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Rule and Implementation Information for the Aerospace Industry

(Docket#A-92-20)

Announcements:

On February 3, 2011, the Office of Management and Budget approved the Section 114 Information Collection Request for the aerospace manufacturing and rework industry. The due date for the response is April 4, 2011; please see the Risk and Technology Review section of this webpage for additional information on this data collection effort.

Program Contact

Kim Teal
919-541-5580
teal.kim@epa.gov

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Rule Information

Proposed and Promulgated Rules

Subpart GG - National Emission Standards for Aerospace Manufacturing and Rework Facilities

Date Citation Action Description File Download
06/06/94 59 FR 29216 Proposed Rules Original Proposal incl. Method 309 [TTN file] (WPD format)
08/01/94 59 FR 38949 Proposed Rules Public Hearing & Comment Period Extension not available
11/22/94 59 FR 60101 Proposed Rules Reopening of Public Comment Period for Exterior Commercial Primers, New Coating, Milling Maskant -Type I Etchants, Control Device Capture, Recordkeeping for Low Organic HAP and VOC Primer, Depainting Small Aircraft, Depainting With HAPs, and Mhod 309  [TTN file] (WPD format)
09/01/95 60 FR 45956 Rules/Regulations Original Promulgation w/o Method 309  
02/09/96 61 FR 4903 Rules/Regulations Correction to Initial Notification Date  
10/29/96 61 FR 55842 Proposed Rules Corrections and Clarifications for References, Definitions, Cleaning, Space Vehicles, Type I Maskants,Topcoat and Primer Application and Depainting, Water-Reducible Coatings,Cleaning Solvents, Compliance Dates, Spray Booth, Monitoring, and Specialty Coatings, and New Filtration Efficiency Method 319  
12/17/96 61 FR 66227 Rules/Regulations Correction to 02/09/96 Correction  
3/10/98 N/A Rules/Regulations Amendments to Final Rule, Red-line/ Strike-out version[TTN File - not published in FR]    (WPD format)
3/27/98 63 FR 15038 Proposed Rules General Aviation Definitions, Primer and Topcoat Standards, FAA Regulations, Hand-Wipe Cleaning, Automated Spray Equipment Nozzle Tips, Pumpless Waterwash System Monitoring, & Charged Media Certification With Method 319  
3/27/98 63 FR 15016 Rules/Regulations Final Rule and Release of Final Control Technique Guideline (CTG) Document. Corrections, Clarifications and Additions for References, Definitions, Cleaning, Space Vehicles, Type I Maskants, New Filtration Efficiency Method 319, Topcoat and Primer Application and Depainting, Water-Reducible Coatings, Hand-Held Spray Cans, Cleaning Solvents, Compliance Dates, Spray Booths, Emissions Averaging, Monitoring, Depainting, Subpart A Cross Reference Table, and Specialty Coating Definitions  
9/1/98 63 FR 46525 Rules/Regulations Amendments to Final Rule. New definitions for general aviation and general aviation rework facility, separate coating limits for primers and topcoats used at general aviation rework facilities, and additional changes resulting from public comments on previously proposed (October 29, 1996) amendments to the final rule.  
1/24/00 65 FR 3642 Proposed Rules Proposal is to include a separate emission standard for exterior primers used for large commercial aircraft components (parts or assemblies) or fully assembled large commercial aircraft at existing facilities.  
12/08/00 65 FR 76941 Final Rule Final amendments for the standards to include a separate emission limit for exterior primers used for large commercial aircraft at existing facilities that produce fully assembled, large commercial aircraft

NOTE:All files are Government Printing Office (GPO) files unless otherwise indicated.

