33% goal was reached in 1991, and the 50% goal -
                     a reduction of 745 million pounds of toxic wastes ~ was reached in 1994.
                     The 33/50 Program  can provide case studies on  many of the corporate
                     accomplishments in reducing waste (Contact 33/50 Program Director David
                     Sarokin - 202-260-6396).

                     Table 19 lists those companies participating in the 33/50 program that
                     reported four-digit SIC codes within 372 and 376 to TRI.  Some of the
                     companies shown also listed facilities that are  not producing aerospace
                     products. The number of facilities within each company that are participating
                     in the 33/50 program and that report aerospace SIC codes is shown. Where
                     available and quantfiable against 1988 releases and transfers, each company's
                     33/50 goals for 1995  and the actual total releases and transfers and percent
                     reduction between 1988 and 1995 are presented.  Thirteen of the seventeen
                     33/50 target chemicals were reported to TRI by aerospace facilities in 1995.
                     These 13 chemicals accounted for 77 percent of the total releases and 65
                     percent of the total transfers reported to the 1995 TRI by aerospace facilities.

                     Table 19 shows that 47 companies comprised of 506 facilities reporting SIC
                     372 and 376 participated in the 33/50 program. For those companies shown
                     with more than one aerospace facility, all facilities may not have participated
                     in 33/50. The 33/50  goals shown for companies with multiple aerospace
                     facilities, however, are company-wide, potentially aggregating more than one
                     facility and facilities not carrying  out aerospace operations. In addition to
                     company-wide goals, individual facilities within a company may have had
                     their own 33/50 goals or may be specifically listed as not participating in the
                     33/50 program. Since the actual percent reductions shown in the last column
                     apply to all of the companies' aerospace facilities and only aerospace
                     facilities, direct comparisons to those company goals incorporating non-
                     aerospace facilities or excluding certain facilities may not be possible.  For
                     information on specific facilities participating in 33/50,  contact David
                     Sarokin (202-260-6907) at the 33/50 Program Office.

                     With the completion  of the 33/50 program, several lessons were learned.
                     Industry and the environment benefitted by this program for several reasons.
                     Companies were  willing to participate because cost  savings  and risk
                     reduction were measurable and no additional record keeping and reporting
                     was required.  The goals of the program were clear and simple and EPA
                     allowed industry to achieve the  goals in whatever manner they could.
                     Therefore, when companies can see the benefits of environmental programs
                     and be an active part of the decision-making process, they are more likely to
                     participate.
Sector Notebook Project
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Aerospace Industry
                     Activities and Initiatives
Table 19: Aerospace Industry Participation in the 33/50 Program
Parent Company
(Headquarters Location)
Aeroforce Corp.- Muncie, IN
Aerothrust Corp.- Miami, FL
Allied-Signal Inc.- Morristown, NJ
Aluminum Co. of America- Pittsburgh, PA
Arkwin Industries- Westbury, NY
Arrowhead Holdings Corp.- Bala Cynwyd, PA
BF Goodrich Co.- Akron, OH
Boeing Commercial Airplane- Seattle, WA
Chemical Milling Intl. Corp.- Rosamond, CA
Chrysler Corp.- Auburn Hills, MI
Ciba-^Geigy Corp.- Tarrytown, NY
Dassault Falcon Jet Corp.- Paramus, NJ
Dynamic Metal Prods. Co.- Manchester, CT
Eaton Corp.- Cleveland, OH
FR Holdings Inc.- Aurora, CO
Gencorp Inc.- Akron, OH
General Dynamics Corp.^- Falls Church, VA
General Electric Corp.- Fairfield, CT
General Motors Corp.- Detroit, MI
Globe Engineering Co.- Wichita, KS
Howmet Corp.- Greenwich, CT
Interlake Corp.- Lisle, IL
JT Slocomb Co.- South Glastonbury, CT
K Systems Inc.- Foster City, CA
Kimberly-Clark Corp.- Irving, TX
Large Stractrals Business Ops.- Portland, OR
Lockheed Martin Corp.- Bethesda, MD
Lucas Industries- Troy, MI
McDonnell Douglas Corp.- St. Louis, MO
Meco Inc. Paris, IL
NMB USA Inc.- Chatsworth, CA
Northrop Grumman Corp.- Los Angeles, CA
Pall Rai Inc.- Hauppauge, NY
Parker Hannifin Corp.- Cleveland, OH
Raytheon Co.- Lexington, MA
Rockwell Intl. Corp.- Seal Beach, CA
Rohr Industries Inc.- Chula Vista, CA
Company-
Owned
Aerospace
Facilities
Reporting
33/50
Chemicals
1
1
, 91
1
1
1
30
24
2
2
1
2
1
1
2
14
3
130
3
1
5
1
2
2
1
5
41
7
14
1
1
11
2
6
3
2
7
Company-
Wide %
Reduction
Goal1
(1988-
1995)
0
100
50
51
50
0
49
50
0
80
50
40
0
50
32
33
81
50
0
0
0
37
50
0
50
26
42
14
50
0
0
35
31
50
50
50
25
1988 TRI
Releases
and
Transfers of
33/50
Chemicals
(pounds)2
1,500
72,500
6,018,249
220,733
134,100
39,855
2,251,997
13,471,898
234,356
43,155
81,555
355,070
0
22,199
124,250
7,639,190
291,110
19,129,041
483,255
0
56,240
224,486
41,001
0
0
89,890
6,121,565
229,051
4,619,458
36,162
0
2,339,803
43,900
143,380
1,036,083
150,513
1,849,382
1995 TRI
Releases
and
Transfers of
33/50
Chemicals
(pounds)2
8,601
9,995
1,535,148
83,830
0
24,800
1,109,800
2,251,461
0
154,561
17,650
34,005
0
0
0
3,412,754
24,755
4,557,753
0
15,740
15,905
5,116
0
0
0
68,538
520,120
47,555
903,626
78,792
0
731,032
46,763
0
355,298
0
436,056
Actual %
Reduction
for
Aerospace
Facilities
(1988-1995)
-473%
86%
74%
62%
100%
38%
51%
83%
100%
-258%
78%
90%
—
100%
100%
55%
91%
76%
100%
—
72%
98%
100%
—
—
24%
92%
79%
80%
118%
—
69%
-7%
100%
66%
100%
76%
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Aerospace Industry
                      Activities and Initiatives
Parent Company
(Headquarters Location)





