EPA targets aerospace segment

The Environmental Protection Agency (EPA) proposed in February to tighten up air emission standards for aerospace manufacturing and fabrication facilities.

The agency said it initially surveyed 1,300 facilities nationwide that potentially could emit hazardous air pollutants (HAPs); all of these facilities fall into a category the agency designates as "aerospace manufacturing and rework facilities." But the proposed rule estimated only 144 facilities would be subject to the rule, when it is finalized.

The proposed amendments would, for the first time, add limitations on emissions of organic and inorganic HAPs from specialty coating application operations. That is the big initiative here. Facilities that cannot meet whatever new specialty coating standards the agency finalizes probably would have to install high-efficiency application equipment.

The proposal also would remove the exemptions from the emission limitations operations already covered. This includes finishing activities such as topcoating and priming during the periods of start-up, shutdown, and malfunction (SSM). This move results in the affected units being subject to the emission standards at all times. The proposal also would revise provisions to address recordkeeping and reporting requirements applicable to periods of SSM.

The other somewhat significant initiative in the proposed rule applies to all aerospace coatings operations already covered under this aerospace/rework air rule. This entails all primers, topcoats, specialty coatings, and chemical milling maskants.

The agency would allow facilities to use an alternative compliance demonstration to prove their volatile organic chemical (VOC) emissions are below the aerospace/rework limits. That will allow them to avoid using EPA Method 24, which costs more than $500 per sample, according to published vendor data. The EPA estimates the average cost of these amendments per facility (the 144 ostensibly covered), including any new equipment for specialty coating operations, is less than $10,000 per year.