MEMORANDUM

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

FROM: Eastern Research Group, Inc. (ERG)

DATE: January 21, 2015

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, either 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 milling 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 conducted 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 

practices, 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 considered during MACT development) that could result in significant 

additional emission reduction;

• Any work practice or operational procedure that was not identified and considered 

during MACT development;

www.erg.com

1
• Any process change or pollution prevention alternative that could be broadly applied 

that was not identified and considered 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 original 

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 TECHNOLOGY 

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 California 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 pollution 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 Available 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 areas). 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 established 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 related 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 and 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 preliminary 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 the 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. This 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 surface 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 permits 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 strippers” 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 limitations 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 subsequent 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 regulatory 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 add-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 

subcategory 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 Coating 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 application 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 affected source for each coating category or subcategory in each of these 

NESHAP.

4

 
Table 1. Subsequent Regulatory Actions for Sources Similar to 

Aerospace Depainting Operations

Nine Metal 

Fabrication 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 District (SCAQMD), the San Diego County Air Pollution Control District 

(SDAPCD), the Ventura County Air Pollution Control 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 sources 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 collectors. For 

chemical stripping, work practices and low or non-MeCl strippers are reported, with the HAPcontaining 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 may 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 through evaporation 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 per 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 Depainting 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 Technology 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 (That 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 primers, 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 discontinued, 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 provisions, 

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 additional 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 Depainting
Appendix 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 MediaVacuum 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 MDepaint 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-CYCLOTotally 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-Rotoclone
Appendix 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 1Fully 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 GritClean 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 GritClean 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 PMB
Appendix 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) collector
Appendix 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/A
Appendix 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 equally 

among 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 use
Appendix 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 application
Appendix 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 are 

either 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 are 

either 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