Closely Related Rules, Policies or Program Guidance

12/97 Aerospace Manufacturing and Rework Operations CTG (EPA-453/R-97-004)
12/97 Figure 319-1, Schematic Illustration of the Fractional Efficiency Test Rig

Risk and Technology Review

Data Gathering

The following file provides facility-wide emission rates for each of the identified major and synthetic area or synthetic minor sources that submitted data in response to the 2011 data collection survey. EPA took total HAP emissions divided by total gallons of solids from all the material reported at each facility which provided us with lb HAP/gal solids. One approach to addressing all the emission points at aerospace sources is to pursue a facility-wide emission limit similar to what was done previously with Miscellaneous Metal Parts and Products (PDF) (63pp, 413k) or Plastic Parts and Products (PDF) (55pp, 406k). This approach provided flexibility to each facility in those source categories that aerospace facilities may or may not feel necessary.

5/23/13 Aerospace Facility-Specific Emission Rates

PLEASE READ:  For facilities identified as “Synthetic Area” in the attached file; please confirm your source’s status as such by reviewing the information provided at the bottom of the spreadsheet in the notes. You may then send an electronic mail message to Kim Teal at teal.kim@epa.gov confirming or revising your status.  These responses will determine which sources are to be modeled for the risk and technology review currently underway. If we receive no response, we will leave the facility in and plan to model their emissions.

 

The following Section 114 Information Collection Request (ICR) has been approved by OMB and is being sent to aerospace manufacturing and rework facilities, that are Major or Synthetic Minor sources of hazardous air pollutants (HAP), in the U.S . The due date for the response is April 4, 2011; if you have questions or concerns regarding this data collection please contact Kim Teal at teal.kim@epa.gov. To provide sources the greatest amount of time possible for responding to the survey we are posting the ICR and instructions below; however, the following forms are intended for hard copy submittal only. If sources prefer to submit their information electronically, they may use the following file transfer protocol (FTP) site:

http://www.cleanairinfo.com/aerospace/

2/4/11 Aerospace ICR Instructions
2/4/11 Aerospace Survey Print Version
2/8/11 Aerospace ICR Mailing List

Electronic Components

We have received many questions regarding the definition of electronic components for the purposes of completing the information collection request (ICR) for the aerospace source category. The aerospace rule provided an exemption for electronic components but it did not provide a definition or guidance for "electronic component". Therefore, I suggest that facilities use their best judgment on what constitutes an electronic component. If you have a solid justification, that any reasonable person would accept, for the part or component being an electronic component then please do not report the activities associated with that part or component on the ICR. However, if you question whether or not it would be considered an electronic component then you should report the activities associated with that part or component.

Extension Requests

We have received numerous extension requests to the submission deadline for the Information Collection Request (ICR) for Aerospace Manufacturing and Rework. I have received approval from my management to provide the following relief for submission of data.

  • April 4, 2011 Major sources must supply only the coating data specific to RTR (i.e., those coatings for which the Aerospace NESHAP provides specific emission limits) modeling needs (see table,Aerospace ICR April 4 2011 data requirements)
  • May 4, 2011 Major and Synthetic Minor sources must supply all remaining data on the ICR

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Technical Information

Background Information Document (BID)/Response to comments

4/94 Aerospace BID for Proposed Standards, Preliminary Draft (Chapters 1-6) (WPD format)
4/94 Aerospace BID for Proposed Standards, Preliminary Draft (Chapters 7-9) (WPD format)
7/95 Aerospace BID for Promulgated Standards (WPD format)
1/98 Aerospace BID for Promulgated Standards, Addendum
7/98 Aerospace BID for Promulgated Standards, Addendum