SEGL Inc.- Los Angeles, CA
SKF USA Inc.- King of Prussia, PA
Skyline Products- Harrisburg, OR
Sundstrand Corp.- Rockford, IL
Talley Industries Inc.- Phoenix, AZ
Thiokol Corp.- Ogden, UT
Trinova Corp.- Maumee, OH
United Technologies Corp.- Hartford, CT
US Air Force- Washington, DC
Total
Company-
Owned
Aerospace
Facilities
Reporting
33/50
Chemicals
1
1
1
3
9
14
1
60
4
517
Company-
Wide %
Reduction
Goal'
(1988-
1995)

13
0
0
0
0
40
50
50
0
—
1988 TRI
Releases
and
Transfers of
33/50
Chemicals
(pounds)2
75,000
0
0
494,750
133,323
2,687,295
0
8,496,888
1,643,050
81,125,233
1995 TRI
Releases
and
Transfers of
33/50
Chemicals
(pounds)2
23,005
0
0
4,293
177,213
788,979
14,400
952,497
460,159
18,940,200
Actual %
Reduction
for
Aerospace
Facilities
(1988-1995)

69%
—
—
85%
-33%
71%
—
89%
72%
77%
Source: U.S. EPA 33/50 Program Office, 1996.
1 Company- Wide Reduction Goals aggregate all company-owned facilities which may include facilities not producing
aerospace products.
2 Releases and Transfers are from aerospace facilities only.
       Project XL
                    Project XL was initiated in March 1995 as a part of President Clinton's
                    Reinventing Environmental Regulation  initiative.  The projects seek to
                    achieve cost effective environmental benefits by providing participants
                    regulatory flexibility  on  the  condition that  they  produce  greater
                    environmental benefits. EPA and program participants will negotiate and
                    sign a Final Project Agreement, detailing specific environmental objectives
                    that the regulated entity shall satisfy. EPA will provide regulatory flexibility
                    as an incentive for the participants' superior environmental performance.
                    Participants are  encouraged  to  seek  stakeholder  support from local
                    governments,  businesses,  and environmental groups.   EPA hopes to
                    implement fifty  pilot projects in four  categories, including industrial
                    facilities,  communities,  and  government facilities regulated by EPA.
                    Applications will be accepted on a rolling basis. For additional information
                    regarding XL projects, including application procedures and criteria, see the
                    May 23, 1995 Federal Register Notice.  (Contact: Fax-on-Demand Hotline
                    202-260-8590, Web: http://www.epa.gov/ProjectXL, or Christopher Knopes
                    in EPA's  Office of Reinvention 202-260-9298)
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Aerospace Industry
                     Activities and Initiatives
       Energy Star® Buildings and Green Lights® Partnership

                    In 1991, EPA introduced Green Lights®, a program designed for businesses
                    and organizations to proactively combat pollution by installing energy-
                    efficient lighting technologies in their commercial and industrial buildings.
                    In April 1995, Green Lights® expanded into Energy Star® Buildings- a
                    strategy that optimizes whole-building energy-efficiency opportunities.

