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2 NESHAP info sources http//ttnwww.rtpnc.epa.govhttp//ttnwww.rtpnc.epa.gov –(919) USEPA Region IX, San FranciscoUSEPA Region IX, San Francisco –(415)

3 Rule and Implementation Information for Part 63 General Provisions (Subpart A) Rule and Implementation Information for the Aerospace Industry List of a dozen Manufacturers of Paint Arrestors Certified by Method 319 by Method 319 Aerospace Manufacture & Rework Facilities; NESHAP and Control Techniques Guideline; Final and Proposed Rules Control Techniques Guideline; Final and Proposed Rules

4 (b) list of 188 HAP(b) list of 188 HAP (c) list of sources emitting these HAP(c) list of sources emitting these HAP (d) performance standard shall be the Maximum Achievable Control Technology (MACT) (twelfth percentile of existing installations)(d) performance standard shall be the Maximum Achievable Control Technology (MACT) (twelfth percentile of existing installations) (f) residual risk(f) residual risk EPA’s Hazardous Air Pollutants Program Clean Air Act §112

5 EPA’s Hazardous Air Pollutants Program Aerospace NESHAP General Provisions 40 CFR 63, subpart A, 1994General Provisions 40 CFR 63, subpart A, 1994 List of sources emitting 40 CFR 61 List of sources emitting 40 CFR 61 MACT standard for Aerospace Coating Operations 40 CFR 63 Subpart GGMACT standard for Aerospace Coating Operations 40 CFR 63 Subpart GG Residual risk - not yet draftedResidual risk - not yet drafted

6 General NESHAP Final Compliance Date September 1, 1998

7 NESHAP vs District Rules The NESHAP provides additional HAP reductions and enhanced compliance by self reporting

8 NESHAP vs District Rules The following substances are listed as federal HAP but are exempt from existing district VOC rules 1,1,1- Trichloroethane Perchloroethylene Methylene Chloride

9 NESHAP vs District Rules Both the district breakdown rule and the NESHAP malfunction provision allow the source to continue operating while affecting repairs. EPA has traditionally opposed variances. EPA has traditionally opposed variances. Will the variance application and report delineating emission minimization during breakdown satisfy EPA’s malfunction plan requirements? Will the variance application and report delineating emission minimization during breakdown satisfy EPA’s malfunction plan requirements?

10 NESHAP vs District Rules District rules require new and existing sources meet the same limits. The NESHAP has stricter limits for reconstructions with a capital cost in excess of 50% of the cost of the facility. District rules will likely be changed.District rules will likely be changed.

11 NESHAP vs SCAQMD Rule Spot stripping exemption South Coast 3 gal/day (1695 gal. of methylene chloride /yr) NESHAP less than 6 vehicles/yearunlimited more than 6 vehicles/yr26 gal/vehicle/yr (no limit on gal.)

12 NESHAP vs SCAQMD Rule Coatings exemption South Coast Facilities using less than 3 gal/day of VOC containing coatings & solventsFacilities using less than 3 gal/day of VOC containing coatings & solvents Temporary markingsTemporary markings AerosolsAerosolsNESHAP Containing less than 0.1% HAP & VOC or less than 1.0% non-carcinogens

13 NESHAP vs SCAQMD Rule Coatings VOC content exemption South Coast 20 gal/yr of a coating provided facility uses less than 200 gal/yr combined20 gal/yr of a coating provided facility uses less than 200 gal/yr combined 10 gal/yr of adhesives10 gal/yr of adhesivesNESHAP 50 gal/yr of any one coating provided facility uses less than 200 gal/yr combined

14 NESHAP vs SCAQMD Rule Coatings : VOC content & transfer efficiency exemption South Coast 1.5 gal/day for repair at military facility provided facility uses less than 5 gal/day combined NESHAP 0.1% HAP and VOC or 1.0% non- carcinogen

15 NESHAP vs SCAQMD Rule Controled Coatings South Coast 86% Control (90% capture x 95% control) or 50 ppm at exhaust NESHAP 81% Control

16 NESHAP vs District Rules No specific “minimize spills” provision in district rule. For handwipe cleaning district has “200 gms VOC” vs. compositional compliance or 60% volume reduction in NESHAP. No HAP limit in district VOC rules Districts will need to incorporate HAP limits for coatings and cleaning solvents. Likely handwipe limit will be less than 0.1% carcinogen & less than 1.0% non-carcinogenic HAP to qualify for exemption.

