1 

MEMORANDUM 

TO: Anne Pope and Kim Teal, U.S. EPA 

FROM: Stacie Enoch, Jason Huckaby, Ashley Penrod, and Darcy Wilson, ERG 

DATE: December 17, 2014 

SUBJECT: Aerospace Manufacturing and Rework Facilities RTR Modeling File Preparation 

I. Introduction 

The purpose of this memorandum is to provide information on the U.S. Environmental Protection 

Agency (EPA) Risk and Technology Review (RTR) database used in estimating residual risk for the 

Aerospace Manufacturing and Rework Facilities National Emission Standards For Hazardous Air 

Pollutants (NESHAP) source category. This NESHAP covers only major sources. 

Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to address 

emissions of hazardous air pollutants (HAPs) from stationary sources. In the first stage, section 

112(d) requires the EPA to develop technology-based standards for categories of industrial sources. 

In the second stage, known as the residual risk stage, section 112(f)(2) requires EPA to assess the 

health and environmental risks that remain after sources come into compliance with standards 

based on the Maximum Achievable Control Technology (MACT). If additional risk reductions are 

necessary to protect public health with an ample margin of safety or to prevent adverse 

environmental effects, EPA must develop standards to address these remaining risks. As part of this 

second stage, data were gathered to assess the residual risks from the Aerospace Manufacturing 

NESHAP source category. 

The 2002 National Emissions Inventory (NEI) data served as the starting point for the initial phase of

this assessment. Using the process regulatory code,1 a subset of the NEI was developed that 

contained facility, process, and emissions data for each facility potentially subject to the Aerospace

Manufacturing and Rework Facilities NESHAP (40 CFR 63, subpart GG) and in the Aerospace 

Manufacturing source category (regulatory code 63GG). The 2002 NEI data for Aerospace 

Manufacturing facilities were released through an Advanced Notice of Proposed Rulemaking (ANPR) 

in March of 2007, where NEI revisions for facilities in the MACT source category were solicited from 

State and local agencies, industry representatives, and EPA. The revisions that were provided to EPA 

were incorporated into the 2005 NEI. 

The 2005 NEI data then served as the starting point for the next phase of the RTR assessment. 

 

1

 Assigning data with regulatory codes allows EPA to determine reductions attributable to the MACT program. The 

NEI associates regulatory codes corresponding to MACT source categories with stationary major and area source 

data. 

www.erg.com 
2 

On February 4, 2011, EPA sent out an information collection request (ICR) requesting data on 

aerospace-related processes and general information about each facility. Information was requested 

on operations subject to 40 CFR 63, subpart GG (coatings, blast depainting operations, solvent 

depainting operations, and solvent cleaning operations) as well as specialty coatings, chemical 

milling and metal finishing operations, composite processing, storage tanks, and wastewater 

treatment. Information was also requested on booth characteristics and control devices and 

locational coordinates. 

On October 2, 2012, EPA sent out an ICR requesting stack emissions testing data for select coating 

operations and spray booths and blast depainting, composite processing and metal finishing 

operations. 

On May 23, 2013, EPA provided the estimated facility-wide emissions rates for major sources and 

synthetic minor sources based on the results of the ICR data collection effort for industry review. 

On September 18, 2013, EPA issued a request for supplemental coatings analyses for select facilities. 

On May 15, 2014, EPA provided industry the opportunity for a final review of the estimated 

emissions (and emission estimation methods) for processes subject to 40 CFR 63, subpart GG and 

other processes included in the February 4, 2011 ICR request, as well as other facility operations 

included in the 2011 NEI. Review comments were also solicited on stack parameters (including 

fugitive area dimensions) and locational coordinates. 

The following sections detail how EPA calculated emissions and conducted quality assurance/quality 

control (QA/QC) of the data. 

II. Category and Specialty Coatings Actual Emissions Development 

a. Regulated processes included coatings, blast depainting, solvent depainting, and 

solvent cleaning. Non-regulated processes included specialty coatings, chemical 

milling and metal finishing, composite processing, storage tanks, and wastewater 

treatment. 

b. February 4, 2011 ICR Data Compilation 

The ICR requested data on coating usage and physical property data, emissions, booth 

characteristics, and locational coordinates. Forms A-1 and A-2 requested facility 

address and contact information. Form B-1 requested paint spray-booth-specific 

information. Form C-1 (and C-2 in metric units) requested coating usage and physical 

property data that EPA then used in calculating HAP emission estimates. Forms D-1, 

E-1 through E-3, G-1, and H-1 requested HAP emission estimates from tanks used for 

chemical milling or metals finishing operations, blast depainting/cleaning operations, 

solvent depainting operations, solvent cleaning operations, storage tanks, and 

wastewater treatment. Form F-1 requested resins usage and physical property data 

that EPA then used in calculating HAP emission estimates from composites processing 

operations. Forms J-1 through J-10 requested information specific to each control 

device used. 
3 

c. Development of Actual Emissions Estimates 

The following equations and assumptions were used to develop actual emissions 

estimates from the ICR data. 

Coating Operations (C1)

Emissions were calculated for each HAP within a coating and for each booth in which 

the coating was used. The following equations were used to calculate coating 

emissions in tons per year. 

• Organic HAP stack emissions from coating usage inside a booth: 

	 ∗ 	

 ∗ 		
	 ∗

(

		
	
	
h/100) ∗ ("
	#$$
/100) ∗

(1 − (
	#$$
/100)) ∗ (1/2000) 

• Organic HAP fugitive emissions from coating usage inside a booth: 

	 ∗ 	

 ∗ 		
	 ∗

(

		
	
	
h/100) ∗ (1 − "
	#$$
/100) ∗

(1/2000) 

• Organic HAP fugitive emissions from coating usage outside of a booth: 

	 ∗ 	

 ∗ 		
	

∗ (

		
	
	
h/100) ∗ (1/2000)

• Inorganic HAP stack emissions: 

	 ∗ 	

 ∗ 		
	 ∗

(

	 
	
	
h 100 ⁄ ) ∗ (


	
 ∗

("
	#$$
/100) ∗ (1 − (
	
	#$$
/100)) ∗

(1/2000) 

• Inorganic HAP fugitive emissions: 

	 ∗ 	

 ∗ 		
	 ∗

(

	 
	
	
h 100 ⁄ ) ∗ (


	
	 ∗ (1 −

"
	#$$
/100) ∗ (1/2000) 

• Inorganic HAP fugitive emissions (out of booth usage): 

	 ∗ 	

 ∗ 		
	 ∗

(

	 
	
	
h 100 ⁄ ) ∗ (


	
 ∗(1/2000) 

Where: 

Volume = total coating volume used (gal/yr); 
4 

Density = density of the coating (lb coating/gal coating);

HAP Mass Fraction = the fraction of a specific HAP in the coating (lb HAP/lb 

coating); 

Coating Usage Pct = the portion of the annual coating usage at the specified 

location (i.e., in the identified booth, or outside of booth usage); 

Adjustment Factor = factor to account for the transfer of coating solids to the 

part being coated (assumed 65%) and fallout for coatings applied within a 

booth (assumed 50%); 

Capture Efficiency = the percent of emissions captured by the booth; 

Control Efficiency = the percent reduction achieved by the control device 

(organic); 

Filter control efficiency = the percent reduction achieved by the booth filter 

(inorganic HAP). 

