Regulation Changes to Air Emissions Standards for Aerospace Industry - Is Your Aerospace Facility Impacted? Final Amendments to the Aerospace NESHAP – 40 CFR 63 Subpart GG

In December 2015, the United States Environmental Protection agency published final amendments to the National Emission Standards for Aerospace Manufacturing and Rework Facilities (Aerospace NESHAP) based on the recently completed risk and technology review (RTR).   Major amendments to the regulation include:

• New volatile organic compound (VOC) and hazardous air pollutant (HAP) limitations for certain specialty coatings
• Removal of exemptions for periods of startup, shutdown and malfunction so that affected units will be subject to the emission standards at all timesNew electronic reporting requirements through EPA’s Compliance and Emissions Data Reporting Interface (CEDRI)
• Simplification of recordkeeping and reporting requirements for compliant coatings
  - Under the new regulations, facilities that use coating manufacturer's supplied data to demonstrate compliance with organic HAP or VOC limits may retain the manufacturer's documentation and annual purchase records in place of the monthly usage records

The revisions are effective immediately.

Does this apply to my facility?
​The Aerospace NESHAP applies to that are engaged in the manufacture or rework, including surface coating, of aerospace vehicles or components and that are major sources of HAPs.  Typically, facilities subject to this regulation fall under one of the following NACIS Codes:

NAICS Code	Description	NAICS Code	Description
336411	Aircraft Manufacturing	481111	Scheduled Passenger Air Transportation
336412	Aircraft Engine and Engine Parts Manufacturing	481112	Scheduled Freight Air Transportation
336413	Other Aircraft Parts and Auxiliary Equipment Manufacturing	481211	Nonscheduled Chartered Passenger Air Transportation
336414	Guided Missile and Space Vehicle Manufacturing	481212	Nonscheduled Chartered Freight Air Transportation
336415	Guided Missile and Space Vehicle Propulsion Unit and Propulsion Unit Parts Manufacturing	481219	Other Nonscheduled Air Transportation
336419	Other Guided Missile and Space Vehicle Parts and Auxiliary Equipment Manufacturing

Facilities in California:

This is nothing new for facilities in California. Many local air districts already have rules that are at least as stringent as the revised federal Aerospace NESHAP. For example, South Coast Air Quality Management District Rules 109 and 1124 require aerospace manufacturing facilities to tracking usage of all coatings that contain volatile organic compounds (VOCs).

What do I need to do?

Under the new regulation, specialty coatings must be applied, controlled, and tracked similarly to primers and topcoats. This means that specialty coatings must meet the newly established HAP limits and must be applied in spray booths with filters meeting minimum efficiency requirements. The existing low-volume exemptions for spray-applied coatings would also apply for specialty coatings (50 gallons annually of any one coating, and 200 gallons total). Although aerosol coatings are listed as specialty coatings, the recent amendments did not establish VOC or HAP content limits for aerosol coatings, and aerosol coatings will remain exempt from the application operation requirements of 40 CFR §63.745(f) and 40 CFR §63.745(g).

All requirements and emission limits within the regulation need to be followed, even during periods of startup, shutdown, and malfunction. Coatings cannot be applied while emission control devices are down, and any additional emissions during these periods must be treated as excess emissions.

​Facilities must submit electronic copies of certain required performance test reports through EPA’s Central Data Exchange using CEDRI. The submission of performance test data electronically to the EPA applies only to those performance tests conducted using test methods that will be supported by the ERT. The ERT contains a specific electronic data entry form for most of the commonly used EPA reference methods. A listing of the pollutants and test methods supported by the ERT is available at http://www.epa.gov/ttn/chief/ert/index.html.

Alta Environmental has over 25 years of experience in surface coating permitting and compliance. Our team of qualified professionals can get your facility into compliance with the new Aerospace NESHAP and provide continuing VOC and HAP tracking, reporting, and compliance services. Contact us with your questions at 888-608-3010.  

(Blog post by Chris Waller, Senior Associate II)