United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-456/R-97-006
January 2001 (Update)
www.epa.gov/ttn/uatw/aerosp/aeropg.html
EPA
National Emission Standards for
Aerospace Manufacturing and
Rework Facilities: Summary of
Requirements for Implementing the
NESHAP
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EPA-456/R-97-006
NATIONAL EMISSION STANDARDS FOR
AEROSPACE MANUFACTURING AND REWORK FACILITIES:
SUMMARY OF REQUIREMENTS FOR
IMPLEMENTING THE NESHAP
Prepared for:
Information Transfer and Program Integration Division (ITPID)
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Prepared by:
Pacific Environmental Services, Inc. (August 1997)
Midwest Research Institute (March 1998)
EPA, Information Transfer & Program Integration (ITPID) (December 1998)
January 2001 (new amendments update, changes highlighted)
December 1998 (update)
March 1998 (update)
August 1997 (original)
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Disclaimer
The Office of Air Quality Planning and Standards (OAQPS) and the Office of Enforcement and
Compliance Assistance (OECA) of the U. S. Environmental Protection Agency (EPA) have reviewed
this document and approved it for publication.
When using this document, remember that it isn't legally binding and doesn't replace the final rule -
"National Emission Standard for Hazardous Air Pollutants for Aerospace Manufacturing and Rework
Facilities" (published in the Federal Register, 9/1/95, 60 FR 45948) or any State and local rules that
may apply to your facility.
This document isn't intended, nor can you rely on it, to create any rights enforceable by any party
in litigation with the United States. The EPA may change this document at any time without public
notice.
This document includes requirements from the final rule and amendments published in the Federal
Register on 3/27/98 (63 FR 15006) through 12/8/00 (65 FR 76945).
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1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
Appendix A.
Appendix B.
Content
Purpose of the document
Summary of the rule
Compliance Timeline
4
Regulatory Overview
5 Rule Applicability
6
Cleaning Operations
7
Primer and Topcoat Operations (Organic HAP and VOC)
Primer and Topcoat Operations (Inorganic HAP and VOC)
Depainting
Chemical Milling Maskant
Applicability flow charts
Inspection procedures
Inspection checklists
Rule Applicability
57
Cleaning Operations
61
Primer and Topcoat Operations (Organic & Inorganic HAP and VOC)
age
1
3
16
23
28
37
43
50
56
Chemical Milling Maskant
Other implementation materials
Example calculations
List of cleaning solvent substitutions
Glossary
Example initial notification form
73
Depainti
ng
82
89
94
96
102
105
111
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Appendix C. General Provisions applicability to Subpart GG
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1.0 Introduction
The U.S. Environmental Protection Agency (EPA or we) wrote this document to help educate
sources, EPA Regional Office staff and State/local air pollution control agency personnel (you) on
the requirements of the final rule - National Emission Standards for Hazardous Air Pollutants
(NESHAP) for aerospace manufacturing and rework facilities. In this document, we've included an
overview of the rule, applicability flow charts and inspection checklists. The flowcharts should help
you understand if your process is subject to the rule. The checklists provide the detail needed to
help you check if you're in compliance with the rule.
On September 1, 1995, we published the final aerospace NESHAP. The rule regulates emissions of
Hazardous Air Pollutants (HAP) from aerospace manufacturing and rework facilities (including
maintenance and repair) that are a major source of HAP.
You can find a copy of the rule in Title 40 of the Code of Federal Regulations (CFR) Part 63,
Subpart GG or in the September 1, 1995 Federal Register, beginning on page 45948. Since
September 1, 1996, we've also published amendments to the rule. You can find a copy of these
amendments in the March 27, 1998 Federal Register, beginning on page 15006, and the September
1, 1998 Federal Register, beginning on page 46525.
We wrote the Aerospace NESHAP to reduce emissions of HAP from solvent and other materials
used in four types of aerospace operations:
cleaning
primer and topcoat application
paint removal (depainting)
application of chemical milling maskants
The rule allows you to use multiple compliance options for each of these operations. All options are
summarized in Section 2.0.
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To summarize, we've included all of the following in this document:
Section 2.0 discusses the sources subject to this rule and summarizes the rule provisions. Section
3.0 contains applicability flow charts to help you determine if the rule affects your operations.
Sections 4.0 and 5.0 suggest some procedures that personnel performing an field inspection can
follow before, during, and after the inspection. Other materials that might be helpful in
understanding and enforcing this rule are listed in Section 6.0. Section 7.0 includes example
calculations and spreadsheets for demonstrating compliance with the surface coating (primer and
topcoat) requirements. A listing of possible substitutions for cleaning solvents is provided in
Section 8.0. A glossary of terms associated with the standard is included in Appendix A. And
finally, a sample initial notification form is included in Appendix B.
When using this document, realize that we haven't included requirements in the General Provisions,
40 CFR 63, Subpart A. The General Provisions were published in the Federal Register on March
16, 1994 (59 FR 12408) and apply to all NESHAPs, including the aerospace rule. Thus, when you
became subject to this rule, you also became subject to the General Provisions. Some sections of
the aerospace rule override the General Provisions. You should check Appendix C to see which
sections of the General Provisions apply for this rule and which don't.
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2.0 Summary of the Rule
This section summarizes the major requirements of the NESHAP for aerospace manufacturing and
rework facilities. While we've attempted to be as complete as possible, you shouldn't use this
summary as a substitute for the final rule (published 9/1/95, 60 FR 45948) and any subsequent
amendments (published 3/27/98, 63 FR 15006 and 9/1/98, 63 FR 46525).
This document summarizes only the final rule and the 3/27/98 and amendments through 12/8/00.
You should keep abreast of new requirements, printed after 9/1/98, by periodically checking the
Federal Register and the Code of Federal Regulations (CFR).
Remember, in addition to the requirements summarized in this section, you're also subject to §§63.1
through 63.15 of the General Provisions. See Appendix C for specific requirements since we
haven't included them here.
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Regulatory Overview
CFR Location: 40 CFR 63 Subpart GG
Regulatory Activity Rule Proposal 6/6/94
Rule Promulgation (effective date): 9/1/95 [60 FR 45948]
Rule Corrections: 2/9/96 [61 FR 4902],
12/17/96 [61 FR 66226]
Final Amendme:^- 'Release of Final CTG 3/27/98 [63 ,FRrl5,OII£] .,.,.,
W ft3 FRJ 46525]
Final Amendmei
Compliance and Reporting: See Figure 1 for information on compliance dates, performance
testing, and reporting.
What is an affected facility?
An affected facility is one that is a major source of Hazardous Air Pollutants (HAPs). By that we
mean, a facility where the total HAPs emitted are> 10 tons/yr of any HAP OR > 25 tons/yr of any
combination of HAP.
What is an affected source?
This rule applies to operations associated with the manufacturing or rework (including maintenance
and repair) of aerospace vehicles and components. An affected source includes any of the
following:
all hand-wipe cleaning operations
each spray gun cleaning operation (by that we mean each spray gun cleaning operation is a
separate affected source)
all flush cleaning operations
for organic HAP or VOC emissions, each primer application operation (which is the total of
all primer applications at a facility)
for organic HAP or VOC emissions, each topcoat application operation (which is the total of
all topcoat applications at a facility)
for organic HAP or VOC emissions, each depainting operation (which is the total of all
depainting at a facility)
each chemical milling maskant application operation (which is the total of all such
applications at a facility)
each waste storage and handling operation (which is the total of all such operations at a
facility)
for inorganic HAP emissions, each spray booth or hangar that contains a primer, topcoat, or
depainting operation (by that we mean each booth or hangar is a separate affected source)
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Rule Applicability
[63.741]
Various processes performed at your aerospace manufacturing and rework facility are not covered
under the rule. Also, some processes are exempt from the rule and from control requirements.
These exemptions include:
The following are EXEMPT from 40 CFR 63, Subpart GG:
Specialty coatings (see Appendix A to 40 CFR 63, Subpart GG)
Sealants and adhesives
Adhesive bonding primers
Primers, topcoats, chemical milling maskants, strippers, and cleaning solvents containing
HAP and VOC <0.1% for carcinogens; <1% noncarcinogens. By this we mean the
threshold limits as outlined by the Occupational Safety and Health Administration (OSHA)
for reportable quantities on a Material Safety Data Sheet (MSDS)
Low-volume use of primers, topcoats, and chemical milling maskants which does not
exceed 50 gal (189 liters) per year per formulation; with a combined annual total of all such
primers, topcoats, and chemical milling maskants used at the facility not exceeding 200 gal
(757 liters); otherwise exempt coatings excluded from totals [63.741(g)]
Activities associated with space vehicles (except for depainting)
Rework of antique aerospace vehicles or components (>30 yrs old)
The following are NOT COVERED under 40 CFR 63, Subpart GG:
Rework of aircraft or aircraft components if the holder of the Federal Aviation
Administration (FAA) design approval, or the holder's licensee, is not actively
manufacturing the aircraft or aircraft component [63.741(f)]
Parts and assemblies not critical to vehicle's structural integrity or flight performance
Electronic parts and assemblies (except for cleaning and topcoating of completed
assemblies)
Research and development; Quality control
Laboratory testing activities
Chemical milling
Metal finishing
Electrodeposition (except the electrodeposition of paints)
Composites processing (except for some cleaning, coating, and composite tooling
operations)
Aircraft transparencies manufacturing
Handling of waste subject to RCRA, 40 CFR 262 -268
Wastewater operations
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Cleaning Operations
[63.744(a)]
What is covered under this section of the rule?
These cleaning requirements apply only to the cleaning of aerospace vehicles and components. If
your cleaning operations are subject to the hand-wipe cleaning, flush cleaning, or spray gun cleaning
requirements as described later in this section, they are also subject to these general cleaning
requirements.
What compliance options do I have?
You have two compliance options available:
Option 1: Use cleaning solvents that meet the requirements in the following table [63.744(a)]:
Cleaning Solvent
Type
Composition Requirements
Aqueous
Cleaning solvents in which water is the primary ingredient (> 80% of
cleaning solvent solution as applied must be water)
Aqueous solutions must have a flash point >200 °F (93 °C) as reported by
the manufacturer
Solution must be miscible with water
Hydrocarbon-
Based
Cleaners that are composed of photochemically reactive hydrocarbons and,
or oxygenated hydrocarbons
Have a maximum vapor pressure (VP) of 7 mm Hg at 20°C (3.75 in. H2O at
68°F)
Contain no HAP
Option 2: If you use a solvent that don't meet the requirements in Option 1, do all of the following
[63.744(a)]:
place solvent-laden cloth, paper or other absorbent applicators in bags or other closed
containers after you've finished using them (cotton-tipped swabs used for very small
cleaning operations are exempt from this requirement)
keep containers closed at all times, except when depositing or removing materials (cotton-
tipped swabs used for very small cleaning operations are exempt from this requirement)
store fresh and spent solvents in closed containers (except semi-aqueous cleaners)
handle and transfer solvents to, or from cleaning operations, and to waste handling areas in
a manner that minimizes spills
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What monitoring must I do?
You don't have any monitoring requirements under this section.
What records must I keep?
You must keep all of the following records:
All Options, record the following for each cleaning solvent used [63.752(b)(l)]:
name of the product your using
it's vapor pressure
documentation showing the organic HAP constituents
What reports must I submit?
You must submit all of the following reports:
All Options, semiannual report (every 6 months from the date of notification of compliance status)
which includes [63.753(b)]:
if the operation has been in compliance for the semiannual period, a statement that the
cleaning operations have been in compliance
the statement must be signed by a responsible official
Reporting of noncompliance is covered under the hand-wipe, flush, and spray gun cleaning sections.
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Hand-Wipe Cleaning Operations
[63.744(b)]
What is covered under this section of the rule?
Hand-wipe cleaning of aerospace vehicles or components at an aerospace facility.
What is not covered under this section of the rule?
All of the following operations or processes aren't covered:
Note: Recordkeeping is still required if you use a noncompliant cleaning solvent on an exempt
operation. See "What Records Must I Keep " under this section for specific information.
wipe cleaning operations involving spray gun cleaning (under separate provision)
[63.744(b)]
cleaning during manufacture, assembly, installation, maintenance, or testing of:
> Components of breathing oxygen systems that are exposed to breathing oxygen
[63.744(e)(l)]
> Components that are exposed to strong oxidizers or reducers [63.744(e)(2)]
cleaning and surface activation prior to adhesive bonding [63.744(e)(3)]
cleaning during the fabrication, assembly, installation, and maintenance of textile materials
used in the interior of the aircraft [63.744(e)(8)]
cleaning and cleaning solvent usage associated with research and development, quality
control, or laboratory testing [63.744(e)(ll)]
cleaning operations, using nonflammable liquids, conducted within 5 feet of energized
electrical systems [63.744(e)(12)]
cleaning of:
> electronic parts and assemblies containing electronic parts [63.744(e)(4)]
> aircraft and ground support equipment fluid systems that are exposed to fluid
[63.744(e)(5)]
> fuels cells, fuel tanks, and confined spaces [63.744(e)(6)]
> surfaces of solar cells, coated optics, and thermal control surfaces [63.744(e)(7)]
> metallic and nonmetallic materials used in honeycomb cores [63.744(e)(9)]
> aircraft transparencies, polycarbonate, or glass substrates [63.744(e)(10)]
> cleaning operations identified as essential uses under the Montreal Protocol
[63.744(e)(13)]
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What compliance options do I have?
You have three compliance options available:
Option 1: Use cleaning solvents that satisfy Option 1 under "Cleaning Operations" [63.744(b)(l)]
Option 2: Use a cleaning solvent with a composite vapor pressure of 24.1 in. H,0 (45 mm Hg) or
less at 68°F (20°C) [63.744(b)(2)]. Determine composite vapor pressure by following 63.750(b)
Option 3: Demonstrate that the volume of hand-wipe cleaning solvent usage has been reduced by
at least 60 percent from an approved baseline that is adjusted for production. Calculate the baseline
by using 1996 and 1997 data, or as otherwise agreed upon by the your permitting agency. The
baseline must be approved by the EPA or your permitting agency and be included as part of your
title V or Part 70 permit [63.744(b)(3)]
What monitoring must I do?
You don't have any monitoring requirements under this section.
What records must I keep?
Keep all of the following records based on the option you use:
If Option 1 or semi-aqueous cleaners is used record the following [63.752(b)(2)]:
name of each cleaning solvent used
demonstration that the cleaning solvent complies with one of the composition requirements
annual records of the volume of each solvent used, from facility purchase or usage records.
If Option 2 is used, record the following [63.752(b)(3)]:
name of each cleaning solvent used
composite vapor pressure of each cleaning solvent used
all vapor pressure test results (if appropriate), data, and calculations used to determine the
composite vapor pressure of each cleaning solvent
the amount (in gallons) of each cleaning solvent used each month at each operation
(purchase records may be used if you can link the quantity of materials to each operation)
If Option 3 is used, maintain a copy of the alternative plan approved by your permitting agency and
all supporting documentation. [63.744(b)(3)]
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If a cleaning solvent used in an exempt hand-wipe cleaning operation doesn't conform to the
vapor pressure or composition requirements in Option 1 or 2, record all of the following
[63.752(b)(4)]:
the identity and amount (in gallons) of each cleaning solvent used each month at each
operation (purchase records may be used if you can link the quantity of material to each
operation)
a list of exempt operations in which these solvents are being used
You can download example and blank recordkeeping forms by going to the implementation section
of the Unified Air Toxics Website (UATW) aerospace page at
www.epa.gov/ttn/uatw/aerosp/aeropg.html. Download example #1. The form is optional, but you
may find it useful.
What reports must I submit?
Report all of following information semiannually (every 6 months from date of notification of
compliance status) based on the option you use [63.753(b)]:
If Option 1 or 2 is used [63.744(b)(l), (2)]:
any instance where a noncompliant cleaning solvent is used for a nonexempt hand-wipe
cleaning operation
a list of any new cleaning solvents used for hand-wipe cleaning in the previous 6 months,
including evidence of their compliance (such as composite VP or notification that they
comply with the composition requirements)
If Option 3 is used [63.744(b)(3)]:
none, but, submit your alternative plan to your permitting authority for approval.
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Spray Gun Cleaning Operations
[63.744(c)]
What is covered under this section of the rule?
Spray gun cleaning associated with the aerospace manufacturing and rework operations performed
at an aerospace facility.
What is not covered under this section of the rule?
Cleaning of nozzle tips of automated spray equipment systems, except for robotic systems that can
be programmed to spray into a closed container [63.744(c)(5)].
What compliance options do I have?
You have four compliance options available:
Ontion 1: Enclosed System [63.744(c)(l)(i)]
clean spray gun in an enclosed system that is leak checked on a monthly basis. Enclosed
systconsits of forcing cleaning solvent through the gun.
Option 2: Nonatomized Cleaning [63.744(c)(2)]
without the use of atomizing air, clean the spray gun by placing cleaning solvent into a
pressure pot and forcing the solvent through the spray gun into a waste container that is
closed when not in use
Option 3: Disassembled Gun Cleaning [63.744(c)(3)]
clean the disassembled spray gun by hand or by soaking in a vat that is closed when not in
use or during soaking
Option 4: Atomized Cleaning [63.744(c)(4)]
force cleaning solvent through the gun and spray directly into a waste container that is fitted
with a device to capture the atomized solvent
What monitoring must I do?
Monitor all of the following based on the option you use:
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If Option 1 is used, perform the following:
visually inspect seals and other potential sources of leaks of each enclosed system monthly
(while operating) [63.751 (a)]
if leak is found, repair within 15 days or remove solvent and shut down system until leak is
repaired [63.744(c)(l)(ii)]
If Option 2. 3. or 4 is used, no monitoring required.
What records must I keep?
Keep all of the following records based on the option you use:
If Option 1 is used, record the following for each leak found [63.752(b)(5)]:
source identification
date leak was discovered and repaired
If Option 2. 3 or 4 is used, no recordkeeping required.
You can download example and blank recordkeeping forms by going to the implementation section
of the Unified Air Toxics Website (UATW) aerospace page at
www.epa.gov/ttn/uatw/aerosp/aeropg.html. Download example #2. The form is optional, but you
may find it useful.
What reports must I submit?
Report all of following information semiannually (every 6 months from date of notification of
compliance status) based on the option you use [63.753(b)]:
If Option 1 is used [63.753(b)(l)(iii), (iv)]:
any instance where a noncompliant spray gun cleaning method is used
any instance where a leaking enclosed spray gun cleaner remains unrepaired and in use for
more than 15 days
If Option 2. 3. or 4 is used, no reporting required.
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Flush Cleaning Operations
[63.744(d)]
What is covered under this section of the rule?
These requirements apply only to flush cleaning operations associated with an aerospace part or
assembly, or components of a coating unit.
Flush cleaning is defined as the removal of contaminants such as dirt, grease, and coatings
from an aerospace vehicle or component or coating equipment by passing solvent over, into, or
through the item being cleaned. The solvent may simply be poured into the item being cleaned
and then drained, or be assisted by air or hydraulic pressure, or by pumping [63.742].
What is not covered under this section of the rule?
Other (nonflush) cleaning operations, spray gun cleaning (which are covered under separate
subsections), and hand-wipe cleaning operations where wiping, scrubbing, mopping, or other hand
action is used, are not subject to the flush cleaning requirements [63.742 and 63.744(d)].
What compliance options do I have?
You have two compliance options available:
Option 1: Use only cleaning solvents that satisfy Option 1 under "Cleaning Operations"; OR are
semi-aqueous cleaners (a solution in which >60% of the solvent solution as applied is water)
[63.744(d)]
Option 2: If cleaning solvent used does not meet the requirements in Option 1, do the following
[63.744(d)]:
empty flushed solvent into an enclosed container or collection system OR into a system
with equivalent emission control
keep your collection system closed when not in use
What monitoring must I do?
You don't have any monitoring requirements under this section.
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What records must I keep?
Keep all of the following records based on the option you use:
If Option 1 (semi-aqueous cleaners) is used record the following [63.752(b)(2)]:
name of each cleaning solvent used
all data and calculations that demonstrate that the cleaning solvent complies with the
composition requirements
annual records of the volume of each solvent used, as determined from facility purchase or
usage records
If Option 1 (nonsemi-aqueous cleaners) is used no recordkeeping required.
If Option 2 is used no recordkeeping required.
You can download example and blank recordkeeping forms by going to the implementation section
of the Unified Air Toxics Website (UATW) aerospace page at
www.epa.gov/ttn/uatw/aerosp/aeropg.html. Download example #3. The form is optional, but you
may find it useful.
What reports must I submit?