Assumptions

• Due to the overall lack of control efficiency data, all control efficiency values 

were assumed based on the type of control device (95% emission control for 

carbon adsorbers and scrubbers and 98% control for thermal incinerators). If no 

control device was listed, the control efficiency was assumed to be zero. 

• All materials applied inside a booth were assumed to be spray applied. 

• If no filter control efficiency was provided, a value of 98% was assumed. 

• If no capture efficiency was provided, the capture efficiency was assumed based 

on the booth type and pollutant type. 

o For organic pollutants, the capture efficiencies were assumed to be as 

follows: (open/open face/other: 90%, permanent total enclosure (PTE): 

100%; enclosed but not a PTE: 98%); if the facility did not provide a 

capture efficiency or booth type, a value of 90% was assumed. 

o For inorganic pollutants, the capture efficiencies were assumed to be as 

follows: (open/open face/other: 99%, permanent total enclosure (PTE): 

100%; enclosed but not a PTE: 99.5%); if the facility did not provide a 

capture efficiency or booth type, a value of 99% was assumed. 

• It was assumed that inorganic fugitive emissions from application of coatings 

outside of the booth are zero if the coatings were not spray applied. If the 

coatings were spray applied, the transfer efficiency was assumed to be 65%. If 

the application method for coatings applied outside of the booth was not 

specified, it was assumed to be spray applied. 

Chemical Milling and Metal Finishing Operations (D1) 

Facilities conducting these types of operations were required to report emissions 

directly instead of providing the usage/composition data required to calculate 

emissions (such as in C1). Therefore, the only calculation required was to convert 

emissions from pounds per year to tons per year. 
5 

Blast Depainting/Cleaning Operations (E1), Solvent Depainting Operations (E2), and 

Storage Tanks (G1)

Facilities conducting these types of operations were required to report emissions 

directly instead of providing the usage/composition data required to calculate 

emissions (such as in C1). However; it was assumed that the emission values reported 

(Emislbyr in equations below) were stack emissions after capture and control, and it 

was therefore necessary to back-calculate the fugitive emissions from the stack 

emissions. The following equations were used to calculate emissions for E1, E2, and 

G1 operations in tons per year. 

• Stack emissions: 

# ∗ (1/2000) 

• Fugitive emissions for units not equipped with a control device: 

(#/("
	#$$
/100)) ∗ (1

− ("
	#$$
/100)) ∗ (1/2000)	

• Fugitive emissions for units equipped with a control device: 

(#/(("
	#$$
/100) ∗ (1 − (
	#$$
/

100)))) ∗ (1 − ("
	#$$
/100)) ∗ (1/2000) 

Assumptions

• As stated above, it was assumed that the emission values reported in the 

survey are stack emissions after capture and control. 

• If no capture efficiency was provided, a value of 70% was used for E1 and E2 

operations, and zero was used for G1 operations. 

• All control efficiency values were assumed based on the type of control device, 

as outlined for C1 operations. 

• If a facility indicated that total mass balance emissions were reported instead 

of stack emissions after control, then the emissions were adjusted to take into 

account the capture and control efficiencies as requested. 

Solvent Cleaning Operations – Point and Fugitive Sources (E3)

Facilities conducting solvent cleaning operations were required to report emissions 

directly as either stack or fugitive emissions. Therefore, the only calculation required 

was to convert emissions from pounds per year to tons per year. 

Composite Processing Operations (F1 Resins)

Emissions were calculated for each HAP within the resin and for each booth in which 

the resin was used. The following equations were used to calculate emissions from 

composite processing operations in tons per year. 
6 

• Stack emissions: 

	 ∗ 	

 ∗ 		
	 ∗ (
		

/100) ∗

()
		
	
	
h/100) ∗ ("
	#$$
/100) ∗ (1 −

(
	#$$
/100)) ∗ (1/2000) 

• Fugitive emissions: 

	 ∗ 	

 ∗ 		
	 ∗ (
		

/100) ∗

()
		
	
	
h/100) ∗ (1 − ("
	#$$
/100)) ∗

(1/2000) 

• Fugitive emissions (out of booth usage): 

	 ∗ 	

 ∗ 		
	 ∗ (
		

/100) ∗

()
		
	
	
h/100) ∗ (1/2000) 

Assumptions

• All control efficiency values were assumed based on the type of control device, 

as outlined for C1 operations. 

• All materials applied inside a booth were assumed to be spray applied. 

• If no capture efficiency was provided, the capture efficiency was assumed 

based on the booth type and pollutant type. 

o For organic pollutants, the capture efficiencies are assumed to be as 

follows: (open/open face/other: 90%, permanent total enclosure (PTE): 

100%; enclosed but not a PTE: 98%); if the facility did not provide a 

capture efficiency or booth type, a value of 90% was assumed. 

o For inorganic pollutants, the capture efficiencies are assumed to be as 

follows: (open/open face/other: 99%, permanent total enclosure (PTE): 

100%; enclosed but not a PTE: 99.5%); if the facility did not provide a 

capture efficiency or booth type, a value of 99% was assumed. 

• For outside the booth application, if the percent HAP emitted was not 

provided, a value of 100 percent was assumed for organic pollutants. For 

inorganic pollutants from resins that are applied outside of a booth that are 

not spray applied, it was assumed that 0% was emitted. If the out of booth 

resins are spray applied, the transfer efficiency was assumed to be 65% (or 35% 

emitted). If the application method for resins applied outside of the booth was 

not specified, it was assumed to be spray applied. 

• For inorganic pollutants from resins applied inside a booth, the percent HAP 

emitted was adjusted to account for an assumed transfer efficiency of 65% and 

50% fallout within the booth (see adjustment factor used in equations for C1). 