17 NESHAP vs District Rules For chemical milling maskants there is No commonality between rules. SCoast Chemical Milling & Chemical Processing 250g/l NESHAP Type I 622 g/l Type II 160g/l

18 NESHAP vs District Rules For “any alternative approved by the director” EPA has 180 days to decide. Districts suggest authority reverts to local district after 15 days.

19 Aerospace NESHAP Matrix Applicability Exemptions Standards Tests, Recordkeeping & Reporting Organic Depainting Inorganic Depainting Gun Cleaning Surf. Cleaning Painting

20 Aerospace Coating MACT Applicability Exemptions Standards Tests, Recordkeeping & Reporting

21 Aerospace NESHAP Applicability A major HAP source making or reworking commercial, civil or military vehicles or components and Applying primer, topcoat or chemical milling maskant, cleaning with solvent or stripping paint

22 NESHAP-General Provisions Applicability Major sources - those facilities with the potential to emit 10 tpy of any listed HAP or 25 tpy of any combination of listed HAPMajor sources - those facilities with the potential to emit 10 tpy of any listed HAP or 25 tpy of any combination of listed HAP

23 Aerospace NESHAPApplicability All hand wipe and flush cleaning operationsAll hand wipe and flush cleaning operations Each spray gun cleaner, chemical milling maskant application operation, waste storage and handling operationEach spray gun cleaner, chemical milling maskant application operation, waste storage and handling operation Each primer, topcoat and depainting operation that emits organic HAP or VOCEach primer, topcoat and depainting operation that emits organic HAP or VOC Each spray booth or hangar that contains a primer, topcoat or depainting operation emitting inorganic HAPEach spray booth or hangar that contains a primer, topcoat or depainting operation emitting inorganic HAP

24 Not covered by the Aerospace NESHAP Applicability- Not Covered Electronic parts & assembliesElectronic parts & assemblies Quality control & Laboratory testingQuality control & Laboratory testing Composites processingComposites processing Chemical millingChemical milling Manufacture of aircraft transparenciesManufacture of aircraft transparencies Metal finishing and electroplating (electrodeposition of organic coatings is subject to the rule)Metal finishing and electroplating (electrodeposition of organic coatings is subject to the rule) Wastewater operationsWastewater operations Waste handling subject to RCRA, 40 CFR Waste handling subject to RCRA, 40 CFR

25 Aerospace NESHAP Exemptions Specialty coatings (listed in Appendix A) Sealants and adhesives Adhesive bonding primers Any coating, stripper or solvent containing less than 0.1% carcinogen or less than 1.0% non-carcinogen Facilities that use less than 50 gal/yr of each coating or maskant and less than 200 gal/yr for all coatings & maskants Parts and assemblies not critical to vehicle’s structural integrity or flight performance Activities associated with space vehicles (except for depainting) Rework of antique aerospace vehicles or components

26 NESHAP- General Provisions 63.9 Tests, Recordkeeping & Reporting Notifications to be sent to Regional Federal authority and Local (State) authorityNotifications to be sent to Regional Federal authority and Local (State) authority Initial aerospace notification (A/C or permit app) due 1 Sept 1998Initial aerospace notification (A/C or permit app) due 1 Sept 1998 followed by: Performance test, Continuous Monitoring System, Compliance statusfollowed by: Performance test, Continuous Monitoring System, Compliance status

27 Aerospace Cleaning MACT Applicability Exemptions Standards Tests, Recordkeeping & Reporting

28 NESHAP- Cleaning Operations (a) Applicability A major HAP source making or reworking commercial, civil or military vehicles or components and Hand-wipe clean : remove contaminants from an aerospace vehicle or component by rubbing with material moistened with a cleaning solvent Flush clean: passing solvent over, into or through the component

