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
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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
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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
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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
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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
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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-
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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.
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Aerospace Industry
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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.
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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:
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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.
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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.
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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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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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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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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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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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Industrial Process Description
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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Industrial Process Description
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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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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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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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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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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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).
Sector Notebook Project
35
November 1998
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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
Sector Notebook Project 36 November 1998
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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.
Sector Notebook Project
37
November 1998
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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
Sector Notebook Project
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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.
Sector Notebook Project
39
November 1998
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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.
Sector Notebook Project
40
November 1998
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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.
Sector Notebook Project
41
November 1998
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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.
Sector Notebook Project
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November 1998
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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.
Sector Notebook Project
43
November 1998
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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
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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
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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
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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.
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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
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November 1998
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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.
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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
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November 1998
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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.
Sector Notebook Project
52
November 1998
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Aerospace Industry
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.
Sector Notebook Project
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November 1998
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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).
Sector Notebook Project
54
November 1998
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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.
Sector Notebook Project
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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
56
November 1998
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Aerospace Industry
Chemical Releases and Transfers
Figure 7; Summary of TRI Releases and Transfers by Industry
500 .
.-. 40°
.0
1
w 300
•a
c
3
O
0.
! 200 .
H
100
n
. n_,rL,
-,
Lur
Qj /^\^ rt% Or y^b t
ii
n
Li
,
SIC Range
p Total Releases
_
I
,«^
4 ^
f Total Transfers
Source: US EPA 1995 Toxics Release Inventory Database.
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
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Chemical Releases and Transfers
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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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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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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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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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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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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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Pollution Prevention Opportunities
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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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
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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
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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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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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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).
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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.
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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
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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.
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Sector Notebook Project
97
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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
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November 1998
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Aerospace Industry
Compliance and Enforcement History
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Sector Notebook Project
99
November 1998
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Aerospace Industry
Compliance and Enforcement History
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Sector Notebook Project
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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November 199S
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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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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.
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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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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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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.
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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
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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.
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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.
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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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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.
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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
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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.
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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.
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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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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
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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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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.
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i United States Government
_ i INFORMATION
JBLICATIONS * PERIODICALS * ELECTRONIC PRODUCTS
Charge your order.
It's easy!
frder Processing Code:
3212
Fax your orders (202) 512-2250
Phone your orders (202) 512-1800
Qty
GPO Stock #
055-000-00512-5
055-000-00513-3
055-000-00518-4
055-000-00515-0
055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
055-000-00529-0
055-000-00514-1
055-000-00570-2
055-000-00576-1
055-000-00571-1
055-000-00573-7
055-000-00574-5
055-000-00575-3
055-000-00577-0
055-000-00578-8
055-000-00572-9
055-000-00579-6
055-000-00619-9
055-000-00620-2
Title
Published in 1995
Profile of the Dry Cleaning Industry, 104 pages
Profile of the Electronics and Computer Industry, 160 pp.
Profile of the Fabricated Metal Products Industry, 164 pp.
Profile of the Inorganic Chemical Industry, 136 pages
Profile of the Iron and Steel Industry, 128 pages
Profile of the Lumber and Wood Products Industry, 136 pp.
Profile of the Metal Mining Industry, 1 48 pages
Profile of the Motor Vehicle Assembly Industry, 156 pages
Profile of the Nonferrous Metals Industry, 140 pages
Profile of the Non-Fuel, Non-Metal Mining Ind., 108 pages
Profile of the Organic Chemical Industry, 152 pages
Profile of the Petroleum Refining Industry, 160 pages
Profile of the Printing Industry, 124 pages
Profile of the Pulp and Paper Industry, 156 pages
Profile of the Rubber and Plastic Industry, 152 pages
Profile of the Stone, Clay, Glass and Concrete Ind., 124 pp.
Profile of the Transportation Equipment Cleaning Ind., 84 pp.
Profile of the Wood Furniture and Fixtures Industry, 132 pp.
Published in 1997
Profile of the Air Transportation Industry, 90 pages
Profile of the Fossil Fuel Electric Power Generation Ind., 160
Profile of the Ground Transportation Industry, 130 pages
Profile of the Metal Casting Industry, 150 pages
Profile of the Pharmaceutical Manufacturing Industry, 147
Profile of the Plastic Resin & Man-made Fiber Industry, 1 80
Profile of the Shipbuilding and Repair Industry, 120 pages
Profile of the Textile Industry, 130 pages
Profile of the Water Transportation Industry, 90 pages
Published in 1998:
Sector Notebook Data Refresh- 1997, 210 pages
Profile of the Aerospace Industry, 130 pages
Published in 1999:
Profile of Local Government Operations, 310 pages
Price <»ch)
$6.50
$11.00
$11.00
$9.00
$8.00
$9.00
$10.00
$11.00
$9.00
$6.00
$11.00
$11.00
$7.50
$11.00
$11.00
$7.50
$5.50
$8.00
$7.50
$14.00
$10.00
$13.00
$13.00
$15.00
$9.50
$10.00
$7.50
$17.00
-^•$10.00
$25.00
Total
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