### MEMORANDUM

TO : Kim Teal and Keith Barnett, U.S. Environmental Protection Agency

FROM : Eastern Research Group, Inc. (ERG)

DATE : January 21 , 201 5

SUBJECT : Technology Review for Depainting Operations in the Aerospace Source Category



## 1.0 INTRODUCTION Section 112 of the Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to establish technology

- based standards for listed source categories. These technology

- based standards are often referred to as maximum achievable control technology (MACT) standards. The Aerospace MACT (40 CFR part 63, subpart GG) regulates HAP emissions from facilities that are major sources and are engaged, ei ther in part or in whole, in the manufacture or rework of commercial, civil, or military aerospace vehicles or components. The rule requires the use of MACT to reduce HAP emissions from the following operations: cleaning; primer, topcoat and chemical milli ng maskant application; depainting; and waste storage and handling. Section 112 also contains provisions requiring the EPA to periodically revisit these standards. Specifically, section 112(d)(6) states: (6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than every 8 years. To comply with this CAA requirement, the EPA conducte d a technology review for the Aerospace MACT standard for major sources. This memorandum addresses the portion of the technology review for depainting operations. For the purposes of reviewing a MACT standard, the EPA considers a “development” in practic es, processes, and control technologies to be:

• Any add

- on control technology or other equipment that was not identified and considered during MACT development;

• Any improvements in add

- on control technology or other equipment (that was identified and consid ered during MACT development) that could result in significant additional emission reduction;

• Any work practice or operational procedure that was not identified and conside red during MACT development; www.erg.com

1

### • Any process change or pollution prevention alternative that could be broadly applied that was not identified and con sidered during MACT development; and

• Any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during the development of the o riginal MACT standards). Section 2 of this memorandum presents a summary of the sources of data that were used to conduct the technology review and Section 3 presents the technology review for depainting operations.


## 2 .0 SOURCES OF AVAILABLE CONTROL TECHNOL OGY INFORMATION To identify any developments in practices, processes, or control technologies that could be applicable to depainting operations in the Aerospace industry, we consulted the following sources of data: RACT/BACT/LAER Clearinghouse, the Califor nia Statewide Best Available Control Technology (BACT) Clearinghouse, regulatory actions promulgated subsequent to the Aerospace MACT, regional and state regulations, and correspondence with state agencies and industry. In addition, in order to assess developments in practices, processes and control technologies that have occurred in the aerospace manufacturing and rework industry since promulgation of the MACT standards, the EPA sent out a comprehensive information collection request (ICR) to all known facilities in February 2011. The ICR requested information on material usage and control techniques used on all of the regulated and unregulated emission sources. Responses were received from 100 major source facilities and 145 synthetic minor facilities with adequate information to determine the current level of control of HAP emissions, as well as to calculate HAP emissions.

2.1 RACT/BACT/LAER Clearinghouse Database Under the EPA's New Source Review (NSR) program, if a company is planning to build
a new plant or modify an existing plant such that criteria air pollution emissions will increase by a certain amount, then the company must obtain an NSR permit. The NSR permit is a construction permit which generally requires the company to minimize air polluti on emissions by changing the process to prevent air pollution and/or installing air pollution control equipment. The terms "RACT," "BACT," and "LAER" are acronyms for different program requirements relevant to the NSR program. RACT, or Reasonably Availab le Control Technology, is required on sources in areas that are not meeting national ambient air quality standards (non

- attainment areas). BACT, or Best Available Control Technology, is required on new or modified major sources in clean areas (attainment a reas). LAER, or Lowest Achievable Emission Rate, is required on new or modified major sources in non

- attainment areas. BACT and LAER (and sometimes RACT) are determined on a case

- by

- case basis, usually by State or local permitting agencies. The EPA establ ished the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central data base of air pollution technology information (including past BACT and LAER decisions contained in NSR permits) to promote the sharing of

2

### information among permitting agencies and to aid in future case

- by

- case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy prevention and control technology decisions and information may be included even if they are not relat ed to past RACT, BACT, or LAER decisions. The RBLC contains over 5,000 air pollution control permit determinations that can help identify appropriate technologies to mitigate most air pollutant emission streams. It was designed to help permit applicants a nd reviewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial processes.

The RBLC provides several options for searching the permit database on

- line to locate applicable control technologies. On September 25 , 2014 we conducted a search of the RBLC. There are no process types in the RBLC for “depainting” operations

. As a preliminar y step, a search of the RBLC process 41.001 (Aerospace Surface Coating) was performed and reviewed for depainting operations. None of these records were specific for depainting, although one entry (WA

- 0344) for a paint booth/hanger indicated an annual VOC rolling average by “compliance with 40 CFR Part 63, Subpart GG and low VOC vapor pressure cleaning solvents and strippers.“ While unclear in the RBLC information, this permit condition is likely similar or based upon the same type of permit condition as t he Washington State permit discussed later in this section. We then specified a broader search using the “Aerospace” keyword to ensure that there weren’t any applicable processes described that were not captured by the term “depainting” or included in the Aerospace Surface Coating process records. This search turned up four items, but these were all surface coating operations and none of them pertain to depainting processes. Next, we searched for the term “blast” to pick up abrasive blasting sources. One item was identified that applied to an Aerospace abrasive blasting source. The BACT determination applies to particulate matter from a cornstarch abrasive blasting unit, and considers BACT a filter rated at 99.99% efficiency for 0.5 micron particles. Th is process unit is used to remove excess adhesive materials. According to the determination, 99.99% filtration efficiency should not necessarily be a permit condition. The determination was last updated on November 17, 2005, and is presented in Appendix 1. Finally, the keyword “stripping” was searched for to identify any chemical stripping source determinations in RBLC. This search only yielded three determinations, but each of these pertain to process waste stream stripping operations, and not to surfa ce coating removal. A search of the California’s Statewide Best Available Control Technology (BACT) Clearinghouse yielded the same single matching result identified in the RBLC search described above. Finally, a search of Washington State’s records of perm its for aerospace facilities identified a Prevention of Significant Deterioration (PSD) permit amendment dated February 19, 2013 (included as Appendix 2 to this memorandum). In this, the PSD permit applies a “Low VOC vapor pressure cleaning solvents and s trippers” condition of less than 45 millimeters mercury (mm Hg) to depainting operations covered by the permit. This is considered more stringent than the depainting operations requirements of the Aerospace MACT, but allows the same vapor pressure limitat ions provided in the hand

- wipe cleaning operations requirements of

3

### the Aerospace MACT (i.e., 45 mm Hg vapor pressure or meeting composition requirements of Table 1 to section 63.744).

2.2 Subsequent Regulatory Actions No regulatory actions promulgated subs equent to the Aerospace MACT were identified for depainting operations. However, various regulatory actions related to surface finishing operations were reviewed as they include controls similar to those used to control depainting operations . These regulat ory actions, listed in Table 1, were reviewed for developments in practices, processes and control technologies.
Table 1. Subsequent Regulatory Actions for Sources Similar to Aerospace Depainting Operations
MACT Standards Subpart Date Practices, Processes, and Control Technologies Evaluated Surface Coating of Metal Furniture RRRR 5/23/2003 No specific provisions for depainting or stripping, but these activities are included as part of the coating operation under the definition of “cleaning materials.” 1 A facility may use a dd

- on control devices (e.g., carbon adsorbers, thermal or catalytic oxidizers, concentrators) to comply with emission limits for coating operations that are given in mass HAP per unit coating solids for a coating subcategor y in these NESHAP that includes all parts of the coating operation. However, the emission limitations were based on an average across the coating subcategory, and the application of add

- on controls were not specific to the depainting operations. Surface C oating of Wood Building Products QQQQ 5/28/2003
Surface Coating of Large Appliances NNNN 7/23/2002 Surface Coating of Automobiles and Light

- Duty Trucks IIII 4/26/2004
Surface Coating of Plastic Parts and Products PPPP 4/19/2004
Surface Coating of Miscellaneous Metal Parts and Products MMMM 01/02/2004

Area Source Standards Subpart Date Practices, Processes, and Control Technologies Evaluated
Paint Stripping and Miscellaneous Surface Coating Operations HHHHHH 1/9/2008 Reduce methylene chloride ( MeCl) emissions through management practices; if annual MeCl usage exceeds 1 ton, reduce MeCl using alternatives such as the following: non or low

- MeCl chemical strippers, mechanical stripping, blasting, thermal and cryogenic decomposition.