                    The energy needed to run commercial and industrial buildings in the United
                    States produces 19 percent of U.S. carbon dioxide emissions, 12 percent of
                    nitrogen oxides, and 25 percent of sulfur dioxide, at a cost of 110 billion
                    dollars  a year. If implemented in every U.S. commercial and industrial
                    building, Energy Star® Buildings' upgrade approach could prevent up to 35
                    percent of the emissions associated with these buildings and cut the nation's
                    energy bill by up to 25 billion dollars annually.

                    The  over 2,500  participants  include  corporations,  small  businesses,
                    universities, health care facilities, nonprofit organizations, school districts,
                    and federal  and  local  governments.  As of January  1, 1998,  Energy
                    Star®Buildings and Green Lights® Program participants have reduced their
                    annual energy use by 7 billion kilowatt hours and annually save more than
                    517 million dollars. By joining, participants agree to upgrade 90 percent of
                    their owned facilities with energy-efficient lighting and 50 percent of their
                    owned  facilities  with whole-building upgrades, where profitable, over a
                    seven-year period. Energy Star participants first reduc&Jheit energy loads
                    with the Green Lights approach to building tune-ups, then focus on "right
                    sizing" their heating and cooling equiprnenj: to march their new energy needs.
                    EPA predicts this strategy will prevent more than 5.5 MMTCE of carbon
                    dioxide by the year 2000. EPA's Qffice of Air and Radiation is responsible
                    for operating the Energy Star Buildings and Green Lights Program. (Contact
                    the Energy Star Hotline number, 1-888-STAR-YES  (1-8,88-872-7937) or
                    Maria Tikoff Vargas, Co-Director at (202) 564-9178 or visit the website at
                    http://www.epa.gov/buildings.)

        WasteWi$e Program

                     The WasteWiSe Program was started in 1994 by EPA's Office of Solid
                     Waste  and  Emergency Response.  The  program is aimed  at reducing
                     municipal solid wastes by promoting waste prevention, recycling collection
                     and the manufacturing and purchase of recycled products.  As of 1998, the
                     program had about 700 business, government, and institutional partners.
                     Partners agree to identify and implement actions to reduce their solid wastes
                     setting waste reduction goals and providing EPA with yearly progress reports
                     for a three year period.  EPA, in turn, provides partners with technical
                     assistance, publications, networking opportunities, and national and regional
                     recognition.  (Contact: WasteWi$e Hotline at 1-800-372-9473 or Joanne
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                                                                          November 1998

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 Aerospace Industry
                       Activities and Initiatives
        NICE3
                      Oxley, EPA Program Manager, 703-308-0199)
                      The U.S. Department of Energy sponsors a grant program called National
                      Industrial Competitiveness through Energy, Environment, and Economics
                      (NICE3).   The NICE3 program provides funding to state and industry
                      partnerships (large and small business) for projects demonstrating advances
                      hi energy efficiency and clean production technologies.  The goal of the
                      NICE3 program is to demonstrate the performance  and economics  of
                      innovative technologies in the U.S.,  leading to the commercialization of
                      improved industrial manufacturing processes.  These processes should
                      conserve energy, reduce waste, and improve industrial cost-competitiveness.
                      Industry applicants must submit project proposals through a state energy,
                      pollution prevention, or business development office. The following focus
                      industries, which represent the dominant energy users and waste generators
                      in the U.S. manufacturing sector, are  of particular interest to the program:
                      Aluminum,  Chemicals, Forest Products, Glass, Metal-casting, and Steel.
                      Awardees  receive  a one-time,  three-year  grant of up to $400,000,
                     representing up to  50 percent of a project's total cost.  In addition, up to
                      $25,000 is available to support the state applicant's cost share. (Contact:
                     http//www.oit.doe.gov/Access/nice3, Steve Blazek, DOE, 303-275-4723 or
                     Eric Hass, DOE, 303-275-4728)
       Design for the Environment (DfE)
                     DfE is working with several industries to identify cost-effective pollution
                     prevention strategies that reduce risks to workers and the environment. DfE
                     helps  businesses compare and evaluate the performance,  cost, pollution
                     prevention benefits, and human health and environmental risks associated
                     with existing and alternative technologies. The goal of these projects is to
                     encourage businesses to consider and use cleaner products, processes, and
                     technologies. For more information about the DfE Program, call (202) 260-
                     1678.  To obtain copies of DfE materials or for general information about
                     DfE, contact EPA's Pollution Prevention Information Clearinghouse at (202)
                     260-1023 or visit the DfE Website at http://www.epa.gov/dfe.

                     Several DfE projects have been completed pertaining to the aerospace
                     industry.  Brief descriptions follow.

