National Emission Standards for Aerospace Manufacturing and Rework Facilities

130 Pages·2000·0.29 MB·English

United States Office of Air Quality EPA-456/R-97-006
Environmental Protection Planning and Standards January 2001 (Update)
Agency Research Triangle Park, NC 27711
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
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)
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).
Content
Page
1.0 Purpose of the document 1
2.0 Summary of the rule 3
Compliance Timeline
4
Regulatory Overview
5 Rule Applicability
6
Cleaning Operations
7
Primer and Topcoat Operations (Organic HAP and VOC) 16
Primer and Topcoat Operations (Inorganic HAP and VOC) 23
Depainting 28
37
Chemical Milling Maskant
3.0 Applicability flow charts 43
4.0 Inspection procedures 50
5.0 Inspection checklists 56
Rule Applicability
57
Cleaning Operations
61
Primer and Topcoat Operations (Organic & Inorganic HAP and VOC) 73
Depainti
ng
82
89
Chemical Milling Maskant
6.0 Other implementation materials 94
7.0 Example calculations 96
8.0 List of cleaning solvent substitutions 102
105
Appendix A. Glossary
111
Appendix B. Example initial notification form
Appendix C. General Provisions applicability to Subpart GG 115
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
6/6/94
Regulatory Activity: Rule Proposal
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 Amendments/Release of Final CTG 3/27/98 [63 FR 15006]
Final Amendments 9/1/98 [63 FR 46525]
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:
C all hand-wipe cleaning operations
C each spray gun cleaning operation (by that we mean each spray gun cleaning operation is a
separate affected source)
C all flush cleaning operations
C for organic HAP or VOC emissions, each primer application operation (which is the total of
all primer applications at a facility)
C for organic HAP or VOC emissions, each topcoat application operation (which is the total of
all topcoat applications at a facility)
C for organic HAP or VOC emissions, each depainting operation (which is the total of all
depainting at a facility)
C each chemical milling maskant application operation (which is the total of all such
applications at a facility)
C each waste storage and handling operation (which is the total of all such operations at a
facility)
C 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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