Wastewater Treatment Operations (H1)

Facilities conducting wastewater treatment operations were required to report 

emissions directly as either stack or fugitive emissions. Therefore, the only calculation 

required was to convert emissions from pounds per year to tons per year. 
7 

Assumptions

It was assumed that the reported stack emission values are after capture and control. 

Therefore, no capture or control efficiencies were applied. If a facility did not report 

whether an emission value was fugitive or stack, it was assumed to be stack. 

d. Regulatory Code and Emission Process Group Assignments 

i. The regulatory code “63GG” was assigned for processes that are currently 

subject to 40 CFR 63, Subpart GG: coatings, blast depainting, solvent 

depainting, and solvent cleaning. 

ii. Emission process group and source classification code (SCC) were assigned as 

shown below based on information provided in the ICR response: 

 

Table 1. Aerospace Manufacturing and Rework Emission Process Groups and SCCs

EMISSION_PROCESS_GROUP SCC SCC Description 

Blast Depainting 30900201

Industrial Processes; Fabricated Metal Products; Abrasive 

Blasting of Metal Parts; General 

Blast Depainting 68241001

MACT Source Categories; Miscellaneous Processes; Paint 

Stripper Users - Non-chemical Strippers; Media Blasting 

Coatings 40202401

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Large Aircraft; Prime Coating Operation

Coatings 40202406

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Large Aircraft; Topcoat Operation 

Coatings 40202499

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Large Aircraft; Other Not Classified 

Solvent Cleaning 40202402

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Large Aircraft; Cleaning/Pretreatment 

Solvent Depainting 68240030

MACT Source Categories; Miscellaneous Processes; Paint 

Stripper Users - Chemical Strippers; Application, 

Degradation, and Coating Removal Steps 

Specialty Coatings 40200801

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Coating Oven - General; General 

Specialty Coatings 40202401

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Large Aircraft; Prime Coating Operation

Specialty Coatings 40202406

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Large Aircraft; Topcoat Operation 

Specialty Coatings 40202499

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Large Aircraft; Other Not Classified 

Chemical Milling and Metal 

Finishing 30901018

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Hard Chromium - Electroplating 

Tank 
8 

Table 1. Aerospace Manufacturing and Rework Emission Process Groups and SCCs

EMISSION_PROCESS_GROUP SCC SCC Description 

Chemical Milling and Metal 

Finishing 30901038

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Chromic Acid Anodizing -

Anodizing Tank 

Chemical Milling and Metal 

Finishing 30901042

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Copper (cyanide, including strike) 

- Electroplating Tank 

Chemical Milling and Metal 

Finishing 30901048

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Copper (general) - Electroplating 

Tank 1000 amp-hr current applied 

Chemical Milling and Metal 

Finishing 30901052

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Cadmium (cyanide) - 

Electroplating Tank 1000 amp-hr current applied 

Chemical Milling and Metal 

Finishing 30901058

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Cadmium (general) - 

Electroplating Tank 1000 amp-hr current applied 

Chemical Milling and Metal 

Finishing 30901065

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Nickel (sulfamate or watts) - 

Electroplating Tank 1000 amp-hr current 

Chemical Milling and Metal 

Finishing 30901068

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Nickel (general) - Electroplating 

Tank 

Chemical Milling and Metal 

Finishing 30901098

Industrial Processes; Fabricated Metal Products; 

Electroplating Operations; Other Not Classified 

Chemical Milling and Metal 

Finishing 30901101

Industrial Processes; Fabricated Metal Products; Conversion 

Coating of Metal Products; Alkaline Cleaning Bath 

Chemical Milling and Metal 

Finishing 30901102

Industrial Processes; Fabricated Metal Products; Conversion 

Coating of Metal Products; Acid Cleaning Bath (Pickling) 

Chemical Milling and Metal 

Finishing 30901103

Industrial Processes; Fabricated Metal Products; Conversion 

Coating of Metal Products; Anodizing Kettle 

Chemical Milling and Metal 

Finishing 30901199

Industrial Processes; Fabricated Metal Products; Conversion 

Coating of Metal Products; Other Not Classified 

Chemical Milling and Metal 

Finishing 30901501

Industrial Processes; Fabricated Metal Products; Chemical 

Milling of Metal Products; Milling Tank 

Chemical Milling and Metal 

Finishing 30904001

Industrial Processes; Fabricated Metal Products; Metal 

Deposition Processes; Metallizing: Wire Atomization and 

Spraying 

Chemical Milling and Metal 

Finishing 30904010

Industrial Processes; Fabricated Metal Products; Metal 

Deposition Processes; Thermal Spraying of Powdered Metal 

Chemical Milling and Metal 

Finishing 30999999

Industrial Processes; Fabricated Metal Products; Other Not 

Classified; Other Not Classified 
9 

Table 1. Aerospace Manufacturing and Rework Emission Process Groups and SCCs

EMISSION_PROCESS_GROUP SCC SCC Description 

Composite Processing 30800720

Industrial Processes; Rubber and Miscellaneous Plastics 

Products; Fiberglass Resin Products; General 

Storage Tanks 40100550

Petroleum and Solvent Evaporation; Organic Solvent 

Evaporation; Solvent Storage; General Processes: Drum 

Storage - Pure Organic Chemicals 

Wastewater Treatment 40282001

Petroleum and Solvent Evaporation; Surface Coating 

Operations; Wastewater, Aggregate; Process Area Drains 

III. Testing ICR 

a. The test data were reviewed to confirm there were no additional source ID or 

pollutant matches that were missed when incorporating test data into the modeling 

file. 

b. The methodology that was used to include (or not include) emissions test data in 

the modeling file was reviewed. Findings were as follows: 

 

 Test data were compiled for 15 facilities. 

 The compiled test data for one facility were not included for modeling file 

updates, because the units of measure could not be converted to a pound per 

hour or other comparable emissions rate. 

 One test point for one facility was excluded from the modeling file updates, 

because it overlapped with a different test point that was included in the 

modeling file updates. 

 With the exception of the test point noted above, test data for the remaining 

14 facilities were added to the modeling file if the data met three criteria: 

• There was at least one test run where emissions were not below 

detection limits. For the purpose of the aerospace source category risk 

analysis, test points where all three runs were below detection limits 

were assumed to not emit that HAP from that process type and these 

emissions were not included in the risk modeling file. This assumption 

was made for this source category because of the variability in 

processes and input materials used at aerospace facilities (for example, 

some coatings do not contain certain HAP and, therefore, are not 

expected to be sources of those HAP). 