                     The National Science Foundation (NSF), the State of Massachusetts, the
                     Biodegradable Polymer Research Center, the Toxics Use Reduction Institute,
                     and the Center for Environmentally Advanced Materials were partners in a
                     DfE project on aerospace metal degreasing.
Sector Notebook Project
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November 1998

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Aerospace Industry
Activities and Initiatives
                    EPA established an interagency agreement with the Department of Energy,
                    in  partnership with  the  Joint  Association  for the Advancement of
                    Supercritical Technology, to determine the suitability of supercritical carbon
                    dioxide as an alternative method for cleaning and degreasing parts.  The
                    degree of contaminant removal of the cleaners as well as human health and
                    environmental effects were evaluated under this project.  In another
                    agreement with the Department of Energy, EPA obtained the services of the
                    Oak Ridge National Laboratory to perform research and prepare toxicity
                    summaries in support of EPA  risk assessment activities conducted on all
                    segments of the aerospace DfE project.

                    The Experimental Aircraft Association (EAA) was awarded by the EPA for
                    a demonstration project in small aircraft paint stripping. This project, begun
                    as  a DfE project  jointly run  by OPPT and the Coast Guard, explored
                    alternatives to methylene  chloride  and other  hazardous solvent paint
                    strippers. In the summer of 1997, the EAA completely stripped and repainted
                    a small plane using products that contained no chemicals on the EPA's
                    Hazardous Air Pollutant list and that met the definition  of low volatile
                    organic chemical (VOC) releases (P2 Newsletter, 1997).
       Small Business Compliance Assistance Centers

                     The  Office of  Compliance,  in  partnership with  industry, academic
                     institutions, environmental groups, and other federal and state agencies, has
                     established national Compliance Assistance Centers for four specific industry
                     sectors heavily populated with small businesses that face substantial federal
                     regulation. These sectors are printing, metal finishing, automotive services
                     and repair, agriculture, painted coatings, small  chemical manufacturers,
                     municipalities, and transportation.

                     The purpose of the Centers is to improve compliance of the customers they
                     serve by  increasing their awareness of the  pertinent federal regulatory
                     requirements and by providing the information that will enable them to
                     achieve compliance. The Centers accomplish this by offering the following:

                     •"First-Stop Shopping" - serve as  the first place that small businesses and
                     technical assistance providers go to get comprehensive, easy to understand
                     compliance information targeted specifically to industry sectors.

                      •"Improved Information Transfer" - via the Internet and other means, create
                      linkages between the small business community and providers of technical
                      and regulatory assistance and among the providers themselves to share tools
                      and knowledge and prevent duplication of efforts.
                      •"Compliance Assistance Tools" - develop and disseminate plain-English

  Sector Notebook Project                    111
          November 1998

-------
 Aerospace Industry
                       Activities and Initiatives
                      guides, consolidated checklists, fact sheets, and other tools where needed by
                      small businesses and their information providers.

                      •"Links Between Pollution Prevention and Compliance Goals" - provide easy
                      access to information and  technical assistance  on technologies to help
                      minimize waste generation and maximize environmental performance.

                      •"Information on Ways to  Reduce the Costs of Compliance" - identify
                      technologies and best management practices that reduce pollution while
                      saving money.

                     For general information regarding EPA's compliance assistance centers,
                     contact Lynn Vendinello at (202)564-7066, or go to http://www.epa.gov/
                     oeca/mfcac.html.
Sector Notebook Project
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November 1998

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Aerospace Industry
                                                               Activities and Initiatives
VIH.C. Trade Association/Industry Sponsored Activity

       VDI.C.1. Industry Research Programs

             NASA Langley Research Center and the Tidewater Interagency P2 Program

                    NASA's Langley Research  Center (LaRC) is devoted to aeronautics and
                    space research and has initiated a broad-based pollution prevention program
                    guided by a Pollution Prevention Program Plan and implemented through
                    specific projects.  The Program Plan contains an environmental baseline,
                    opportunities for P2, and establishes a framework to plan, implement, and
                    monitor specific prioritized P2 projects. LaRC is one of the participants in
                    the Tidewater Interagency Pollution Prevention Program (TIPPP).  TIPPP
                    was developed under an interagency agreement and designed to integrate P2
                    concepts and practices at Federal installations in the Tidewater, Virginia area.

              Air Force Center for Environmental Excellence

                    The Air Force Center for Environmental Excellence (AFCEE) is working
                    toward  environmental  leadership  and  pollution  prevention.    The
                    Environmental Quality Directorate of the AFCEE has developed a Base
                    Pollution Prevention Management Action Plan (PPMAP).   Each base
                    environmental manager must submit a PPMAP for his/her shop. Many Air
                    Force Bases  have  also completed Pollution  Prevention  Opportunity
                    Assessment Reports (O ARs) which outline alternative approaches that a Base
                    can use for P2 in Base-specific operations, including rework of aircraft.

