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NESHAP for the Aerospace Manufacturing and Rework Industry - Background Information for Promulgated Standards, Addendum
NESHAP for Aerospace Manufacturing and Rework Industry, Background Information for Promulgated Standards, July 1995
|Signed by: Bruce Jordan, Director, Emission Standards Division
Signature Date: February 3, 1998
Emission Standards Division (OAQPS)
Background Information Documentsgy Emission Standards
National Emission Standards for Hazardous Air Pollutants
Volatile organic compounds
Clean Air Act
BACKGROUND INFORMATION DOCUMENT
On September 1, 1995, the U. S. Environmental Protection Agency (EPA) promulgated national emission standards for hazardous air pollutant (HAP) emissions from major sources in the aerospace industry (60 FR 45948). These final standards implemented section 112(d) of the Clean Air Act as amended in 1990 (the Act). On October 29, 1996, the EPA proposed amendments to the final rule and release of a draft control techniques guideline (CTG) document (61 FR 55842). There were 18 comment letters submitted by 19 different commenters, which consisted primarily of trade associations, component suppliers and State and local air pollution control agencies. In addition, comments were received from one general aviation facility, private environmental organizations, and U.S. Government agencies. Summarizes of the comments, and the EPA's responses, are presented in this document. This comment summary and the Agency's responses served as the basis for the revisions (amendments) made to the final NESH AP. This document is an addendum to Volume II of "National Emission Standard for Hazardous Air Pollutants (NESHAP) for the Aerospace Industry - Background Information for Promulgated Standards," July 1995, EPA Document No. EPA/R-97-003b (Docket A-92-20, item III-B-1). This report also includes a discussion of the changes made to the draft CTG in finalizing the CTG document.
The proposed amendments requested comment regarding corrections to several references in the rule; revisions and additions to definitions; clarification of the applicability of the cleaning operations standards; clarification of the applicability of the rule to space vehicles; addition of standards for Type I chemical milling maskants; revision of standards for new and existing sources using dry particulate filters to control emissions from topcoat and primer application and depainting operations; addition of a test method for determining the filtration efficiency of dry particulate filters; addition of an exemption for certain water-reducible coatings; addition of an essential use exemption for cleaning solvents; clarification of compliance dates; clarification of the applicability of new source MACT to spray booth standards; clarification of the requirements for new and existing primer and topcoat application operations; clarification of monitoring requirements for dry particulate filte r usage; addition of Appendix A to this subpart containing definitions for specialty coatings, and addition of a cross reference to requirements in the General Provisions in Subpart A of part 63. The EPA announced in the same Federal Register notice the availability of a draft CTG document for control of volatile organic compound (VOC) emissions from aerospace manufacturing and rework facilities for public review and comment. This document was prepared to assist States in analyzing and determining reasonably available control technology (RACT) for stationary sources of VOC emissions located within ozone national ambient air quality standard nonattainment areas.