Questions and Answers

3/01 Q&A - What is the definition of "closed container" in the cleaning provisions. Note: Q&A was previously identified as question #38 in the combined workshop and implementation Q&A document of 10/98.
1/01 Q&A - Aerospace questions (4) dealing with aircraft washing, flush cleaning, composition data, and Method 24.
7/99 Q&A - Are aerosol cans subject to Subpart GG Cleaning Requirements?
6/99 Q&A - Are aircraft evacuation systems subject to Subpart GG and 112(j)?
4/99 Q&A - Do I have to submit a NOCS if I don't perform a performance test?
3/99 Q&A - From STAPPA/ALAPCO to OAQPS. Aerospace questions (4) dealing with maskants, carcinogens/noncarcinogens, solvent recovery devices and rolling averages.
10/98 Combined Q&A's from implementation document and August workshops (files combined to provide a more user-friendly document). NOTE: Question #38 removed 3/01 and placed in separate Q&A document; clarifications to Question #109 made 10/9/01.
10/98 Q&A - Does subpart GG apply to maintenance and repair facilities?
10/98 Q&A - Is maintenance touch-up painting covered under 63.745?

FACT Sheets

7/95 FACT SHEET - Technical - Final Rule
7/96 FACT SHEET - Technical - Draft Control Technique Guidelines and Proposed Amendments

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Implementation Information

Implementation Tools

4/29/04 Final Report - Evaluation of the Effectiveness of the Implementation Tools for the Aerospace NESHAP

NOTICE:  EPA's Subpart GG Implementation Document has been modified to reflect the final amendments published 12/8/00 and other minor typo corrections. Changes are highlighted and have been made to the following pages: i, ii, 3, 4, 7, 11, 17, 22, 27, 34, 36, 39, and 75.

1/01 (update) National Emission Standards for Aerospace Manufacturing and Rework Facilities:  Summary of Requirements for Implementing the NESHAP [Includes the 3/98 through the 12/00 final amendments and corrections to errors found through 12/29/00] (EPA-456/R-97-006)     
3/98 Brochure: New Regulations Controlling Air Emissions for Aerospace Manufacturing and Rework Facilities 40 CFR 63, Subpart GG [Includes the 3/98 final amendments]

Source Identification and Location Information

Source list file currently unavailable for download

Example Notices and Reports

Aerospace NESHAP Reporting Requirements from Naval Facilities Engineering Service Center (2/12/01 version). NOTE: This document is not sanctioned, nor has it been checked for accuracy, by the EPA. It is being provided for FYI only.
Initial Notification [with example responses]
Notification of Compliance Status [with example responses]     
Semiannual/Annual Notification Report [with and without example responses, two files zipped]. Updated 1/4/01 to reflect the 2/8/00 final amendments. All files are zipped.     
Note: To use all the functions of the Semiannual/Annual Report in the PDF version, you'll need Adobe Acrobat V4 with Exchange. Adobe Acrobat Exchange allows you to save any data that you enter onto the PDF form. We are in the process of working with NTIS to make the PDF form bundled with Adobe Acrobat Exchange available on CD-ROM for a minimal cost. As soon as additional information is available we'll post it here.

Outreach and Training Materials

Note: The following files contain materials that were presented at the EPA Aerospace Training Workshop in CA (Aug 19-20, 1998), CT (Aug 4, 1998), FL (Aug 6-7, 1998), KS (Aug 13, 1998) and WA (Aug 18, 1998).    Example recordkeeping forms are provided as examples only and are not required forms.
Aerospace NESHAP Background, overview, CTG, P2 Overview
Aerospace NESHAP Example Calculations
Example Compliance Options Checklist
Example #1 - Hand Wipe Cleaning Recordkeeping Form (includes example and blank form)
Example #2 - Enclosed Spray Gun Cleaning Recordkeeping Form (includes example and blank form)
Example #3 - Flush Cleaning Recordkeeping Form (includes example and blank form)
Example #4(a) - Primer and Topcoat Recordkeeping Form (includes example and blank form)
Example #5 - Paint/Depaint Booth: Pressure Drop/Water Flow Recordkeeping Form (includes example and blank form)
Example #6 - Chemical Stripping Recordkeeping Form (includes example and blank form)
Example #7 - Non-Chemical Paint Removal Recordkeeping Form (includes example and blank form)

 