              Lean Aircraft Initiative Program

                     The Lean Aircraft Initiative (LAI) is a three-year program which strives to
                     define and foster dynamic, fundamental change in both the U.S.  defense
                     aircraft industry and government operations over the next decade.  LAI is a
                     cooperative venture of private industry, the U.S. Air Force, and the EPA,
                     supported by the analytical and research expertise of the Massachusetts
                     Institute of Technology.  By building on and extending the "lean" paradigm
                     through an organized process of research, the program seeks to develop the
                     knowledge base that will lead to greater affordability of systems, higher
                     quality, and increased efficiency including efficient use of materials.

               Chemical Strategies Partnership

                     The Chemical Strategies Partnership (CSP), funded by the Pew Charitable
                     Trusts, began a pilot project with Hughes Missile Systems Company and
                     Nortel.  The CSP project aims to reduce their use and release  of toxic
                     chemicals in  manufacturing while improving production efficiency and
                     competitiveness.
  Sector Notebook Project
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                                                                          November 1998

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  Aerospace Industry
                                                                 Activities and Initiativ
               Joint Depot Environmental Panel (JDEP)

                      The  Joint Policy Coordinating Group on  Depot Maintenance in the
                      Department of Defense chartered the Joint Depot Environmental Panel
                      (JDEP) in 1988 to facilitate information exchange on environmental issues,
                      technologies,  and processes with  potential application in the  depot
                      maintenance community.  The JDEP's functions are to review the depot's
                      current environmental program, compile information on techniques and
                      processes with potential  application, coordinate  the development and
                      implementation of environmental  initiatives, and establish liaisons with
                      federal agencies. The JDEP has hosted over 37 meetings and distributed over
                      500 technical briefings.  Total dismantling of JDEP will occur in October
                      1998. (see JASPPA below.)

              Joint Group on Acquisition Pollution Prevention (JGAPP)

                     The Department of Defense has developed the Joint Group on Acquisition
                     Pollution Prevention (JGAPP) as a military/industry initiative to reduce the
                     use of hazardous material in manufacturing processes.   The initiative
                     involves seven major corporations and their related services.  The JGAPP is
                     working with manufacturers at their facilities to reduce the use of specific
                     hazardous materials in all of the programs at the facility.

              Joint Acquisition & Sustainment Pollution Prevention Activity (JASPPA)

                     The Joint Logistics Commanders of the Department of Defense tasked the
                     JGAPP and JDEP to explore the possibility of a single pollution prevention
                     activity. Since then the JDEP and the Joint Pollution Prevention Advisory
                     Board (JPPAB, which JGAPP is part  of) have been working and meeting
                     together to develop various avenues of consideration for that tasking.  As a
                     result, the JDEP and JPPAB have decided to merge to  form a single
                     integrated  group  called  the Joint Acquisition & Sustainment Pollution
                     Prevention Activity (JASPPA).  The JASPPA will function as a single
                     integrating activity for all pollution prevention efforts for both the acquisition
                     and sustainment communities. (For more information, contact Carl Adams
                     in the Joint Depot Maintenance Activities Group, (937)656-2771.)

             Aerospace Environmental Roundtable

                    The Aerospace Environmental Roundtable is an informal monthly meeting
                    coordinated by the Aerospace Industries Association(AIA).  Attendees
                    include other trade associations, contractors, and anyone else interested in
                    discussing  environmental  issues,  increasing awareness,  and sharing
                    information pertaining to  the aerospace industry. (For more information,
                    contact Glynn Rountree, (202)371-8401.)
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Aerospace Industry
                                                               Activities and Initiatives
       VIII.C.2. Trade Associations
                    Aerospace Industries Association of America (AIA)
                    1250 Eye St. NW, Suitel200         (202)371-8400
                    Washington, DC 20005              (202)371-8401 FAX
                    John Douglass, Pres.

