Aerospace Environmental Compliance

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 Environmental Compliance

Aerospace MACT: Final Amendments

On December 7, 2015, the U.S. Environmental Protection Agency (EPA) published in the Federal Register the final version of the 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.

The final rule is largely unchanged from the February 2015 proposed amendments.  The major changes associated with the rule are as follows:

  • Establish hazardous air pollutants (HAP) and Volatile Organic Compound (VOC) emission limits for specialty coating application operations.
  • Simplify recordkeeping and reporting requirements for compliant coatings.
  • Remove startup, shutdown and malfunction exemptions, so that affected sources are subject to emission standards at all times.

There are a few noteworthy changes in the final rule compared to the proposed rule as a result of comments, additional technical review, information collection requests, and EPA’s subsequent responses.  These changes include, but are not limited to, the following:

  • Added option for recordkeeping requirements when using coating manufacturer’s supplied data:  Sites can demonstrate compliance with the organic HAP limit using manufacture’s data and can now add non-HAP solvent to those coatings as long as records of the non-HAP solvent are kept;
  • Clarification of the averaging option for compliance:  The averaging of HAP content is not allowable between specialty coating groups or other major coating groups, such as topcoats and primers;
  • Revision of recordkeeping requirements:  Monthly usage records are only required if the averaging option is used for compliance.  Otherwise, a record of annual consumption of each coating is sufficient;
  • Clarification of specialty coating application methods for spray coatings:  Application techniques now include airless spray, air-assisted airless spray, and any other coating applications that meet the transfer efficiency equivalent to or better than the application methods listed.  Definitions of application techniques were also updated for clarification;
  • Addition of exemptions:  New exemptions were added for the specialty coating spray application equipment requirements;
  • Clarification of compliance demonstration for coatings:  Language was added clarifying  when the coating organic HAP content or VOC content can be used to demonstrate compliance versus when the HAP content must be used;
  • Clarification of inorganic HAP control requirements:  An option to install an interlock system that will automatically shut down a coating operation if out of manufacturer ranges was added for sites demonstrating compliance with inorganic HAP control requirements using a conventional waterwash or pumpless system;
  • Clarification of waste storage and handling requirements:  The exemption that waste subject to the Resource Conservation and Recovery Act (RCRA) of 1976 are not subject to MACT GG was removed.  Language was added to 63.744(a) Housekeeping measures regarding the exemption of spent cleaning solvents and solvent-laden applicators if the materials are handled and stored in compliance with 40 CFR parts 262 through 268; and
  • Revision of the compliance date requirement for existing sites:  Sites that are in existence prior to February 17, 2015, shall now have three years from December 7, 2015 (effective date of rule) to come into compliance versus the previously proposed 1-year.

For more details regarding specific changes in the final rule or for a site-specific compliance determination, including action items necessary for the site, please contact us at (800) 229-6655.

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.

Project Profiles

  • 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.
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