You don't have any reporting requirements under this section.
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Primer and Topcoat Operations
(Organic HAP and VOC Control)
[63.745]
What is covered under this section of the rule?
Organic HAP-containing primer and topcoat (including self-priming topcoat) application operations
on aerospace vehicles, parts, or assemblies [63.745(a)-(f)]
From here one, whenever you see the term "topcoat" it includes "self-priming topcoat".
What is not covered under this section of the rule?
Coatings applied to aerospace equipment that is no longer operational, not intended for
public use, and not easily capable of being moved [63.745(a)]
The following are exempt from the application technique requirements only. All other
regulatory requirements apply [63.745(f)(3)]:
+ Operation that normally requires the use of an airbrush or extension on the spray
gun
> Application of coatings that contain fillers which adversely affect atomization with
HVLP guns (permitting agency determination required)
* Applications that normally have a dried film thickness of < 0.0005 in. (0.0013 cm)
(permitting agency determination required)
* The use of airbrush application methods for stenciling, lettering, or marking
+ Use of hand-held spray cans
* Touchup and repair operations
What compliance options do I have?
All Options: Use the following application equipment and housekeeping measures:
Handle and transfer primers and topcoats in a manner to minimize spills [63.745(b)]
Apply coatings using one or more of the following application techniques [63.745(f)]:
* Flow/curtain coating
* Dip coat application
> Roll coating
> Brush coating
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> Cotton-tipped swab application
* Electrodeposition (dip) coating
» HVLP spraying
> Electrostatic spray application
* Other application methods that achieve emission reductions equivalent to HVLP or
electrostatic spray. You must follow 63.750(i) when making this determination
Operate application devices according to company procedures, local specified operating
procedures, and, or manufacturer's specifications [63.745(f)(2)]
If application equipment is modified, maintain a transfer efficiency equal to HVLP and
electrostatic spray [63.745(f)(2)]
Option 1: Uncontrolled, compliant coatings. Use primers and topcoats that comply with the limits
below [63.745(c)]:
Coating Type
Primers
Topcoats (including self-
priming)
General Aviation (all coating
categories)
Large commercial aircraft
components, fully assembled or
components (exterior primer)
Maximum Content, as Applied"
Organic HAP Content
g/liter
350
420
540
650
Ib/gal
2.9
3.5
4.5
5.4
VOC Content
g/liter
350
420
540
650
Ib/gal
2.9
3.5
4.5
5.4
HAP content is measured "less water"; VOC content is measured less water and exempt solvents.
Include thinner added to calculation.
Option 2: Uncontrolled, low HAP coatings. Use "low HAP content" coatings that comply with the
limits below [63.752(c)(3)]. Option 2 provides reduced recordkeeping and reporting:
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Coating Type
Primers
Topcoats (including self-
priming)
Maximum Content, as Applied"
Organic HAP Content
g/liter
250
420
Ib/gal
2.1
3.5
VOC Content
g/liter
250
420
Ib/gal
2.1
3.5
* HAP content is measured "less water"; VOC content is measured less water and exempt solvents.
Include thinner added to calculation.
Option 3: Uncontrolled, averaged coatings. Average coatings in a manner that meets all of the
following criteria [63.745(e)(2). 63. 743 (d)]:
Use any combination of uncontrolled primers or topcoats such that the monthly volume-
weighted average of organic HAP and VOC content of the combination of primers and
topcoats complies with the content limits in 63.745(c), which is the same as Option 1.
Only uncontrolled primers and topcoats can use this option. The permitting agency can
specify a shorter averaging period than monthly [63. 743 (d)]
Averaging primers together with topcoats is not allowed
Averaging schemes must be pre-approved by the permitting authority as adopted as part of
your title V operating permit
Option 4: Controlled Coatings. Use add-on controls that meet all of the following criteria
[63.745(d)]:
Note: You may use air pollution control devices not listed in the rule, but to do so, you must
submit information about the system you wish to use no later than 120 days prior to the
compliance date. See 63. 743 (c) for additional information.
Demonstrate an overall removal efficiency (of both organic HAP and VOC) of >81%.
Overall efficiency is the product of the capture efficiency and the destruction or removal
efficiency. Capture and destruction efficiency is determined by following 63.750(g) if your
control device is a carbon adsorber, or 63.750(h) whenever a control device other than a
carbon adsorber is used
Conduct initial performance test unless a waiver is obtained [63.749(d)(2)]
Option 5: Waterborne Coatings: Use waterborne coatings that meet all of the following criteria
Note: Waterborne coatings are exempted from the folio-wing sections of the rule if they meet the
organic HAP and VOC content limits in 63. 745 (c) : 63. 745 (d) [control devices], 64. 745 (e)
[compliant coatings], 63. 749(d) [performance tests], 63. 750(c)-(h) [HAP and VOC content
18
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determination], 63.752(c) [organicHAP and VOC recordkeeping], and 63.753(c) [primer and
topcoat reporting].
Maintain manufacturer's data and annual purchase records for 5 years
Waterborne coatings may be averaged under 63.743(d)
What monitoring must I do?
If Option 1. 2. 3. or 5 is used, no monitoring is required.
If Option 4 is used, monitor control device operation as follows:
Control device is a carbon adsorber:
+ Establish as a site-specific operating parameter the outlet total HAP or VOC
concentration or the control device efficiency [63.751(b)(l)]
> For nonregenerative carbon systems, the carbon replacement time interval may be
established as the site-specific operating parameter [63.751(b)(2)]
> For capture systems, submit a monitoring plan that identifies the operating
parameter to be monitored, discusses why this parameter is appropriate, and
identifies the specific monitoring procedures [63.751(b)(3)(i)]
> Conduct monitoring in accordance with the submitted plan unless EPA comments
require an alternate monitoring scheme [63.751(b)(3)(iii)]
> Install, calibrate, operate, and maintain a continuous emission monitor that complies
with CFR specifications and requirements [63.751(b)(6)(ii), (iii)(A)]
* Do not operate the control device at an average control efficiency less than the
required level for three consecutive adsorption cycles or over a 7- to 30-day rolling
average, as applicable [63.75 l(b)(6)(iii)(B), (C)]
> Do not operate the capture device at an average parameter value greater or less than
(as appropriate) the established value for any 3-hour period [63.751(b)(6)(iv)]
Control device is an incinerator:
> Install, calibrate, maintain, and operate temperature monitoring equipment or a
CEMS. Replace or have temperature sensors recalibrated every 3 months
[63.751(b)(8)]
> Install a thermocouple equipped with a continuous recorder and operate
continuously (correct locations indicated in rule) [63.751(b)(9), (10)]
> Establish site-specific temperature parameters during each performance test
), (12)]
19
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What records must I keep?
If Option 1 is used, record the following [63.762(c)(l,2)]:
Name and VOC content as received and as applied for each primer and topcoat used
Mass of organic HAP (Hj) and VOC (G() emitted per unit volume of coating as applied for
each coating formulation within each coating category used each month (calculate using
§63.750(c) and (e))
All data, calculations, and test results used in determining 1^ and Q
Volume (gal) of each coating formulation within each coating category used each month
If Option 2 is used, record the following [63.752(c)(3)]:
Annual purchase records of the total volume of each primer purchased
All data, calculations, and test results used in determining organic HAP and VOC as applied,
including:
> Manufacturer's certification when the primer is applied as received
> All data and calculations used to determine f{ if not applied as received
If Option 3 is used, record the following [63.752(c)(4)]:
Monthly volume-weighted average masses of organic HAP (HJ and VOC (GJ for all
coatings as applied (calculate using §63.750(d) and (f), as applicable)
All data and calculations used to determine H, and Ga
If Option 4 is used, record the following [63.752(c)(5), (6)]:
Control device is not a carbon adsorber:
> Overall control efficiency of the control system and all test results, data, and
calculations used
Control device is incineration (catalytic and noncatalvtic):
> Continuous records of the firebox temperature and all calculated 3-hour averages
Control device is a carbon adsorber:
> calculations used
> The length of the rolling material balance period and all data and calculations used
> The record of the certification of the accuracy for the device that measures HAP or
VOC recovered
Control device is a nonregenerative carbon adsorber:
20
-------
> Overall control efficiency of the system and all test results, data, and calculations
used
> The record of the carbon replacement time established as the site-specific operating
parameter
If Option 4 is used, perform the following [63.743(b)]:
Prepare a startup, shutdown, and malfunction plan (excluding any dry particulate filters
operated per manufacturer's instructions) which includes:
* Requirements in §63.6
> Operation and maintenance criteria
> A standardized equipment operation and maintenance checklist
> Procedures for identifying and reporting malfunctions
> Procedures to prevent malfunctions due to preventable conditions
Operate all control equipment during startup, shutdown and malfunction in accordance with
the startup, shutdown, and malfunction plan.
If Option 5 is used, record the following [63.741(i)]:
Manufacturer's supplied data and annual purchase records for each exempt waterborne
coating
Retain records for 5 years
You can download example and blank recordkeeping forms by going to the implementation section
of the Unified Air Toxics Website (UATW) aerospace page at
www.epa.gov/ttn/uatw/aerosp/aeropg.html. Download example #4(a). The form is optional, but
you may find it useful.
21
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What reports must I submit?
All Options, report the following (except for the use of waterborne coatings) [63.753(c)]:
Semiannual reports occurring every 6 months (from the date of notification of compliance
status) that identify required reporting for each painting category
If the operations have been in compliance for the semiannual period, a statement that the
operations have been in compliance with the applicable standards
If Option 1 or 2 is used, report the following: [63.753(c)(l)(i)]
Each value of f{ and Q that exceeds the applicable organic HAP or VOC content limit
If Option 3 is used, report the following: [63.753(c)(l)(ii)]
Each value of H, and Ga that exceeds the applicable organic HAP or VOC content limit
If Option 4 is used, report the following: [63.753(c)(l)(iii),(iv)]
Control device is incineration:
All periods when the 3-hour average combustion temperature is less than the average
combustion temperature established during the most recent performance test
Control device is a carbon adsorber:
* Each rolling period when the overall control efficiency of the control system is less
than 81%, the initial material balance calculation and any exceedance as
demonstrated through calculations
Control device is a nonregenerative carbon adsorber:
> Submit the design evaluation, the continuous monitoring system performance
report, and any excess emissions as demonstrated through deviations of monitored
values
Control device is something other than an incinerator or carbon adsorber:
* Each exceedance of the operating parameters established for the control device
under the initial performance test during which compliance was demonstrated
If Option 5 is used, no reporting is required.
22
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Primer and Topcoat Operations
(Inorganic HAP Control)
[63.745 (g)]
What is covered under this section of the rule?
Inorganic HAP-containing primers and topcoats (including self-priming topcoats) that are spray
applied and are used to coat aerospace parts, assemblies, or vehicles [63.745(g)].
What is not covered under this section of the rule?
Coatings applied to aerospace equipment that is no longer operational, not intended for
public use, and not easily capable of being moved [63.745(a)]
Touchup of scratched surfaces or damaged paint [63.745(g)(4)(i)]
Hole daubing for fasteners [63.745(g)(4)(ii)]
Touchup of trimmed edges [63.745(g)(4)(iii)]
Coating prior to joining dissimilar metal components [63.745(g)(4)(iv)]
Stencil operations performed by brush or airbrush [63.745(g)(4)(v)]
Section joining and sealant detackifying [63.745(g)(4)(vi), (viii)]
Touchup of bushings and other similar parts [63.745(g)(4)(vii)]
Painting of parts in an area identified in a Title V permit, where the permitting authority has
determined that it is not technically feasible to paint the parts in a booth [63.745(g)(4)(ix)]
Use of hand-held spray can application methods [63.745(g)(4)(x)]
What compliance options do I have?
All covered coating operations must be conducted in a spray booth or hangar. Air flow must be
downward or across the part and must be exhausted through a control device [63.745(g)].
Note: You may use air pollution control devices not listed in the rule, but to do so, you must
submit information about the system you wish to use no later than 120 days prior to the
compliance date. See 63.743(c) for additional information.
Control Device Options for Existing Sources [63.745(gy2yiV|:
Option 1: Pass air through a dry particulate filter that meets the existing source filtration
efficiencies below [63.745(g)(2)(i)(A)]
23
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Performance Requirements for Inorganic HAP Arresters1
Filter type/test
conditions
Aerodynamic particle
size (micron)
Minimum required
filtration efficiency (%)
Existing Sources (two-stage arrestor)
Liquid phase
challenge
Solid phase
challenge
>5.7
>4.1
>2.2
>8.1
>5.0
>2.6
>90
>50
>10
>90
>50
>10
'Filters must be certified by the filter manufacturer or distributor, paint/depainting booth
supplier, and, or facility owner or operator that the filters meet or exceed these
efficiency data points. Certification must be based on Method 319 testing [63.750(o)].
Option 2: Pass air through a waterwash system [63.745(g)(2)(i)(B)]
Option 3: Use another control system that meets efficiencies in Option 1 and is approved
by the permitting authority [63.745(g)(2)(i)(C)]
Control Device Options for New Sources [63.745(g)(2)(ii)]:
Option 1: Pass air through a dry filter that meets new source filtration efficiencies below
[63.745(g)(2)(n)(A)]:
Performance Requirements for Inorganic HAP Arresters2
Filter type/test
conditions
Aerodynamic particle
size (micron)
Minimum required
filtration efficiency (%)
New Sources (three-stage arrestor)
Liquid phase
challenge
Solid phase
challenge
>2.0
>1.0
>0.42
>2.5
>1.1
>0.70
>95
>80
>65
>95
>85
>75
Tilters must be certified by the filter manufacturer or distributor, paint/depainting booth
supplier, and, or facility owner or operator that the filters meet or exceed these
efficiency data points. Certification must be based on Method 319 testing [63.750(o)].
24
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Option 2: Use another control system that meets new source efficiencies and is approved
by the permitting authority [63.745(g)(2)(ii)(B)]
Control Device Options for Sources Constructed or Reconstructed After June 6. 1994 and
prior to October 29. 1996 [63.745(g)(2)(iii)]:
Option 1: Pass air through a 2-stage dry filter or a waterwash system before exhausting it
to the atmosphere [63.745(g)(2)(iii)(A)]
Option 2: For primers or topcoats containing chromium or cadmium, install a HEPA filter
system, 3-stage filter system, or approved system equivalent to a 3-stage filter
[63.745(g)(2)(m)(B)]
What monitoring must I do?
For dry filters. perform the following [63.745(g)(2)(iv)]:
Maintain system in good working order
Install differential pressure gauge across the filter banks
Continuously monitor pressure drop across the filter
Read and record the pressure drop across the filter once per shift
Shut down operation and take corrective action when pressure drop exceeds or falls below
manufacturer's recommendation
Shut down operation if scheduled maintenance has not been performed
For conventional waterwash systems, perform the following [63.745(g)(2)(v)]:
Continuously monitor the booths water flow rate
Read and record the water flow rate once per shift
Shut down operation when waterwash fails the visual continuity/flow characteristics check
Shut down operation when recorded water flow rate goes outside of manufacturer's limits
Shut down operation if scheduled maintenance has not been performed
For pumpless waterwash systems, perform the following [63.745(g)(2)(v)]:
Operate the booth in accordance with the operating efficiency range (parameters)
recommended by the manufacturer
Continuously monitor the booths parameters
Read and record the parameters once per shift
25
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Shut down operation when the efficiency range goes outside of manufacturer's limits
Shut down operation if scheduled maintenance has not been performed
What records must I keep?
All Options, perform the following [63.743(b)]:
Prepare a startup, shutdown, and malfunction plan (excluding dry particulate filters operated
per manufacturer's instructions) which includes:
» Requirements in §63.6
> Operation and maintenance criteria
> A standardized equipment operation and maintenance checklist
> Procedures for identifying and reporting malfunctions
> Procedures to prevent malfunctions due to preventable conditions
Operate all control equipment during startup, shutdown and malfunction in accordance with
the startup, shutdown, and malfunction plan
If dry filters are used record the following [63.752(d)(l)]:
Record the pressure drop across the operating system once each shift during operation
Record the acceptable limit(s) of pressure drop as specified by the filter or booth
manufacturer
If a conventional waterwash system is used record the following [63.752(d)(2)]:
Record the water flow rate through the operating system once each shift during operation
Record the acceptable limit(s) of water flow rate as specified by the booth manufacturer
If a pumpless waterwash system is used record the following [63.752(d)(2)]:
Record the parameter(s) recommended by the booth manufacturer that indicate the
performance
Record the parameter through the operating system once each shift during operation
You can download example and blank recordkeeping forms by going to the implementation section
of the Unified Air Toxics Website (UATW) aerospace page at
www.epa.gov/ttn/uatw/aerosp/aeropg.html. Download example #4(a) and #5. The forms are
optional, but you may find it useful.
26
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What reports must I submit?
All Options, report the following [63.753(c)]:
Semiannual reports occurring (every 6 months from the date of notification) for each
category
If the operations are in compliance, a statement that the operations have been in compliance.
If dry filters are used report the following [63.753(c)(l)(vi), (c)(2)]:
(Semiannual) All times when a topcoat or primer operation was not immediately shut down
when the pressure drop across a dry particulate filter system was recorded to be outside
specified limits
(Annual) Number of times the pressure drop for each dry filter was outside specified limits
If a convential waterwash system is used report the following [63.753(c)(l)(vi), (c)(2)]:
(Semiannual) All times when a topcoat or primer operation was not immediately shut down
when the waterwash system was recorded to be outside specified limits
(Annual) Number of times the water flow rate for each waterwash system was outside
specified limits
If a pumpless waterwash system is used report the following [63.753(c)(l)(vi), (c)(2)]:
(Semiannual) All times when a topcoat or primer operation was not immediately shut down
when the waterwash system was recorded to be outside specified limits
(Annual) Number of times the recommended parameters for each waterwash system was
outside specified limits
For booths or hangars that do not have the potential to emit 10 tons/vr or more of an
individual inorganic HAP or 25 tons/vr or more of all inorganic HAP combined
[63.743(a)(10)]:
Notify the Administrator of such construction or reconstruction on an annual basis. Make
notification by March 1 of each year for construction or reconstruction during the prior
calendar year and include information in 63.5(b)(4), except that such information is to be
limited to inorganic HAP
27
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Depainting ^Derations
What is covered under this section of the rule?
Depainting operations on the outer surface areas of completed aerospace vehicles (including the
fuselage, wings, and vertical and horizontal stabilizers of the aircraft) and the outer casing and
stabilizers of missiles and rockets [63.746(a)(l)].
Depainting of parts and assemblies for space vehicles designed to travel beyond the limit of the
earth's atmosphere, including but not limited to satellites, space stations, and the Space Shuttle
System (including orbiter, external tanks, and solid rocket boosters) must comply with this section
[63.741(h)].
What is not covered under this section of the rule?
The following operations are exempt from the requirements of this section:
Aerospace manufacturing or rework facility that depaints 6 or fewer completed aerospace
vehicles per year [63.746(a)]
Equipment that is no longer operational, intended for public display, and not easily moved
[63.746(a)(2)]
Depainting of parts or units normally removed from the vehicle for depainting (except for
wings and stabilizers) [63.746(a)(l), (3)]
Depainting of radomes [63.746(a)(3)]
Mechanical and hand sanding operations are exempt from requirements to perform work in
an enclosed area and use a control system [63.746(b)(5)]
What compliance options do I have?
Option 1: Use non-HAP chemical strippers that meet all of the following requirements
[63.746(b)(l)]:
Emit no organic HAP from chemical stripping formulations, agents, or chemical paint
softeners
Option 2: Use nonchemical based equipment that meet all of the following requirements:
[63.746(b)(2)]:
Note: You may use air pollution control devices not listed in the rule, but to do so, you must
submit information about the system you wish to use no later than 120 days prior to the
compliance date. See 63.743(c) for additional information.
28
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Operate and maintain equipment in accordance with manufacturer's specifications or locally
prepared operating procedures
During periods of malfunction, substitute materials may be used during the repair period
> Use substitutes no more than 15 days annually, unless organic HAP-free
> Substitutes selected shall minimize HAP emissions
For dry media blasting systems generating airborne inorganic HAP emissions
[63.746(b)(4)], comply with all of the following:
> Perform depainting operations in an enclosed area (unless a closed-cycle system is
used)
h For existing sources, pass exhaust air through a dry particulate filter system
meeting existing source filter efficiencies (as identified in "Primer and
Topcoat Operations - Inorganic HAP Control"), or through a baghouse or
though a waterwash system prior to exhausting to the atmosphere
h For new sources, pass exhaust air through a dry particular filter system
meeting new source filter efficiencies (as identified in "Primer and Topcoat
Operations - Inorganic HAP Control"), or through a baghouse prior to
exhausting to the atmosphere
h For sources constructed or reconstructed after June 6, 1994 and prior to
October 29,1996, pass air through a 2-stage dry filter or a waterwash
system before exhausting it to the atmosphere [63.745(g)(2)(iii)(A)]. For
primers or topcoats containing chromium or cadmium, install a HEPA filter
system, 3-stage filter system, or approved system equivalent to a 3-stage
filter [63.745(g)(2)(m)(B)]
Option 3: Organic HAP-containing chemical stripper [63.746(c)]:
Note:You may use air pollution control devices not listed in the rule, but to do so, you must
submit information about the system you wish to use no later than 120 days prior to the
compliance date. See 63.743(c) for additional information.
