For more than 20 years, Trinity Consultants has assisted facilities in the aerospace industry with regulatory compliance and environmental management issues. Our experience conducting over 400 projects for airlines and aerospace manufacturing and completions facilities give us the expertise to assist your facility with its environmental compliance needs.
Regulatory Round Up
Aerospace MACT: Proposed Amendments
On February 17, 2015, the United States Environmental Protection Agency (EPA) published in the Federal Register the proposed amendments to the Aerospace Maximum Achievable Control Technology (MACT) found in 40 CFR Part 63, Subpart GG based on its Risk and Technology Review (RTR). The Federal Register notice can be found at here.
Section 112(f)(2) of the Clean Air Act (CAA) requires the EPA to perform an RTR every eight years for any industry subject to MACT standards. Furthermore, Section 112(d)(6) of the CAA requires the EPA to review and revise the MACT standards to account for new developments in practices, processes, and control technologies associated with these industries. The review and associated revisions account for any residual health risks remaining after the application of current MACT standards. The proposed amendments to MACT GG potentially affect major sources of hazardous air pollutants (HAPs) and synthetic minor source installations that are owned or operated by the Armed Forces of the U.S. (including Department of Defense and the Coast Guard) and the National Aeronautics and Space Administration.
The amendments include the following changes:
- Set new organic HAP content limits for specialty coatings
- Limit emissions of inorganic HAP from spray-applied specialty coatings that contain inorganic HAP
- Eliminate start-up, shutdown, and malfunction (SSM) exemption provisions
- Add an alternative compliance demonstration provision for all types of coating application operations
Once the final rule is published in the Federal Register, affected sites must be in compliance based on the schedule:
- All amendments are effective 60 days after publication of the final rule with one exception
- Exception – existing specialty coating affected sources (i.e., existing on the date the changes are final) would have one (1) year after the date the rule is final to comply with the standards for specialty coatings
EPA is seeking comments from the regulated community on the proposed rule. All comments must be received by April 3, 2015 so there is not much time for industry to respond. In response to these proposed amendments, Trinity will be holding luncheons in Seattle, Washington and Dallas, Texas, on March 17, 2015. These events will help industry understand the impacts of the proposed changes, and help environmental and regulatory professionals quickly respond during the brief comment period. Instructors have been actively involved with the aerospace industry, including assisting with the response to the Section 114 information requests that are the basis of this RTR.
For more information on these events, or if you are interested in having an event in your area, please contact Ms. Jenna Parenton (Dallas, TX) by email at jparenton@trinityconsultants or by phone at (972) 661-8100 or Ms. Linda Nguyen (Seattle, WA) by email at firstname.lastname@example.org or by phone at (253) 867-5600).
Other Potentially Applicable NESHAPs
Beyond NESHAP GG, there are several Maximum Achievable Control Technology (MACT) standards (40 CFR 63) that may affect sources in the aerospace industry as bulleted below:
- Miscellaneous Metal Parts MACT (Subpart MMMM) applies to entities that own or operate a miscellaneous metal parts and products surface coating facility that uses at least 250 gallons of coating materials per year and is a major source of HAPs or is located at a major source.
- Plastic Parts & Products MACT (Subpart PPPP) affects all entities that own or operate a plastic parts and products surface coating facility that is a major source or is located at a major source.
- Paint Stripping and Miscellaneous Surface Coating Operations MACT (Subpart HHHHHH) applies to area sources involved in paint stripping operations which use chemical strippers that contain methylene chloride; autobody refinishing operations that encompass motor vehicle and mobile equipment spray-applied surface coating operations; and spray application of coatings containing target HAP compounds (chromium, lead, manganese, nickel or cadmium) to any part or product made of metal or plastic, or combinations of metal and plastic that are not motor vehicles or mobile equipment.
- Chromium Electroplating and Anodizing MACT (Subpart N) applies to all facilities that use chromium electroplating or anodizing tanks, regardless of size.
- Boiler MACTs for Area Sources (Subpart JJJJJJJ) and Major Sources (Subpart DDDDD) were recently issued on February 1, 2013 and January 31, 2013, respectively, which may potentially have a large impact on liquid and solid-fuel boilers operating at aerospace facilities.
- Stationary Reciprocating Internal Combustion Engine MACT (Subpart ZZZZ) affects engines of all sizes located at both area and major sources.
- Halogenated Solvent Cleaning MACT (Subpart T) applies to solvent cleaning machines which use halogenated HAP solvents in a total concentration greater than 5 percent by weight as a cleaning and/or drying agent.
- During a long-standing relationship with a major aerospace manufacturing facility, Trinity has performed the following past and on-going projects:
- Supported long-term on-site assignments for a variety of environmental needs
- Created an initial facility-wide air emission unit inventory consisting of approximately 1,500 individual units
- Conducted a facility review to determine if any chemicals on-site were above thresholds that would require a Risk Management Plan (RMP)
- Provided on-site support for training of hourly employees in preparation for Aerospace NESHAP and other environmental regulations
- Prepared state construction permits for various facility expansion projects
- Created custom compliance tools for both the annual emission inventory and recordkeeping associated with the Aerospace NESHAP
- Prepared an air dispersion model in anticipation of future need for PSD permitting
- Prepared an initial Title V application including determination of applicability of Compliance Assurance Monitoring (CAM) and submittal of CAM plans
- Conducted several compliance audits focusing on various environmental issues
- For a major airline, Trinity performed an emission inventory and compliance assessment for one of its aircraft maintenance facilities, evaluating applicability of the Aerospace NESHAP, Title V permitting, and state construction permitting requirements. Trinity personnel performed a one-day site visit to gather data and review the operations. Based on this data, Trinity calculated the potential emissions of regulated air pollutants for the facility then compared the potential emissions to the appropriate thresholds for the regulations of interest in order to document their applicability.
- For an aircraft maintenance facility, Trinity provided assistance in responding to a Notice of Violation related to compliance with the Aerospace NESHAP and participated in direct communication with the regulatory agency. Trinity personnel also provided assistance in creating data management tools to assist in documenting future compliance.
- For an aerospace completion and refurbishment facility, Trinity prepared an application for renewal of the facility’s Title V operating permit, evaluating applicability of various local, state, and federal regulations. Trinity also assisted in negotiating changes to the current operating permit to allow increased operational flexibility and reduced recordkeeping requirements for the facility.
- For an aircraft assembly facility, Trinity prepared an annual emission inventory and conducted a facility review to determine which chemicals on-site were subject to EPCRA Tier II reporting.