29 NESHAP- Cleaning Operations (a) Standards - Hand wipe compliance alternatives (a)* and (a)** compliance alternatives (a)* and (a)** use aqueous solvent (>80% H 2 O) or hydrocarbon solvent with a maximum vapor pressure of 7mm Hg at 20 o C and contains no HAPuse aqueous solvent (>80% H 2 O) or hydrocarbon solvent with a maximum vapor pressure of 7mm Hg at 20 o C and contains no HAP solvents containing HAP or VOC at concentrations less than 0.1% for carcinogens and 1.0% for non- carcinogens (63.741(f))solvents containing HAP or VOC at concentrations less than 0.1% for carcinogens and 1.0% for non- carcinogens (63.741(f)) no other requirements need be met (*) is an imaginary number not appearing in the federal document

30 NESHAP- Cleaning Operations Standards - Hand wipe Compliance alternatives (b)(2) and (b)(3) Use solutions that have a composite VP of < 45mm Hg at 20 o C (b)(2) orUse solutions that have a composite VP of < 45mm Hg at 20 o C (b)(2) or Demonstrate 60% volume reduction in use of hand wipe solvents over baseline (b)(3)Demonstrate 60% volume reduction in use of hand wipe solvents over baseline (b)(3) and...

31 NESHAP- Cleaning Operations Standards - hand wipe operations compliance alternative b place solvent laden wipes in bags or other closed containers immediately after useplace solvent laden wipes in bags or other closed containers immediately after use store fresh and spent solvent (except semi- aqueous) in closed containersstore fresh and spent solvent (except semi- aqueous) in closed containers minimize spills through proper handling and transferminimize spills through proper handling and transfer

32 7 cleaning solvent exemption level7 cleaning solvent exemption level 13Methyl-n-propyl ketone13Methyl-n-propyl ketone 18Water18Water 23Methyl-isopropyl ketone23Methyl-isopropyl ketone 43Ethanol43Ethanol 45cleaning solvent standard (b)(2)45cleaning solvent standard (b)(2) 80Methyl ethyl ketone (MEK)80Methyl ethyl ketone (MEK) 170Acetone170Acetone 300Methylene chloride (MC)300Methylene chloride (MC) Selected Vapor Pressures in mm Hg at 20 o C Terone

33 NESHAP- Cleaning Operations Standards - Gun cleaning (c) One of these approved techniques shall be used with HAP or VOC solvents enclosed system nonatomized cleaning disassembled gun atomized

34 NESHAP- Cleaning Operations Tests, Recordkeeping & Reporting Enclosed Systems (b)(1)(iii),(iv) Enclosed Systems (b)(1)(iii),(iv) Inspect seals on enclosed systems monthly. Repair leaks within 15 days ( or remove from service ). Record date leak found and date fixed.Inspect seals on enclosed systems monthly. Repair leaks within 15 days ( or remove from service ). Record date leak found and date fixed. Report semiannually when non-compliant gun cleaner is used and unrepaired leaks exceeding 15 days.Report semiannually when non-compliant gun cleaner is used and unrepaired leaks exceeding 15 days. No reporting requirements for all other cleaner types

35 NESHAP- Cleaning Operations Empty used solvent into a container that is kept closed when not in use does not apply to approved cleaning solvents (vapor pressure less than 7 mm Hg) No record keeping required. Standards- Flush cleaning (d)

36 NESHAP- Cleaning Operations Exempt operations hand wipe cleaning with solvents containing no HAP or VOC solvents containing HAP or VOC at concentrations less than 0.1% for carcinogens and 1.0% for non- carcinogens (63.741(f)) non Aerospace related cleaning activities

37 NESHAP- Cleaning Operations Exempt operations (e) breathing oxygen systemsbreathing oxygen systems assemblies exposed to strong oxidizers or reducersassemblies exposed to strong oxidizers or reducers preparatory to surface bondingpreparatory to surface bonding electronic parts & assemblieselectronic parts & assemblies solar cells, coated optics, and thermal control surfacessolar cells, coated optics, and thermal control surfaces textiles for interiorstextiles for interiors honeycomb cores, glass or polycarbonate transparencieshoneycomb cores, glass or polycarbonate transparencies cleaning with nonflammable liquids within 5 feet of live electrical systemscleaning with nonflammable liquids within 5 feet of live electrical systems operations covered by essential use waiveroperations covered by essential use waiver