Use a control system to reduce organic HAP emissions by 81% for existing sources and
95% for new sources from baseline established from 1996 and 1997, on a usage per
aircraft or usage per ft2 of surface basis
* Control system options include carbon adsorption or noncarbon adsorption
29
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> Overall efficiency is the product of capture and destruction or removal efficiency,
and may take into account the volume of chemical stripper used relative to the
baseline. Capture and destruction efficiency is determined by following 63.750(g)
if your control device is a carbon adsorber, or 63.750(h) whenever a control device
other than a carbon adsorber is used
> Perform initial performance test unless a waiver is obtained [63.749(d)(2)]
Spot Stripping and Decal Removal (in addition to Option 1. 2. or 3) [63.746(b)(3)]:
On an annual average basis, use no more than 26 gallons of organic HAP-containing
chemical strippers or alternatively 190 pounds of organic HAP per commercial aircraft
depainted
On an annual average basis, use no more than 50 gallons of organic HAP-containing
chemical strippers or alternatively 365 pounds of organic HAP per military aircraft
depainted.
What monitoring must I do?
Note: Mechanical and hand sanding operations are exempt from the requirements in paragraph
63.746(b)(4)oftherule.
If Option 1 is used, no monitoring is required.
If Option 2 is used, ensure the following:
If dry particulate filter system is used [63.746(b)(4)(iii)]:
* Maintain system in good working order
> Install differential pressure gauge across filter banks
> Continuously monitor the pressure drop across the filter
* Read and record the pressure drop once per shift
> Shut down operation when pressure drop exceeds or falls below manufacturer's
limits
> Shut down if scheduled maintenance procedures have not been performed
For conventional waterwash systems, perform the following [63.746(b)(4)(iv), (v)]:
> Continuously monitor the booths water flow rate
> Read and record the flow rate once per shift
* Shut down operation when waterwash fails the visual continuity/flow
characteristics check
30
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> Shut down operation when recorded water flow rate goes outside of
manufacturer's limits
> Shut down operation if scheduled maintenance has not been performed
For pumpless waterwash systems, perform the following [63.746(b)(4)(iv), (v)]:
> Operate the booth in accordance with the operating efficiency range (parameters)
recommended by the manufacturer
> Continuously monitor the booths parameters
* Read and record the parameters once per shift
> Shut down operation when the efficiency range goes outside of manufacturer's
limits
> Shut down operation if scheduled maintenance has not been performed
If Option 3 is used, monitor control device operation as follows:
Control device is a carbon adsorber:
* Establish as a site-specific operating parameter the outlet total HAP or VOC
concentration or the control device efficiency [63.751(b)(l)]
> For nonregenerative carbon systems, the carbon replacement time interval may be
established as the site-specific operating parameter [63.751(b)(2)]
> For capture systems, submit a monitoring plan that identifies the operating
parameter to be monitored, discusses why this parameter is appropriate, and
identifies the specific monitoring procedures [63.751(b)(3)(i)]
> Conduct monitoring in accordance with the submitted plan unless EPA comments
require an alternate monitoring scheme [63.751(b)(3)(iii)]
* Install, calibrate, operate, and maintain a continuous emission monitor that complies
with CFR specifications and requirements [63.751(b)(6)(ii), (iii)(A)]
> Do not operate the control device at an average control efficiency less than the
required level for three consecutive adsorption cycles or over a 7- to 30-day rolling
average, as applicable [63.75 l(b)(6)(iii)(B), (C)]
> Do not operate the capture device at an average parameter value greater or less than
(as appropriate) the established value for any 3-hour period [63.751(b)(6)(iv)]
Control device is an incinerator:
> Install, calibrate, maintain, and operate temperature monitoring equipment or a
CEMS. Replace or have temperature sensors recalibrated every 3 months
[63.751(b)(8)]
* Install a thermocouple equipped with a continuous recorder and operate
continuously (correct locations indicated in rule) [63.751(b)(9), (10)]
31
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Establish site-specific temperature parameters during each performance test
), (12)]
What records must I keep?
For HAP strippers used for spot stripping and decal removal, record the following
[63.752(e)(6)]:
Volume of organic HAP-containing chemical stripper used or weight of organic HAP used
Annual average volume of organic HAP-containing stripper or volume of organic HAP used
per aircraft
Annual number of aircraft stripped
All data and calculations.
If Option 1 is used, record the following [63.752(e)(l)]:
Name of each chemical stripper
Monthly volumes or weights of each HAP stripper used.
If Option 2 is used, record the following [63.752(e)(5)]:
Name and type of nonchemical based equipment
Malfunction information, including:
The nonchemical method or technique that malfunctioned
The date the malfunction occurred
A description of the malfunction
The methods used to depaint during the malfunction period
The dates that these methods were begun and discontinued
The date the malfunction was corrected
If the control system is a dry particulate filter system [63.752(e)(7)]:
Actual pressure drop across the particulate filters once each shift during operation
Record the acceptable limit(s) of pressure drop as specified by the filter or booth
manufacturer
If a conventional waterwash system is used, record the following [63.752(e)(7)]:
32
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> Record the water flow rate through the operating system once each shift during
operation
> Record the acceptable limit(s) of water flow rate as specified by the booth
manufacturer
If a pumpless waterwash system is used, record the following [63.752(e)(7)]:
> Record the parameter(s) recommended by the booth manufacturer that indicate the
performance
> Record the parameter through the operating system once each shift during
operation
If Option 3 is used, record the following [63.752(e)(l)-(4)]:
For chemical strippers used in depainting, a listing of the parts, subassemblies, and
assemblies normally removed from the aircraft before depainting
> Prototype, test models, or aircraft that exist in low numbers (<25 aircraft) are
exempt
The name of each chemical stripper used
Monthly volumes of each organic HAP stripper used
Control system information including:
> For carbon adsorption systems:
h Overall control efficiency
h All test results, data, and calculations used in determining efficiency
h Length of the rolling material balance period and all data and calculations
h A record of the certification of the accuracy of the device that measures
the amount of HAP or VOC recovered
> For nonregenerative carbon adsorption systems:
J- Overall control efficiency
h All test results, data, and calculations used in determining efficiency
h The record of the carbon replacement time established as the site-specific
operating parameter
33
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For other control devices:
h Overall control efficiency
h All test results, data, and calculations used in determining efficiency.
For Options 2 and 3. perform the following [63.743(b)]:
Prepare a startup, shutdown, and malfunction plan (excluding dry particulate filters operated
per manufacturer's instructions) which includes:
* Requirements in §63.6
> Operation and maintenance criteria
> A standardized equipment operation and maintenance checklist
* Procedures for identifying and reporting malfunctions
> Procedures to prevent malfunctions due to preventable conditions
Operate all control equipment during startup, shutdown and malfunction in accordance with
the startup, shutdown, and malfunction plan
You can download example and blank recordkeeping forms by going to the implementation section
of the Unified Air Toxics Website (UATW) aerospace page at
www.epa.gov/ttn/uatw/aerosp/aeropg.html. Download example #5, 6 and 7. The forms are
optional, but you may find it useful.
What reports must I submit?
All Options, report the following [63.753(d)(l)(i), (viii), (ix) ]:
Report semiannually (every 6 months from the date of notification of compliance status):
> If the operations have been in compliance, a statement that the operations have
been in compliance
> A list of new and discontinued aircraft models depainted at the facility
> A list of parts normally removed for depainting for each new aircraft model being
depainted
* Any 24-hour period where organic HAP were emitted from the depainting of an
aerospace vehicle (other than when a control device was used)
34
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For spot stripping and decal removal, report the following [63.753(d)(2)(i)]:
Report annually:
> The average volume per aircraft of organic HAP-containing chemical strippers or
weight or organic HAP used for spot stripping and decal removal operations when
depainting limits in 63.746(b)(3) or weight of organic HAP are exceeded
For booths or hangars that do not have the potential to emit 10 tons/vr or more of an
individual inorganic HAP or 25 tons/vr or more of all inorganic HAP combined
[63.743(a)(10)]:
Notify the Administrator of such construction or reconstruction on an annual basis. Make
notification by March 1 of each year for construction or reconstruction during the prior
calendar year and include information in 63.5(b)(4), except that such information is to be
limited to inorganic HAP
If Option 1 or 2 is used, report the following [63.753(d)(l)(v), (vi)]:
Report semiannually:
> Any new nonchemical depainting technique used at the facility since the notification
of compliance status or any subsequent semiannual report
> Any periods of equipment malfunction
h The nonchemical method or technique that malfunctioned
h The date the malfunction occurred
h A description of the malfunction
h The methods used to depaint during the malfunction period and dates
begun and discontinued
h The date the malfunction was corrected.
If Option 2 is used, also report the following [63.753(d)(l)(vii), (d)(2)]:
Report semiannually:
> The periods where a nonchemical depainting operation was not immediately shut
down when the pressure drop, water flow rate or recommended parameter(s) was
outside acceptable limits
Report annually:
* Description of any control device currently used that was not listed in the
notification of compliance status or any subsequent report
> The number of times the pressure drop for each filter system exceeds acceptable
limits
35
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> The number of times the water flow rate or recommended booth parameters if
using a pumpless system for each waterwash system exceeds acceptable limits
If Option 3 is used, report the following [63.753(d)(l)(i)-(iv)]:
Report semiannually [63.753(d)(l)(i)-(iv)]:
> Any 24-hour period where organic HAP were emitted from the depainting of an
aerospace vehicle (other than when a control device was used)
> Any new chemical stripper used at the facility during the reporting period
* The organic HAP content of these new chemical strippers
> The organic HAP content of each chemical stripper that undergoes reformulation.
Also report semiannually [63.753(d)(3)]:
* Description of any control device currently used that was not listed in the
notification of compliance status or any subsequent report
> If carbon adsorber is used:
h Each rolling period when the overall control efficiency is calculated to be
less than 81% for existing systems and 95% for new systems, the initial
material balance calculation, and any exceedances as demonstrated through
the calculation
> If nonregenerative carbon adsorbers are used:
h Submit design evaluation, the continuous monitoring system performance
report, and any excess emissions as demonstrated through deviations in
monitoring values
* If other control devices are used:
h Each exceedance of the operating parameters established for the control
device under the initial performance tests
36
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Chemical Milling Maskant Operations
[63.747]
What is covered under this section of the rule?
Chemical milling maskant application operations on aluminum aerospace vehicles, parts, and
assemblies. The provisions apply to applications associated with either Type I or Type II etchants
[63.742, 63.747].
What is not covered under this section of the rule?
Bonding maskants, critical use and line sealer maskants and seal coat maskants [63.742]
Maskants that must be used with a combination of Type I and Type II etchants [63.742]
Chemical milling maskants used to touch-up scratched surfaces, trimmed edges, or
damaged maskant are exempt from the requirements in Option 1 only [63.747(c)(3)]
What compliance options do I have?
All Options: Handle and transfer materials in a manner that minimizes spills [63.747(b)].
Option 1: Uncontrolled, compliant maskants. Use compliant maskants that comply with the limits
below [63.747(c)(l), (2)]:
Coating Type
Type I Maskant
Type II Maskant
Maximum Content, As Applied
Organic HAP Content
g/liter
622
160
Ib/gal
5.2
1.3
VOC Content
g/liter
622
160
Ib/gal
5.2
1.3
HAP content is measured "less water"; VOC content is measured less water and exempt solvents.
Include thinner added to calculation.
Option 2: Uncontrolled, averaged maskants. Average maskants a manner that meets all of the
following criteria [63.747(e)(2). 63.743(d)]:
Use any combination of uncontrolled maskants such that the monthly volume-weighted
average of organic HAP and VOC content of the combination of maskants complies with
the content limits in 63.747(c), which is the same as Option 1. Only uncontrolled maskants
37
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can use this option. The permitting agency can specify a shorter averaging period than
monthly [63. 743 (d)]
Averaging Type I and Type II maskants together is not allowed
Averaging schemes must be pre-approved by the permitting authority as adopted as part of
your title V operating permit
Option 3: Controlled Maskants. Use add-on controls that meet all of the following criteria
[63.747(d)]:
Note: You may use air pollution control devices not listed in the rule, but to do so, you must
submit information about the system you -wish to use no later than 120 days prior to the
compliance date. See 63. 743 (c) for additional information.
Demonstrate an overall removal efficiency (of both organic HAP and VOC) of >81%.
Overall removal efficiency is the product of the capture efficiency and the destruction
efficiency
Operate in a manner that minimizes spills [63.747(b)]
Perform initial performance testing unless a waiver is obtained [63.749(d)(2)]
Option 4: Waterborne Maskants. Use waterborne maskants that meet all of the following criteria
Note: Waterborne coatings are exempted from the following sections of the rule if they meet the
organic HAP and VOC content limits in 63. 747 (c) : 63. 747 (d) [control devices], 64. 747 (e)
[compliant maskants], 63. 749 (h) [performance tests], 63. 750(k)-(n) [HAP and VOC content
determination], 63. 752 (f) [organic HAP and VOC recordkeeping], and 63. 753(e) [primer and
topcoat reporting].
Maintain manufacturer's data and annual purchase records for 5 years
Waterborne coatings may be averaged under 63. 743 (d)
What monitoring must I do?
If Options 1. 2 and 4 are used no monitoring is required.
If Option 3 is used, monitor control device operation as follows:
Control device is a carbon adsorber [63.751(b)(l)-(7)]:
> Establish as a site-specific operating parameter the outlet total HAP or VOC
concentration or the control device efficiency [63.751(b)(l)]
38
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> For nonregenerative carbon systems, the carbon replacement time interval may be
established as the site-specific operating parameter [63.751(b)(2)]
> For capture systems, submit a monitoring plan that identifies the operating
parameter to be monitored, discusses why this parameter is appropriate, and
identifies the specific monitoring procedures [63.751(b)(3)(i)]
* Conduct monitoring in accordance with the submitted plan unless EPA comments
require an alternate monitoring scheme [63.751(b)(3)(iii)]
> Install, calibrate, operate, and maintain a continuous emission monitor that complies
with CFR specifications and requirements [63.751(b)(6)(ii), (iii)(A)]
> Do not operate the control device at an average control efficiency less than the
required level for three consecutive adsorption cycles or over a 7- to 30-day rolling
average, as applicable [63.75 l(b)(6)(iii)(B), (C)]
> Do not operate the capture device at an average parameter value greater or less than
(as appropriate) the established value for any 3 -hour period [63.751(b)(6)(iv)]
Control device is an incinerator [63.751(b)(9)-(12)]:
> Install, calibrate, maintain, and operate temperature monitoring equipment or a
CEMS. Replace or have temperature sensors recalibrated every 3 months
[63.751(b)(8)]
> Install a thermocouple equipped with a continuous recorder and operate
continuously (correct locations indicated in rule) [63.751(b)(9), (10)]
> Establish site-specific temperature parameters during each performance test
), (12)]
What records must I keep?
If Option 1 is used record the following [63.752(f)(l)]:
Mass of organic HAP (FQ and VOC (G() (less water and exempt solvents) emitted per unit
volume of chemical milling maskant as applied (less water) for each maskant formulation
used each month (calculate using §63.750(k) and (m))
All data, calculations, and test results used in determining FJ and Q
Volume (gal) of each chemical milling maskant used each month
If Option 2 is used, record the following [63.752(f)(2)]:
Monthly weighted volume of organic HAP (FFj and VOC (GJ emitted per unit volume of
chemical milling maskant as applied for each maskant formulation used each month
(calculate using §63.750(1) and (n))
All data, calculations, and test results used in determining F[ and Ga.
39
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If Option 3 is used, record the following:
For carbon adsorption systems [63.752(f)(3)(i)J:
* Overall control efficiency
> All test results, data, and calculations used in determining efficiency
> Length of the rolling material balance period and all data and calculations
> A record of the certification of the accuracy of the device that measures the
amount of HAP or VOC recovered
For nonregenerative carbon adsorption systems [63.752(f)(3)(ii)J:
* Overall control efficiency
> All test results, data, and calculations used in determining efficiency
* The record of the carbon replacement time established as the site-specific operating
parameter
For other control devices [63.752(f)(4)]:
> Overall control efficiency
* All test results, data, and calculations used in determining efficiency
For incineration (catalytic and noncatalvtic) [63.752(F)(4Yii'). (in)]:
> Continuous records of the firebox temperature and all calculated 3-hour averages
For Options 3 is used perform the following [63.743(b)]:
Prepare a startup, shutdown, and malfunction plan (excluding dry particulate filters operated
per manufacturer's instructions) which includes:
Requirements in §63.6
Operation and maintenance criteria
A standardized equipment operation and maintenance checklist
Procedures for identifying and reporting malfunctions
Procedures to prevent malfunctions due to preventable conditions
Operate all control equipment during startup, shutdown and malfunction in accordance with
the startup, shutdown, and malfunction plan
40
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If Option 4 is used, record the following [63.741(i)]:
Manufacturer's supplied data and annual purchase records for each exempt waterborne
coating
Retain records for 5 years.
There are not example recordkeeping forms for chemical milling maskant operations available for
download.
What reports must I submit?
All Options, report the following [63.753(e)]:
Semiannual reports occurring every 6 months (from the date of notification of compliance
status) which identify required reporting for each category. If the operations have been in
compliance for the semiannual period, a statement that the operations have been in
compliance with the applicable standards
All chemical milling maskants currently used that were not listed in the notification of
compliance status or any other subsequent semiannual report
If Option 1 is used, report the following:
When nonaveraging methods are used [63.753(e)(l)]:
Each value of f{ and Q that exceeds the applicable organic HAP or VOC content limit.
If Option 2 is used, report the following:
When averaging methods are used [63.753(e)(2)]:
Each value of H and G^ that exceeds the applicable organic HAP or VOC content
limit.
If Option 3 is used, report the following [63.753(e)(5)]:
Description of any control devices currently in use that were not listed in the notification of
compliance status or any subsequent reports
Control device is incineration [63.753(e)(3)(i)]:
> All periods when the 3-hour average combustion temperature is less than the average
combustion temperature established during the most recent performance test
demonstrating compliance
Control device is a carbon adsorber [63.753(e)(3)(ii)(A)]:
41
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> Each rolling period when the overall control efficiency of the control system is less than
81%, the initial material balance calculation, and any exceedance as demonstrated
through calculations
Control device is a nonregenerative carbon adsorber [63.753(e)(3)(ii)(B)]:
> Submit the design evaluation, the continuous monitoring system performance report,
and any excess emissions as demonstrated through deviations of monitored values
Control device is something other than an incinerator or carbon adsorber [63.753(eY3yiiiN)]:
> Each exceedance of the operating parameters established for the control device under
the initial performance test during which compliance was demonstrated
If Option 4 is used, no reporting is required.
42
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3.0 APPLICABILITY FLOW CHARTS
The simplified flow charts in this section illustrate the applicability decision process for facilities
potentially subject to the provisions of the Aerospace NESHAP. Since these charts are in a
condensed form, the rule provisions should be consulted prior to making any final applicability
decision. In addition, the EPA or the permitting authority should be consulted with any questions
related to applicability.
43
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Chart 1
General Applicability
Is the facility a
Major Source of
HAP?
NO
YES
NO
Is the facility engaged
in manufacture or
rework of aerospace
vehicles or components?
YES
Cleaning
Provisions
Do Not Apply
NO
Perform Cleaning Operations on
aerospace vehicles or components
(Hand-Wipe, Spray Gun, Flush)?
YES
Coating
Provisions
Do Not Apply
NO
r
Cleaning Provisions
Apply, See Chart 2
Perform Coating Operations
(Primer, Topcoat, Self-Priming
Topcoat) on aerospace
vehicles or components ?
YES
Coating Provisions
Apply, See Chart 3
\
Continued
44
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Chart 1
General Applicability
(Concluded)
Perform Depainting
Operations on aerospace
vehicles or components
(Chemical Stripping,
Blasting, Other)?