1 In all these major source subparts, “Cleaning material” is defined to mean “a solvent used to remove contaminants and other materials, such as dirt, grease, oil, and dried or wet coating (e.g., depainting), from a substrate before or after coating applica tion or from equipment associated with a coating operation, such as spray booths, spray guns, racks, tanks, and hangers. Thus, it includes any cleaning material used on substrates or equipment or both.” Cleaning materials were included as part of the affec ted source for each coating category or subcategory in each of these NESHAP.



### 4Table 1. Subsequent Regulatory Actions for Sources Similar to Aerospace Depainting Operations

Nine Metal Fa brication and Finishing Source Categories XXXXXX 7/23/2008 Management practices to minimize dust generation, capture and vent to filtration control device for enclosed and vented chambers (no control efficiency specified), remove contaminants from abrasive

blasting media prior to re

- use (for large open blasting), use of low PM

- emitting blast media Residual Risk Standards Subpart Date Practices, Processes, and Control Technologies Identified as Developments Shipbuilding and Ship Repair II 11/21/2011 Not applicable to depainting or stripping

Wood Furniture Manufacturing JJ 11/21/2011 Not applicable to depainting or stripping



### Developments identified in the regulatory actions listed in Table 1 will be discussed in Section 3 (Technology Review for Depainting Operations).

2.3 State and Regional Regulations In addition to the RLBC and subsequent regulatory actions, we examined a variety of regulations of the Bay Area Air Quality Management District (BAAQMD), the South Coast Air Quality Management Dist rict (SCAQMD), the San Diego County Air Pollution Control District (SDAPCD), the Ventura County Air Pollution Co ntrol District (VCAPCD), Missouri Department of Natural Resources , and Washington Department of Ecology . These regulations generally address VOC emissions, rather than volatile organic HAP emissions, but in many cases include provisions to reduce organic evaporative emissions from strippers just as intended for depainting affected source s under the Aerospace MACT.

2.4 2011 ICR Data for Depainting The database of responses to the 2011 ICR were also reviewed to determine the technologies and practices reported by industry. For mechanical depainting operations, the reported control devices consist of fabric filters, wet collectors, and mechanical col lectors. For chemical stripping, work practices and low or non

- MeCl strippers are reported, with the HAP

containing stripper use being limited to difficult to strip areas or for paint gun cleaning. Appendix 3 contains two tables listing the results of the ICR database query for blast depainting and solvent depainting operations.


## 3.0 TECHNOLOGY REVIEW FOR DEPAINTING OPERATIONS Depainting or stripping operations remove unwanted or old surface coatings to prepare the surface for painting. These operations ma y be chemical (strippers) or non

- chemical processes. Inorganic HAP emissions occur when non

- chemical, such as abrasive blasting, depainting is performed and there are inorganic HAP in the removed paint particles. Organic HAP emissions occur thr ough evapo ration of the stripper

.

5

### 3.1 Summary of Existing MACT Level of Control The Aerospace MACT standard (subpart GG) promulgated in 1995 requires the following for depainting operations :

• Non

- HAP chemical strippers and technologies:

o Operate and maintain non
- chemical based equipment according to manufacturer’s specifications

o On an average annual basis, use less than the following organic HAP containing chemical strippers for spot stripping and decal removal:

– Commercial aircraft: 26 gallons or 190 pounds pe r aircraft

– Military aircraft: 50 gallons or 365 pounds per aircraft

o For processes that generate airborne inorganic HAP emissions from dry media blasting:

– Perform depainting in enclosed area

– Existing sources

– pass air stream through a baghouse or waterwash system that meets or exceeds the following:

– For two

- stage arrestors, liquid phase for existing sources Filtration efficiency requirement, % Aerodynamic particle size range, μm >90 >5.7 >50 >4.1 >10 >2.2

– For two

- stage arrestors, solid phase for existing sources Filtration efficiency requirement, % Aerodynamic particle size range, μm >90 >8.1 >50 >5.0 >10 >2.6

– New sources

– pass air stream through a particulate control system that meets or exceeds the following:

– For three

- stage arrestors, liquid phase for existing sources Filtration efficiency requirement, % Aerodynamic particle size range, μm >95 >2.0 >80 >1.0 >65 >0.42

6

### – For three

- stage arrestors, solid phase for existing sources Filtration efficiency requirement, % Aerodynamic particle size range, μm >95 >2.5 >85 >1.1 >74 >0.70

– If the coating being removed contains chromium or cadmium, control using a HEPA filter, three

- stage filter, or other system equivalent to a three

- stage filter.

• Organic HAP

- containing chemical strippers

o Existing sources

– reduce organic HAP emissions by 81 percent or greater (capture and control efficiency combined)

o New sources

– reduce organic HAP emissions by 95 percent or greater (capture and control efficiency, plus any reduction in volume of chemical stripper used)
These requirements do not apply to mechanical and hand sanding operations, or to operations that depaint six or less completed aerospace vehicles in one year.

3.2 Identified Control Measures for Depaintin g Operations Current industry practices employed to control emissions from depainting operations include the use of a control device, such as fabric filters, wet collectors , and product substitutions, such as non
- MeCl solvents

. 3.2.1 Add

- On Control Techn ology or Other Equipment Not Identified and Considered During MACT Development No new equipment or control technologies were identified that were not considered during MACT development.

3.2.2 Improvements in Add

- On Control Technology or Other Equipment (Th at Was Identified and Considered During MACT Development) The MACT standard dry phase particulate matter control efficiency challenge for new sources is greater than 74% for particles greater than 0.7 microns

. According to the RBLC database, there has been a determination specifying a 99.99% control efficiency. However, this process is a corn starch blast operation for removing excess adhesives. This narrow scope may not be widely applicable to other depainting operations used to remove topcoats and primer s, and furthermore the determination notes that this control efficiency should not necessarily be applied as a permit condition. A review of the controls and efficiencies reported in the 2011 ICR (see Appendix 3) does not indicate the level of control by aerodynamic particle size, so we are unable to equate whether the RBLC determination is applicable to current aerospace depainting operations. For chemical strippers, the ICR data seem to indicate instances where the chemical stripping operation has been d iscontinued, or that the source is complying with the volume of

7

### organic

- HAP per airplane limits of the MACT. Other types of non

- HAP chemical strippers do not seem to be widely demonstrated for aerospace operations at this time, so we are unable to
assess whether the spot stripping organic HAP

- containing stripper volumetric limits may be lowered. For the Washington PSD permit, the low VOC requirement for strippers is not directly applicable to the depainting operations. The Aerospace NESHAP contains HAP pr ovisions, primarily to address MeCl use and emissions from its use. MeCl, however, is not a VOC. Therefore, the additional VOC provision contained in the PSD permit would not have an impact on MeCl use. As a result, we are unable to ascertain that the a dditional provision for the PSD permit described above (and in Appendix 2) is an improvement that would result in lower HAP emissions.