38 NESHAP- Cleaning Operations Tests, Recordkeeping & Reporting Vapor Pressure Determination Vapor Pressure Determination single component solvents see MSDS, product data sheet or other reference blended solvents - calculate composite vp using manufacturer’s data and partial pressures per equation in (b)(2)

39 NESHAP- Cleaning Operations Tests, Recordkeeping & Reporting Name, Vapor Pressure, & organic HAP content of each solvent used For composition compliance,(a)* and (a)**, record calculations and annual consumption For vp compliance,(b)(2), record vp, calculations, test results, & monthly consumption at each operation For 60% reduction compliance, (b)(3), copy of approved alternative plan and all supporting documentation For exempt operations using non-complying solvents record monthly volumes by operation and keep a list of processes using exemption (b)(4) Maintain purchase records and MSDS for exempt coatings

40 NESHAP- Cleaning Operations Tests, Recordkeeping & Reporting Semi-annual For control options (a)*, (a)** and (b)(2) Compliant and Non-compliant cleaning solvent usageCompliant and Non-compliant cleaning solvent usage New cleaning solvents and vapor pressure or compositionNew cleaning solvents and vapor pressure or composition Compliance certification statementCompliance certification statement For option (b)(3) Demonstrate that the 60% reduction is equivalent to options (a) or (b)(2)Demonstrate that the 60% reduction is equivalent to options (a) or (b)(2)

41 NESHAP- Coating Operations Exempt coatings a) a) any coating, stripper or solvent containing less than 0.1% carcinogen or less than 1.0% non- carcinogen b) b) specialty coatings listed in Appendix A c) c) facilities that use less than 50 gal/yr of each coating or maskant and than less 200 gal/yr for all exempt coatings & maskants

42 Standards (organic spray operations) minimize spills during handling & transfer (b)minimize spills during handling & transfer (b) coatings must be applied with HVLP or electrostatic equipment which is operated within manufacturer’s specifications, or dip, flow, roll, brush, electrodeposition, (f)coatings must be applied with HVLP or electrostatic equipment which is operated within manufacturer’s specifications, or dip, flow, roll, brush, electrodeposition, (f) meet one of five compliance options (c), (c)(3), (d), (e)(2) or (i)meet one of five compliance options (c), (c)(3), (d), (e)(2) or (i) NESHAP- Coating Operations

43 Standards compliance option (c) (organic HAP w/o control device) HAP and VOC content limitsHAP and VOC content limits Primers 350g/l (2.9#/gal) Topcoats 420g/l (3.5#/gal) Type I Maskants 622g/l (5.2#/gal) Type II Maskants 160g/l (1.3#/gal) or

44 NESHAP- Coating Operations Standards (c)(3 ) (i) compliance option (c)(3 ) (low HAP primer) HAP and VOC content limits ( grams per liter and equivalent (pounds per gallon), less water ) Primers 250g/l (2.1#/gal) This option allows reduced recordkeeping and reporting. There is no “standard” requiring this limit.

45 NESHAP- Coating Operations Standards compliance option (d) organic HAP with a control device add on controls with an overall efficiency of 81% (95% for new maskant systems) –Overall efficiency = capture efficiency X control efficiency

46 NESHAP- Coating Operations Standards compliance option (e)(2) (Averaging) Use any combination of coatings to achieve equivalency with option (d) Averaging of primers with topcoats is not allowed. Averaging plan must be preapproved

47 NESHAP- Coating Operations Standards compliance option (i) Waterborne Coatings Maintain for 5 years manufacturer’s data and purchase records showing coating contains more than 5 % water by weight and VOC in compliance with option (c)Maintain for 5 years manufacturer’s data and purchase records showing coating contains more than 5 % water by weight and VOC in compliance with option (c) Must still use high transfer efficiency application (HVLP, electrostatic, hand paint)Must still use high transfer efficiency application (HVLP, electrostatic, hand paint) These coatings may be averaged for option (d)

48 NESHAP- Coating Operations Exempt operations R and D, Quality control, and laboratory testing airbrush, spray cans, touch up (art and repair) antique vehicles

49 NESHAP- Coating Operations Standards (Inorganic HAP) (g) Must be applied in a booth or hangar with: one of the following five compliance options (i)(A), (i)(B), (ii), (iii)(A), or (iii)(B).one of the following five compliance options (i)(A), (i)(B), (ii), (iii)(A), or (iii)(B).