                    AIA was founded in 1919 as a trade association which represents the nation's
                    manufacturers of commercial, military and business aircraft, helicopters,
                    aircraft engines, missiles, space craft, and related components and equipment.
                    AIA maintains the AIA Aerospace Research Center to compile statistics on
                    the industry.  AIA's annual budget is roughly seven million dollars. They
                    publishAerospace Facts and Figures annually which contains statistical and
                    analytical information on  aircraft  production, missile  programs, space
                    programs, and air transportation, as well as  an annual report and an AIA
                    newsletter.
                     Aircraft Electronics Association (AEA)
                     PO Box 1963
                     Independence, MO 64055-0963
                     Monte Mitchell, Pres.
           (816)373-6565
           (816)478-3100 FAX
                     AEA was founded in 1958 by companies engaged in the sales, engineering,
                     installation, and service of electronic aviation equipment and systems. AEA
                     works to advance the science of aircraft electronics, promote uniform and
                     stable regulations and standards of performance, gather and disseminate
                     technical data, and educate the aircraft electronics community and the public.
                     They publish Avionics News, a monthly trade magazine. The annual budget
                     is one million dollars.
                     American Helicopter Society (AHS)
                     217 N. Washington St.
                     Alexandria, VA 22314
                     Morris E. Flatter, Exec. Dir.
            (703)684-6777
            (703)739-9279 FAX
                      AHS was founded in 1943 and is composed of aircraft designers, engineers,
                      government personnel, operators, and industry  executives in over forty
                      countries interested in V/STOL aircraft.   AHS conducts research and
                      educational and technical meetings concerning professional training and
                      updated information. They publish an annual composite of technical papers
                      presented at the AHS  forum, a quarterly journal, Journal of the American
                      Helicopter Society, A bimonthly magazine, VertFlite, and other technical
                      papers. They operate  on a one million dollar budget.
  Sector Notebook Project
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                                                                          November 1998

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  Aerospace Industry
                                                                 Activities and Initiativ
                      Aviation Distributors and Manufacturers Association (ADMA)
                      1900 Arch St.                      (215)564-3484
                      Philadelphia, PA 19103-1498        (215)564-2175 FAX
                      Patricia A. Lilly, Exec. Dir.

                      ADMA was  founded in 1943  as an association  of wholesalers  and
                      manufacturers of general aviation aircraft parts, supplies, and equipment.
                      They publish ADMA News bimonthly, Aviation Education News Bulleting
                      bimonthly, and an annual directory.
                     Council of Defense and Space Industry Associations (CODSIA)
                     2111 Wilson Blvd., Suite 400        (703)247-9490
                     Arlington, VA 22201-3061
                     Peter Scrivner, Exec. Sec.

                     CODSIA was founded in 1964 and is comprised of the Aerospace Industries
                     Association  of America,  Contract  Services  Association  of America,
                     Electronic Industries Association, National Security Industrial Association,
                     Shipbuilders  Council of America,  American Electronics Association,
                     Professional Services Council, and Manufacturers' Alliance for Productivity
                     and Innovation. CODSIA holds three meetings per year in order to simplify,
                     expedite, and improve industry-wide communications regarding policies,
                     regulations, and problems.
                     Flight Safety Foundation (FSF)
                     2200 Wilson Blvd. Ste. 500
                     Arlington, VA 22201
                     Stuart Matthews, Pres.
(703)522-8300
(703)525-6047 FAX
                     FSF was founded in 1945 to represent aerospace manufacturers, domestic
                     and foreign airlines, insurance companies, fuel and oil companies, schools,
                     and miscellaneous organizations having an interest in the promotion of safety
                     in flight.  They have an annual budget of 2.5 million dollars and publish
                     several bimonthly newsletters, studies, and an annual membership directory.
                    General Aviation Manufacturers Association (GAMA)
                    1400 K St. NW, Ste. 801             (202)393-1500
                    Washington, DC 20005              (202)842-4063 FAX
                    Edward W. Simpson, Pres.

                    GAMA was founded in 1970 as an association of manufacturers of aviation
                    airframes, engines, avionics, and components. They strive to create a better
                    climate for the growth of general aviation.  GAMA publishes quarterly and

Sector Notebook Project                   Tl6~                    ~     November 1998

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Aerospace Industry
                                                               Activities and Initiatives
                    annual reports as well as films and printed material on the aviation industry.
                    Helicopter Safety Advisory Conference (HSAC)
                    PO Box 60220                     (713)960-7654
                    Houston, XX 77205                 (713)960-7660 FAX
                    Dick Landrum, Chm.

                    HSAC is comprised of helicopter operators, manufacturers, and others
                    involved in the transport of workers by helicopter. HSAC promotes safety
                    and seeks to improve operations through establishment of standards of
                    practice. HSAC was founded in 1979.


                    International Society of Transport Aircraft Trading (ISTAT)
                    5517 Talon Ct                      (703)978-8156
                    Fairfax, VA 22032-1737             (703)503-5964 FAX
                    Dawn O'Day Foster, Exec. Dir.

                    ISTAT was founded in 1983 as a society of professionals engaged in the
                    purchase, sale, financing, manufacturing, appraising, and leasing of new and
                    used commercial aircraft. ISTAT publishes a quarterly newsletter, JeTrader,
                    and an annual membership directory.
                     Light Aircraft Manufacturers Association (LAMA)
                     22 Deer Oaks Ct.                   (510)426-0771
                     Pleasanton, CA 94588
                     Lawrence P. Burke, Pres.