NO
Depainting
Provisions
Do Not Apply
YES
Depainting Provisions
Apply, See Chart 4
Chemical Milling
Maskant Provisions
Do Not Apply
NO
Apply Chemical Milling
Maskant to aerospace
vehicles or components?
YES
I
Chemical Milling
Maskant Provisions
Apply, See Chart 5
Produce waste
which contains
HAP?
NO
YES
Handling and Storage
of Waste Provisions
Do Not Apply
Handling and Storage
of Waste Provisions
Apply, See §63.748
(RCRA waste not subject)
45
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Chart 2
Cleaning Operations Applicability
Do you perform Cleaning
Operations on aerospace
vehicles or components?
YES
NO,
Do you perform
Hand-Wipe
Cleaning Operations?
ningop;
YEsI
NO
Spray Gun
Provisions
Do Not Apply
NO
Cleaning
Provisions
Do Not Apply
Hand-Wipe
Provisions
Do Not Apply
Hand-Wipe Provisions
Apply. See §63.744(b).*
.
Do you perform Spray
Gun Cleaning Operations?
YEsI
Spray Gun Provisions
Apply. See §63.744(c)*
Do you perform Flush
Cleaning Operations?
eanmg(
YEsI
NO
Flush Cleaning
Provisions
Do Not Apply
Flush Cleaning Provisions
Apply. See §63.744(d).*
Cleaning housekeeping requirements also apply. See §63.744(a).
46
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Charts
Primer/Topcoat* Operations Applicability
Do you perform Primer or
Topcoat* Application on
aerospace vehicles or
components?
YESJ
NO
Primer and
Topcoat* Provisions
Do Not Apply
See § 63.745(c)-(f).
Inorganic HAP
Coating Provisions
Do Not Apply
NO
Do you apply primers or
topcoats* containing organic
HAP and/or VOC?
YESl
NO _
Organic HAP and/or VOC
Organic HAP
Coating Provisions
Do Not Apply
Do you spray apply primers or
topcoats* containing inorganic
HAP?
YESl
Inorganic HAP Coating
Provisions Apply.
See § 63.745(g).
* Including self-priming topcoat
47
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Chart 4
Depainting Operations Applicability
Do you depaint the outer
surface of 7 or more
completed aerospace
vehicles per year?
NO
Depainting
Provisions
Do Not Apply
YES.
PICK ONE OR
MORE OPTIONS
*
Perform dry or non-chemical
depainting operations
Cblastina or otherV
!
Use stripper
containing HAP with
a control svstem.
+
Use non-HAP
chemical strippers.
Dry or non-chemical
provisions apply.
See §63.746(b).
Control system
provisions apply.
See §63.746(c).
Non-HAP chemical
provisions apply.
See§63.746(b)(1).
May use an annual average of up to 26 gal
of HAP strippers (commercial) or 50 gal (military)
per aircraft depainted (spot/decal). See §63.746(b)(3).
48
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ChartS
Chemical Milling Maskant
Operations Applicability
Do you apply Type 1 or Type II
chemical milling maskants to
aluminum aerospace components?
NO
Maskant
Provisions
Do Not Apply
YES.
PICK ONE OR
BOTH OPTIONS
i
Use compliant
maskants.
See §63.747 (c).
Use add-on controls.
See §63.747 (d).
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4.0 INSPECTION PROCEDURES1
This section contains guidelines for conducting an onsite or self inspection of an aerospace
manufacturing or rework facility that is presumed or known to be subject to the Aerospace
NESHAP. The next section includes inspection checklists which should be useful tools in carrying
out an inspection at the site.
Preparing for the inspection
It is important to obtain as much information about the facility prior to the site visit. You may want
to review the information available in the source file, including:
permit applications;
approved permits;
equipment lists;
conditions for each permit unit;
previous inspections including reports of violation;
breakdown reports;
enforcement actions taken;
complaints;
variance history;
alternative emission control plans;
lists of operations conducted; and
cleaning solvents and coatings in use
The inspector should become familiar with any aerospace operations claimed by the facility as
exempt, as well as with the compliance options chosen by the source. The provisions of the
NESHAP, including allowable exemptions, must also be understood.
Exerpted from the Aerospace Coating Operations Manual, January 1997 Compliance Division,
California U. S. Environmental Protection Agency. See page 7-1, document 1.
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Inspecting the facility - Overview
The appropriate compliance checklists (see Section 5.0) are intended to guide the inspector through
the inspection for the four principal regulated operations: cleaning, primer and topcoat application,
depainting, and chemical milling maskant application. It may be most efficient to concentrate on
each of these operations in turn. Keep in mind that depainting is essentially a rework and not a
manufacturing operation, and that the use of chemical milling maskants is a usually a fairly
specialized operation carried out by the larger manufacturers or by companies that specialize in
doing chemical milling on a subcontractor basis.
In using the checklists, the inspector first checks the box for the compliance option or options
chosen for the operation (in instances where options are available), and then checks "Yes" or "No"
to indicate the status of the facility with each individual requirement. A separate log for notes and
explanations pertaining to certain entries (especially "No" entries) is advised to describe details of the
plant's status.
After all of the operations have been inspected, the inspector may need to review the file information
with facility personnel a second time to clarify and correct certain information based on the
observations made. Records from the facility files should also be checked to verify compliance,
both with operational requirements and with the requirements to keep the records themselves.
Material safety data sheets (MSDS) and/or other product data sheets for the cleaning solvents,
primers, topcoats, and chemical milling maskants in use could also be collected if they have not
already been obtained.
When the inspection and the file review are complete, a wrap-up meeting with appropriate facility
personnel should be held to summarize findings, explain any compliance violations noted, and review
next steps in the process.
51
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Specific Activities - Cleaning Operations
Be aware of operations exempted from the cleaning requirements (and note whether the exemption
applies to all requirements or to hand-wipe only). The inspector needs to view records of all
cleaning solvent usages, and the type of cleaning performed with each. Note any open containers
for solvents or applicators, and general housekeeping practices (spill provision). Remember,
cleaning solvents are used throughout a facility in practically every facet of the production process.
Determine how spray guns are cleaned, and verify that one or more of the allowed options (or
equivalents) are being used. Verify through observation or by questioning the painter that solvent
containers or reservoirs associated with these cleaners are kept closed except when parts are added
or removed.
Specific Activities - Primers and Topcoats
The coatings storage/mix room should be inspected in order to observe coating labels and other
records for organic HAP and VOC content. Note whether the information is as-supplied or as-
applied. Look for any manufacturer mixing instructions. Ask the painter how he or she reduces the
coatings (i.e., is thinner applied), how the viscosity is measured, and what is done if the viscosity is
too high or too low. Verify what solvents are used for reduction.
Examine each coating operation to identify the coatings in use (including exempt operations and use
of specialty coatings and waterborne coatings). Determine the application equipment used and
compare with the allowable equipment (equipment claimed as equivalent should have a
demonstration as outlined in the standard). Observe that all electrostatic systems are operated
correctly (power on with a clean ground attached, etc.).
For HVLP type spray guns, maximum air pressure as spray exits the gun is specified as 10 psig.
The inspector should check to see whether individual spray guns meet these limits. (Some
manufacturers supply a small kit that allows the exit air pressure to be measured, while others may
supply a gauge for the same purpose.) The gun operator should be able to supply some assistance
52
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on how the required air pressure is achieved or measured. If different application methods than
those specified in the NESHAP are in use, determine if a demonstration of equivalent transfer
efficiency has been approved. Verify that current conditions match demonstration conditions.
Specific Activities - Spray Booths
Dry filter systems or waterwash systems are used for either inorganic HAP-containing primer and
topcoat (including self-priming topcoat) application or depainting operations. The maintenance of
the booth (including filters, fan, and ductwork) is very important in the continuing control efficiency
for fine particulate generated by these operations (i.e., paint overspray or dry media/paint residue
from blast depainting). Check whether any parts of the filter bank are missing, damaged, or
improperly installed. Note how often filters are replaced and if the filters appear to be overloaded.
Examine the pressure drop across the filters or the water flow rate of the waterwash, and compare
the value with the manufacturer's value as contained in the operator's log. Note whether the
pressure drop instrument (manometer) contains fluid and is functional (attains a nonzero reading
when the fan is activated). For waterwash systems, observe whether the curtain has dry spots, and
whether it appears uniform and regular.
Specific Activities - Depainting
If a facility selects the option of using a new nonchemical paint removal system (i.e., dry media
blasting), they will need to install a dry filter system or other control device that meets required
efficiencies. For existing removal systems, they will need to install a dry filter system, waterwash
system, or other equivalent control device. Ask about the facility's maintenance practices for the
filters, fan, and ductwork. As with the paint spray booth, check the condition of the filters for
completeness and freedom from damage. Note whether the pressure drop instrument (manometer)
contains fluid and is functional (attains a nonzero reading when the fan is activated). For
waterwash systems, observe whether the curtain has dry spots, and whether it appears uniform and
regular. Determine the maintenance and chemical additives schedule.
53
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Except for spot stripping allowances, a facility that selects the use of HAP-containing chemical
strippers (i.e., methylene chloride), which are not specifically exempted from the regulation, is
required to have an add-on control device in place. See the next subsection for a discussion of add-
on controls.
Specific Activities - Chemical Milling Maskant
Chemical milling maskants are considered a coating along with primers and topcoats. The organic
HAP/VOC contents of the maskants need to be verified in a similar manner to the other types of
coatings. Content and use records are also similar. Each maskant has to be characterized with
respect to its use with either Type I or Type II etchants.
As with primer and topcoat applications, and depainting, the use of an add-on control device is an
optional approach if the use of compliant coatings is not feasible or desirable. Inspection
approaches for add-on controls are addressed in subsection 4.3.2.6.
Specific Activities - Control Devices
Check the integrity of ductwork and any collection hoods. Observe the structural integrity of the
device to determine any possible locations of fugitive leaks. Examine the latest source test records
to verify that the required capture and control efficiency is being attained. Read the operating
parameter value and compare with the established value and monitoring records provided by the
source. Ensure that all required records are available from the source.
Specific Activities - Sampling Techniques
It is important that, if any samples are to be collected, they be collected and preserved in
accordance with defensible procedures. All samples should be representative of the cleaning solvent
or coating as applied. Observe the operator if he is filling your container. Do not let the filled
container leave your sight or control. The EPA has issued procedures in the document EPA-
340/191-010, "Standard Procedure for Collection of Coating and Ink Samples for Analysis by
54
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Reference Methods 24 and 24A." As a general rule, samples should be collected into containers that
are clean, dry, unbreakable, scalable, nonreactively lined (if needed), and appropriate for the material
to be sampled.
Specific Activities - Materials Documentation
Material safety data sheets (MSDS) are guides to workplace safety and, as such, they have limited
usefulness in determining the precise content or emission potential of materials. The inspector
should be aware that the HAP or VOC listed on the MSDS sheets is not necessarily representative of
the content of a specific batch of cleaner or coating, or these contents may not be listed at all.
Source operators, further, are free to add materials before applying the cleaner or coating.
Technical specification sheets are provided by the manufacturer usually upon request of the user.
They are often tailored for air pollution regulations to include VOC or HAP contents as supplied, and
include recommended mixing and thinning ratios. Be sure to ask for the latest MSDS, specification
sheet, or product technical bulletin, because formulations may be changed over time. When
calculating VOC or HAP in accordance with the test procedures identified within the rule, it may be
helpful to review EPA document EPA-340/1-86-016, "A Guideline for Surface Coating
Calculations," July 1986; and EPA-450/3-84-019, "Procedures for Certifying Quantity of Volatile
Organic Compounds Emitted by Paint, Ink, and Other Coatings," December 1984.
55
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5.0 INSPECTION CHECKLISTS
This section contains checklists for use in performing NESHAP inspections of the four production
operations covered by the regulation: cleaning, primer and topcoat application, depainting, and
chemical milling maskant application. These checklists may serve as useful tools for agencies and
sources tasked to implement the rule. You will find that the checklists will, when necessary, refer
the user back to Section 2.0, Summary of the Rule. However, since the checklists and the rule
summary do not contain all details of the NESHAP, the rule itself and any amendments should be
referred to when performing facility inspections. Separate sheets may be needed to record more
specific information about the operations at individual facilities.
56
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CHECKLIST A
APPLICABILITY CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: This checklist will establish whether a facility or operations within a facility are subject to
this NESHAP.
1. GENERAL INFORMATION
A Date of Inspection:
B. Facility Name:
C. Facility Address:
D. Facility Contact:
(Name, Title, and Phone)
E. Is the facility a major or an area source? Major n Area n
(NESFIAP applies to major sources only)
F. Inspector(s):
Name Title/Affiliation Phone Number
2. SOURCE IDENTIFICATION
A Does this facility engage in the manufacture or rework of aerospace vehicles, assemblies, or
components? Yes n No n (If No, do not proceed, this rule does not apply)
B. Does this facility perform any of the following operations on aerospace vehicles,
assemblies, or components? (If Yes to any, proceed, the rule applies)
Cleaning operations Yes D No D
Hand-wipe cleaning Yes D No D
Spray gun cleaning Yes D No D
Flush cleaning Yes D No D
Topcoat or primer application Yes n No n
Depainting operations Yes n No n
Chemical milling maskant Yes n No n
Handling and storage of waste Yes n No n
57
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A - APPLICABILITY
3. RULE APPLICABILITY
Various processes that may be performed at aerospace manufacturing and rework facilities are not
covered under 40 CFR 63, Subpart GG. In addition, exemptions from 40 CFR 63, Subpart GG and
from control requirements are also identified within the rule. Listed below are processes and
materials not covered or exempt from the rule. This listing of overall exemptions is not repeated
within individual checklists. The cited regulatory provision and §63.742 Definitions should be
consulted for more details and for any qualifications on the exemptions. Complete the form by
checking off all that apply.
Citation
§63.741(e)
§63.741(f)
Process
Handling of waste subject to RCRA,
40 CFR 262-268
Research and development
Quality control operations
Laboratory testing activities
Chemical milling
Metal finishing
Electrodeposition (except the
electrodeposition of paints)
Composite processing (except for
cleaning and coating of composite
parts or components that become part
of an aerospace vehicle or component
as well as composite tooling that
comes in contact with such composite
parts or components prior to cure
Aircraft transparencies manufacturing
Wastewater operations
Electronic parts and assemblies (except
for cleaning and topcoating of
completed assemblies)
Parts and assemblies not critical to the
vehicle's structural integrity or flight
performance
Specialty coatings
Sealants and adhesives
Measurement,
Calculation, or
Observation
Does Facility
Perform Indicated
Operation?
Yes
No
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A - APPLICABILITY
Citation
§63.741(f)
§63.741(g)
§63.741(h)
§63.7410)
Process
Adhesive bonding primers
Use primers, topcoats, chemical milling
maskants, strippers, and cleaning
solvents containing HAP and VOC
<0.1% for carcinogens, <1.0% for
noncarcinogens
Rework of aircraft or aircraft
components if the holder of the Federal
Aviation Administration (FAA) design
approval, or the holder's licensee, is
not actively manufacturing the aircraft
or aircraft component
Low- volume use of primers, topcoats,
and chemical milling maskants which
do not exceed 50 gal (189 liters) per
year per formulation, with a combined
annual total of all such primers,
topcoats and chemical milling
maskants used not to exceed 200 gal
(757 liters). Otherwise exempt coatings
are excluded from totals.
Space vehicles (except for depainting)
Antique vehicles and components
Measurement,
Calculation, or
Observation
Does Facility
Perform Indicated
Operation?
Yes
No
4. CHECKLISTS:
If it has been determined that the facility or plant is subject to this NESHAP, go to the appropriate
Checklist indicated below and complete the form.
Cleaning operations
Hand-wipe cleaning
Spray gun cleaning
Flush cleaning
Topcoat & Primer application
Depainting operations
Chemical milling maskant
Go to Cleaning Checklist (Checklist B)
Go to Hand-Wipe Cleaning Checklist (Checklists B & C)
Go to Spray Gun Cleaning Checklist (Checklists B & D)
Go to Flush Cleaning Checklist (Checklists B & E)
Go to Fainter/Topcoat Checklist (Checklist F)
Go to Depainting Checklist (Checklist G)
Go to Chemical Milling Maskant Checklist (Checklist H)
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A - APPLICABILITY
5. INSPECTOR COMMENTS:
END OF CHECKLIST A
60
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CHECKLIST B
CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: Cleaning operations requirements are applicable only to the cleaning of aerospace vehicles,
assemblies, and components. Cleaning operations subject to the hand-wipe cleaning (Checklist C),
flush cleaning (Checklist D), or spray gun cleaning (Checklist E) requirements are also subject to
these requirements.
1. GENERAL INFORMATION
A Source Location (if applicable):
B. Installation Date (if applicable):
2. REQUIREMENTS
Owners/operators may choose one of the following options. Complete the table below by checking
either "Yes" or "No" to document the measurement, calculation, or observation meeting the
NESHAP requirement(s). It may be necessary to write "N/A" (not applicable) for some
requirements.
Citation
Option 1
(§63.744(a))
These requirements
are referred to as
Table 1 in the rule
Requirement
Aqueous cleaning solvents (>80%
water content as applied), miscible with
water, flash point > 200 °F (93 °C) are
used
Hydrocarbon based cleaning solvents
(mixture of photochemically reactive HC
and/or oxygenated HC), maximum vapor
pressure (VP) of 3.75 in. H2O at 68°F (7
mm Hg at 20°C), and containing no
HAP are used
Measurement,
Calculation, or
Observation
Yes
No
If using Option 1, skip Section 3 and go directly to Section 4.
Option 2
(§63.744(a))
Solvent not meeting requirements in
Option 1
If using Option 2, go to Section 3, Housekeeping Measures
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B - CLEANING
3. HOUSEKEEPING MEASURES
Housekeeping measures are required if Option 2 is used to comply with the cleaning operation
requirements. Check either "Yes" or "No" to document the measurement, calculation, or
observation meeting the NESHAP requirement.
Citation
§63.744(a)(l)
§63.744(a)(2)
§63.744(a)(3)
Requirement
Place absorbent applicators in closed
containers upon completing use (except
cotton-tipped swabs)
Store fresh and spent cleaning solvents
in closed containers (except semi-
aqueous cleaners)
Handle and transfer solvent between
containers in a manner that minimizes
spills
Measurement,
Calculation, or
Observation
Yes
No
4. RECORDKEEPING
The following recordkeeping is required for all options. Check either "Yes" or "No" to document
the measurement, calculation, or observation meeting the NESHAP requirement. Additional
requirements will be found in individual sections of the hand-wipe, spray gun, and flush cleaning
checklists.
Citation
§63.752(b)(l)
§63.10(b)(l)
Requirement
Name, vapor pressure, and
documentation showing the organic
HAP constituents for each cleaning
solvent
Necessary records to be maintained for
5 years (2 years onsite)
Measurement,
Calculation, or
Observation
Yes
No
62
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B - CLEANING
5. INSPECTOR COMMENTS:
END OF CHECKLIST B
63
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CHECKLIST C
HAND-WIPE CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: Cleaning operations subject to the hand-wipe cleaning requirements are also subject to the
cleaning requirements (Checklist B).
1. GENERAL INFORMATION
A Source Location (if applicable):
B. Installation Date (if applicable):
2. EXEMPTIONS
The following hand-wipe cleaning operations are exempted from portions of the regulatory
NESHAP provisions shown in the table (please note that some recordkeeping is required for exempt
operations where a noncompliant cleaning solvent is used). The cited regulatory provision and
§63.742 Definitions should be consulted for more details and for any qualifications on the
exemptions.
The following exemptions apply specifically to the use of hand-wipe cleaning solvents:
Citation
§63.744(e)(l)
§63.744(e)(2)
§63.744(e)(3)
§63.744(e)(4)
§63.744(e)(5)
§63.744(e)(6)
§63.744(e)(7)
Exempt Operation
Cleaning of components of breathing
oxygen systems that are exposed to the
breathing oxygen
Cleaning related to parts that are exposed
to strong oxidizers or reducers
Cleaning and surface activation prior to
adhesive bonding
Electronic parts, and assemblies
containing electronic parts
Aircraft and ground support equipment
fluid systems exposed to the fluid (e.g.,
air-to-air heat exchangers and hydraulic
fluid systems)
Fuel cells, fuel tanks, and confined
spaces
Solar cells, coated optics, and thermal
control surfaces
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
64
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C - HAND-WIPE CLEANING
The following exemptions apply specifically to the use of hand-wipe cleaning solvents:
Citation
§63.744(e)(8)
§63.744(e)(9)
§63.744(e)(10)
§63.744(e)(ll)
§63.744(e)(12)
§63.744(e)(13)
Exempt Operation
Cleaning related to upholstery, curtains,
carpet, and other textiles used in aircraft
interiors
Metallic and nonmetallic materials used
in honeycomb cores
Aircraft transparencies, polycarbonates,
and glass substrates
Cleaning associated with R&D, quality
control, or laboratory testing
Cleaning operations conducted within
5 feet of energized electrical systems
Cleaning operations that are "essential
uses" under the Montreal Protocol
(40 CFR §82.4)
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
3. REQUIREMENTS
Check off the compliance option or options selected by the owner/operator for hand-wipe cleaning
operations.