• The data that could be mapped to source IDs were already included in 

the modeling file. 

• The test pollutants were not reported in the original ICR data. If the test 

pollutants were already reported in the original ICR data for the 
10 

corresponding source ID, then the stack test data were not added to the 

modeling file. 

 If the test data met the three criteria, then the average emissions from the test 

runs were added to the modeling file. If at least one run was above the 

detection limit, one-half of the detection limit was used for any runs that were 

below the detection limit. If all three runs were below the detection limit, then 

emissions of that HAP were assumed to not be present for that process in the 

aerospace source category. Stack test data were added to the modeling file for 

11 out of 14 facilities. (Although it is common practice to use one half of the 

detection limit for below detection limit in other source categories, the 

methodology used in developing the aerospace risk modeling file reflects the 

fact that some HAP are not present in the coatings and other raw materials used 

in aerospace processes and are not expected to be emitted.) 

c. Industry-supplied materials and prior EC/R analysis of emissions test data and 

capture efficiencies were reviewed to determine whether any calculations or 

assumptions currently used should be revised. 

d. Emissions test data amendments and results of coatings test data were reviewed to: 

1) identify which pollutants in the emissions test data were not being reported 

under material balance-based coatings records already (i.e., should be added to the 

coatings category records); 2) which pollutants were measured in the emission 

tests, but were not found in coatings tests, and therefore should not be allocated to 

the coatings process group; 3) confirm that those pollutants in the emissions test 

data that were not flagged for appending were reflected in material balance-based 

coatings records; and 4) provide analytical test data instead of MSDS-supplied 

metals content values where the tested coating could be matched up to coatings 

reportedly being used. 

IV. Speciation 

a. Chromium (Cr) emissions from coatings and specialty coatings were speciated into 

its two most prevalent oxidation states: trivalent chromium (Cr III) and hexavalent 

chromium (Cr VI). Chromium from ICR processes were speciated using a profile of 

20.6% Cr VI and 79.4% Cr III. The coatings test results showed that strontium 

chromate is the predominant compound. Therefore, as a first step, a 25.5% weight 

fraction was applied to estimate how much of the compound is chromium. The 

25.5% weight fraction was then multiplied by 0.807 to adjust this factor downward, 

because the test results indicated that not all of the Cr in the coatings is Cr VI. The 

average ratio of Cr VI to Cr in the coatings test data is 0.807, as can be seen in the Cr 

VI to Cr ratio calculation from coatings test data found in Appendix A. Records that 

were previously speciated using a 25% Cr VI/75% Cr III were re-speciated using the 

profile described above for ICR processes. 
11 

b. Mercury (Hg) emissions were speciated into three forms (elemental gaseous, 

particulate divalent, and gaseous divalent) using SCC-based NEI defaults. If a SCC 

from the modeling file did not match the NEI defaults, the generic 20% particulate 

divalent, 30% gaseous divalent, and 50% elemental gaseous profile was used. 

V. Industry Reviews 

a. Draft modeling file records were provided to all parent companies (in the EPA 

modeling file format) on May 15, 2014, for review. The file included the coating 

emission calculations in addition to modeling data. EPA provided review files to 

171 facilities. Responses were received for 84 facilities. Nine facilities were not 

included in the draft modeling file as of May 2014 and were added after the industry 

review period. 

b. Revisions to the modeling file records included changes to emission values, control 

device types, stack parameters, locational coordinates, fugitive area dimensions, 

pollutant information, and removal of units or processes that are shutdown or 

otherwise not part of the facility. Revisions to the coating calculations included 

adding missing coatings and pollutants, removing pollutants no longer emitted, and 

revising the coating calculation inputs (volume, density, HAP mass fraction, coating 

usage percent, booth type and capture percent, control efficiency, filter control 

efficiency, and the adjustment factor). 

VI. Development of Allowable Emissions for Category 

Facilities were asked to provide a multiplier in the ICR survey to scale up average hourly 

emissions to maximum hourly emissions for air dispersion modeling. As there are typically a 

large number of emission points at a facility, determining the maximum hourly emissions 

from each and every emission point can be difficult. Therefore, EPA chose to use a single 

multiplier of 1.02 to scale average annual emissions to allowable annual emissions. The 

allowable emissions multiplier is based on the difference between 2008 production 

utilization rate of 83.1 and the 20-year historical maximum production utilization rate of 

85.0 (i.e., 85 ÷ 83.1 = 1.02). 

VII. Development of Acute Emissions for Category 

EPA determined that an acute factor of 1.2 was appropriate for the aerospace 

manufacturing industry. This multiplier is based on the ratio of the 2008 production 

utilization rate (83.1) and the maximum production rate of 100 (i.e., 100 ÷ 83.1 = 1.2). 

VIII. Non-Category Aerospace Manufacturing Facility Emissions 

a. Non-category emissions for aerospace manufacturing facilities were obtained from 

the 2011 NEI. Non-category emissions were not available in the 2011 NEI or 2008 NEI 

for three facilities; emissions were pulled from the 2005 National-Scale Air Toxics 

Assessment (NATA) inventory for these three facilities. 
12 

b. Appendix B shows a list of SCCs that were included in the non-category records. 

Appendix C shows a list of additional SCCs that were included in the non-category 

records only if the record had the specific unit description shown. Individual 

chromium records were excluded if they were found to overlap with a regulated 

process. 

c. Speciation 

i. Chromium 

SCC-based NEI Cr speciation defaults were used for non-ICR processes. If a SCC 

from the modeling file did not match the NEI default, the Cr profile for ICR 

processes was used. 

ii. Mercury 

Mercury (Hg) emissions were speciated into three forms (elemental gaseous, 

particulate divalent, and gaseous divalent) using SCC-based NEI defaults. If a SCC 

from the modeling file did not match the NEI defaults, the generic 20% 

particulate divalent, 30% gaseous divalent, and 50% elemental gaseous profile 

was used. 

d. Industry Review 

The 2014 industry review responses described in Section V above included 

changes for non-category records from NEI. 