                     LAMA was  founded  in 1984  as  an association of manufacturers  of
                     experimental  and ultralight aircraft, suppliers to  the homebuilt aircraft
                     community, media and other professionals involved with the light aircraft
                     industry.  LAMA works to assure  that the interests of the industry are
                     properly represented to the FAA and to Congress and provides uniform
                     standards of  manufacturing quality and airworthiness.  Lama publishes
                     newsletters, standards, and a membership directory.
  Sector Notebook Project
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                                                                         November 1998

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  Aerospace Industry
                        Contacts and References
  IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS
  For further information on selected topics within the aerospace industry a list of contacts and
  publications are provided below.

  Contacts5
Name
Anthony Raia
Linda Nunn
Glynn Rountree
Steven Geil
Barbara Driscoll
George Smith
Bruce Moore
Ric Peri
Vfary Dominiak
^ieutenant Commander
Michelle Fitzpatrick
Organization
USEPA, OECA
California Air Resources Board
Aerospace Industries Association
USEPA, OW
USEPA, OAQPS
USEPA, OAQPS
USEPA, OAQPS
National Air Transport
Association
USEPA
US Coast Guard

(202)564-6045
(916)323-1070
(202)371-8401
(202)260-9817
(919)541-0164
(919)541-1549
(919)541-5460
(703)845-9000
(202)260-7768
(860)441-2859

General notebook contact
Risk Reduction
Industry Activities
Clean Water Act
Clean Air Act
Rocket Engine Test
Firing/ Engine Test
Facilities NESHAPs
Micellaneous Metal
Parts/ Plastic Parts
NESHAPs
Industry Activities
Design for the
Environment
Aircraft Rework P2
  Many of the contacts listed above have provided valuable information and comments during the development of
this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily
endorse all statements made within this notebook.
Sector Notebook Project
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November 1998

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Aerospace Industry
                                                            Contacts and References
Section II: Introduction to the Aerospace Industry
Aerospace Source Book, Aviation Week & Space Technology, January 12,1998.

Smith, Bruce A., "Industry Outlook Is Mix of Growth, Stabilization," Aviation Week & Space
Technology, March 23,1998.

USDOC, 1992 Census of Manufactures Industry Series, Aerospace Equipment, Including Parts,
Bureau of the Census, Economics and Statistics Administration, US Department of Commerce,
1995.

USDOC, U.S. Industry & Trade Outlook '98, International Trade Commission, US Department of
Commerce, McGraw-Hill, 1998.

USEPA/OAQPS, National Emission Standardsfor HazardousAir Pollutants for Source Categories:
Aerospace Manufacturing and Rework- Background Information for Proposed Standards, Office
of Air Quality Planning and Standards, USEPA, Research Triangle Park, NC, May 1994.

Section III; Industrial Process Description    	_^______	

California Air Resources Board, Guidelines for the Aerospace Industry Facilities, Emissions
Assessment Branch, California Environmental Protection Agency, November 1997.

Home, D.F. Aircraft Production Technology, Cambridge University Press, Cambridge, 1986.

 Ohio EPA, Extending the Life of Metal Working Fluids, Fact Sheet Number 11, Office of Pollution
 Prevention, March 1993.

 Ohio EPA, Pollution Prevention in Painting and Coating Operations, Fact Sheet Number 23, Office
 of Pollution Prevention, September 1994.

 USEPA,  Guide to Cleaner Technologies, Alternative Metal Finishes, Office  of Research and
 Development, USEPA, September 1994.

 USEPA/NRMRL, Environmental  Research Brief,  Pollution Prevention Assessment for a
 Manufacturer of Aircraft Landing Gear, National Risk Management Research Library, USEPA,
 Cincinnati, OH, August  1995.

 USEPA/OAQPS, Control of Volatile Organic Compound Emissions from Coating Operations at
 Aerospace Manufacturing and Rework Operations, Office of Air Quality Planning and Standards,
 USEPA, Research Triangle Park, NC, December 1997.

 USEPA/OAQPS, National Emission Standards for Hazardous Air Pollutants for Source Categories:
 Aerospace Manufacturing and Rework-Background Information for Proposed Standards, Office
 of Air Quality Planning and Standards, USEPA, Research Triangle Park, NC, May 1994.
  Sector Notebook Project
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                                                                       November 1998

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  Aerospace Industry
                      Contacts and References
  USEPA/OPPT, Pollution Prevention Options in Metal Fabricated Products Industries, Office of
  Pollution Prevention and Toxics, USEPA, January 1992.

  USEPA/ORD, Guides to Pollution Prevention, The Fabricated Metal Products Industry, Office of
  Research and Development, USEPA, Washington, DC, July 1990.

  USEPA/OW, Development Document for  the Proposed Effluent Limitations Guidelines and
  Standards for the Metal Products and Machinery Phase I Point Source Category, Office of Water
  USEPA, April 1995.