8

## Appendix 1 RBLC Results for Abrasive Blasting

### COMPREHENSIVE REPORT Report Date:09/25/2014 

## Facility Information

RBLC ID: 

### CA-1093 (final) Date Determination Last Updated: 11/17/2005 Corporate/Company Name: GOODRICH AEROSPACE Permit Number: 391420 Facility Name: ROHR, INC. (DIVISION OF GOODRICH AEROSPACE) Permit Date: 11/30/2001 (actual) Facility Contact: FRS Number: 110000479544 Facility Description: SIC Code: 3728 Permit Type: A: New/Greenfield Facility NAICS Code: 327910 Permit URL: EPA Region: 9 COUNTRY: USA Facility County: RIVERSIDE Facility State: CA Facility ZIP Code: 925031499 Permit Issued By: SOUTH COAST AQMD, CA (Agency Name) MR. AL BAEZ(Agency Contact) (909)396-2516 abaez@aqmd.gov Other Agency Contact Info: SOUTH COAST AQMD, MARTIN KAY, 909-396-3115, MKAY@AQMD.GOV Permit Notes: CARB ID: 796.0, OPERATING PERMIT DATE: 11-30-2001, STARTUP DATE: 01-01-2002 NEW CONSTR MODIFICATION: NEW CONSTRUCTION TECH STATUS: BACT DETERMINATION NO SOURCE TEST AVAILABLE



### Process/Pollutant Information

PROCESS NAME: ABRASIVE BLASTING

Process Type: 99.001 (Abrasive Blasting) Primary Fuel: NONE-APPLICABLE Throughput: 12.50 12.5 W X 8 H X 17 L
Process Notes: EQUIP: , MFR: CLEMCO INDUSTRIES, TYPE: CORNSTARCH, MODEL: , FUNC EQUIP: TO REMOVE EXCESS ADHESIVE MATERIALS

FROM PARTS, FUEL_TYPE: , SCHEDULE: CONTINUOUS, H/D: 24, D/W: 7, W/Y: 52, NOTES: BACT IS CONSIDERED VENTING TO A FILTER RATED AT 99.99% EFFICIENCY FOR 0.5 MICRON PARTICLES. THIS IS NOT MEANT TO SUGGEST THAT 99.999% FILTRATION EFFICIENCY SHOULD NECESSARILY BE A PERMIT CONDITION. SOURCE TEST RESULTS:POLLUTANT NAME: Particulate matter, fugitive

CAS Number: PM Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 99.9900 % FILTRATION EFF. Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (A) FILTER Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: 99.99% FILTRATION EFFICIENCY FOR 0.5 MICRON PARTICLES

## Appendix 2 Washington State Aerospace PSD Permit

## Appendix 3 Aerospace ICR Information for DepaintingAppendix 3.1 Blast Depainting ICR Survey Data 1

SPPD_FACILITY_IDENTIFIER FACILITY_NAME EMISSION_PROCESS_GROUP EMISSION_UNIT_ID Location Media Purpose AvgHrs AvgDays CtrlID 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting B0116 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting D0053 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting D0097 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting D0182 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting D0183 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting D0184 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting D0205 2008 Dept. of the Navy, Fleet Readiness Center East Blast Depainting E0080 2021 American Airlines Maintenance and Engineering Center Blast Depainting 7892814 Inside, in a fully enclosed booth Plastic Beads Paint Removal 18 250 7892814 2021 American Airlines Maintenance and Engineering Center Blast Depainting 7892815 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609656 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614008 Inside, in a fully enclosed booth Metal Shot Cleaning Operation 18 250 9609656 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614018 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609656 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614030 Inside, in a fully enclosed booth Plastic Beads Cleaning Operation 18 250 9614030 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614046 Inside, in a fully enclosed booth Plastic Beads Paint Removal 18 250 9609537 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614054 Inside, in a fully enclosed booth Plastic Beads Cleaning Operation 18 250 9609655 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614057 Inside, in a fully enclosed booth Plastic Beads Cleaning Operation 18 250 9614057 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614058 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609715 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614061 Inside, in a fully enclosed booth Alumium Oxide Cleaning Operation 18 250 9609502 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614065 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609691 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614066 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609693 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614068 Inside, in a fully enclosed booth Plastic Beads Cleaning Operation 18 250 9609655 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614069 Inside, in a fully enclosed booth Ceramic Shot Cleaning Operation 18 250 9609656 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614071 Inside, in a fully enclosed booth Metal Shot Cleaning Operation 18 250 9609681 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614072 Inside, in a fully enclosed booth Metal Shot Cleaning Operation 18 250 9609682 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614097 Inside, in a fully enclosed booth Plastic Beads Cleaning Operation 18 250 9609655 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614099 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609503 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614115 Inside, in a fully enclosed booth Plastic Beads Paint Removal 18 250 9609535 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614117 Inside, in a fully enclosed booth Plastic Beads Paint Removal 18 250 9609535 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614123 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609684 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614124 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609684 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614125 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609684 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614126 Inside, in a fully enclosed booth Aluminum Oxide Cleaning Operation 18 250 9609684 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9614138 Inside, in a fully enclosed booth Aluminum Oxide Paint Removal 18 250 9609536 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9666931 Inside, in a fully enclosed booth Cleaning Operation 18 250 9666931 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9666938 Inside, in a fully enclosed booth Plastic Beads Cleaning Operation 18 250 9666938 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9666940 Inside, in a fully enclosed booth Metal Shot Cleaning Operation 18 250 9609656 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9669816 Inside, in a fully enclosed booth Aluminum Oxide Paint Removal 18 250 9609538 2021 American Airlines Maintenance and Engineering Center Blast Depainting 9669817 Inside, in a fully enclosed booth Plastic Beads Paint Removal 18 250 9609539 2022 Palmdale Blast Depainting A006778 Fully enclosed hangar Wheat starch Depainting 8 55 C006781

2023 George C Marshall Space Flight Center Blast Depainting 4745 Sand Blaster partially enclosed booth Black Beauty & silica Remove paint/clean metal pa 8 52 N/A

246 Pratt and Whitney Engine Services Blast Depainting R-1418-BR16 Walk In Bast Booth Fully Enclosed Grit 20/30 Plastic Abrasive Media Vacuum blaster used for rem 3 356 US Filters BCP - JP 343 CTL Aerospace, Inc. Blast Depainting 2038 In a fully enclosed booth Aluminum Oxide - 120 Grit Depaint larger parts 8 255 2038 A 343 CTL Aerospace, Inc. Blast Depainting 2066 In a fully enclosed booth OPTI-BLAST T-5 PLASTIC BLAST M Depaint small parts 8 255 2066 A 356 Carleton Life Support Systems Inc. Blast Depainting Cooler Room 1 Fully enclosed booth 60 Micron Aluminum Oxide Surface Preparation 1 100 02-470 356 Carleton Life Support Systems Inc. Blast Depainting Cooler Room 2 Fully enclosed booth 60 Micron Aluminum Oxide Surface Preparation 1 100 02-479 356 Carleton Life Support Systems Inc. Blast Depainting Sieve Room Fully enclosed booth #100 Emerald Creek Garnet Surface Preparation 1 20 02-265

388 Delta Air Lines, Inc. Technical Operations Center Blast Depainting 1839 Fully Enclosed Booth Aluminum Oxide Removal of Plasma Spray Coa 6 340 1839-DC

388 Delta Air Lines, Inc. Technical Operations Center Blast Depainting 4737 Fully Enclosed Booth Aluminum Oxide Removal of Plasma Spray Coa 4 340 4737-DC