IX. Quality Assurance/Quality Control (QA/QC) 

All of the QA/QC procedures discussed in the revised Quality Assurance Project Plan (QAPP) 

dated June 6, 2014 were implemented for the aerospace manufacturing and rework 

emissions estimates, locational coordinates, stack parameters, fugitive parameters, and 

non-category emissions records. Manual and computerized verification by a team member 

who did not perform the original data entry or calculations was conducted to ensure that all 

ICR data were correctly incorporated, and that all automated emission calculations were 

implemented correctly. Additional computerized QA/QC checks were then implemented, 

thereby conducting checks on close to 100% of the records. 

a. Aerospace Manufacturing and Rework Facilities Emission Estimates 

The Aerospace Manufacturing and Rework Facilities emission records included in the 

modeling file were reviewed to verify that no emissions were double counted, and 

that the emitted pollutants were consistent with the reported SCCs/unit or process 

descriptions. HAPs not typically emitted from the processes were removed. For 

example, EPA removed homopolymers from coating emissions where facilities 

reported both the homopolymer and hexamethylene diisocyanate (HMDI) 

components of a coating material and adjusted HMDI estimates that were 

overestimated using an average ratio from the study “Determination of 1,6-
13 

Hexamethylene Diisocyanate (HDI) Emissions from Spray Booth Operations2.” Outliers 

(e.g., HAPs emitted in very large quantities relative to similar processes at other 

facilities) were flagged for investigation. For example, one facility reported specialty 

coating emissions in pounds per year instead of reporting coating inputs; EPA adjusted 

these emissions to tons per year. EPA contacted four facilities and made revisions for 

two facilities as needed based on responses. For example, specialty coating emissions 

were reassigned to non-category processes and duplicate emission values were 

removed for one facility, and fugitive chromium emissions from surface coating were 

removed for the other facility. 

b. Locational Coordinates 

Location coordinates (X_COORDINATE and Y_COORDINATE) were reviewed using 

ArcGIS®. Coordinates that placed stack emission release points over facility buildings, 

stacks, hangers, etc., were considered suitable. If coordinates placed an emission 

release point over parking lots, vegetation, residential housing, or other non-facility 

building, new coordinates were assigned. Fugitive emission release points are 

represented in modeling files as rectangles or squares. Coordinates of these release 

points should be located in the southwest corner of the fugitive area to be modeled. 

Fugitive coordinates were also QA’ed based on the fugitive length (y), width (x), and 

angle associated with the fugitive area or building. These parameters are discussed 

below and an example is displayed in Figure 1. If a fugitive area was shown to be over 

vegetation, residential housing, etc., the coordinates were reassigned to the 

southwest corner of the facility building based on the fugitive length, width, and 

angle. 

Figure 1. Depiction of Fugitive Area Source Parameters3

 

2

 Ontario Ministry of the Environment, April 2006. 

3

 Figure created by ICF International. 
14 

c. Stack Parameters 

Stack parameters included in the ICR submittals and the modeling file include stack 

diameter, stack height, exhaust stream temperature, and stream flow rate. Stream 

velocity is provided in the modeling file and was calculated based on stack diameter 

and flow rate. If one or more of the ICR stack parameters was not provided, aerospace 

stack parameter defaults were assigned using the average of stack parameters 

reported in the ICR for other aerospace release points. The average aerospace stack 

parameters assigned as defaults are: 

Stack height: 48.43091684 ft 

Stack temperature: 76.27270788°F 

Stack diameter: 4.846738822 ft 

Stack velocity: 50.7294305266868 ft/sec 

Stack flow rate: 978.086679026503 ft3/sec 

The QA ranges for stack parameters for the aerospace modeling file are listed below. 

One exception to the QA ranges is for engine testing and internal combustion engines 

where the temperature can exceed the normal QA maximum. If either diameter or 

velocity was out of range for category records, diameter, velocity and flow rate were 

all set to the aerospace stack parameter defaults. 

Table 2. Aerospace Stack Parameter QA Ranges

Parameter 

QA Range for Category 

Records 

QA Range for NonCategory Records Units 

Min Max Min Max

Stack Height 0.1 1,200 0.1 1,200 ft

Exhaust Gas 

Temperature 50 1,800 50 1,800 °F 

Stack Diameter 0.1 40 0.1 50 ft

Exhaust Gas Velocity 0.1 200 0.1 200 ft/sec

Exhaust Gas Flow Rate ft3/sec

d. Fugitive Parameters 

Fugitive parameters in the modeling file include the same stack parameters as well as 

fugitive length, width, and angle. The fugitive area is comprised of the southwest 

corner of the representative building, or latitude and longitude, the length and width, 

or x and y depicted in Figure 1, and the angle at which the area is rotated in relation to 

the southwest corner. The fugitive angle must be between 0 and 90 degrees. The 

national defaults for fugitive parameters are listed below. 
15 

Table 3. Fugitive Stack Parameter Defaults Applied

National Defaults Units

Stack Height 10 ft

Exhaust Gas 

Temperature 72 °F 

Stack Diameter 0.003 ft

Exhaust Gas Velocity 0.0003 ft/sec

Exhaust Gas Flow Rate 0 ft3/sec

e. Addition of new HAPs to RTR file 

There were several new HAPs provided in the facility ICRs that were not yet included 

in the RTR (or NEI) pollutant look-up tables. The HAPs added to the RTR look-up table 

are provided in the following table. 

Table 4. Additional Aerospace HAPs

Pollutant Pollutant Code

Cadmium Selenide Sulfide 12626367 

Cobalt Neodecanoate 27253312

Cobalt(II) Nitrate 10141056 

Cobalt(II) Phosphate Octahydrate 10294505 

Coronene 191071

Dibasic Lead Phosphate 15845520 

Iron Chromite Brown Spinel (C.I. Pigment Brown 35) 68187097 

Lead Chromate Molybdate Sulfate (C.I. Pigment Red 104) 12656858 

Manganese Ferrite Black Spinel (C.I. Pigment Black 26) 68186947

Magnesium Dichromate 14104859

Phosphoric Acid, Reaction Products with Aluminum Hydroxide 

and Chromium Oxide (CrO3) 

92203026

Zinc Potassium Chromate 37224570

f. Non-category Emission Estimates 

The NEI non-aerospace emission records included in the modeling file were 

reviewed to verify that no emissions were double counted, and that the emitted 

pollutants were consistent with the reported SCCs/unit or process descriptions. 