  USEPA/OECA, Profile of the Motor  Vehicle Assembly Industry, Office of Enforcement and
  Compliance Assurance, USEPA, September 1995.

  Section IV; Chemical Release and Transfer Profile	_____	

  1995 Toxics Release Inventory Public Data Release, USEPA Office of Pollution Prevention and
 Toxics, April 1997. (EPA 745-R-97-005)

 NIOSH Pocket Guide to Chemical Hazards, US Department of Health and Human Services, Center
 for Disease  Control and Prevention, June 1994.

 ChemFinder Database, 

 Section V; Pollution Prevention Opportunities   	

 Air Force Center for Environmental Excellence, Environmental Quality Directorate, Pollution
 Prevention Model Shop Report, Flightline Maintenance Shops, Brooks Air Force Base November
 30, 1994, modified June 30, 1995.


 Boeing Company Web Site, .
 California Department of Health Services, Waste Reduction for the Aerospace Industry, Toxic
 Substances Control Program, Alternative Technology Division, April 1990.

 Chao, S.C. and McHardy, J., Progress in Supercritical CO2 Cleaning, Electro-Optical and Data
 Systems Group, Hughes Aircraft Company.

 Dykema, Kevin J., and Larsen, George R., "The  Greening of Corporate Culture: Shifting the
 Environmental Paradigm at Martin Marietta Astronautics Group," Pollution Prevention Review
 Spring 1993.

 Evanoff, Stephen P., "Environmental Resources Management, Case Study #4: Substitution of Low
 Vapor Pressure Organic Solvents and Aqueous Cleaners for CFC-113 Based Cleaning Solvents,"
 EPA/ICOLP  Eliminating CFC-113 and Methyl Chloroform in Aircraft Maintenance Procedures
 October 1993.


Ohio EPA, Extending the Life of Metal Working Fluids, Fact Sheet Number 11, Office of Pollution
Sector Notebook Project
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November 1998

-------
Aerospace Industry
                                                             Contacts and References
Prevention, March 1993.

Ohio EPA, Source Reduction and Metal Recovery Techniques for Metal Finishers, Fact Sheet
Number 24, Office of Pollution Prevention, September 1994.

State of Michigan, Fact Sheet, Waste Reduction Checklist, Office of Waste Reduction Services,
Departments of Commerce and Natural Resources, December 1989.

USEPA, Guide to Cleaner Technologies, Alternative Metal Finishes, Office of Research and
Development, USEPA, September 1994.

USEPA/NRMRL, Environmental  Research  Brief, Pollution Prevention Assessment for a
Manufacturer of Aircraft Landing Gear, National Risk Management Research Library, USEPA,
Cincinnati, OH, August 1995.

USEPA/OAQPS, Control of Volatile Organic Compound Emissions from Coating Operations at
Aerospace Manufacturing and Rework Operations, Office of Air Quality Planning and Standards,
 USEPA, Research Triangle Park, NC, December 1997.

 USEP A/OAR, Eliminating CFC-113 andMethyl Chloroform in Aircraft Maintenance Procedures,
 Office of Air and Radiation, USEPA, October 1993.

 USEPA/OECA, Profile of the Shipbuilding and Repair Industry,  Office of Enforcement  and
 Compliance Assurance, USEPA, September 1997.

- USEPA/OPPT, Pollution Prevention Options in Metal Fabricated Products Industries, Office of
 Pollution Prevention and Toxics, USEPA, January 1992.

 USEPA/ORD, Guides to Pollution Prevention, The Fabricated Metal Products Industry, Office of
 Research and Development, USEPA, Washington, DC, July 1990.


 Section VIII: Compliance Activities and Initiatives       		_	

 Air Force Center for Environmental Excellence, Pollution Prevention Model Shop Report, Flightline
 Maintenance Shops, Environmental Quality Directorate, AFCEE, Brooks AFB, June 30,1995.

 Dominiak, Mary, "EPA Award Presented to the Experimental Aircraft Association," P2 Newsletter,
 December 1997.

 Jaszczak, Sandra, ed.  Gale Encyclopedia of Associations.   31st ed., International Thomson
 Publishing Co., 1996.

 NASA, Joint EPA/NASA/USAF Interagency Depainting Study, Fifth Progress Report, November
  1997.  '
  Sector Notebook Project
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                                                                       November 1998

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  Aerospace Industry
                                                             Contacts and Refei
                                      rence!
  "Project May Offer New Model for Supplier Relationships," Business and the Environment, August
  i yy I •



  ^SEPA/OA^EliminatingCFC-nSandMethylChloroformmAircmftMamtenanceProcedures
  Office of Air and Radiation, October 1993.
Sector Notebook Project
122
November 1998

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