431 Robins Air Force Base Blast Depainting A008 - Bldg 142, Blast Room 4 fully enclosed booth Plastic media Depaint aircraft stabilizers 5 250 Fabric Filter 4 - A0

431 Robins Air Force Base Blast Depainting D003 - Bldg 137, Bay 3 and 4 fully enclosed booth Plastic media Depaint F-15 aircraft and par 16 250 Fabric Filter 1 (sta

433 Davis-Monthan Air Force Base, Tucson, AZ Blast Depainting 10502 Abrasive Blast Booth Fully enclosed drive-in blast booth Plastic Media Depaint Various Aircraft Part 6 150

433 Davis-Monthan Air Force Base, Tucson, AZ Blast Depainting 10532 (C130 Wheel Wells) Fully enclosed portable enclosure Plastic Media Depaint C-130 wheel wells. 1 14

453 Learjet, Inc Blast Depainting IA-SAND9/SV-BLDGVNT/CE-CYCLO Totally Enclosed Booth Sand Blast Chamber Removing rust and imperfect 10 365 460 NORDAM Repair Division Blast Depainting Blast Room #2 Fully enclosed Booth Plastic Type II 20/30 mesh Coating and Corrosion Remo 4 156 Torit #1 460 NORDAM Repair Division Blast Depainting Blast Room #3 Partially enclosed Booth Aluminum Oxide 120 Grit Corrision Removal 3 104 Torit #2 460 NORDAM Repair Division Blast Depainting Blast Room #4 Fully enclosed Booth Wheat Starch 12/30 mesh Selective Coating Removal 6 208 Torit #3 479 PCC Airfoils, LLC Blast Depainting Jet Wheel Blast Inside, fully enclosed unit Steel Shot Clean Metal for Re-melting 19 312 P016-RotocloneAppendix 3.1 Blast Depainting ICR Survey Data 2

SPPD_FACILITY_IDENTIFIER FACILITY_NAME EMISSION_PROCESS_GROUP EMISSION_UNIT_ID Location Media Purpose AvgHrs AvgDays CtrlID 520 Rohr, Inc. Blast Depainting D214 Fully enclosed booth Corn starch Depainting 8 200 C216

523 Southwest United Industries, Inc. Blast Depainting Cab. #2-P-03 Empire Building 2: inside a fully isolated blasting cabinet Aluminum Oxide Prepare parts for masking or 7 287 N/A (see commen

523 Southwest United Industries, Inc. Blast Depainting Cab. #2-S-01 Clamshell Building 2: inside a fully isolated blasting cabinet Aluminum Oxide Prepare parts for masking or 7 287 N/A (see commen

523 Southwest United Industries, Inc. Blast Depainting Cab. #2-S-05 Glass Building 2: inside a fully isolated blasting cabinet Glass Bead Prepare parts for masking or 2 260 N/A (see commen

523 Southwest United Industries, Inc. Blast Depainting Polishing Room Building 5: Polishing & Buffing Only Buffing Compound 80% Final Cleaning / 20% Pre 7 260 Fabric Filter 1 (J-4

524 GE Aviation, Evendale Blast Depainting EA-021-J Fully-enclosed Peen Booth Carbon-steel Cut-wire Shot Surface-enhancement (e.g., h 4 260 No External or Sec

524 GE Aviation, Evendale Blast Depainting EA-021-K Fully-enclosed Peen Booth Steel Shot Surface-enhancement (e.g., h 2 180 No External or Sec 529 United States Army Garrison Fort Wainwright, Alaska Blast Depainting BD-2077 Fully Enclosed Booth Walnut Shell Rework operations to remov 0 100 BD-2077

532 Boeing Auburn Blast Depainting A003293 Inside fully enclosed booth that vents outside through a cartridge-style baghouse Poly V Plastic Blast Abrasive (Typ Depainting 0 44 A0016511

630 Ametek Rotron, Inc. Blast Depainting P-1 (Procedyne) Fully enclosed tank fine sand + heat Removes cured varnish dripp 8 260

634 U.S. Naval Station Mayport Blast Depainting AB008 Fully Enclosed Booth Plastic Media Type 5, size 20/30, Blast depainting of various ai 1 250 Fabric Cartridge F

65 Hawker Beechcraft Corporation Blast Depainting Starch Blast Paint Removal/Plant 1 Fully Enclosed Booth Envirostrip XL 16/60 Corn Starch Paint removal of aircraft part 12 260 CE-BDDCWSB1

660 Avco Corporation d/b/a Lycoming Engines Blast Depainting Experimental Blast Cabinet Inside fully enclosed booth Aluminum Oxide (180 grit) Clean parts for experimental 4 260 Pangborn DC 1

660 Avco Corporation d/b/a Lycoming Engines Blast Depainting Teardown- Blast 1 Inside fully enclosed booth Walnut Shell Clean parts from engine tear 4 260 Empire DC-1

660 Avco Corporation d/b/a Lycoming Engines Blast Depainting Teardown- Blast 2 Inside fully enclosed booth Walnut Shell Clean parts from engine tear 4 260 Empire DC-2

660 Avco Corporation d/b/a Lycoming Engines Blast Depainting Teardown- Blast 3 Inside fully enclosed booth Walnut Shell Clean parts from engine tear 8 260 Empire DC-3

660 Avco Corporation d/b/a Lycoming Engines Blast Depainting Wheelabrator (1056) Inside fully enclosed booth Amasteel Cast Steel Shot and Grit Clean parts prior to heat trea 1 260 Wheelabrator DC660 Avco Corporation d/b/a Lycoming Engines Blast Depainting Wheelabrator (7026) Inside fully enclosed booth Amasteel Cast Steel Shot and Grit Clean parts prior to heat trea 3 260 Wheelabrator DC663 Hill Air Force Base Blast Depainting 1289 walk-in booth garnet grit 100 prep parts for plating 0 0 1289 663 Hill Air Force Base Blast Depainting 1340 type V PMB booth plastic beads, type II and type V remove paint from large aero 16 250 1340

663 Hill Air Force Base Blast Depainting 1426 large blasting booth garnet large ground support equipm 7 250 1426 663 Hill Air Force Base Blast Depainting 2162 large blast booth plastic bead depaint F-16 planes and plan 9 300 2162 663 Hill Air Force Base Blast Depainting 2401 double glovebox aluminum oxide grit cleaning aircraft parts 4 140 2401 663 Hill Air Force Base Blast Depainting 2402 glovebox aluminum oxide grit cleaning and depainting aircr 6 245 2402 663 Hill Air Force Base Blast Depainting 3165 walk-in booth crushed garnet cleaning aircraft parts 3165 663 Hill Air Force Base Blast Depainting 3271 large abrasive blaster steel shot clean brake parts 4 245 3271 663 Hill Air Force Base Blast Depainting 602 partially enclosed booth plastic bead paint removal on steel parts 7 260 602 663 Hill Air Force Base Blast Depainting 617 large booth plastic bead paint removal from F-16 9 300 617 663 Hill Air Force Base Blast Depainting 618 large booth plastic bead paint removal from F-16 9 300 618 663 Hill Air Force Base Blast Depainting 627 walk-in steel shot S-280 prep parts for plating 4 340 627 663 Hill Air Force Base Blast Depainting 628 walk in booth garnet prep parts for plating 4 340 628 663 Hill Air Force Base Blast Depainting 8470 blast booth plastic beads cleaning aircraft parts 7 260 8470

672 Honeywell Aerospace Blast Depainting P108 (2200; R&O) Fully enclosed booth Plastic blast media Depainting parts 1 270 Fabric Filter 1 693 Sikorsky Aircraft Corporation - Stratford Facility Blast Depainting PMB Fully enclosed booth U.S. Technology Corporation Poly Aircraft depainting 0 60 PMBAppendix 3.1 Blast Depainting ICR Survey Data 3