HAPs not typically emitted from the processes were removed. Outliers (e.g., HAPs 

emitted in very large quantities relative to similar processes at other facilities) were 

flagged for investigation. For example, the NEI emissions from a wastewater 

treatment process at one facility were adjusted. EPA contacted three facilities and 

made revisions as needed based on responses. For example, combustion emissions 
16 

were corrected at two facilities, and tetrachloroethylene emissions were removed 

from the third facility. 
A-1 

Appendix A. Coatings Test Data where Chromium and Chromium (VI) Data are Available 

Facility MSDS Coating ID Avg CrVI Content (mg/kg) Avg Chromium Content (mg/kg) Fraction ChromeV

1

Black Super Koropon base #528x310 31.1 48.6 0.6399176

1

Eco Prime Yellow-Green # EWDEO72 A Base 19590 21005 0.9326350

2 515X349 BASE COMPONENT 25033.33333 30015.33333 0.83401812

BR 127 Corrosion Inhibiting Primer 2080.666667 2699.333333 0.7708076

5

10P20-44_High Solids Epoxy Primer 36912 49047.96411 0.7525694

6

10P8-10NF; Fluid Resistant Epoxy Primer 14814.66667 21178.15975 0.6995256

6

515X346 Room Temperature Bonding Primer 15944.5 37971.39558 0.419908

8

463-6-4; Aluminized Epoxy Primer Base 639.5 2801 0.2283113

8

BMS10-11AA-TYPE I-CLASS A GRADE E BASE 64922.5 65226 0.9953469

9 10P8-11LC Primer 18874.5 22901 0.8241779

10

MIL-PRF-85582D, TYPE I, CLASS C2 BASE 34477 40365 0.8541310

10

MIL-PRF-85582D-TYPE I-CLASS C2-CATALYST 2.53 1.92 1.31770833

11

MIL-PRF-23377K TYPE 1 CLASS C2 PART A BASE 35750 36691 0.9743533

11

MIL-PRF-23377K TYPE 1 CLASS C2 PART B CATALYST 3.07 3.03 1.0132013

11

MIL-PRF-85582D, TYPE I, CLASS C2, 44GN072 BASE 66158 84002 0.7875764

13 10P8-10NMF Base 19021.5 21092.5 0.901813413 BMS10-11A Type I Class A Cat 7.54 3.8 1.98421052
A-2 

Appendix A. Coatings Test Data where Chromium and Chromium (VI) Data are Available 

Facility MSDS Coating ID Avg CrVI Content (mg/kg) Avg Chromium Content (mg/kg) Fraction ChromeV

13

BMS10-11A Type I Class A Primer 64112.5 67715.5 0.9467920

14

AQUAPRIME PRIMER, MIL-PRF- 85582D, TYPE I, CLASS C2, PART A 30680 39440 0.7778904

Average: 

a Measured Cr VI was greater than Cr; all reported Cr is assumed to be Cr VI. 
B-1 

Appendix B. Non-category SCCs SCC SCC Description 10100224 External Combustion Boilers; Electric Generation; Subbituminous Coal; Boiler, Spreader Stoker10100501 External Combustion Boilers; Electric Generation; Distillate Oil - Grades 1 and 2; Boiler, Normal firing 10100602 External Combustion Boilers; Electric Generation; Natural Gas; Boiler < 100 Million BTU, except tangenti10102101 External Combustion Boilers; Electric Generation; Other Oil; All 10200204 External Combustion Boilers; Industrial; Bituminous Coal; Spreader Stoker 10200206 External Combustion Boilers; Industrial; Bituminous Coal; Underfeed Stoker 10200212 External Combustion Boilers; Industrial; Bituminous Coal; Pulverized Coal: Dry Bottom (Tangential) 10200401 External Combustion Boilers; Industrial; Residual Oil - Grade 6; Boiler 10200404 External Combustion Boilers; Industrial; Residual Oil; Grade 5 Oil 10200501 External Combustion Boilers; Industrial; Distillate Oil - Grades 1 and 2; Boiler 10200502 External Combustion Boilers; Industrial; Distillate Oil; 10-100 Million BTU/hr ** 10200503 External Combustion Boilers; Industrial; Distillate Oil; < 10 Million BTU/hr ** 10200601 External Combustion Boilers; Industrial; Natural Gas; > 100 Million BTU/hr 10200602 External Combustion Boilers; Industrial; Natural Gas; 10-100 Million BTU/hr 10200603 External Combustion Boilers; Industrial; Natural Gas; < 10 Million BTU/hr 10200799 External Combustion Boilers; Industrial; Process Gas; Other: Specify in Comments 10300203 External Combustion Boilers; Commercial/Institutional; Bituminous Coal; Cyclone Furnace 10300209 External Combustion Boilers; Commercial/Institutional; Bituminous Coal; Spreader Stoker 10300402 External Combustion Boilers; Commercial/Institutional; Residual Oil; 10-100 Million BTU/hr **10300403 External Combustion Boilers; Commercial/Institutional; Residual Oil; < 10 Million BTU/hr ** 10300404 External Combustion Boilers; Commercial/Institutional; Residual Oil; Grade 5 Oil 10300501 External Combustion Boilers; Commercial/Institutional; Distillate Oil - Grades 1 and 2; Boiler 10300502 External Combustion Boilers; Commercial/Institutional; Distillate Oil; 10-100 Million BTU/hr ** 10300503 External Combustion Boilers; Commercial/Institutional; Distillate Oil; < 10 Million BTU/hr **10300504 External Combustion Boilers; Commercial/Institutional; Distillate Oil; Grade 4 Oil 10300601 External Combustion Boilers; Commercial/Institutional; Natural Gas; > 100 Million BTU/hr 10300602 External Combustion Boilers; Commercial/Institutional; Natural Gas; 10-100 Million BTU/hr 10300603 External Combustion Boilers; Commercial/Institutional; Natural Gas; < 10 Million BTU/hr 
B-2 

