Aerospace
For more than 15 years, Trinity Consultants has assisted facilities in the aerospace industry with regulatory compliance and environmental management issues. Our experience conducting over 300 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
The National Emission Standards for Aerospace Manufacturing and Rework Facilities (Aerospace NESHAP) was promulgated on September 1, 1995. According to section 112(f) of the Clean Air Act, the EPA is required to assess residual risks from the same source category and develop additional emission standards, as necessary. On April 24, 2006, the EPA published its Spring 2006 Unified Agenda, which included a timetable for rulemaking on the Residual Risk Standards for the Aerospace NESHAP. According to this timetable, the Notice of Proposed Rulemaking is scheduled for December 2007, with Final Action expected in December 2008.
After a multi-year scientific review of methyl ethyl ketone (MEK), the EPA removed it from the HAPs list on December 13, 2005. Although this is great news for many industries subject to MACT standards, it has little affect on those subject to the Aerospace NESHAP. This is due to the fact that the Aerospace NESHAP regulates primers, topcoats, and cleaning solvents based on both HAP and volatile organic compound (VOC) content. Since MEK is still considered a VOC, the MEK delisting does not allow aerospace facilities to resume use of this solvent.
Additionally, several Maximum Achievable Control Technology (MACT) standards that may affect sources in the aerospace industry have been promulgated. The Miscellaneous Metal Parts MACT 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. The Plastic Parts & Products MACT 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. The U.S. EPA has provided a broad definition of “facility maintenance” that should exclude most activities at aerospace facilities from regulation under these MACT standards. In addition, the Industrial, Commercial, and Institutional Boiler and Process Heaters NESHAP (Boiler MACT) may potentially have a large impact on liquid and solid-fuel boilers operating at aerospace facilities. Units must comply with the requirements of the Boiler MACT by September 13, 2007.
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 record keeping 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 provided assistance in negotiating changes to the current operating permit to allow increased operational flexibility and reduced record keeping 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.