A Option 1. (§63.744(b)(l)) Meet Table 1 composition requirements G
[Table 1 found in rule and in Checklist B (Cleaning), Section 2]
B. Option 2: (§63.744(b)(2)) Meet Composite vapor pressure limit G
Requirement:
Is the composite vapor pressure 24 in. H,0 (45 mm Hg) or less at 68°F (20°C)?
Yes GNo G
C. Option 3: (§63.744(b)(3)) Solvent usage reduction G
Requirement:
Was the hand-wipe cleaning solvent usage reduced at least 60% from a 1996 and 1997
baseline value (or other value approved by the permitting agency), adjusted for production?
Yes GNo G
65
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C - HAND-WIPE CLEANING
Does the plan demonstrate a reduction equivalent to Option 1 or 2, and has an alternative
plan been filed?
Yes G No G
4. RECORDKEEPING
Recordkeeping requirements are based on the option or options selected by the owner/operator.
Check either "Yes" or "No" to document the measurement, calculation, or observation meeting the
NESHAP requirement(s).
For hand-wipe solvents complying with Option 1 - Table 1 criteria
Citation
§63.752(b)(2)
Requirement
Keep records of:
1 . name of each cleaning solvent,
2. data and calculations demonstrating
compliance with Table 1 , and
3. annual volume of each solvent used
(facility purchase or usage records)
Measurement,
Calculation, or
Observation
Yes
No
For hand-wipe solvents complying with Option 2 - vapor pressure limit
§63.752(b)(3)
Keep records of:
1 . name of each cleaning solvent,
2. composite vapor pressure of each
solvent,
3. test results (if applicable), data, and
calculations for composite VP, and
4. monthly volume of each solvent used
at each operation (purchase records
may be used if the quantity purchased
can be linked to each operation)
For hand-wipe solvents used in exempt cleaning operations that do not comply with Option 1 or 2
§63.752(b)(4)
Keep records of:
1 . identity and monthly volume of each
solvent used at each operation
(purchase records may be used if the
quantity purchased can be linked to
each operation), and
2. a list of the exempt operations in
which these solvents are being used
66
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C - HAND-WIPE CLEANING
5. INSPECTOR COMMENTS:
END OF CHECKLIST C
67
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CHECKLIST D
SPRAY GUN CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: Cleaning operations subject to the spray gun cleaning requirements are also subject to the
cleaning requirements (Checklist B).
1. GENERAL INFORMATION
A Source Location (if applicable):
B. Installation Date (if applicable):
2. REQUIREMENTS
Owners/operators may choose one of the following options. Determine what type of spray gun
cleaning operations are performed by completing the table below.
Citation
Option 1
§63.744(c)(l)
Option 2
§63.744(c)(2)
Option 3
§63.744(c)(3)
Option 4
§63.744(c)(4)
Requirement
Enclosed system cleaning
Nonatomized cleaning
Disassembled gun cleaning (manual or soaking)
Atomized cleaning
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
68
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D - SPRAY GUN CLEANING
3. RECORDKEEPING
A Option 1. (§63.744(c)(l)) Enclosed System G
Citation
Compliance
§63.744(c)(l)(i)
Monitoring
§63. 751 (a)
Compliance
§63.744(c)(l)(ii)
Recordkeeping
§63.752(b)(l)
Recordkeeping
§63.752(b)(5)
Requirement
Clean spray gun in enclosed system kept
closed except when inserting or removing
gun. Cleaning consists of forcing the
cleaning solvent through the gun.
Visually inspect seals and other potential
leak sources monthly, while system is in
operation.
Repair any leak in system as soon as
practicable, but no later than 15 days after
finding leak. Shut down system if not
repaired within 1 5 days. Repair and restart,
or decommission.
Keep records of name, vapor pressure, and
organic HAP constituents for each
cleaning solvent.
Keep records of leaks showing source ID,
date each leak found, and date each leak
repaired.
Measurement,
Calculation, or
Observation
Yes
No
B. Option 2: (§63.744(c)(2)) Nonatomized cleaning G
Citation
Compliance
§63.744(c)(2)
Recordkeeping
§63.752(b)(l)
Requirement
Clean spray gun by forcing solvent
through gun with atomizing cap in
place. No atomizing air is used. Collect
solvent from gun in closed container.
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
Measurement,
Calculation, or
Observation
Yes
No
69
-------
D - SPRAY GUN CLEANING
C. Option 3: (§63.744(c)(3)) Disassembled manual cleaning or soaking
Citation
Compliance
§63.744(c)(3)
Recordkeeping
§63.752(b)(l)
Requirement
Clean disassembled spray gun by hand
(vat kept closed when not in use), or
soak components (vat kept closed when
not inserting or removing components).
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
Measurement,
Calculation, or
Observation
Yes
No
D. Option 4: (§63.744(c)(4)) Atomized cleaning with emissions captur£
Citation
Compliance
§63.744(c)(4)
Recordkeeping
§63.752(b)(l)
Requirement
Clean spray gun by forcing solvent
through gun, collect atomized spray into
container that captures the solvent
emissions.
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
Measurement,
Calculation, or
Observation
Yes
No
4. INSPECTOR COMMENTS:
END OF CHECKLIST D
70
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E - FLUSH CLEANING
CHECKLIST E
FLUSH CLEANING CHECKLIST
Aerospace Manufacturing and Rework NESHAP
NOTE: Cleaning operations subject to the flush cleaning requirements are also subject to the
cleaning requirements (Checklist B). Flush cleaning means the removal of contaminants by passing
solvent over, into, or through the item (spray guns not included) being cleaned.
1. GENERAL INFORMATION
A Source Location (if applicable):
B. Installation Date (if applicable):
2. REQUIREMENTS
Check off the compliance option or options selected by the owner/operator for flush cleaning
operations.
NOTE: Exempt from the compliance requirements of §63.744(d) are: (1) semi-aqueous
cleaning solvents (>60% water as applied), and (2) Table 1 cleaning solvents (Checklist B,
Section 2).
A Option 1. Table 1 or semi-aqueous cleaning solvent^
[See Checklist B, Section 2 or Table 1 in rule.
Semi-aqueous: >60% water content as applied.]
B. Option 2: Enclosed system or collection system G
3. RECORDKEEPING
For operations using an enclosed system for flush cleaning (does not apply to spray gun cleaning)
Citation
Compliance
§63.744(d)
Requirement
Empty the used cleaning solvent from
flush cleaning into enclosed container
or collection system and keep it closed
when not in use, or empty into system
with equivalent emission control.
Measurement,
Calculation, or
Observation
Yes
No
For all flush cleaning operations, unless otherwise noted
Recordkeeping
§63.752(b)(l)
Keep records of name, vapor pressure,
and organic HAP constituents for each
cleaning solvent.
71
-------
E - FLUSH CLEANING
Citation
Requirement
Measurement,
Calculation, or
Observation
Yes
No
For semi-aqueous cleaning operations
Recordkeeping
§63.752(b)(2)
For semi-aqueous cleaning solvents
(used under Option 1 ), record name,
documentation that each meets
composition requirements, and annual
volume usage or purchase records.
Table 1 solvents are not subject to this
recordkeeping requirement.
4. INSPECTOR COMMENTS:
END OF CHECKLIST E
72
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F - PRIMER/TOPCOAT
CHECKLIST F
PRIMER/TOPCOAT CHECKLIST
Aerospace Manufacturing and Rework NESHAP
1. GENERAL INFORMATION
A Source Location (if applicable):
B. Installation Date (if applicable):
C. The following coating application operations are performed at the facility/plant:
n topcoating (containing organic/inorganic HAP)
n priming (containing organic/inorganic HAP)
n self-priming topcoating (containing organic/inorganic HAP)
n application of waterborne coatings
2. EXEMPT OPERATIONS
The following primer/topcoat (including self-priming) operations are exempt based on the regulatory
NESHAP provisions shown in the table. The cited regulatory NESHAP provision and §63.742
Definitions should be consulted for more details and for any qualifications on the exemptions.
The following exemptions apply to all primer and topcoat applications:
Citation
§63.741(i)
§63.745(a)
Exempt Operation
Waterborne primers/topcoats (limited
exemption, see rule for specific information)
Public display, nonoperational, and not
easily moved equipment
Measurement,
Calculation, or
Observation
Does Facility
Perform Indicated
Operation?
Yes
No
The following are exempt from the application technique requirements for organic HAP requirements only.
All other requirements apply.
§63.745(fX3)
Application
Equipment
Use of airbrush or spray gun extension
Coating containing fillers that adversely
affect atomization with HVLP
Film thicknesses <0.0005 inch
Airbrushed stenciling, lettering, or marking
Hand-held spray cans
Touchup and repair
The following are exempt from the inorganic HAP requirements only.
73
-------
F - PRIMER/TOPCOAT
Citation
§63.745(g)(4)
Inorganic HAP
Exempt Operation
Touchup of scratches, paint damage
Hole daubing for fasteners
Touchup of trimmed surfaces
Coating prior to joining dissimilar metal
components
Stencil operations performed by brush or
airbrush
Sectionjoining
Touchup of bushings
Sealant detackifying
Use of hand-held spray cans
Coating of parts that the permitting authority
has determined (and which is identified in a
Title V permit) is not technically feasible to
paint in a booth
Measurement,
Calculation, or
Observation
Does Facility
Perform Indicated
Operation?
Yes
No
3. COMPLIANCE OPTIONS - ORGANIC HAP EMISSIONS
There are five options for demonstrating compliance with the organic HAP emissions requirements.
Check off the compliance option/options selected by the owner/operator. Owners and operators
are required to meet the application techniques and housekeeping measures identified below
regardless of the compliance option(s) chosen:
A All Options: Application techniques and Housekeeping (§63.745(b) and (f))
B. Option 1: Primers/topcoats meet organic HAP/VOC limits (§63.745(e)(l))
C Option 2: Primers meet "low HAP content" limit (§63.752(c)(3))
D. Option 3: Weighted average content (§63.745(e)(2))
E. Option 4: Add-on controls (§63.745(d)) G
F. Option 5: Use ofwaterborne coatings (§63.741(i))
G
G
G
G
74
-------
F - PRIMER/TOPCOAT
4. REQUIREMENTS - ORGANIC HAP EMISSIONS
Document compliance with the specific option or options chosen by the owner/operator by
checking "Yes" or "No" for each item in the table for that option. If application or requirement is
not applicable, write "N/A" across the "Yes" or "No" column.
A All Options: Application techniques, Housekeeping, and Recordkeeping.
Citation
Compliance
§63.745(b)
Compliance
§63.745(f)
Recordkeeping
§63.745(f)(2)
Recordkeeping
§63.10(b)(l)
Requirement
Handle primers and topcoats in such a
manner that minimizes spills
Apply coatings using one or more of
the following methods:
flow/curtain coating
dip coat application
roll coating
brush coating
cotton-tipped swab application
electrodeposition (dip) coating
. HVLP spraying
electrostatic spray
other approved methods that meet
HVLP or electrostatic spray
Operate application devices in
accordance with company procedures,
local specified operating procedures,
and, or manufacturer specifications
Necessary records to be maintained for
5 years (2 years onsite)
Measurement,
Calculation, or
Observation
Yes
No
B. Option 1: Primers/topcoats meet organic HAP/VOC limits (uncontrolled coatings)
Citation
Compliance
§63.745(c)and(e)(l)
Requirement
Each primer and topcoat in use meets
the following content limits for both
organic HAP and VOC:
Primers: 2.9 Ib/gal (350 g/liter)
Topcoats: 3.5 Ib/gal (420 g/liter)
General aviation (all coatings) 4.5 Ib/gal
(S40 p/liter"!
Larae commercial aircraft and
assfmbles (exterior primer) 5.4 Ib/gal
(650 g/1)
Measurement,
Calculation, or
Observation
Yes
No
75
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F - PRIMER/TOPCOAT
Citation
Recordkeeping
§63.752(c)(l)
Recordkeeping
§63.752(c)(2)
(without averaging)
Requirement
Keep records of name and VOC and
HAP content of each primer and
topcoat as received and as applied.
Keep monthly records of mass of
organic HAP and VOC emitted per unit
volume of coating as appliedybr each
coating formulation, all
documentation for these emission
values, and the monthly volume usage
for each primer and topcoat
formulation.
Measurement,
Calculation, or
Observation
Yes
No
C. Option 2: Primers meet "low HAP content" limit (uncontrolledprimers)
Citation
Recordkeeping
§ 63.752(c)(3)(i)
Recordkeeping
§ 63.752(c)(3)(ii)
Requirement
Keep annual volume purchase records
of each low HAP or VOC content
coating (<2.1 Ib/gal).
Keep all data, calculations, and test
results, if applicable, used in
determining low organic HAP and VOC
content as applied, or manufacturer's
certification when primer is applied as
received.
Measurement,
Calculation, or
Observation
Yes
No
D. Option 3: Weighted average content (uncontrolled coatings)
76
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F - PRIMER/TOPCOAT
Citation
Compliance
§63.745(c) and (e)(2)
Recordkeeping
§63.752(c)(4)
Requirement
Any combination of primers or
topcoats such that the monthly
volume- weighted average organic HAP
and VOC contents of the combination
meet the following limits:
Primers: 2.9 Ib/gal (350 g/liter)
Toncoats: 3.5 Ib/sal (420 e/liter)
Gfnfral aviation (all coatings) 4.5 Ib/gal
(S40 p/liter"!
Larae commercial aircraft and
assfmbles (exterior primer) 5.4 Ib/gal
(650 g/1)
Keep records of monthly volume-
weighted average mass of organic
HAP and VOC per unit volume of
coating as applied for all primers and
all topcoats, and all documentation for
these calculations.
Measurement,
Calculation, or
Observation
Averaging scheme, if
applicable, approval
date
Yes
No
E. Option 4: Add-on control system (controlled coatings)
Citation
Compliance
§63.745(d)
Monitoring
§63.75 l(b)(3)(iii) and
(b)(4)
Monitoring
§63.751(b)(6)(m)(A)
Monitoring
§63.751(b)(6)(ii)
Requirement
Use a control system that reduces
organic HAP and VOC emissions with at
least 81% overall efficiency
(= capture efficiency x removal
efficiency).
Conduct monitoring of capture and
operating parameters established by
plan and calculate site specific
operating parameter value(s) that
demonstrate compliance.
Install, calibrate, operate, and maintain a
continuous emission monitor to
measure total HAP or VOC
concentration exhausted from control
device (portable monitor allowed for
nonregenerative carbon adsorbers).
Perform a quarterly audit of the
continuous emission monitor.
Measurement,
Calculation, or
Observation
Yes
No
77
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F - PRIMER/TOPCOAT
Citation
Monitoring
§63.751(b)(6)(m)(D)
Monitoring
§63.751(b)(8)
Monitoring
§63.751(b)(9)
Monitoring
§63.751(b)(10)
Recordkeeping
§63.752(c)(6)
Recordkeeping
§63.752(c)(5)
Requirement
For nonregenerative carbon adsorption
systems, replace the carbon at a regular
predetermined time interval.
For incinerators, install, calibrate,
maintain, and operate temperature
monitoring equipment according to
manufacturer's specifications. Every
3 months, replace or recalibrate
temperature sensors (or use a CEMS to
verify destruction efficiency).
For noncatalytic incinerators, install
thermocouples with continuous
recorders immediately downstream of
the firebox.
For catalytic incinerators, install
thermocouples with continuous
recorders immediately before and after
the catalyst bed.
Records for carbon adsorbers, as
appropriate for the type of system:
1 . Overall control efficiency, with all
data and calculations used to calculate
efficiency;
For mass balance calculation:
1. Length of rolling material balance
period, with all data and calculations;
3. Certification of accuracy for the
device that measures recovered HAP or
VOC; and
For nonregenerative carbon adsorbers:
4. Record of carbon replacement time,
as required.
Records for other control devices, as
appropriate:
1. Overall control efficiency;
2. Continuous records of firebox
temperature and calculated 3-hour
averages;
3. Continuous records of temperature
before and after the catalyst bed.
Measurement,
Calculation, or
Observation
Yes
No
F. Option 5: Use waterborne coatings
78
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F - PRIMER/TOPCOAT
Citation
Compliance
§63.741(i)
Recordkeeping
§63.741(i)
Requirement
Coating contains more than 5% water
by weight as applied in its volatile
fraction and meets applicable HAP and
VOC limits. Exemptions from several
rule requirements are specified in the
rule.
Keep manufacturer's supplied data and
annual purchase records for each
exempt waterborne coating for 5 years.
Measurement,
Calculation, or
Observation
Yes
No
79
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F - PRIMER/TOPCOAT
5. COMPLIANCE OPTIONS - INORGANIC HAP EMISSIONS
There are several options for meeting the inorganic HAP emissions requirements based on whether
the source is new or existing. Check off the compliance option(s) selected by the owner/operator.
If the requirement is not applicable, write "N/A" across the "Yes" or "No" portion of the applicable
column.
Citation
All Options
§63.745(g)(l)
Option 1
§63.745(g)(2)(i)
Option 2
§63.745(g)(2)(ii)
Option 3
§63.745(g)(2)(m)(A)
§63.745(g)(2)(m)(B)
Requirement
Apply coatings in a booth or hangar in
which air flow is directed downward
onto or across the part or assembly
being coated.
For existing sources, use a waterwash
system, a dry particulate filter meeting
the efficiencies in Tables 1 and 2 of
§63.745, or equivalent approved system.
For new sources, use a dry particulate
filter meeting the efficiencies in Tables 3
and 4 of §63.745, or equivalent
approved system.
For new sources constructed between
6/6/94 and 10/29/96, use a 2-stage dry
filter, or a waterwash system.
For new sources constructed between
6/6/94 and 10/29/96 that apply primers
or topcoats containing chromium or
cadmium, use a HEPA filter, 3-stage
filter, or approved equivalent to a
3-stage control system.
Measurement,
Calculation, or
Observation
Does Facility
Perform Indicated
Operation?
Yes
No
80
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F - PRIMER/TOPCOAT
6. REQUIREMENTS - INORGANIC HAP EMISSIONS
These requirements apply to the spray application of primers or topcoats that contain inorganic
HAP. If the requirement is not applicable, write "N/A" across the "Yes" or "No" portion of the
applicable column.
Citation
Requirement
Measurement,
Calculation, or
Observation
Yes
No
Is facility using a dry particulate filter system to control the coating operation? If Yes:
Compliance
§63.745(g)(2)(iv)(A)
Compliance
§63.745(g)(2)(iv)(B)
Compliance
§63.745(g)(2)(iv)(C)
Compliance
§63.745(g)(2)(iv)(D)
Compliance
§63.745(g)(3)
Recordkeeping
§63.752(d)(l)
Recordkeeping
§63.752(d)(3)
Maintain dry particulate filter in good
working order.
Install a differential pressure gauge
across the filter banks.
Continuously monitor pressure drop
across filter, read and record pressure
drop once per shift in which coating
occurs.
Take corrective action when pressure
drop goes outside manufacturer's
recommended limit(s).
Shut down coating operation and take
corrective action if pressure drop goes
outside specified limit(s).
Shut down coating operation if
specified maintenance procedures have
not been performed as scheduled.
Record pressure drop across operating
filter system once per shift in which
coating occurs.
Log shall include acceptable limit(s) for
pressure drop.
Is facility using a waterwash system (conventional and pumpless) to control the coating operation? If Yes:
Compliance
§63.745(g)(2)(v)
Continuously monitor the water flow
rate or operating efficiency range (for
pumpless systems), and read and record
the water flow rate or efficiency range
once per shift in which coating occurs.
81
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F - PRIMER/TOPCOAT
Citation
Compliance
§63.745(g)(3)
Recordkeeping
§63.752(d)(2)
Recordkeeping
§63.752(d)(3)
Requirement
Shut down coating operation and take
corrective action:
1 . If water path fails visual
continuity /flow characteristics check or
water flow rate or operating efficiency
range goes outside specified limit(s), or
2. If specified maintenance procedures
have not been performed as scheduled.