Appendix B. Non-category SCCs SCC SCC Description 10301002 External Combustion Boilers; Commercial/Institutional; Liquified Petroleum Gas (LPG); Propane10500105 External Combustion Boilers; Space Heaters; Industrial; Distillate Oil 10500106 External Combustion Boilers; Space Heaters; Industrial; Natural Gas 10500206 External Combustion Boilers; Space Heaters; Commercial/Institutional; Natural Gas 20100102 Internal Combustion Engines; Electric Generation; Distillate Oil (Diesel); Reciprocating 20100107 Internal Combustion Engines; Electric Generation; Distillate Oil (Diesel); Reciprocating: Exhaust 20100201 Internal Combustion Engines; Electric Generation; Natural Gas; Turbine 20100202 Internal Combustion Engines; Electric Generation; Natural Gas; Reciprocating 20100901 Internal Combustion Engines; Electric Generation; Kerosene/Naphtha (Jet Fuel); Turbine 20200102 Internal Combustion Engines; Industrial; Distillate Oil (Diesel); Reciprocating 20200103 Internal Combustion Engines; Industrial; Distillate Oil (Diesel); Turbine: Cogeneration 20200104 Internal Combustion Engines; Industrial; Distillate Oil (Diesel); Reciprocating: Cogeneration20200201 Internal Combustion Engines; Industrial; Natural Gas; Turbine 20200202 Internal Combustion Engines; Industrial; Natural Gas; Reciprocating 20200203 Internal Combustion Engines; Industrial; Natural Gas; Turbine: Cogeneration 20200252 Internal Combustion Engines; Industrial; Natural Gas; 2-cycle Lean Burn 20200253 Internal Combustion Engines; Industrial; Natural Gas; 4-cycle Rich Burn 20200254 Internal Combustion Engines; Industrial; Natural Gas; 4-cycle Lean Burn 20200401 Internal Combustion Engines; Industrial; Large Bore Engine; Diesel 20200402 Internal Combustion Engines; Industrial; Large Bore Engine; Dual Fuel (Oil/Gas) 20200901 Internal Combustion Engines; Industrial; Kerosene/Naphtha (Jet Fuel); Turbine 20201001 Internal Combustion Engines; Industrial; Liquified Petroleum Gas (LPG); Propane: Reciprocating 20201012 Internal Combustion Engines; Industrial; Liquified Petroleum Gas (LPG); Reciprocating Engine 20300101 Internal Combustion Engines; Commercial/Institutional; Distillate Oil (Diesel); Reciprocating20300102 Internal Combustion Engines; Commercial/Institutional; Distillate Oil (Diesel); Turbine 20300201 Internal Combustion Engines; Commercial/Institutional; Natural Gas; Reciprocating 20300203 Internal Combustion Engines; Commercial/Institutional; Natural Gas; Turbine: Cogeneration 20300301 Internal Combustion Engines; Commercial/Institutional; Gasoline; Reciprocating 
B-3 

Appendix B. Non-category SCCs SCC SCC Description 20301001 Internal Combustion Engines; Commercial/Institutional; Liquified Petroleum Gas (LPG); Propane: Recipro20400101 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Turbojet 20400102 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Turboshaft 20400110 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Jet A Fuel 20400199 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Other Not Classified 20400201 Internal Combustion Engines; Engine Testing; Rocket Engine Testing; Rocket Motor: Solid Propellant 20400302 Internal Combustion Engines; Engine Testing; Turbine; Diesel/Kerosene 20400305 Internal Combustion Engines; Engine Testing; Turbine; Kerosene/Naphtha 20400402 Internal Combustion Engines; Engine Testing; Reciprocating Engine; Diesel/Kerosene 20400406 Internal Combustion Engines; Engine Testing; Reciprocating Engine; Kerosene/Naphtha (Jet Fuel) 30101602 Industrial Processes; Chemical Manufacturing; Phosphoric Acid: Wet Process; Gypsum Pond 30188801 Industrial Processes; Chemical Manufacturing; Fugitive Emissions; Specify in Comments Field 30400360 Industrial Processes; Secondary Metal Production; Grey Iron Foundries; Castings Finishing 30400401 Industrial Processes; Secondary Metal Production; Lead; Pot Furnace 30400409 Industrial Processes; Secondary Metal Production; Lead; Casting 30400867 Industrial Processes; Secondary Metal Production; Zinc; Kettle (Pot) Melting Furnace 30400873 Industrial Processes; Secondary Metal Production; Zinc; Casting 30402201 Industrial Processes; Secondary Metal Production; Metal Heat Treating; Furnace: General 30499999 Industrial Processes; Secondary Metal Production; Other Not Classified; Specify in Comments Field 30501050 Industrial Processes; Mineral Products; Coal Mining, Cleaning, and Material Handling; Vehicle Traffic: Lig30600101 Industrial Processes; Petroleum Industry; Process Heaters; Oil-fired ** 30601301 Industrial Processes; Petroleum Industry; Coke Handling System; Storage and Transfer 30622003 Industrial Processes; Petroleum Industry; Underground Storage Remediation & Other Remediation; Soil: 30700752 

Industrial Processes; Pulp and Paper and Wood Products; Plywood Operations; Softwood Plywood, VeneNatural Gas-Fired, Heated Zones 

30900500 Industrial Processes; Fabricated Metal Products; Welding; General 30901003 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Entire Process: Nickel 30901006 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Entire Process: Chrome 
B-4 

Appendix B. Non-category SCCs SCC SCC Description 30901018 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Hard Chromium - Electroplat30901028 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Decorative Chromium - Elect30901098 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Other Not Classified 30901102 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; Acid Cleaning Ba30901103 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; Anodizing Kettle 30901104 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; Rinsing/Finishin30901199 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; Other Not Class30905100 Industrial Processes; Fabricated Metal Products; Shielded Metal Arc Welding (SMAW); General 30905200 Industrial Processes; Fabricated Metal Products; Gas Metal Arc Welding (GMAW); General 30990003 Industrial Processes; Fabricated Metal Products; Fuel Fired Equipment; Natural Gas: Process Heaters 30999999 Industrial Processes; Fabricated Metal Products; Other Not Classified; Other Not Classified 31299999 Industrial Processes; Machinery, Miscellaneous; Miscellaneous Machinery; Other Not Classified31399999 Industrial Processes; Electrical Equipment; Other Not Classified; Other Not Classified 31499999 Industrial Processes; Transportation Equipment; Other Not Classified; Other Not Classified 39000699 Industrial Processes; In-process Fuel Use; Natural Gas; General 39001299 Industrial Processes; In-process Fuel Use; Solid Waste; General 39090001 Industrial Processes; In-process Fuel Use; Fuel Storage - Fixed Roof Tanks; Residual Oil: Breathing Loss 39090003 Industrial Processes; In-process Fuel Use; Fuel Storage - Fixed Roof Tanks; Distillate Oil (No. 2): Breathing 39090004 Industrial Processes; In-process Fuel Use; Fuel Storage - Fixed Roof Tanks; Distillate Oil (No. 2): Working 39090011 Industrial Processes; In-process Fuel Use; Fuel Storage - Fixed Roof Tanks; Dual Fuel (Gas/Oil): Breathing 39091004 Industrial Processes; In-process Fuel Use; Fuel Storage - Floating Roof Tanks; Distillate Oil (No. 2): Withd39091011 Industrial Processes; In-process Fuel Use; Fuel Storage - Floating Roof Tanks; Dual Fuel (Gas/Oil): Standin39900601 Industrial Processes; Miscellaneous Manufacturing Industries; Process Heater/Furnace; Natural Gas 39990003 