SPPD_FACILITY_IDENTIFIER 2008 2008 2008 2008 2008 2008 2008 2008 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2021 2022

2023

246 343 343 356 356 356

388

388

431

431

433

433

453 460 460 460 479 DevType CapEff CapEff_test CapEff_spec CapEff_est WorkPractice Comments

Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 95 X Fabric filter (other than spray booth fi 100 Yes
4745 Sand Blaster used for research and development activities Fabric Filter 99.9 No Yes No N/A Note 1: Emissions is based on a AP-42 Section 13.2.6 Table 4-2 Fabric filter (other than spray booth fi No Yes No Continued preventative maintenance Fabric filter (other than spray booth fi No Yes No Continued preventative maintenance Fabric filter (other than spray booth fi 99.9 Yes Used for surface preparation for bonding Fabric filter (other than spray booth fi 99.9 Yes Used for surface preparation for bonding Fabric filter (other than spray booth fi 95 Yes Used for surface preparation for bonding
Fabric filter (other than spray booth fi 99.9 X Operate in accordance with manufacturer's instructions.
Fabric filter (other than spray booth fi 99.24 X Operate in accordance with manufacturer's instructions.

Fabric filter (other than spray booth fi 99.99 no yes no All equipment is operated and maintained according to manufacturer's specifications. Filter system complies with terms and conditions of Title V permit.

Fabric filter (other than spray booth fi 99.9 no yes no All equipment is operated and maintained according to manufacturer's specifications. Filter system complies with terms and conditions of Title V permit.
Fabric filter (other than spray booth fi 99.9 Typical for filters of this type. Pleated cartridge filters. Emissions estimated based on TCLP analysis of waste stream and conservative assumptions.
Fabric filter (other than spray booth fi 99.97 Vendor Literature, AirVerter PP-500XP filteration unit Filtration unit uses coarse filter panel, followed by pocket filter, followed by 0.3 micron HEPA filter.

Sand-blasting is for cleaning rust and imperfections off of parts, about 10% of this booth's operations is for removing paint from part. Fabric filter (other than spray booth fi 99 Yes Fabric filter (other than spray booth fi 99 Yes Fabric filter (other than spray booth fi 99 Yes Hydrostatic (Wet) collector 99 Yes NA Hydrostatic (Wet) collectorAppendix 3.1 Blast Depainting ICR Survey Data 4

SPPD_FACILITY_IDENTIFIER 520

523

523

523

523

524

524 529

532

630

634

65

660

660

660

660

660

660 663 663

663 663 663 663 663 663 663 663 663 663 663 663

672 693 DevType CapEff CapEff_test CapEff_spec CapEff_est WorkPractice Comments Fabric filter (other than spray booth fi 99 Yes Overall efficiency

Mechanical collector N/A N/A N/A Vacuum powered drum mounted fines collector Operation is a fully enclosed and isolated glovebox blasting cabinet

Mechanical collector N/A N/A N/A Vacuum powered drum mounted fines collector Operation is a fully enclosed and isolated glovebox blasting cabinet

Mechanical collector N/A N/A N/A Vacuum powered drum mounted fines collector Operation is a fully enclosed and isolated glovebox blasting cabinet
Fabric filter (other than spray booth fi 99.99 No Yes No Vacuum powered filtration system Operation is a buffing and polishing area and not a blasting operation

N/A This equipment is on a Preventive Maintenance program to ensure normal operation. Per §II,Q.2, internal filters are integral to the process.

N/A This equipment is on a Preventive Maintenance program to ensure normal operation. Per §II,Q.2, internal filters are integral to the process. Vacuum Collector N/A N/A N/A N/A N/A

Fabric filter (other than spray booth fi 100 Yes Depainting is done in blast cabinet approximately 30 minutes per week. Emissions calculations are based on removing approximately 1 sq. ft. of chrome-containing primer/week for 44 weeks in 2008 (44 weeks rather than 52 weeks because of the work stoppage HAP emissions unlikely. Cured varnish wastage may still contain residual ethyl benzene and/or xylenes.

Fabric filter (other than spray booth fi 87.5 EPA Method 5 Follow O&M. Inorganic HAP emissions were back calculated from TCLP analysis and removal efficiency and represent the average from two stacks.

Mechanical collector 99.98415 Yes Inspect Dust Collector and Filters Every 180 Days and Replace Filters Once Annually/Keep Daily Magne

Fabric filter (other than spray booth fi 100 X NA Emissions Calcs based on waste testing. Capture Efficiency based on typical capture efficiency for type of equipment.

Fabric filter (other than spray booth fi 100 X NA Equipment Vents inside building. Emissions Calcs based on waste testing. Capture Efficiency based on typical capture efficiency for type of equipment.

Fabric filter (other than spray booth fi 100 X NA Equipment Vents inside building. Emissions Calcs based on waste testing. Capture Efficiency based on typical capture efficiency for type of equipment.

Fabric filter (other than spray booth fi 100 X NA Equipment Vents inside building. Emissions Calcs based on waste testing. Capture Efficiency based on typical capture efficiency for type of equipment.
Fabric filter (other than spray booth fi 100 X NA Emissions Calcs based on waste testing. Capture Efficiency based on typical capture efficiency for type of equipment.
Fabric filter (other than spray booth fi 100 X NA Emissions Calcs based on waste testing. Capture Efficiency based on typical capture efficiency for type of equipment. Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 95 none
Fabric filter (other than spray booth fi 99.8 general houskeeping, equipment preventive maintenance, regular rotation of media Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 90 none Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 85 none Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 99.8 none Fabric filter (other than spray booth fi 90 none
Fabric filter (other than spray booth fi 100 Yes Does not account for trace metal HAPS that may be found in the metal substrates, such as steel or aluminum. Fabric filter (other than spray booth fi 99.99 N/A Yes N/A Routine maintenance on control system N/AAppendix 3.2 Solvent Depainting ICR Survey Data 5

SPPD_FACILITY_ IDENTIFIER FACILITY_NAME EMISSION_PROCESS_GROUP EMISSION_UNIT_ID Purpose AvgHrs AvgDays CtrlID DevType CapEff CapEff_test CapEff_spec CapEff_est WorkPractice Comments

2007 Cessna Aircraft Company Solvent Depainting EU-2207 Paint Stripping 16 312 NA NA NA NA Lid on tank kept closed. No dedicated stack associated with dip tank. Location data refers to tank and general vent location. 2008 Dept. of the Navy, Fleet Readiness Center East Solvent Depainting D0120 2009 Bell Helicopter Textron Plant 1 Solvent Depainting BLDG 2 FUG LAB & TESTING USE ONLY 24 365 N/A N/A N/A N/A N/A N/A 2009 Bell Helicopter Textron Plant 1 Solvent Depainting BLDG 29 FUG LAB & TESTING USE ONLY 24 365 N/A N/A N/A N/A N/A N/A 2010 Bell Helicopter Textron Plant 5 Solvent Depainting 5 Minor rework Other (specify in comments) N/A N/A N/A Max of 5 gallons used per year Paint kitchen. No control for VOCs.

2021 American Airlines Maintenance and Engineering Center Solvent Depainting 2041 Emergency Landing inspect 1 30

2021 American Airlines Maintenance and Engineering Center Solvent Depainting 2223 Emergency Landing inspect 1 30

2023 George C Marshall Space Flight Center Solvent Depainting 4760 -Depaint Remove paint from 2 10 N/A 4760 depainting activities for research and development 2024 Naval Air Weapons Station Solvent Depainting PMF Depaint non-blastable portions of exterior 2 1 Store solvents in closed containers. RCRA compliance. Performed inside blast/paint booth.