Compliance and Enforcement Information

10/15/98 EPA Region 10 Memo  -  Preval Spray Units Applicability
11/19/98 EPA Region 10 Memo  -  Aircraft interior parts (e.g. stowbins, interior doors, doorway liners, flight deck liners) applicability to the Aerospace NESHAP
Applicability Determination Index (ADI).  The ADI is maintained by EPA's Office of Enforcement and Compliance Assurance (OECA) and provides a data base of memoranda dealing with applicability issues.  The database is searchable by Subpart.
Aerospace Sector Notebook.  Sector notebooks are developed by EPA's Office of Enforcement and Compliance Assurance (OECA)and contain multimedia information (air, water, and land pollutant release data) for a specific industry.
Air Transportation Compliance Assistance Center. The center is maintained by EPA's Office of Enforcement and Compliance Assurance (OECA) and provides multimedia information for the air transportation industry.

State Programs

The Environmental Council of the States. Exit EPA disclaimer The website provides state delegation information for environmental programs. To view delegation information for a specific state or for a specific program, go to http://www.sso.org. Exit EPA disclaimer To see delegation information for the Clean Air Act specifically, go to Exit EPA disclaimer http://www.sso.org/ecos/states/statutes/caa.htm.
Georgia Department of Natural Resources (DNR) Pollution Prevention Publications Page. Exit EPA disclaimer Website contains links to P2 publications available for a variety of topics, including Aerospace. Aerospace information includes: (1) P2 tips for Aerospace include: "Blast Room Construction," "Blast Media Alternatives," "Powder Coatings," and "A Primer on Waterborne Coatings." (2) Articles on Aerospace include: "Basics of Spray Painting." (3) Pollution Prevention Case Studies on Aerospace include: "Substitution of a Water-Based Topcoat for a Solvent-Based Topcoat at Geiger Brickel," and "Solvent Elimination at Lockheed Martin Aeronautical Systems."

Other

10/5/10 updated Manufacturers of Paint Arrestors Certified by Method 319  
7/98 Joint EPA/NASA/USAF Interagency Depainting Study, Sixth Progress Report
Coating Alternatives Guide (CAGE). CAGE is a pollution prevention tool which provides information on low-emitting alternative coating technologies to coatings users. CAGE currently addresses alternative, low-emitting coatings for metal and plastic part coating operations, but, future versions will address alternative coatings for wood, and other substrates.
Paints and Coatings Resource Center (PCRC). EPA's Office of Enforcement and Compliance Assurance (OECA) has created several compliance assistance centers for the coating industry.  Free membership to the PCRC can be obtained on-line.  The PCRC provides regulatory compliance and pollution prevention information topcoating facilities, industry vendors and suppliers, federal, state and local agencies, academia, and other interested parties. The site does contain information on the aerospace industry.  To find aerospace related information, go to "Technical Database", "Search by Keyword" then enter "aerospace".
National Metal Finishing Resource Center (NMFRC). EPA's Office of Enforcement and Compliance Assurance (OECA) has created several compliance assistance centers for the coating industry.  Free membership to the NMFRC can be obtained on-line.  Although the NMFRC is geared primarily toward the metal finishing industry, the site does contain information on the aerospace industry.  To find aerospace related information, go to "Members", "Technical Database", "Search by Keyword" then enter "aerospace".
Other Compliance Assistance Centers.EPA's Office of Enforcement and Compliance Assurance (OECA) has created several compliance assistance centers in addition to PCRC and NMFRC which may be valuable to industry in obtaining regulatory and compliance information. This link goes to the main compliance assistance center webpage which lists all centers currently available with a brief description of what type of information the center provides.
Aerospace Industries Association (AIA).   Exit EPA disclaimerAIA is a trade association representing manufacturers of commercial, military, and business aircraft, helicopters, aircraft engines, missiles, spacecraft, and related components and equipment.  Environmental related information is available at the site.

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