Record water flow rate or operating
efficiency range through system once
each shift in which coating occurs.
Log shall include acceptable limit(s) for
water flow rate or operating efficiency.
Measurement,
Calculation, or
Observation
Yes
No
7. INSPECTOR COMMENTS:
END OF CHECKLIST F
82
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CHECKLIST G
DEPAINTING OPERATIONS
Aerospace Manufacturing and Rework NESHAP
NOTE: The rule covers depainting operations on the outer surface areas of completed aerospace
vehicles (including the fuselage, wings, and vertical and horizontal stabilizers of the aircraft) and the
outer casing and stabilizers of missiles and rockets. The rule also applies only to facilities that
depaint more than six completed aerospace vehicles per calendar year.
1. GENERAL INFORMATION
A Source Location (if applicable):
B. Installation Date (if applicable):
2. EXEMPT OPERATIONS
Depainting performed in the situations or on the parts shown in the table is exempted from the
control requirements in §63.746. The cited regulatory NESHAP provisions and §63.742 Definitions
should be consulted for more details and for any qualifications on the exemptions.
Citation
§63.746(a)(l)
§63.746(a)(2)
§63.746(a)(3)(i)
§63.746(a)(3)(ii)
§63.746(b)(5)
Exempt Operation
Parts normally removed from vehicle for
depainting (except wings and
stabilizers)
Public display, nonoperational, and not
easily moved equipment
Depainting of radomes
Parts, subassemblies, and assemblies
normally removed from primary aircraft
structure before depainting
Mechanical and hand sanding
operations are exempt from the
requirements to perform work in an
enclosed area and use a control system .
All other requirements apply.
Measurement,
Calculation, or
Observation
Does Facility
Depaint Indicated
Parts?
Yes
No
83
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G - DEPAINTING
3. REQUIREMENTS
Check off the compliance option or options selected by the owner/operator and check "Yes" or
"No" for each item in the table for that option. If the requirement is not applicable, write "N/A"
across the "Yes" or "No" portion of the applicable column.
Citation
Option 1
§63.746(b)(l)
Option 2
§63.746(b)(2)
Option 3
§63.746(c)
Requirement
Non-HAP chemical strippers and
technologies
Nonchemical based equipment
Organic HAP chemical strippers
(emissions reduced by control system)
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
A Option 1: (§63.746(b)(l)) Non-HAP chemical strippers and technologies G
Check "Yes" or "No" for each item in the table when using non-HAP chemical strippers and
technologies.
Citation
Compliance
§63.746(b)(l)
Compliance
§63.746(b)(3)
Recordkeeping
§63.752(e)(l)(i)
Requirement
Each chemical stripping formulation or
agent, and each chemical paint softener,
used for depainting shall emit no
organic HAP during depainting
operations, except for spot stripping
and decal removal.
For spot stripping and decal removal,
use no more than:
1 . 26 gal organic HAP-containing
chemical strippers or 1 90 Ib organic
HAP per commercial aircraft depainted,
and
2. 50 gal HAP strippers or 365 Ib
organic HAP per military aircraft
depainted, on an annual average basis.
Keep records of name of each stripper
used.
Measurement,
Calculation, or
Observation
Yes
No
84
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G - DEPAINTING
Citation
Recordkeeping
§63.752(e)(l)(ii)
Recordkeeping
§63.752(e)(6)
Requirement
Keep records of monthly volume of
each organic HAP containing stripper or
weight of organic HAP used for spot
stripping and decal removal.
For spot stripping and decal removal:
1 . Volume of organic HAP stripper or
weight of organic HAP used;
2. Annual average volume of organic
HAP stripper or weight of organic HAP
used per aircraft;
3 . Annual number of aircraft stripped;
and
4. All data and calculations used.
Measurement,
Calculation, or
Observation
Yes
No
B. Option 2: (§63.746(b)(2)) Nonchemical based equipment G
Check "Yes" or "No" for each item in the table when using nonchemical based equipment.
Citation
Compliance
§63.746(b)(2)
Requirement
Maintain nonchemical based depainting
equipment according to manufacturer's
specifications or locally prepared
procedures.
During malfunctions, use substitute
materials that minimize HAP emissions.
Substitute materials are not to be used
for more than 15 days annually, unless
non-HAP.
Measurement,
Calculation, or
Observation
Yes
No
Does facility use dry media blasting equipment that generates airborne inorganic HAP emissions? If Yes:
Compliance
§63.746(b)(4)(i)
Compliance
§63.746(b)(4)(ii)(A)
Perform depainting in an enclosed area
or use a closed-cycle depainting
system.
For existing sources, use a waterwash
system, baghouse, or a dry particulate
filter. Dry particulate filters must meet
the efficiency data points in Tables 1
and 2 of §63.745.
85
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G - DEPAINTING
Citation
Compliance
§63.746(b)(4)(ii)(B)
Requirement
For new sources, use a dry particulate
filter system meeting the efficiency data
points in Tables 3 and 4 of §63.745 or a
baghouse.
Measurement,
Calculation, or
Observation
Yes
No
Is facility using a dry particulate filler system to control the media blasting operation? If Yes:
Compliance
§63.746(b)(4)(ui)(A)
Compliance
§63.746(b)(4)(iu)(B)
Compliance
§63.746(b)(4)(iu)(C)
Compliance
§63.746(b)(4)(ui)(D)
Compliance
§63.746(b)(4)(v)
Maintain dry particulate filter in good
working order.
Install a differential pressure gauge
across the filter banks.
Continuously monitor pressure drop
across the filter.
Take corrective action when pressure
drop goes outside manufacturer's
recommendation.
Shut down depainting operation and
take corrective action if filter pressure
drop goes outside specified limits.
Shut down depainting operation and
take corrective action if specified
maintenance procedures have not been
performed as scheduled.
Is facility using a waterwash system (conventional or pumpless) to control the media blasting operation? If
Yes:
Compliance
§63.746(b)(4)(iv)
Compliance
§63.746(b)(4)(v)
Compliance
§63.746(b)(4)(v)
Continuously monitor the water flow
rate or operating efficiency range (for
pumpless systems)
Shut down depainting operation and
take corrective action if water path fails
visual continuity /flow characteristics
check or the water flow rate or efficiency
range goes outside specified limits.
Shut down depainting operation and
take corrective action if specified
maintenance procedures have not been
performed as scheduled.
86
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G - DEPAINTING
Citation
Requirement
Measurement,
Calculation, or
Observation
Yes
No
For a dry particulate filter or a waterwash system:
Monitoring
§63.751(d)
Recordkeeping
§63.752(e)(5)(i)
Recordkeeping
§63.752(e)(5)(ii)
Recordkeeping
§63.752(e)(7)
Continuously monitor pressure drop
across dry filter or water flow rate for
conventional waterwash systems or
operating efficiency range for pumpless
systems, and read and record these
parameters once per shift.
Records of names and types of
nonchemical based equipment (dry
media blast, etc.)
For malfunction periods, the technique
that malfunctioned, date, description of
malfunction, methods used during the
period, dates these methods were begun
and stopped, and date the malfunction
was corrected.
Records of actual pressure drop across
dry filters, or visual continuity and
water flow rate for waterwash systems,
recorded once each shift that depainting
occurred. Log also must indicate
acceptable limit(s) for the recorded
parameters.
C. Option 3: (§63.746(c)) Organic HAP chemical strippers G
(Emissions reduced by use of control device)
Check "Yes" or "No" for each item in the table when using organic HAP chemical strippers.
Citation
Compliance
§63.746(c)
Requirement
Use a control system that reduces
organic HAP and VOC emissions with at
least:
1. 81% overall efficiency (= capture
efficiency x removal efficiency) or mass
balance calculations for existing
sources, or
2. 95% overall efficiency for new
sources or mass balance calculation.
Measurement,
Calculation, or
Observation
Yes
No
87
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G - DEPAINTING
Citation
Monitoring
§63.75 l(b)(3)(iii) and
(b)(iv)
Monitoring
§63.751(b)(6)(m)(A)
Monitoring
§63.751(b)(6)(ii)
Monitoring
§63.751(b)(6)(m)(D)
Monitoring
§63.751(b)(8)
Monitoring
§63.751(b)(9)
Monitoring
§63.751(b)(10)
Recordkeeping
§63.752(e)(2)
Requirement
Conduct monitoring of capture and
operating parameters established by
plan and calculate site specific
operating parameter value(s) that
demonstrate compliance.
Install, calibrate, operate, and maintain a
continuous emission monitor to
measure total organic HAP or VOC
concentration exhausted from control
device (portable monitor allowed for
nonregenerative carbon adsorbers).
Perform a quarterly audit of the
continuous emission monitor.
For nonregenerative carbon adsorption
systems, replace the carbon at a regular
predetermined time interval.
For incinerators, install, calibrate,
maintain, and operate temperature
monitoring equipment according to
manufacturer's specifications. Every
3 months, replace or recalibrate
temperature sensors (or use a CEMS to
verify destruction efficiency).
For noncatalytic incinerators, install
thermocouples with continuous
recorders immediately downstream of
the firebox.
For catalytic incinerators, install
thermocouples with continuous
recorders immediately before and after
the catalyst bed.
Records for carbon adsorbers, as
appropriate for the type of system:
1 . Overall control efficiency, with all
data and calculations used to calculate
efficiency;
For mass balance calculation:
1. Length of rolling material balance
period, with all data and calculations;
and
3. Certification of accuracy for the
device that measures recovered HAP or
VOC.
For nonregenerative carbon adsorbers:
4. Record of carbon replacement time
Measurement,
Calculation, or
Observation
Yes
No
-------
G - DEPAINTING
Citation
Recordkeeping
§63.752(e)(3)
Recordkeeping
§63.752(e)(4)
Requirement
Records for other control devices, as
appropriate:
1 . Overall control efficiency and
supporting calculations.
For each aircraft type depainted, a
listing of the parts, subassemblies, and
assemblies normally removed before
depainting. Exempted aircraft types:
prototype, test model, and aircraft of
which <25 exist.
Measurement,
Calculation, or
Observation
Yes
No
4. INSPECTOR COMMENTS:
END OF CHECKLIST G
-------
CHECKLIST H
CHEMICAL MILLING MASKANT OPERATIONS
Aerospace Manufacturing and Rework NESHAP
NOTE: Chemical milling maskant is defined as a coating that is applied directly to aluminum
components to protect surface areas when chemical milling the component with a Type I or Type II
etchant. This does not include bonding maskants and critical use and line sealer maskants, and seal
coat maskants. Additionally, maskants that must be used with a combination of Type I or II etchant
and any of the above types of maskants are also exempt from the chemical milling maskant
requirements.
1. GENERAL INFORMATION
A Source Location (if applicable):
B. Installation Date (if applicable):
2. EXEMPT OPERATIONS
The following maskants are exempt from the rule requirements. The cited regulatory NESHAP
provision and §63.742 Definitions should be consulted for more details and for any qualifications on
the exemptions.
Citation
§63.742
Chemical milling
maskant
§63.747(c)
Exempt Maskant
1 . Bonding maskants
2. Critical use and line sealer maskants
3. Seal coat maskants
4. Maskants used with a combination of
Type I or II etchant and any of the
maskant types in 1, 2, or 3 above.
Maskants used for touchup of
scratched surfaces, damaged maskant,
or trimmed edges
Measurement,
Calculation, or
Observation
Does Facility Use
the Maskant?
Yes
No
90
-------
H - MASKANT
3. COMPLIANCE OPTIONS
Check off the compliance option selected by the owner/operator and check "Yes" or "No" for
each item in the table(s) for that option. If a requirement is not applicable, write "N/A" across
the "Yes" or "No" portion of the applicable column.
Citation
Option 1
§63.747(c)
Option 2
§63.747(d)
Option 3
§63.741(i)
Requirement
Chemical milling maskant meets
organic HAP/VOC limits
Add-on controls
Use of waterbome coatings
Measurement,
Calculation, or
Observation
Does Facility
Perform
Indicated
Operation?
Yes
No
A Option 1: (§63.747(c)) Organic HAP and VOC content limits
I. (§63.747(e)(l)) Each maskant meets limit
Citation
Compliance
§63.747(b)
Compliance
§63.747(c)and
(e)(l)
Recordkeeping
§63.752(fj(l)
Requirement
Handle and transfer maskant between
containers in a manner that minimizes
spills.
Each maskant in use meets the
following content limits for both HAP
and VOC:"
1 . 5.2 Ib/gal (622 g/liter) - Type I
2. 1.3 Ib/gal (160 g/liter) - Type II
Keep monthly records of mass of
organic HAP and VOC emitted per
unit volume of maskant as applied, all
documentation for these emission
values, and the monthly volume
usage for each maskant formulation.
Measurement,
Calculation, or
Observation
Yes
No
"Different content limits apply to maskants used with Type I or Type II etchants, as shown.
OR
91
-------
II. (§63.747(e)(2)) Weighted average content
H - MASKANT
Citation
Compliance
§63.747(b)
Compliance
§63.743(d) and
§63.747(c) and (e)(2)
Recordkeeping
§63.752(f)(2)
Requirement
Handle and transfer maskant between
containers in a manner that minimizes
spills.
The monthly volume-weighted average
organic HAP and VOC contents meet
the following limits:
1 . 5.2 Ib/gal (622 g/liter) - Type I
2. 1.3 Ib/gal (160 g/liter) - Type II
Keep records of monthly volume-
weighted average mass of organic HAP
and VOC for all maskants, and all
documentation for these calculations.
Measurement,
Calculation, or
Observation
Yes
No
B. Option 2: (§63.747(d)) Add-on control system
Citation
Compliance
§63.747(b)
Compliance
§63.747(d)
Monitoring
§63.75 l(b)(3)(iii),
(b)(iv)
Monitoring
§63.751(b)(6)(m)(A)
Requirement
Handle and transfer maskant between
containers in a manner that minimizes
spills.
Use a control system that reduces
organic HAP and VOC emissions with at
least 81% overall efficiency
(= capture efficiency x removal
efficiency or mass balance calculation).
See required Records below for
verification of efficiency.
Conduct monitoring of capture and
operating parameters established by
plan and calculate site specific
operating parameter value(s) that
demonstrate compliance.
Install, calibrate, operate, and maintain a
continuous emission monitor to
measure total HAP or VOC
concentration exhausted from control
device (portable monitor allowed for
nonregenerative carbon adsorbers).
Measurement,
Calculation, or
Observation
Yes
No
92
-------
H - MASKANT
Citation
Monitoring
§63.751(b)(6)(ii)
Monitoring
§63.751(b)(6)(m)(D)
Monitoring
§63.751(b)(8)
Monitoring
§63.751(b)(9)
Monitoring
§63.751(b)(10)
Requirement
Perform a quarterly audit of the
continuous emission monitor.
For nonregenerative carbon adsorption
systems, replace the carbon at a regular
predetermined time interval.
For incinerators, install, calibrate,
maintain, and operate temperature
monitoring equipment according to
manufacturer's specifications. Every
3 months, replace or recalibrate
temperature sensors (or use a CEMS to
verify destruction efficiency).
For noncatalytic incinerators, install
thermocouples with continuous
recorders immediately downstream of
the firebox.
For catalytic incinerators, install
thermocouples with continuous
recorders immediately before and after
the catalyst bed.
Measurement,
Calculation, or
Observation
Yes
No
93
-------
H - MASKANT
Citation
Recordkeeping
§63.752(f)(3) and (4)
Requirement
Records for carbon adsorbers, as
appropriate for the type of system:
1 . Overall control efficiency, with all
data and calculations used to calculate
efficiency;
For mass balance calculation:
1. Length of rolling material balance
period, with all data and calculations;
3. Certification of accuracy for the
device that measures recovered HAP or
VOC; and
For nonregenerative carbon adsorbers:
4. Record of carbon replacement time.
Records for other control devices, as
appropriate:
1 . Overall control efficiency and
supporting calculations;
For noncatalytic incinerators:
1. Continuous records of firebox
temperature and calculated 3-hour
averages;
For catalytic incinerators:
3. Continuous records of temperature
before and after the catalyst bed and all
calculated 3 -hour averages of such
temperatures.
Measurement,
Calculation, or
Observation
Yes
No
C. Option 3: (§63.741(1)) Use waterborne maskants
Citation
Compliance
§63.741(1)
Compliance
§63.747(b)
Recordkeeping
§63.741(1)
Requirement
Maskant contains more than 5%
water by weight as applied in its
volatile fraction and meet applicable
HAP and VOC limits. Exemptions
from several rule requirements are
specified.
Handle and transfer maskants
between containers in a manner that
minimizes spills.
Keep manufacturer's supplied data
and annual purchase records for
each exempt waterborne maskant
for 5 years.
Measurement,
Calculation, or
Observation
Yes
No
94
-------
H - MASKANT
4. INSPECTOR COMMENTS:
END OF CHECKLIST H
95
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6.0 Other Implementation Materials
This chapter provides you with a list of other implementation materials that are available for the
Aerospace NESHAP rule. Although we haven't officially reviewed or sanctioned these mateirals,
we are providing a list since it may be helpful to you. These documents may be obtained by getting
in touch with the contact person associated with the document. You can find additional information
on other implementation materials available by going to www.epa.gov/ttn/uatw/aerosp/aeropg.html.
Document
Author/Agency
Contact
Aerospace Coating Operations
Manual.
January 1997
Compliance Division, California
EPA, Air Resources Board.
Sacramento, CA
Gary Hunter
(916)324-6972
NESHAP Fact Sheet for Aerospace
NESHAP & South Coast Air Quality
Management District Rules 1124 and
1171.
February 11,1997
South Coast Air Quality
Management District.
Diamond Bar, CA
Stacey Ebiner, Senior Air Quality Engineer.
(909) 396-2504
Amir Dejbakhsh, Air Quality Engineer II.
(909)396-2618
PRO-ACT Fact Sheet for the
Aerospace NESHAP
HQ Air Force Center for
Environmental Excellence
PRO-ACT
1(800)233-4356
Web Site:
http://www.afcee.brooks.af.mil/PRO-ACT
Fact Sheets for Air Toxics Rule:
Cleaning Operations
(Available November 1997)
U.S. EPA, Office of
Enforcement and Compliance
Assurance
Transportation Environmental Compliance
Assistance Center
Web Site:
http://es.inel.gov/oeca/tcac/tcac.html
Fact Sheets for Air Toxics Rule:
Depainting and Painting
(Available November 1997)
U.S. EPA, Office of
Enforcement and Compliance
Assurance
Transportation Environmental Compliance
Assistance Center
Web Site:
http://es.inel.gov/oeca/tcac/tcac.html
U.S. EPA Information Pamphlet: New
Regulation Controlling Air Emissions
from Aerospace Manufacturing and
Rework Facilities, 40 CFR 63, Subpart
GG
U.S. EPA, Office of Air Quality
Planning and Standards.
Research Triangle Park, NC
U.S. EPA
Unified Air Toxics Website,
http://www.epa.gov/ttn/uatw
Also, the EPA's Office of Enforcement and Compliance Assurance (OECA) maintains a data base
called the Applicability Determination Index (ADI), which contains memoranda issued by the EPA
on applicability and compliance issues associated with the New Source Performance Standards
(NSPS), NESHAP (Part 61 and MACT, Part 63), and chlorofluorocarbons.
96
-------
Determinations recently issued are added to the data base on a quarterly basis. Also available are
determinations for Subpart T. They can be accessed on the TTN Web at
http://ttnwww.rtrjnc.erja.gov/html/sscd/comrjli.htm.
97
-------
7.0 Example Calculations
This section includes example calculations and spreadsheets to demonstrate compliance with the
surface coating requirements involving primers and topcoats in § 63.745 of the rule. The example
data was derived from actual facilities' data in response to information collection requests conducted
during the aerospace project. Example 1 is a monthly spreadsheet using individual coating
compliance for primers and topcoats. Example 2 demonstrates compliance using emissions
averaging for primers and topcoats. Example 3 demonstrates compliance using rolling average
calculations for primers and topcoats. Additional example calculations can be downloaded from
www.epa.gov/ttn/uatw/aerosp/aeropg.html.
Acronyms (column headings) used in example calculation spreadsheets.