50 NESHAP- CoatingOperations NESHAP- Coating Operations Standards (g)(2) I norganic HAP option (i)(A) for existing sources:option (i)(A) for existing sources: two stage particulate filter certified by method 319 of Appendix A or option (i)(B) water washoption (i)(B) water wash option (ii)(A) New booths are held to a higher standard, requiring a 3 stage filter.option (ii)(A) New booths are held to a higher standard, requiring a 3 stage filter.

51 Standards (g)(2) I norganic HAP option (iii)(A) for sources built betweenoption (iii)(A) for sources built between 6 June 94 and 29 Oct 96 and not spraying 6 June 94 and 29 Oct 96 and not spraying coatings containing Chromium or Cadmium coatings containing Chromium or Cadmium only 2 stage or water wash is required. only 2 stage or water wash is required. option (iii)(B) Sources built before 29 Oct 96option (iii)(B) Sources built before 29 Oct 96 and applying Chromium or Cadmium must and applying Chromium or Cadmium must use a three stage filter or a HEPA filter. use a three stage filter or a HEPA filter. NESHAP- Coating Operations

52 Monitoring Inorganic HAP (g)(2)&(3) Standards - Monitoring Inorganic HAP (g)(2)&(3) Maintain filtration system in good working orderMaintain filtration system in good working order Install gauge for continuous monitoring of pressure drop across the filter or water flow rateInstall gauge for continuous monitoring of pressure drop across the filter or water flow rate Immediately correct any pressure drop or water flow rate excursions beyond limits in owner’s manualImmediately correct any pressure drop or water flow rate excursions beyond limits in owner’s manual

53 Tests, Recordkeeping & Reporting 63.10(b)(1) Records will be retained for five years, (two years on site). NESHAP- Coating Operations

54 Tests, Recordkeeping & Reporting option (d)option (d) – start up control efficiency test –carbon adsorber start up test to establish rolling material balance period –control other than carbon will be tested in 3 one hour runs NESHAP- Coating Operations

55 Tests, Recordkeeping & Reporting control option (d) Filter systems must have pressure gauges. Pressure drop is to be monitored continuously and recorded once per shift.Filter systems must have pressure gauges. Pressure drop is to be monitored continuously and recorded once per shift. Waterwash systems must monitor water flow continuously and record once per shift when used.Waterwash systems must monitor water flow continuously and record once per shift when used. Incinerators must have temperature sensors with continuous recorders.Incinerators must have temperature sensors with continuous recorders.

56 NESHAP- Coating Operations Tests, Recordkeeping & Reporting VOC content & monthly volume of use of coatings option (d) booth pressure drop across filter or water flow rate as recorded once per shift incinerator efficiency & temperature carbon bed efficiency, rolling period & calculations Start up, shutdown, malfunction plan option (i) Manufacturer’s data on water content and annual purchase records

57 NESHAP- Coating Operations Tests, Recordkeeping & Reporting (c) Semi-annual AllAll – new coatings or control device –compliance certification (No further reporting for option (i)) Option dOption d –control device out of compliance –periods when filter pressure drop or water flow was outside of acceptable range and process was not immediately shut down Options (c), (c)(3), (e)(2)Options (c), (c)(3), (e)(2) –Submit data for calculations in (c)(2)(i) when complying by averaging or other mathematical method –HAP/VOC content limit exceedance Annual (option d) number of times the pressure drop or water flow rate was outside of acceptable rangenumber of times the pressure drop or water flow rate was outside of acceptable range

58 Aerospace Depainting MACT Applicability Exemptions Standards Tests, Recordkeeping & Reporting

59 NESHAP- Depainting Operations Applicability A major HAP source making or reworking commercial, civil or military vehicles or components Outer surface of aerospace vehicles fuselage, wings and stabilizers are always covered

60 NESHAP- Depainting Operations Exempt operations facilities that depaint 6 or fewer vehicles per year radomes parts and units normally removed from requirements of “enclosed area” and control system [746 (b)(1)]mechanical and hand sanding exempt from requirements of “enclosed area” and control system [746 (b)(1)]

61 NESHAP- Depainting Operations no organic HAP shall be emitted for chemical stripping formulations or chemical paint softeners (b)(1) Standards Option (b) (1) (Organic HAP)

62 NESHAP- Depainting Operations Standards Option (b)(2) (inorganic HAP) When dry media blasting (not including hand sanding and mechanical sanding) generates airborne inorganic HAP, the user shall:When dry media blasting (not including hand sanding and mechanical sanding) generates airborne inorganic HAP, the user shall: –blast in an enclosed area –use dry filter or waterwash control system as appropriate for existing sources. – For new source control requirements see “primer & topcoat operations” [745(g)(2)(ii)].