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Manufacturing Industries; Heaters 

39999992 Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes; Other 39999993 Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes; Other 39999999 Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes; Other 
B-5 

Appendix B. Non-category SCCs SCC SCC Description 40100198 Petroleum and Solvent Evaporation; Organic Solvent Evaporation; Dry Cleaning; Other Not Classified 40200801 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven - General; General 40301001 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying 13: Breathing Loss (67000 Bbl. Tank Size) 

40301005 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying 10: Breathing Loss (250000 Bbl. Tank Size) 

40301007 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying 13: Working Loss (Tank Diameter Independent) 

40301016 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying Breathing Loss (67000 Bbl. Tank Size) 

40301017 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying Breathing Loss (250000 Bbl. Tank Size) 

40301018 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying Working Loss (Tank Diameter Independent) 

40301019 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying #2: Breathing Loss (67000 Bbl. Tank Size) 

40301020 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying #2: Breathing Loss (250000 Bbl. Tank Size) 

40301021 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying #2: Working Loss (Tank Diameter Independent) 

40301098 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying Breathing Loss (250000 Bbl. Tank Size) 

40301099 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying Working Loss (Tank Diameter Independent) 

40301114 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Floating Roof Tanks (VaryStanding Loss (250000 Bbl. Tank Size) 

40301119 

Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Floating Roof Tanks (VaryWithdrawal Loss 

40400102 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Terminals; Gasoline (67000 Bbl Capacity) - Fixed Roof Tank 

40400108 Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Terminals; Gasoline 
B-6 

Appendix B. Non-category SCCs SCC SCC Description 

(Diameter Independent) - Fixed Roof Tank

40400131 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Terminals; Gasoline Ext. Floating Roof w/ Primary Seal 

40400250 Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Plants; Loading Rac40400254 Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Plants; Tank Truck V40400270 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Plants; Specify LiquiFloating Roof w/ Secondary Seal 

40400316 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Oil and Gas Field Storage Fixed Roof Tank, Diesel, working+breathing+flashing losses 

40400402 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products - UnGasoline RVP 13: Working Loss 

40400411 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products - UnKerosene: Breathing Loss 

40400412 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products - UnKerosene: Working Loss 

40400497 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products - UnSpecify Liquid: Breathing Loss 

40400498 

Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products - UnSpecify Liquid: Working Loss 

40600131 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Tank Cars anSubmerged Loading (Normal Service) 

40600133 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Tank Cars anSubmerged Loading (Normal Service) 

40600136 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Tank Cars anSplash Loading (Normal Service) 

40600301 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Gasoline RetSplash Filling 

40600302 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Gasoline RetSubmerged Filling w/o Controls 

40600306 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Gasoline RetBalanced Submerged Filling 
B-7 

Appendix B. Non-category SCCs SCC SCC Description 40600307 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Gasoline RetUnderground Tank Breathing and Emptying 

40600401 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Filling VehiclVapor Loss w/o Controls 

40600402 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Filling VehiclLiquid Spill Loss w/o Controls 

40600503 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Pipeline PetrGeneral - All Products; Pump Station 

40600707 

Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Consumer (CRefueling - Stage I; Underground Tank Breathing and Emptying 

40799997 Petroleum and Solvent Evaporation; Organic Chemical Storage; Miscellaneous; Specify in Comments 41082001 Petroleum and Solvent Evaporation; Dry Cleaning; Petroleum Solvent - Wastewater, Aggregate; Process 42500101 Petroleum and Solvent Evaporation; Fixed Roof Tanks (210 Bbl Size) Breathing Loss 42500102 Petroleum and Solvent Evaporation; Fixed Roof Tanks (210 Bbl Size) Working Loss 50100402 Waste Disposal; Solid Waste Disposal - Government; Landfill Dump; Fugitive Emissions 50100404 Waste Disposal; Solid Waste Disposal - Government; Landfill Dump; Trench Method 50100406 Waste Disposal; Solid Waste Disposal - Government; Landfill Dump; Gas Collection System: Other 50100601 Waste Disposal; Solid Waste Disposal - Government; Fire Fighting; Structure: Jet Fuel 50200103 Waste Disposal; Solid Waste Disposal - Commercial/Institutional; Incineration; Controlled Air50200602 

Waste Disposal; Solid Waste Disposal - Commercial/Institutional; Landfill Dump; Municipal: Fugitive Emi004-02) 

50300205 Waste Disposal; Solid Waste Disposal - Industrial; Open Burning; Rocket Propellant 50300702 Waste Disposal; Solid Waste Disposal - Industrial; Liquid Waste; Waste Treatment: General 
C-1 

Appendix C. Additional Non-Category SCCs with Unit Descriptions Emission Unit Description SCC SCC Description Building 1665 - open top chemical tank 39999995

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous InOther Not Classified 

Explosives Manufacturing 49099998

Petroleum and Solvent Evaporation; Organic Solvent Evaporation; MiscellaneoCompound Evaporation; Identify the Process and Solvent in Comments 

FIRING RANGE TRAINING OPERATIONS 40200101

Petroleum and Solvent Evaporation; Surface Coating Operations; Surface CoatiGeneral; Paint: Solvent-base 

Solids Handling 39999994

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous InOther Not Classified 

Autoclave (from facility ID 5555) 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven Autoclave (NTR) 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven Boilers and Humidifiers (I and S) 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven Clean Line - Heating Units (I and S) 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven Coating Ovens (NTR) 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven GAS OVENS-PAINT CURING 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven HEATERS (I and S and NTR) 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven Ovens 1-10 (from facility ID 5555)(I and S) 40201001 Petroleum and Solvent Evaporation; Surface Coating Operations; Coating Oven Fire training pit 39999994

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous InOther Not Classified 

Building No. 4035 - hard chrome plating tank [MACT, Subpart N] 39999994

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous InOther Not Classified 

CADMIUM ELECTROPLATING LINE 39999995

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous InOther Not Classified 

Wastewater Treatment 39999995

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous InOther Not Classified 
C-2 

Appendix C. Additional Non-Category SCCs with Unit Descriptions Emission Unit Description SCC SCC Description Wastewater treatment facility 40188898

Petroleum and Solvent Evaporation; Organic Solvent Evaporation; Fugitive EmiComments Field 

Welding Sources 39999995

Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous InOther Not Classified