Column
A
B
C
D
E
F
G
H
I
J
K
L
M
Heading
Paint ID
Type of coating
Usage
vw
ww
vx
Dc
MH
w
VVH
H
Mv
wv
G
Description, units
Coating identification by the supplier or manufacturer
Applicable coating category (i.e., primer or topcoat)
Monthly usage in gallons, (gal/mo)
Volume of water in 1 gal of coating, in gal
Weight fraction of water in coating, in percent (%)
Volume of exempt solvents in 1 gal of coating, in gal
Density of coating, in pounds of coating per gal of coating
(lb/gal)
Mass of organic HAP in 1 gal on coating, in Ib
Weight fraction of organic HAP in coating, in %
Mass of organic HAP emitted per volume of coating (lb/gal)
less water as applied
Mass of VOC in 1 gal of coating, in Ib
Weight fraction of VOC in coating, in %
Mass of VOC emitted per volume of coating (lb/gal) less water
and exempt solvents as applied
98
-------
Example 1. Monthly spreadsheet for demonstrating compliance using individual coating compliance for primers and topcoats.
Paint
ID
515X36
8
BR127
AR022
AR030
AR150
822X45
0
DAOOO
1
DAOOO
2
DAOOO
3
XPT20
0
Type of
coating
Primer
Primer
Primer
Primer
Primer
Topcoa
t
Topcoa
t
Topcoa
t
Topcoa
t
Topcoa
t
Usage,
gal/mo
35
234
43
78
81
34
250
125
50
174
Vw,gal
0
0
0
0
0.32
0
0
0
0
0.21
ww, %
0
0
0
0
0.3
0
0
0
0
0.2
Vx,gal
0
0
0
0
0
0
0
0
0
0
Dc, Ib/gal
8.9
7.3
9.9
9.3
9
9.3
9.9
10.3
10.6
8.8
MH,lb
1.96
2.19
2.67
0.00
0.54
2.05
3.27
2.58
1.59
0.88
WH5%
22
30
27
0
6
22
33
25
15
10
H,
Ib/gal
1.96
2.19
2.67
0.00
0.79
2.05
3.27
2.58
1.59
1.11
MVJlb
2.85
2.85
2.67
2.33
0.99
3.16
3.37
2.58
2.65
0.88
WVJ%
32
39
27
25
11
34
34
25
25
10
G, Ib/gal
2.85
2.85
2.67
2.33
1.46
3.16
3.37
2.58
2.65
1.11
HAP and VOC content limit(s): 2.9 Ib/gal for primers and 2.5 Ib/gal for topcoats
Compliance demonstration: Each primer (as applied) has HAP and VOC contents <2.9 Ib/gal
Compliance demonstration: Each topcoat (as applied) has HAP and VOC contents <2.5 Ib/gal
99
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Example 2. Monthly spreadsheet for demonstrating compliance using emissions averaging for primers and for topcoats.
Paint ID
515X368
BR127
DLP001
DLP002
DLP003
DLP004
DLP004
822X450
DA0001
DA002
DA003
DA003
DA004
DA005
DA006
DA007
DA008
Type of coating
Primer
Primer
Primer
Primer
Primer
Primer
Primer
SUBTOTAL
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
Topcoat
SUBTOTAL
Usage,
gal/mo
35
234
140
10
45
26
42
532
34
250
18
32
35
17
38
102
4
138
668
vw,
gal
0.0
0.0
0.0
0.0
0.1
0.1
0.0
0.0
0.0
0.1
0.3
0.0
0.0
0.0
0.1
0.0
0.0
ww,
%
0
0
0
0
10
6
0
0
0
5
25
0
0
0
10
0
0
Vx,gal
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
DC,
Ib/gal
8.9
7.3
8.38
8.3
12.45
8.76
10.79
9.3
9.9
9.85
9.96
8.3
6.64
7.47
8.33
9.5
9.94
MH5lb
1.96
2.77
0.00
4.57
1.25
2.89
2.16
3.07
3.66
3.45
1.00
4.15
2.79
4.48
1.67
1.43
1.49
WH, %
22
38
0
55
10
33
20
H,
Ib/gal
1.96
2.77
0.00
4.57
1.46
3.09
2.16
Hivg= 1.88
33
37
35
10
50
42
60
20
15
15
3.07
3.66
3.66
1.42
4.15
2.79
4.48
1.85
1.43
1.49
Hivg= 2.84
Mv,lb
2.76
2.77
2.85
4.57
3.11
3.50
2.16
3.07
3.66
3.94
3.69
4.15
4.65
4.48
1.67
2.19
3.48
Wv, %
31
38
34
55
25
40
20
G,
Ib/gal
2.76
2.77
2.85
4.57
3.66
3.74
2.16
Givg = 2.90
33
37
40
37
50
70
60
20
23
35
3.07
3.66
4.19
5.26
4.15
4.65
4.48
1.85
2.19
3.48
Givg= 3.50
Monthly primer use =532
Monthly topcoat use = 668
Monthly average limit(s) = 2.9 Ib/gal for primers and 3.5 Ib/gal for topcoats
Compliance demonstration: monthly primer (as applied) averages: Hsvg and Gavg <2.9 Ib/gal
100
-------
TOTAL (combined) = 1,200 Compliance demonstration: monthly topcoat (as applied) averages: H,^ and Gsvg <3.5 Ib/gal
101
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Example 3. Rolling average calculations
These rolling calculations are intended to be used to demonstrate compliance with the § 63.745(d)
primers and topcoats, § 63.746(c) depainting (chemical strippers), or § 63.747(d) chemical milling
maskants using Equation 9 which is located in § 63.750(g). These calculations are also to be used
"to demonstrate initial and continuous compliance when emissions are controlled by a dedicated
solvent recovery device."
Mr
R = ^^^^^^^^=^^^^^^^^= X 100 Fnnation 9
Sum of [(W01)(Mci) - Rs.)] bquatl°n
where:
R = overall HAP or VOC emission reduction, %;
M,. = the total mass in kilograms of HAP or VOC recovered for a 7 to 30 day period;
Mci = the total mass in kilograms of each batch of coating (i) applied, or of each coating
applied at an affected coating operation during a 7- to 30-day period, as appropriate, as
determined from
Woi = the weight fraction of HAP or VOC in each batch of coating (i) applied, or of each
coating applied at an affected coating operation during a 7- to 30-day period, as
appropriate, as determined by EPA Method 24 or formulation data; and
RSj = the total mass in kilograms of HAP or VOC retained in the coating after drying. (The
value of RSj is zero unless additional documentation is submitted showing that the
measured value of Rs; exceeds zero.)
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Example VOC data for a 10 day period using eight different coatings (A through H).
Day
1
2
3
4
5
6
7
8
9
10
Coating (wt fraction;
wt of coating)
A (55%; 10. lib)
B(51%, 9.9 Ib)
C(48%; ll.Olb)
Volume
applied, gal
22
45
33
Total
weight, Ib
122.2
227.2
174.2
Mass of VOC
recovered, Ib
No coating applied
D (40%; 9.5 Ib)
E (55%; 12.2 Ib)
B (51%; 9.9 Ib)
C(48%; ll.Olb)
F (57%; 10.9 Ib)
15
69
46
7
46
57.0
463.0
232.3
37.0
285.8
325
No coating applied
No coating applied
B (51%; 9.9 Ib)
C(48%; ll.Olb)
F (57%; 10.9 Ib)
22
56
41
111.1
295.7
254.7
1,748
No coating applied.
G (45%; 10.5 Ib)
H (55%; 12.0 Ib)
B (51%; 9.9 Ib)
C(48%; ll.Olb)
F (57%; 10.9 Ib)
82
4
43
24
21
387.5
26.4
217.1
126.7
130.5
For each coating used on each day, (Woi)(Mci) is represented as "TOTAL WEIGHT" and for Day 1,
coating A, the total weight (or mass) of coating A was calculated to be the weight fraction (55%)
multiplied by the weight of the coating (10.1 Ib/gal) multiplied by volume applied (22 gal) = (0.55) x
(10.1) x (22)= 122.2 Ib.
Using Equation 9, the overall VOC reduction, R, for the first week (days 1 through 7) is calculated
as follows (and assuming Rs; = 0):
R =
(325 + 1,748)
(122.2 + 227.2 + 174.2 + 57 + 463 + 232.3 + 37 + 285.8 + 111.1 + 295.7 + 254.7)
R = 2'073 = 0.917 x 100% = 91.7%
2,260.2
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On day 10, the rolling average would be calculated for days 4 through 10 as follows:
R =
(1,748)
(232.3 + 37 + 285.8 + 111.1 + 295.7 + 254.7 + 387.5 + 26.4 + 217.1 + 126.7 + 130.5)
R = 1;748 = 0.830 x 100% = 83.0%
2,104.8
Since the overall reduction has to be greater than or equal to 81%, both of these rolling average
calculations demonstrate compliance for those coating operations being controlled with a dedicated
solvent recovery device.
NOTE: All of the English units used in this example can be converted to metric as defined in the
aerospace final rule and the final result will be the same since we are dealing with ratios.
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8.0 List of Cleaning Solvent Substitutions
This section includes a listing of substitution products that were identified in aerospace industry
responses to a Section 114 information collection request involving cleaning operations. The
comments section reflects industry's associated comments, not EPA's.
Substitution product
97% water, 2% surfactant,
1%MEK
Jettacin
RIMS- 1029
Type 1 Cleaner:
Water 96.8%
MEKO.8%
Triton X- 100 1.8%
Triton X-45 0.6%
d-Limonene
Solvent 64
Citri-Kleen
Emulsion cleaners
Alkaline cleaner:
diethylene glycol
monobutyl ether
(0.01 mmHg) and water
mixture
Blend of low vapor
pressure solvents
d-Limonene based
hydrocarbon solution
Product substituted for
MEK/MIBK blend
MEK
MEK/MIBK blend
MEK
MEK
Carbon remover with
large percent of the
methylene chloride
Vapor degreasers with
trichloroethylene
MEK mixture
85wt%CFC-113
1 5 wt% MEK or organic
solvent blend
Naphtha, methylene
chloride, and
perchloroethylene
Comments
Cleaning of noncritical components
Reduce VOC emissions by 10,000 Ib.
Reduce MEK usage by 25%.
Use in 80-90% of cleaning applications for
final aircraft cleaning.
Reduce VOC and HAP emissions by 98%.
Reduced MEK usage by 99%.
Eliminated MTBK usage.
Used in tool cleaning operations, general
shop cleaning, and other noncritical
aerospace applications general purpose
hand- wipe cleaning.
Eliminated MEK usage.
Batch cleaning of coating equipment and
fabrication of tools.
Wipe solvent.
Used in propeller shop disassembly and
cleaning areas
Used in metal parts cleaning
Estimated reduction of VOC emissions by
5-10 tons per year.
Used in exterior cleaning of wings.
Reduced VOC emissions by 8,000 Ib.
Reduced HAP emissions by 37,500 Ib.
Reduced solvent usage by 308,000 Ib.
General purpose cleaner.
Reduced HAP emissions by 31,000 Ib.
Reduced solvent usage by 27,000 Ib-
solution is recyclable.
Machine shop cleaner.
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Substitution product
Envirosolv KN12000:
mixture of wood
blend terpenes
vapor press =
0.28 mmHg
Ardrox 5523
Bio-T Mex:
Terpene, coors
Diethylene glycol
monobutyl ether
(0.01 mmHg)
Diethylene glycol
monobutyl ether
(0.01 mmHg) and Citra Safe
Alkaline cleaner
Bio-T Max
Aqueous cleaners
<100 gal/L
Mil-C-383334Atypel
(metal conditioner) no VOC
content
Orange all
Aqueous cleaning
solutions, vapor press. =
<26mmHg
Solvents vapor press. =
<45mmHgat20°C:
Turco 6754
Androx5515
Desoclean 20
Diethylene glycol
monobutyl ether
(0.01 mmHg)
Diethylene glycol
monobutyl ether (0.01
mmHg)
Citra-Safe
Product substituted for
MEK and MIBK blend
Vapor press = 43 mmHg
and 1,1,1-TCA vapor
press =100 mmHg
50/50 blend of 1,1,1-TCA
and methylene chloride
MEK, TCA
MEK
MEK
Freon TES
MEK
TCA
Mil-C-5410 376 gal/L
MEK, TCA methylene
chloride
MEK
MEK and acetone
MEK, acetone, toluene
MEK, acetone
MEK
Comments
General purpose wipe cleaner and cold
degreasing activities
Reduced usage of 1,1,1-TCA and methylene
chloride by 30,000 Ib.
Used for spray gun cleaning.
Wiping solvents in machine shop and
machinery repair.
Wipe cleaning
Solvent usage reduced by 50%.
Cleaning in assembly and sheet metal areas.
Parts washer in the machine shop.
Cleaning processes.
Remove grease and oils from machinery
prior to paint
Cleaner
Removal of contaminants from noncritical
items
Wipe solvents
Solvent wiping operations needed for
aircraft parts.
Turco 6754 and Ardrox 5515:
Cleaning parts prior to adhesive
bonding primer application
All phases of production and factory
support, clean spray guns, lines and related
equipment
Reduced solvent usage by 12,000 Ib/yr.
Used in metal cleaning operations.
Reduced MEK and acetone usage by
600 gal. Used in cleaning machine parts and
tool grindings.
Paint gun cleaning.
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Substitution product
d-Limonene
Biogenic
Toluene
Diethylene glycol
monobutyl ether
(0.01 mmHg)
Product substituted for
MEK
Comments
General purpose cleaning and replacement
for solvent cleaning.
Used to remove aircraft corrosion inhibiting
contamination.
Hand wipes.
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Appendix A
Glossary
Aerospace facility means any facility that produces, reworks, or repairs in any amount
any commercial, civil, or military aerospace vehicle or component.
Aerospace vehicle or component means any fabricated part, processed part, assembly
of parts, or completed unit, with the exception of electronic components, of any aircraft
including but not limited to airplanes, helicopters, missiles, rockets, and space vehicles.
Aircraft fluid systems means those systems that handle hydraulic fluids, fuel, cooling
fluids, or oils.
Aircraft transparency means the aircraft windshield, canopy, passenger windows, lenses,
and other components which are constructed of transparent materials.
Antique aerospace vehicle or component means an aircraft or component thereof that
was built at least 30 years ago. An antique aerospace vehicle would not routinely be in
commercial or military service in the capacity for which it was designed.
Carbon adsorber means one vessel in a series of vessels in a carbon adsorption system
that contains carbon and is used to remove gaseous pollutants from a gaseous emission source.
Carbon adsorber control efficiency means the total efficiency of the control system,
determined by the product of the capture efficiency and the control device efficiency.
Chemical milling maskant means a coating that is applied directly to aluminum
components to protect surface areas when chemical milling the component with a Type I or
Type II etchant. Type I chemical milling maskants are used with Type I etchant and Type II
chemical milling maskants are used with a Type II etchant. This definition does not include
bonding maskants, critical use and line sealer maskants, and seal coat maskants. Additionally,
maskants that must be used with a combination of Type I or II etchants and any of the above
types of maskants (e.g., bonding, critical use and line sealer, and seal coat) are also exempt
from this subpart. (See also Type II etchant definition.)
Chemical milling maskant application operation means application of chemical milling
maskant for use with Type I or Type II chemical milling etchants.
Cleaning operation means collectively spray gun, hand-wipe, and flush cleaning
operations.
Cleaning solvent means a liquid material used for hand-wipe, spray gun, or flush cleaning.
This definition does not include solutions that contain HAP and VOC below the de minimis
levels specified in § 63.741(f).
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Closed-cycle depainting system means a dust-free, automated process that removes
permanent coating in small sections at a time, and maintains a continuous vacuum around the
area(s) being depainted to capture emissions.
Coating means a material that is applied to the surface of an aerospace vehicle or
component to form a decorative, protective, or functional solid film, or the solid film itself.
Coating operation means the use of a spray booth, tank, or other enclosure or any area,
such as a hangar, for the application of a single type of coating (e.g., primer); the use of the
same spray booth for the application of another type of coating (e.g., topcoat) constitutes a
separate coating operation for which compliance determinations are performed separately.
Coating unit means a series of one or more coating applicators and any associated drying
area and/or oven wherein a coating is applied, dried, and/or cured. A coating unit ends at the
point where the coating is dried or cured, or prior to any subsequent application of a different
coating. It is not necessary to have an oven or flashoff area in order to be included in this
definition.
Confined space means a space that: (1) is large enough and so configured that an
employee can bodily enter and perform assigned work; (2) has limited or restricted means for
entry or exit (for example, fuel tanks, fuel vessels, and other spaces that have limited means of
entry); and (3) is not suitable for continuous employee occupancy.
Control device means destruction and/or recovery equipment used to destroy or recover
HAP or VOC emissions generated by a regulated operation.
Control system means a combination of pollutant capture system(s) and control device(s)
used to reduce discharge to the atmosphere of HAP or VOC emissions generated by a
regulated operation.
Depainting means the removal of a permanent coating from the outer surface of an
aerospace vehicle or component, whether by chemical or nonchemical means. For
nonchemical means, this definition excludes hand and mechanical sanding, and any other
nonchemical removal processes that do not involve blast media or other mechanisms that
would result in airborne particle movement at high velocity.
Depainting operation means the use of a chemical agent, media blasting, or any other
technique to remove permanent coatings from the outer surface of an aerospace vehicle or
component. The depainting operation includes washing of the aerospace vehicle or component
to remove residual stripper, media, or coating residue.
Electrodeposition of paint means the application of a coating using a water-based
electrochemical bath process. The component being coated is immersed in a bath of the
coating. An electric potential is applied between the component and an oppositely charged
electrode hanging in the bath. The electric potential causes the ionized coating to be electrically
attracted, migrated, and deposited on the component being coated.
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Electrostatic spray means a method of applying a spray coating in which an electrical
charge is applied to the coating and the substrate is grounded. The coating is attracted to the
substrate by the electrostatic potential between them.
Exempt solvent means specified organic compounds that have been determined by the
EPA to have negligible photochemical reactivity and are listed in 40 CFR 51.100.
Exterior primei means the first layer and any subsequent layers of identically formulated
coating applied to the exterior surface of an aerospace vehicle or component where the
component is used on the exterior of the aerospace vehicle. Exterior primers are typically used
for corrosion prevention, protection from the environment, functional fluid resistance, and
adhesion of subsequent exterior topcoats. Coatings that are defined as specialty coatings are
not included under this definition.
Flush cleaning means the removal of contaminants such as dirt, grease, and coatings from
an aerospace vehicle or component or coating equipment by passing solvent over, into, or
through the item being cleaned. The solvent may simply be poured into the item being cleaned
and then drained, or be assisted by air or hydraulic pressure, or by pumping. Hand-wipe
cleaning operations where wiping, scrubbing, mopping, or other hand action are used are not
included.
General aviation (GA) means that segment of civil aviation that encompasses all facets of
aviation except air carriers, commuters, and military. General aviation includes charter and
corporate-executive transportation, instruction, rental, aerial application, aerial observation,
business, pleasure, and other special uses.
General aviation rework facility means any aerospace facility with the majority of its
revenues resulting from the reconstruction, repair, maintenance, repainting, conversion, or
alteration of general aviation aerospace vehicles or components.
Hand-wipe cleaning operation means the removal of contaminants such as dirt, grease,
oil, and coatings from an aerospace vehicle or component by physically rubbing with a material
such as a rag, paper, or cotton swab that has been moistened with a cleaning solvent.
Hazardous air pollutant (HAP) means any air pollutant listed in or pursuant to
section 112(b) of the Act.
High efficiency particulate air (HEPA) filter means a dry particulate filter system that
has a 99.97 percent reduction efficiency for 0.3 micron aerosol.
High volume low pressure (HVLP) spray equipment means spray equipment that is
used to apply coating by means of a spray gun that operates at 10.0 psig of atomizing air
pressure or less at the air cap.
Inorganic hazardous air pollutant (HAP) means any HAP that is not organic.
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Large commercial aircraft means an aircraft of more than 110,000 pounds, maximum
certified take-off weight manufactured for non-military use.
Leak means any visible leakage, including misting and clouding.
Limited access space means internal surfaces or passages of an aerospace vehicle or
component that cannot be reached without the aid of an airbrush or a spray gun extension for
the application of coatings.
Mechanical sanding means aerospace vehicle or component surface conditioning which
uses directional and random orbital abrasive tools and aluminum oxide or nylon abrasive pads
for the purpose of corrosion rework, substrate repair, prepaint surface preparation, and other
maintenance activities.
Natural draft opening means any opening in a room, building, or total enclosure that
remains open during operation of the facility and that is not connected to a duct in which a fan
is installed. The rate and direction of the natural draft through such an opening is a
consequence of the difference in pressures on either side of the wall containing the opening.
Nonchemical based depainting equipment means any depainting equipment or
technique, including, but not limited to, media blasting equipment, that can depaint an
aerospace vehicle or component in the absence of a chemical stripper. This definition does not
include mechanical sanding or hand sanding.