2026 Tinker Air Force Base, OK Solvent Depainting 2052 Aircraft Depainting 24 365 Not Applicable This operation includes emissions from other sources in the total. Operations inlcuded are 2053, 2406, 2413, 2540, 2541, 2542. 2026 Tinker Air Force Base, OK Solvent Depainting 2436 Parts Depainting 24 365 Not Applicable 2026 Tinker Air Force Base, OK Solvent Depainting 2437 Aircraft Depainting 24 365 Not Applicable 2026 Tinker Air Force Base, OK Solvent Depainting 3036 Part Depainting 8 260 Not Applicable 2026 Tinker Air Force Base, OK Solvent Depainting 3062 Aircraft Depainting 8 260 Not Applicable

284 TIMCO Aviation Services, Inc. - Lake City Base Maintenance Operations Solvent Depainting Hangar 9 Depainting Remove paint from aircraft or components prior to repainting 24 365 No control device Compliant materials, housekeeping N/A

292 Naval Air Station Oceana, Virginia Beach, VA Solvent Depainting PNTS-513-003 Remove paint from airframes 8 72 N/A N/A a) Minimize spills: maintain systems and containers in good order with minimal rusting or dents and no openings or leaks; use funnels or other practices when transferring material or waste; b) Immediately clean up spills and repackage containers as needed

292 Naval Air Station Oceana, Virginia Beach, VA Solvent Depainting PNTS-GRP1 Remove exterior paint on jets 0 12 N/A N/A PNTS-GRP1 consists of 4 hangars shared by a group of squadrons. Usage is tracked by squadron, not by building location. Therefore, HAP emissions is reported by group. 292 Naval Air Station Oceana, Virginia Beach, VA Solvent Depainting PNTS-GRP2 Remove exterior paint on jets 0 12 N/A N/A PNTS-GRP2 consists of 3 hangars shared by a group of squadrons. Usage is tracked by squadron, not by building location. Therefore, HAP emissions is reported by group. 293 Naval Station Norfolk, Norfolk Virginina Solvent Depainting Open Hangar painting Area 1 (LF Area) To remove paint from aircraft exterior. 0 12 N/A Hangars are located in 4 areas of the facility. Open Hangar painting Area 1 (LF Area) consists of 2 hangars, Open Hangar painting Area 2 (LP Area) is made up of 5 hangars, Open Hangar painting Area 3 (V Area) is made up of 1 hangar, and Open Hangar pa

293 Naval Station Norfolk, Norfolk Virginina Solvent Depainting Open Hangar painting Area 2 (LP Area) To remove paint from aircraft exterior. 0 12 N/A

293 Naval Station Norfolk, Norfolk Virginina Solvent Depainting Open Hangar painting Area 3 (V Area) To remove paint from aircraft exterior. 0 12 N/A

293 Naval Station Norfolk, Norfolk Virginina Solvent Depainting Open Hangar painting Area 4 (SP Area) To remove paint from aircraft exterior. 0 12 N/A

293 Naval Station Norfolk, Norfolk Virginina Solvent Depainting PNTS-SP300-500 To remove paint from airframes 8 72 N/A a) Minimize spills: maintain systems and containers in good order with minimal rusting or dents and no openings or leaks; use funnels or other practices when transferring material or waste; b) Immediately clean up spills and repackage containers as needed

3000 US Army Corpus Christi Army Depot Solvent Depainting SCGRP12 Depaint Airframes before recoating 6 260 This process is no longer in use at CCAD.

332 The Boeing Company - St. Louis Solvent Depainting Bldg 101 Fugitive Emissions small part cleaning/removal of paint 8 260 NA Used on only one process in the building. Emissions are straight from usage. Some should go out as waste and used up in the reaction, but we do not have data on that.

332 The Boeing Company - St. Louis Solvent Depainting SB-101-02 small part and tool cleaning/removal of paint 8 250 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use Chemical usage info is divided equally among SB-101-33, SB-101-02, and SB-101-40 since chemicals from the booths are taken from the same location. We cannot get any more specific. 332 The Boeing Company - St. Louis Solvent Depainting SB-101-33 small part and tool cleaning/removal of paint 16 306 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use 332 The Boeing Company - St. Louis Solvent Depainting SB-101-39 small part and tool cleaning/removal of paint 16 306 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use Chemical usage info is divided equallyamong SB-101-39, SB-101-47East, and SB101-47West since chemicals from the booths are taken from the same location. We cannot get any more specific.

332 The Boeing Company - St. Louis Solvent Depainting SB-101-40 small part and tool cleaning/removal of paint 8 250 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in useAppendix 3.2 Solvent Depainting ICR Survey Data 6

SPPD_FACILITY_ IDENTIFIER FACILITY_NAME EMISSION_PROCESS_GROUP EMISSION_UNIT_ID Purpose AvgHrs AvgDays CtrlID DevType CapEff CapEff_test CapEff_spec CapEff_est WorkPractice Comments

332 The Boeing Company - St. Louis Solvent Depainting SB-101-46 EAST small part and tool cleaning/removal of paint 8 306 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use 332 The Boeing Company - St. Louis Solvent Depainting SB-101-46 WEST small part and tool cleaning/removal of paint 8 306 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use Chemical usage info is divided equally among SB-101-46West and SB-101-46East since chemicals from both booths are taken from the same location. We cannot get any more specific.

332 The Boeing Company - St. Louis Solvent Depainting SB-101-47 EAST small part and tool cleaning/removal of paint 16 306 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use 332 The Boeing Company - St. Louis Solvent Depainting SB-101-47 WEST small part and tool cleaning/removal of paint 16 306 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use 332 The Boeing Company - St. Louis Solvent Depainting SB-63-01 small part and tool cleaning/removal of paint 16 357 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use Chemical usage info is divided equally among SB-63-01 and SB-63-02 since chemicals from both booths are taken from the same location. We cannot get any more specific. 332 The Boeing Company - St. Louis Solvent Depainting SB-63-02 small part and tool cleaning/removal of paint 16 357 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use 332 The Boeing Company - St. Louis Solvent Depainting SB-78-01 small part and tool cleaning/removal of paint 24 250 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use Chemical usage info is divided equally among SB-78-01, SB-78-02, and SB-78-03 since chemicals from the booths are taken from the same location. We cannot get any more specific. 332 The Boeing Company - St. Louis Solvent Depainting SB-78-02 small part and tool cleaning/removal of paint 24 250 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use 332 The Boeing Company - St. Louis Solvent Depainting SB-78-03 small part and tool cleaning/removal of paint 24 250 NA Controlled access to chemical stripper, require material to be stored in a closed container while not in use 358 Patrick Air Force Base Solvent Depainting Spot Depainting Spot depainting for checks such as corrosion control. 2 50 n/a Approximately 1 to 2 gallons are used per year, brush applied. This material use for spot depainting is considerably less than the 50 gallon per year per military aircraft allowance provided in the Aerospace NESHAP for spot depainting. Building height

v 377 Crider Aircraft Painting, Inc. Solvent Depainting Aircraft depainting process Remove organic coating 24 103 Fabric filter (other than spray booth fi 98 yes Product no longer used Currently using enviro-friendly paint remover, cost averages about 4 times as much. 384 Boeing Commercial Airplane Group-North Boeing Field Solvent Depainting Small touch up paint stripping and paint tounch up and paint gun repair There is minor solvent depainting operations at the facility however there is no purchase data for 2008. HAP estimates estimates above are based on 10 gallons used in 2008, and does not account for the fact that most of the material was discarded as wast

398 Boeing Everett Solvent Depainting Building 40-21 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-22 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-23 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-24 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-25 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-26 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-31 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-32 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-33 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-34 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-35 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-36 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-37 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 40-51 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 45-01 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 45-02 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 45-03 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use. 398 Boeing Everett Solvent Depainting Building 45-04 Depainting of small areas of aerospace components 24 250 Containers of depainting solvent are kept closed when not in use.Appendix 3.2 Solvent Depainting ICR Survey Data 7

SPPD_FACILITY_ IDENTIFIER FACILITY_NAME EMISSION_PROCESS_GROUP EMISSION_UNIT_ID Purpose AvgHrs AvgDays CtrlID DevType CapEff CapEff_test CapEff_spec CapEff_est WorkPractice Comments

428 Eagle Aviation Inc Solvent Depainting 1 Remove paint from aircraft 8 24 1 Scrubber 90 yes This Chemical is no longer used we have changed to a non- Regulated Chemical.