63 Stage 1 Stage 2 Stage 3 3 Stage Particulate filters

64 NESHAP- Depainting Operations Standards Option (c) organic HAP When using organic HAP strippersWhen using organic HAP strippers –existing sources shall achieve 81% –New sources shall achieve 95% control, either by control device alone or through a combination of control device and reduced stripper usage below baseline (baseline is `96-`97 usage per aircraft or per sq ft)

65 NESHAP- Depainting Operations Standards (organic HAP) In addition to limits for Options (b)1, (b)2 and (c) Use of organic HAP materials for spot stripping or decal removal is limited to :Use of organic HAP materials for spot stripping or decal removal is limited to : –190 lbs (26 gal.) per aircraft per year for commercial aircraft –365 lbs. (50 gal.) per aircraft per year for military aircraft

66 NESHAP- Depainting Operations Exempt operations During periods of malfunction, source may substitute materials chosen to minimize HAP emissions - The HAP containing substitute may not be used for more than 15 days per year.During periods of malfunction, source may substitute materials chosen to minimize HAP emissions - The HAP containing substitute may not be used for more than 15 days per year.

67 NESHAP- Depainting Operations Tests, Recordkeeping & Reporting Initial performance test required for control devices to verify compliance with efficiency requirementsInitial performance test required for control devices to verify compliance with efficiency requirements For spot stripping and decal removal, calculate organic HAP use once per calendar yearFor spot stripping and decal removal, calculate organic HAP use once per calendar year.

68 NESHAP- Depainting Operations Tests, Recordkeeping & Reporting Filter system pressure drop to be read and recorded once per shift For waterwash systems, record water flow rate once per shift

69 NESHAP- Depainting Operations Tests, Recordkeeping & Reporting Name & monthly usage of organic HAP used in chemicalName & monthly usage of organic HAP used in chemical Efficiency, rolling period (for carbon adsorbers) & supporting calculations/documentation control deviceEfficiency, rolling period (for carbon adsorbers) & supporting calculations/documentation control device List of parts/units normally removed for depaintList of parts/units normally removed for depaint For non-chemical stripping record malfunctions and date, cause and alternative used For non-chemical stripping record malfunctions and date, cause and alternative used Pressure drop or water flow once per shiftPressure drop or water flow once per shift For spot stripping, annual quantity & mass per aircraftFor spot stripping, annual quantity & mass per aircraft

70 NESHAP- Depainting Operations Tests, Recordkeeping & Reporting Semi-annual 24 hour periods when organic HAP emitted in violation New & reformulated chemical strippers with HAP contentNew & reformulated chemical strippers with HAP content New non-chemical techniquesNew non-chemical techniques Upset/Breakdown of non-chemical technique Including date, cause and depaint alternative used, date of correction of malfunctionUpset/Breakdown of non-chemical technique Including date, cause and depaint alternative used, date of correction of malfunction

71 NESHAP- Depainting Operations Tests, Recordkeeping & Reporting Semi-annual, (con’t) periods when filter pressure drop or water flow was outside of acceptable range and process was not immediately shut down periods when filter pressure drop or water flow was outside of acceptable range and process was not immediately shut down List of new/discontinued aircraft models & parts normally removed for depainting List of new/discontinued aircraft models & parts normally removed for depainting Organic HAP control device exceedanceOrganic HAP control device exceedance Compliance certification statement Compliance certification statement

72 NESHAP- Depainting Operations Tests, Recordkeeping & Reporting Annual Exceedance of average annual HAP limits for spot stripping and decal removal Number of times the pressure drop or water flow rate was outside the acceptable limits


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