Nonregenerative carbon adsorber means a carbon adsorber vessel in which the spent
carbon bed does not undergo carbon regeneration in the adsorption vessel.
Operating parameter value means a minimum or maximum value established for a
control device or process parameter which, if achieved by itself or in combination with one or
more other operating parameter values, determines that an owner or operator has complied
with an applicable emission limitation.
Organic hazardous air pollutant (HAP) means any HAP that is organic.
Primer means the first layer and any subsequent layers of identically formulated coating
applied to the surface of an aerospace vehicle or component. Primers are typically used for
corrosion prevention, protection from the environment, functional fluid resistance, and adhesion
of subsequent coatings. Coatings that are defined as specialty coatings are not included under
this definition.
Radome means the nonmetallic protective housing for electromagnetic transmitters and
receivers (e.g., radar, electronic countermeasures, etc.).
Recovery device means an individual unit of equipment capable of and normally used for
the purpose of recovering chemicals for fuel value, use or reuse. Examples of equipment that
may be recovery devices include absorbers, carbon adsorbers, condensers, oil-water
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separators, or organic-water separators or organic removal devices such as decanters,
strippers, or thin-film evaporation units.
Research and Development means an operation whose primary purpose is for research
and development of new processes and products, that is conducted under the close
supervision of technically trained personnel, and is not involved in the manufacture of final or
intermediate products for commercial purposes, except in a de minimis manner.
Self-priming topcoat means a topcoat that is applied directly to an uncoated aerospace
vehicle or component for purposes of corrosion prevention, environmental protection, and
functional fluid resistance. More than one layer of identical coating formulation may be applied
to the vehicle or component.
Semiaqueous cleaning solvent means a solution in which water is a primary ingredient
(> 60 percent of the solvent solution as applied must be water.)
Softener means a liquid that is applied to an aerospace vehicle or component to degrade
coatings such as primers and topcoats specifically as a preparatory step to subsequent
depainting by nonchemical based depainting equipment. Softeners may contain VOC but shall
not contain any HAP as determined from MSDS's or manufacturer supplied information.
Solids means the nonvolatile portion of the coating which after drying makes up the dry
film.
Space vehicle means a man-made device, either manned or unmanned, designed for
operation beyond earth's atmosphere. This definition includes integral equipment such as
models, mock-ups, prototypes, molds, jigs, tooling, hardware jackets, and test coupons. Also
included is auxiliary equipment associated with test, transport, and storage, which through
contamination can compromise the space vehicle performance.
Specialty coating means a coating that, even though it meets the definition of a primer,
topcoat, or self-priming topcoat, has additional performance criteria beyond those of primers,
topcoats, and self-priming topcoats for specific applications. These performance criteria may
include, but are not limited to, temperature or fire resistance, substrate compatibility,
antireflection, temporary protection or marking, sealing, adhesively joining substrates, or
enhanced corrosion protection. Individual specialty coatings are defined in appendix A to
subpart GG and in the CTG for Aerospace Manufacturing and Rework Operations
(EPA 453/R-97-004).
Spot stripping means the depainting of an area where it is not technically feasible to use a
nonchemical depainting technique.
Spray gun means a device that atomizes a coating or other material and projects the
particulates or other material onto a substrate.
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Stripper means a liquid that is applied to an aerospace vehicle or component to remove
permanent coatings such as primers and topcoats.
Surface preparation means the removal of contaminants from the surface of an
aerospace vehicle or component, or the activation or reactivation of the surface in preparation
for the application of a coating.
Temporary total enclosure means a total enclosure that is constructed for the sole
purpose of measuring the emissions from an affected source that are not delivered to an
emission control device. A temporary total enclosure must be constructed and ventilated
(through stacks suitable for testing) so that it has minimal impact on the performance of the
permanent emission capture system. A temporary total enclosure will be assumed to achieve
total capture of fugitive emissions if it conforms to the requirements found in § 63.750(g)(4) of
the rule and if all natural draft openings are at least four duct or hood equivalent diameters
away from each exhaust duct or hood. Alternatively, the owner or operator may apply to the
Administrator for approval of a temporary enclosure on a case-by-case basis.
Topcoat means a coating that is applied over a primer on an aerospace vehicle or
component for appearance, identification, camouflage, or protection. Coatings that are defined
as specialty coatings are not included under this definition.
Total enclosure means a permanent structure that is constructed around a gaseous
emission source so that all gaseous pollutants emitted from the source are collected and ducted
through a control device, such that 100 percent capture efficiency is achieved. There are no
fugitive emissions from a total enclosure. The only openings in a total enclosure are forced
makeup air and exhaust ducts and any natural draft openings such as those that allow raw
materials to enter and exit the enclosure for processing. All access doors or windows are
closed during routine operation of the enclosed source. Brief, occasional openings of such
doors or windows to accommodate process equipment adjustments are acceptable, but if such
openings are routine or if an access door remains open during the entire operation, the access
door must be considered a natural draft opening. The average inward face velocity across the
natural draft openings of the enclosure must be calculated including the area of such access
doors. The drying oven itself may be part of the total enclosure. An enclosure that meets the
requirements found in § 63.750(g)(4) of the rule is a permanent total enclosure.
Touchup and repair operation means that portion of the coating operation that is the
incidental application of coating used to cover minor imperfections in the coating finish or to
achieve complete coverage. This definition includes out-of-sequence or out-of-cycle coating.
Two-stage filter system means a dry particulate filter system using two layers of filter
media to remove particulate. The first stage is designed to remove the bulk of the particulate
and a higher efficiency second stage is designed to remove smaller particulate.
Type I etchant means a chemical milling etchant that contains varying amounts of
dissolved sulfur and does not contain amines.
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Type II etchant means a chemical milling etchant that is a strong sodium hydroxide
solution containing amines.
Volatile organic compound (VOC) means any compound defined as VOC in 40 CFR
51.100. This includes any organic compound other than those determined by the EPA to be
an exempt solvent. For purposes of determining compliance with emission limits, VOC will be
measured by the approved test methods. Where such a method also inadvertently measures
compounds that are exempt solvent, an owner or operator may exclude these exempt solvents
when determining compliance with an emission standard.
Waterborne (water-reducible) coating means any coating which contains more than
5 percent water by weight as applied in its volatile fraction.
Waterwash system means a control system that utilizes flowing water (i.e., a conential
waterwash system) or pumpless system to remove particulate emissions from the exhaust air
stream in spray coating application or dry media blast depainting operations.
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Appendix B
Example Initial Notification Form
INITIAL NOTIFICATION REPORT2
THIS IS A SAMPLE NOTIFICATION FORM WHICH CAN BE USED BY FACILITIES AT THEIR
DISCRETION TO MEET COMPLIANCE WITH 40 CFR63.753(a)
Applicable Rule: 40 CFR Part 63, Subpart GG - National Emission Standards for
Aerospace
Manufacturing and Rework Facilities. Initial Notification is being made in
accordance
with §63.753(a)(1) and §63.9(b)(2).
1. Print or type the following information for each plant in which aerospace manufacturing
and rework operations are performed (§63.9(b)(2)(i)- (ii)):
Owner/Operator/Title
Street Address
City State Zip Code:
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional).
Plant Address (if different than owner/operator's).
Street Address
City State Zip Code:
2. Indicate your anticipated compliance date (§63.9(b)(2)(iii)):
Q 1 September 1998
Initial notification forms should be sent to the EPA Regional Office servicing your area and
to your State or local Air Pollution Control Agency by September 1, 1997. Part 70 permits
can be used in lieu of an initial notification provided: (1) the same information is contained
in the permit application as required by this rule; (2) the State has an approved Title V
program under Part 70; (3) the State has received delegation of authority by the EPA; and
(4) Title V permits are submitted by September 1, 1997.
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Q Upon startup3 Anticipated startup date
5 Q Waste handling and storage
4 Q Topcoat application
3. Check which affected source(s) (as defined by 40 CFR 63.741 (c)) are performed at
your plant:4
Q Hand wipe cleaning
Q Flush cleaning
Q Spray gun cleaning4 Q Primer application
Q Chemical milling maskant applications Q Q Depainting operations
Briefly describe the nature, size, design and method of operation of the source, including
its operating design capacity. (§63.9(b)(2)(iv)):
EXAMPLE RESPONSE: Plant #4 is responsible for the maintenance, repair and rework of
military and commercial aircraft. The plant occupies approximately 1500 acres and contains 12
maintenance shops and one aircraft hangar where aircraft cleaning, topcoating, priming,
depainting and chemical milling maskant operations are performed.
All topcoating, priming and milling maskant operations, except for minor touchup operations,
are performed in enclosed areas where dry particulate filters are utilized. Depainting of aircraft
parts is performed using plastic media blasting where emissions are controlled by the use of
HEPA filters. Depainting of parts not normally removed from the aircraft are performed using
mechanical or hand sanding. Minor amounts of chemical stripping may be performed in areas
where mechanical or hand sanding is not feasible. Approximately 65% of HAP emissions from
this plant come from painting and priming operations; 5% from chemical milling maskant
operations; 25% from cleaning operations and 5% from depainting operations.
Plant #4 is capable of operating 24 hours per day, 365 days per year but currently operates 16
hours per day (two 8 hour shifts). Approximately 181 aircraft are maintained per year, however,
the plant can accommodate up to 300 aircraft per year for maintenance and repair.
Approximately 60% of the work performed is at this location involves minor maintenance and
Sources may use the application for approval and construction or reconstruction to fulfill
the initial notification requirement.
Operations regulated under 40 CFR 63 Subpart GG include: hand-wipe cleaning, spray
gun cleaning, flush cleaning, primer application, topcoat application, depainting
operations, chemical milling maskant and waste handling/storage.
Proposed changes to the final rule were published on October 29, 1996 (61 FR 55853)
which proposes limiting the definition of an affected source to those activities subject to
the manufacture or rework of aerospace vehicles or components. Until these amendments
are finalized, all cleaning operations at the facility are subject to Subpart GG.
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repair of internal and external aircraft parts. Approximately 40% involve major rework of the
aircraft exterior.
4. Identify each point of emission for each hazardous air pollutant, or if a definitive
identification is not yet possible, a preliminary identification of each point of emission
for each hazardous air pollutant. If additional lines are needed, make copies of this
page (§63.9(b)(2)(iv)).
Please indicate if the information below is:
Q Actual
Q Preliminary
NOTE: 40 CFR 63.741(c)(ii) identifies each spray gun cleaning operation as an affected source.
Each spray gun cleaning operation should be identified separately.
Source
ID
Source Location
Source
Description
Operation Performed
EXAMPLE RESPONSE:
Source ID
N/A
CLEAN- 1
and 2
CLEAN-3
and 4
PAINT- 1
PAINT-2
PAINT-3
Source Location*
Bldg 510, 550, Hangar 1,
Hangar2, Flight Line
Bldg 510, Paint Shop (all
sources located in Room
220)
Hangar2
Bldg 510, PaintShop
(Room 220)
Hangar2
Flight Line
Source Description
Wipe-clean aircraft after sanding
operations and prior to
topcoating, priming and maskant
application
One paint gun cleaner (enclosed
system). One disassembled
spray gun cleaning area
One paint gun cleaner (enclosed
system). One disassembled
spray gun cleaning area
One walk-in paint booth
One corrosion control facility
large enough to contain a 747
Flight Line operations are "touch-
up" only
Operation(s)
Performed
Hand-Wipe Cleaning
Spray Gun Cleaning
Spray Gun Cleaning
Primer and Topcoat
Application
Primer and Topcoat
Application
Primer and Topcoat
Application
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STRIP-1
STRIP-2
MILL-1
N/A
Bldg 510, Depaint Shop
(Room 300)
Bldg 550, Hangar 1, Flight
Line
Hangar2
Bldg 510, 550, Hangar 1,
Hangar2, Flight Line
Plastic media blasting using a
walk-in contained booth
Mechanical and hand sanding;
minor chemical stripping
Apply Type I and II maskant
Store and handle waste
Depainting
Operations
Depainting
Operations
Milling Maskant
Waste Handling and
Storage
* The following information is available at Plant #4 as of the date of this submittal and may change
prior to the compliance date of Subpart GG. Building 510 contains five maintenance shops and
Bldg. 550 contains seven shops for parts assembly and minor repair.
5. Check the box that applies (§63.9(b)(2)(v)):
Q My plant is a major source of Hazardous Air Pollutants (HAP's)
Q My plant is a minor source of HAP's
NOTE: A major source is a facility that emits greater than 10 tons per year of any one
hazardous air pollutant (HAP) or 25 tons per year of multiple HAP's. All other sources
are area sources. The major/area source determination is based on all HAP emission
points inside the plant fenceline, not just the aerospace manufacture and rework
facilities.
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Appendix C
General Provisions Applicability to Subpart GG
Table C-l. General Provisions Applicability to Subpart GG
Reference
63.1(a)(l)
63.1(a)(2)
63.1(a)(3)
63.1(a)(4)
63.1(a)(5)
63.1(a)(6)
63.1(a)(7)
63.1(a)(8)
63.1(a)(9)
63.1(a)(10)
63.1(a)(ll)
63.1(a)(12)
63.1(a)(13)
63.1(a)(14)
63.1(b)(l)
63.1(b)(2)
63.1(b)(3)
63.1(c)(l)
63.1(c)(2)
63.1(c)(3)
63.1(c)(4)
63.1(c)(5)
63.1(d)
63.1(e)
63.2
63.3
63.4(a)(l)
63.4(a)(2)
63.4(a)(3)
Applies to
affected sources
in Subpart GG
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Comment
Reserved
Reserved
Subpart GG does not apply to area sources
Reserved
Reserved
119
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TABLE C-l. (continued)
Reference
63.4(a)(4)
63.4(a)(5)
63.4(b)
63.4(c)
63.5(a)
63.5(b)(l)
63.5(b)(2)
63.5(b)(3)
63.5(b)(4)
63.5(b)(5)
63.5(b)(6)
63.5(c)
63.5(d)(l)(i)
63.5(d)(l)(ii)(A)-(H)
63.5(d)(l)(ii)(I)
63.5(d)(l)(ii)(J)
63.5(d)(l)(m)
63.5(d)(2)-(4)
63.5(e)
63.5(f)
63.6(a)
63.6(b)(l)-(5)
63.6(b)(6)
63.6(b)(7)
63.6(c)(l)
63.6(c)(2)
63.6(c)(3)-(4)
63.6(c)(5)
63.6(d)
63.6(e)
63.6(f)
Applies to
affected sources
in Subpart GG
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
No
Yes
No
Yes
Yes
Comment
Reserved
Reserved
Reserved
Reserved
§ 63.749(a) specifies compliance dates for new sources
Reserved
The standards in Subpart GG are promulgated under
1 12(d) of the Clean Air Act (Act)
section
Reserved
Reserved
§ 63.743(b) includes additional provisions for the startup,
shutdown, and malfunction plan
120
-------
TABLE C-l. (continued)
Reference
63.6(g)
63.6(h)
63.6(1X1X3)
63.6(i)(4)(i)(A)
63.6(i)(4)(i)(B)
63.6(i)(4)(n)
63.6(1X5X12)
63.6(1X13)
63.6(1X14)
63.6(1X15)
63.6(1X16)
63.6(j)
63.7(a)(l)
63.7(a)(2)(i)-(vi)
63.7(a)(2)(vii)-(vm)
63.7(a)(2)(rx)
63.7(a)(3)
63.7(b)
63.7(c)
63.7(d)
63.7(e)
63.7(f)
63.7(g)(l)
63.7(g)(2)
63.7(g)(3)
63.7(h)
63.8(a)(lX2)
63.8(a)(3)
63.8(a)(4)
63.8(b)
Applies to
affected sources
in Subpart GG
Yes
No
Yes
Yes
No
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Comment
The standards
in Subpart GG do not include opacity standards
§ 63.743(a)(4) specifies that requests for extension of
compliance must be submitted no later than 120 days before an
affected source's compliance date
The standards in Subpart GG are promulgated under section
112(d)oftheAct
Reserved
Reserved
Reserved
Reserved
121
-------
TABLE C-l. (continued)
Reference
63.8(c)
63.8(d)
63.8(e)(l)-(4)
63.8(e)(5)(i)
63.8(e)(5)(ii)
63.8(f)(l)
63.8(f)(2)(i)-(vii)
63.8(f)(2)(viii)
63.8(f)(2)(ix)
63.8(f)(3)-(6)
63.8(g)
63.9(a)
63.9(b)(l)
63.9(b)(2)
63.9(b)(3)
63.9(b)(4)
63.9(b)(5)
63.9(c)
63.9(d)
63.9(e)
63.9(f)
63.9(g)(l)
63.9(g)(2)
63.9(g)(3)
63.9(h)(l)-(3)
63.9(h)(4)
63.9(h)(5)-(6)
63.9(1)
63.9(j)
63.10(a)
Applies to
affected sources
in Subpart GG
Yes
No
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Yes
No
No
No
No
Yes
No
Yes
Yes
Yes
Yes
Comment
The standards in Subpart GG do not include opacity
standards
The standards in Subpart GG do not include opacity
standards
§63. 753(a)(l) requires submittal of the initial notification at
least 1 year prior to the compliance date; § 63.753(a)(2) allows a
Title V or Part 70 permit application to be substituted for the
initial notification in certain circumstances
The standards in Subpart GG do not include opacity
standards
The standards in Subpart GG do not include opacity
standards
§ 63.753(a)(l) also specifies additional information to be
included in the notification of compliance status
Reserved
122
-------
TABLE C-l. (continued)
Reference
63.10(b)
63.10(c)(l)
63.10(c)(2)-(4)
63.10(c)(5)-(8)
63.10(c)(9)
63.10(c)(10)-(13)
63.10(c)(14)
63.10(c)(15)
63.10(d)(l)-(2)
63.10(d)(3)
63.10(d)(4)
63.10(d)(5)
63.(10)(e)(l)
63.10(e)(2)(i)
63.10(e)(2)(n)
63.10(e)(3)
63.10(e)(4)
63.10(1)
63.11
63.12
63.13
63.14
63.15
Applies to
affected sources
in Subpart GG
Yes
No
No
No
No
No
No
No
Yes
No
Yes
Yes
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Comment
Reserved
Reserved
§ 63.8(d) does not apply to this subpart
The standards in Subpart GG do not include opacity standards
The standards in Subpart GG do not include opacity standards
The standards in Subpart GG do not include opacity standards
123
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TECHNICAL REPORT DATA
1. REPORT NO.
EPA-456/R-97-006
2.
4. TITLE AND SUBTITLE
National Emission Standards for Aerospace Manufacturing and Rework
Facilities: Summary of Requirements for Implementing the NESHAP
7. AUTHOR(S)
Gregory A. LaFlam (PES) Dave Reeves (MRI) Ingrid Ward (EPA)
9. PERFORMING ORGANIZATION
Pacific Environmental Services, Inc.
5001 South Miami Boulevard, Suite
Revised and Updated by:
Midwest Research Institute
Research Triangle Park, NC 27709
Revised and Updated by:
EPA/OAQPS/ITPID/PRIG
NAME AND ADDRESS
300
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, NC 2771 1
3 . RECIPIENT' S ACCESSION NO.
5. REPORT DATE
December 1998 (update)
March 1998 (original publication))
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D3-0032, WA 111-93 & IV-1 (PES)
68-D6-0012, TO No. 12 (MRI)
EPA, PRIG
13. TYPE OF REPORT AND PERIOD COVERED
Final, Update
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
Project Officer is Mary Wilkins, Mail Drop 12, (919) 541-5229
Work Assignment Manager is Ingrid Ward, Mail Drop 12, (919) 541-0300
16. ABSTRACT
National emission standards to control emissions of HAP from existing and new aerospace manufacturing and rework facilities were promulgated in
1995. This document contains information to assist State and local air pollution control agencies as well as the regulated community in the
implementation of these standards. It contains an overview of the rule along with sample inspection sheets are also provided along with a
bibliography of Federal, State, and local agency sources of additional information related to these standards. This document is available for
download at www.epa.gov/ttn/uatw/aerosp/aeropg.html.
17.
a. DESCRIPTORS
Air pollution
Air pollution control
National emission standards
Hazardous air pollutants
Aerospace industry
Implementation guidance
KEY WORDS AND DOCUMENT ANALYSIS
b. IDENTIFIERS/OPEN ENDED TERMS
Air pollution control
Aerospace manufacturing
Stationary sources
c. COASTI Field/Group
13B
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18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (This page)
Unclassified
21. NO. OF PAGES
138
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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