431 Robins Air Force Base Solvent Depainting D004 - Bldg 180 - Stripping Booths Depaint miscellaneous metal and composite aircraft components including wings and stabs 16 250 None None 0 N/A N/A N/A All equipment is operated and maintained according to manufacturer's specifications. Filter system complies with terms and conditions of Title V permit. No control device

433 Davis-Monthan Air Force Base, Tucson, AZ Solvent Depainting 21409 (Main Paint Hangar) Depainting Aircraft Parts 0 20 Product contains 0-1% sodium chromate, but none is expected to be released to the environment. 433 Davis-Monthan Air Force Base, Tucson, AZ Solvent Depainting 7428 (Maintenance Shelter) Depaint C-130 Flight Controls and Airframe and A10 Airframe 5 18 Product contains 1% chromic acid salt, but none is expected to be released to the environment. Dichloromethane and phenol values are the total in the product. Most of this goes into waste drums, the fraction that volatilzes has not been quantified so t

433 Davis-Monthan Air Force Base, Tucson, AZ Solvent Depainting Fac 7408 F-4 Hangar Depaint F-4 Airframe 0 15 433 Davis-Monthan Air Force Base, Tucson, AZ Solvent Depainting Fac 7436 Hydro Shop Depaint F-4 Struts 0 12 Product contains 1% chromic acid salt, but none is expected to be released to the environment. Dichloromethane and phenol values are the total in the product. Most of this goes into waste drums, the fraction that volatilzes has not been quantified so t

433 Davis-Monthan Air Force Base, Tucson, AZ Solvent Depainting Fac 7506 F-4 Hangar Depaint F-4 Airframe 0 15 Product contains 1% chromic acid salt, but none is expected to be released to the environment. Dichloromethane and phenol values are the total in the product. Most of this goes into waste drums, the fraction that volatilzes has not been quantified so t

438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-112-01 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-2544-01 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-2642-01 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-2681-01 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-2699-01 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-2699-01_1 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-2737-01 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-386-01 16 250 N/A N/A N/A N/A 438 Naval Air Station Whidbey Island (Ault Field) Solvent Depainting SDO-410-01 Spot stripping and decal removal; parts normally removed; <50 gallons average per aircraft per year 16 250 N/A N/A N/A N/A Mat'l-issue control limited to 50 gal./aircraft/year; closed containers when not in use; written procedures limit which parts may be depainted average gallons/aircraft/year <2.0

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Spray Booth 1 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Spray Booth 1

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Spray Booth 2 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Spray Booth 2

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Spray Booth 3 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Spray Booth 3

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Spray Booth 4 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Spray Booth 4

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Spray Booth 5 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Spray Booth 5

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Spray Booth 6 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Spray Booth 6

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Stencil Booth 1 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Stencil Booth 1

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Stencil Booth 2 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Stencil Booth 2

450 Raytheon Integrated Air Defense Center Solvent Depainting SD Indoor Paint Stencil Booth 3 Touch-up 8 260 Good housekeeping and only using the amount appropriate for the job. Vents through Indoor Paint Stencil Booth 3

468 The Boeing Company - San Antonnio Solvent Depainting 0361Z55901 Remove paint from aircraft prior to painting 24 365 0 No VOC control device

468 The Boeing Company - San Antonnio Solvent Depainting 0375Z05901 Remove paint and coatings from parts 16 260 0 No VOC control device

473 The Boeing Company, Defense, Space & Security, Rotorcraft Programs, Philadelphia Solvent Depainting Building 3-12 Paint Stripper clean transmission parts 16 365 100 All of the paint stripper emissions, which were calculated by mass balance, are emitted through the room ventilation stack. The mass balance emissions are all-inclusive and there are no fugitive emissions.

487 Rolls-Royce Corporation Solvent Depainting 13E (Bay S13) Paint Strip 3 50 n/a Keep containers closed No longer in operation 5014 AVIATION TECHNICAL SERVICES, INC. Solvent Depainting Paint Stripping - Bay 4 Remove paint from aerospace components 16 365 N/A

5019 NASA Ellington Field Solvent Depainting E136-PS1-15073 General Paint Stripping 8 50 NA Containers kept closed except for removing product. Excess fluids are cleaned up and stored in sealed containers.

5019 NASA Ellington Field Solvent Depainting E136-ST7-4563 T38 lower strut inspection 8 50 NA Containers kept closed except for removing product. Excess fluids are cleaned up and stored in sealed containers.

5019 NASA Ellington Field Solvent Depainting E276-PR3500 T38 lower strut inspection 8 50 NA Containers kept closed except for removing product. Excess fluids are cleaned up and stored in sealed containers.Appendix 3.2 Solvent Depainting ICR Survey Data 8

SPPD_FACILITY_ IDENTIFIER FACILITY_NAME EMISSION_PROCESS_GROUP EMISSION_UNIT_ID Purpose AvgHrs AvgDays CtrlID DevType CapEff CapEff_test CapEff_spec CapEff_est WorkPractice Comments

5020 NASA Lyndon B. Johnson Space Center Solvent Depainting B9PAINT01 Rework of parts 0 230 NA Containers kept closed except for removing product. Excess fluids are cleaned up and stored in sealed containers.

5025 Randolph Air Force Base Solvent Depainting SDPB230 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5025 Randolph Air Force Base Solvent Depainting SDPH3 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5025 Randolph Air Force Base Solvent Depainting SDPH4 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5025 Randolph Air Force Base Solvent Depainting SDPH40 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5025 Randolph Air Force Base Solvent Depainting SDPH41 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5025 Randolph Air Force Base Solvent Depainting SDPH48 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5025 Randolph Air Force Base Solvent Depainting SDPH5 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5025 Randolph Air Force Base Solvent Depainting SDPH61 Remove paint from air craft components for Non Destructive Inspections. 0 3 N/A N/A N/A N/A N/A This activity occurs 30 times per year across the installation. The activity lasts approximately one hour. 5032 American Airlines - AFW Solvent Depainting 4021571 Remove paint from exterior of aircraft 1 12 Please note that the use of methylene chloride was discontinued in 2009. 513 GKN Aerospace - St. Louis Solvent Depainting MC-STL-01 Limited or spot treatment depainting 1 255 No control Depainting is limited in scope (2010 Data) Depainting at this facilty is limited to spot depainting to correct a nonconformance to the part specification or other minor defeciency discovered during inspection/verification.

529 United States Army Garrison Fort Wainwright, Alaska Solvent Depainting SD-2077 Spot depainting: preparation for Non-destructive inspection 1 100 N/A N/A N/A N/A N/A N/A

532 Boeing Auburn Solvent Depainting 17-07 Removing dried paint from paint application equipment and correction of manufacturing errors

on aero 0 44 0 Use of closed containers for storing and disposal of VOC-containing wastes. Depainting is done via hand-wipe solvents. Emissions are fugitive (zero capture efficiency)Depainting was performed approximately once per week for approximately 10 minutes at a time. Days per year were calculated by multiplying 1 time per week x 44 week 532 Boeing Auburn Solvent Depainting 17-45 Correction of manufacturing errors on aerospace parts 0 5 0 Use of closed containers for storing and disposal of VOC-containing wastes. Depainting is done via hand-wipe solvents. Emissions are fugitive (zero capture efficiency. Depainting is performed for approximately 0.5 hours once every two months. Days per year were calculated by multiplying 0.5 times per month x 10 months (reduced n

532 Boeing Auburn Solvent Depainting 17-62 Primarily correction of manufacturing errors on aerospace parts and a small amount of dried paint re 1 60 0 Use of closed containers for storing and disposal of VOC-containing wastes. Depainting is done via hand-wipe solvents. Emissions are fugitive (zero capture efficiency). Depainting is performed approximately 6 times per month for total of approximately 9 hours per month. Days per year reported above were calculated by multiplying

532 Boeing Auburn Solvent Depainting 17-68 Correction of manufacturing errors on aerospace parts 0 88 0 Use of closed containers for storing and disposal of VOC-containing wastes. Depainting is done via hand-wipe solvents. Emissions are fugitive (zero capture efficiency) Depainting is performed approximately 0.5 hour twice per week. Days per year reported above were calculated by multiplying 2 times per week x 44 weeks (reduced nu 6001 Gulfstream Aerospace Corporation Solvent Depainting Aircraft Paint Stripping Stripping aircraft and parts for the purpose of re-painting or repair 10 23 Drums containing MeCl remain closed, unless it is being applied to the aircraft. The blower fans are ran at a speed not to exceed 60%, to minimize evaporation during the stripping process. As recommended by the manufacturer, the booth temperature during

6001 Gulfstream Aerospace Corporation Solvent Depainting Miscellaneous Parts Stripping - Fugitive Stripping aircraft parts for the purpose of re-painting or repair 8 5 Containers of material containing MeCl remain closed, unless it is being applied to the aircraft parts. Section I, Question #2: Location was picked as an arbitrary point on the Main Facility. Section I, Question #5: Estimated value due to multiple users. 6001 Gulfstream Aerospace Corporation Solvent Depainting Miscellaneous Parts Stripping - P13 Stripping aircraft parts for the purpose of re-painting or repair 10 6 Containers of material containing MeCl remain closed, unless it is being applied to the aircraft parts. Section I, Question #5: Estimated value due to multiple users

6001 Gulfstream Aerospace Corporation Solvent Depainting Miscellaneous Parts Stripping - P15 Stripping aircraft parts for the purpose of re-painting or repair 8 1 Containers of material containing MeCl remain closed, unless it is being applied to the aircraft parts. Section I, Question #5: Estimated value due to multiple users

6003 Dallas Love Field Solvent Depainting Strip-1 Remove paint from aircraft 10 300 viscous liquid applicationAppendix 3.2 Solvent Depainting ICR Survey Data 9

SPPD_FACILITY_ IDENTIFIER FACILITY_NAME EMISSION_PROCESS_GROUP EMISSION_UNIT_ID Purpose AvgHrs AvgDays CtrlID DevType CapEff CapEff_test CapEff_spec CapEff_est WorkPractice Comments

6005 Gulfstream Aerospace Corporation Solvent Depainting Building O (1) removing finish/clear off interior wood furniture components (2) refurb paint guns 20 260 store fresh materials in closed containers, collect and store waste stripping materials in closed containers Use small amount of methylene chloridebased stripper for stripping wood furniture

6005 Gulfstream Aerospace Corporation Solvent Depainting SC01 (1) depainting of aircraft exterior (2) refurb paint guns 20 300 store fresh materials in closed containers, collect and store waste paint stripping materials in closed containers (1) Use a benzyl alcohol-based paint stripper that contains no HAPs for depainting aircraft (2) small amount of methylene chloride based paint stripper used for cleaning of paint guns one time in 2008

6005 Gulfstream Aerospace Corporation Solvent Depainting SC02 (1) refurb paint guns 20 300 store fresh materials in closed containers, collect and store waste stripping materials in closed containers Use small amount of methylene chloride based paint stripper for refurbishing paint guns one time in 2008

6005 Gulfstream Aerospace Corporation Solvent Depainting SC06 (1) refurb paint guns 24 365 store fresh materials in closed containers, collect and store waste stripping materials in closed containers Use small amount of methylene chloride based paint stripper for refurbishing paint guns one time in 2008

6005 Gulfstream Aerospace Corporation Solvent Depainting Service Center (1) removing finish/clear off interior wood furniture components (2) spot stripping aircraft 24 365 store fresh materials in closed containers, collect and store waste stripping materials in closed containers Use small amount of methylene chloridebased stripper for stripping wood furniture and for spot stripping of aerospace vehicle

603 US Airways Pittsburgh International Airport Solvent Depainting SSB-4-B Cleaning and paint removing on parts 8 365 NA NA

626 Kaman Aerospace Corporation - Helicopters Division Solvent Depainting 2B Paint Shop Stripping Localized/Detailed touch up coating removal 0 1 N/A N/A N/A N/A Established applicable KHE Standard production and housekeeping Operation Procedures. This stripping operation involves limited use of S1709 Stripper. This stripping operation is utilized on as-needed basis on difficult to access areas of aerospace parts, which areeither in need of detailing, re-painting or reprocessing due to quality co

626 Kaman Aerospace Corporation - Helicopters Division Solvent Depainting 30B Paint Shop Stripping Localized/Detailed touch up coating removal 0 1 N/A N/A N/A N/A Established applicable KHE Standard production and housekeeping Operation Procedures. This stripping operation involves limited use of S1709 Stripper. This stripping operation is utilized on as-needed basis on difficult to access areas of aerospace parts, which areeither in need of detailing, re-painting or reprocessing due to quality co

634 U.S. Naval Station Mayport Solvent Depainting Bldg. 1553 Depainting of various aircraft components. 1 250 N/A Other (specify in comments) 0 N/A N/A N/A Keep containers closed when not in use. Fugitive Emissions no control device used.

652 PGM of New England LLC Solvent Depainting MS-111 Remove paint from antennas during refurbishing 1 12 N/A None

663 Hill Air Force Base Solvent Depainting 107642 CHEMICAL STRIPPING 1 44 Paint booth control Paint booth filter control 99.2 none chrome emissions reported as hexavalent Cr emissions; Paint booth filter control; process takes place inside of a paint booth.

663 Hill Air Force Base Solvent Depainting 109481 CHEMICAL STRIPPING 1 44 none Chrome emissions reported as hexavalent Cr emissions. Chemical stripping taking place outside of a booth.

672 Honeywell Aerospace Solvent Depainting Paint Stripping (P005) Depainting 9 270 Compliance with 40 CFR 63, Subpart HHHHHH 683 U.S. Coast Guard Base Support Unit Kodiak Solvent Depainting Paint Stripping Surface preparation 4 8 Paint stripping operation is perormed in the paint booth. HAP emmisions were calculated by information provided on MSDS [(VOC 1.7 lbs/gal*4 gal used)(ingredient %/total HAP%)] 693 Sikorsky Aircraft Corporation - Stratford Facility Solvent Depainting Ardrox 3000W Depainting of aircraft and parts 12 115 N/A (see comments below) N/A N/A N/A None The depainting operation is performed in one of the Finishes Building paint cells. The latitude and longitude provided are for the booth exhaust stacks. There is a water floor control system for particulate, but there are no controls for organic emissio