1

MEMORANDUM

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

FROM: Stacie Enoch, Jason Huckaby, Ashley Penrod, and D arcy 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 inform ation on the U.S. Environmental Protection Agency (EPA) Risk and Technology Review (RTR) datab ase used in estimating residual risk for the Aerospace Manufacturing and Rework Facilities Natio nal Emission Standards For Hazardous Air Pollutants (NESHAP) source category. This NESHAP co vers 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 s tationary 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 sta ge, section 112(f)(2) requires EPA to assess the

health and environmental risks that remain after so urces 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 ma rgin of safety or to prevent adverse environmental effects, EPA must develop standards t o address these remaining risks. As part of this second stage, data were gathered to assess the resi dual risks from the Aerospace Manufacturing
NESHAP source category.

The 2002 National Emissions Inventory (NEI) data se rved 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 A dvanced Notice of Proposed Rulemaking (ANPR)
in March of 2007, where NEI revisions for facilitie s 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 t o determine reductions attributable to the MACT pro gram. The NEI associates regulatory codes corresponding to MA CT source categories with stationary major and area source data. www.erg.com2

On February 4, 2011, EPA sent out an information co llection 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 (coa tings, blast depainting operations, solvent depainting operations, and solvent cleaning operati ons) as well as specialty coatings, chemical milling and metal finishing operations, composite p rocessing, 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, c omposite processing and metal finishing
operations.

On May 23, 2013, EPA provided the estimated facilit y-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 sup plemental coatings analyses for select facilities.

On May 15, 2014, EPA provided industry the opportun ity for a final review of the estimated emissions (and emission estimation methods) for pro cesses subject to 40 CFR 63, subpart GG and other processes included in the February 4, 2011 IC R 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 coordinate s.

The following sections detail how EPA calculated em issions and conducted quality assurance/quality control (QA/QC) of the data.

II. Category and Specialty Coatings Actual Emissions De velopment

a. Regulated processes included coatings, blast depain ting, 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 physica l 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) req uested 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 emissio n estimates from tanks used for chemical milling or metals finishing operations, bl ast depainting/cleaning operations, solvent depainting operations, solvent cleaning ope rations, storage tanks, and wastewater treatment. Form F-1 requested resins usa ge and physical property data that EPA then used in calculating HAP emission esti mates from composites processing operations. Forms J-1 through J-10 requested inform ation specific to each control

device used.3 c. Development of Actual Emissions Estimates The following equations and assumptions were used t o develop actual emissions
estimates from the ICR data.

Coating Operations (C1)

Emissions were calculated for each HAP within a coa ting 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 insi de a booth:

	 ∗ 	

 ∗ 		
	 ∗(

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

• Organic HAP fugitive emissions from coating usage i nside a booth:

	 ∗ 	

 ∗ 		
	 ∗(

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

• Organic HAP fugitive emissions from coating usage o utside 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 usag e):

	 ∗ 	

 ∗ 		
	 ∗ ( 

	 
	
	
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 (l b HAP/lb coating); Coating Usage Pct

= the portion of the annual coating usage at the s pecified location (i.e., in the identified booth, or outside of booth usage); Adjustment Factor

= factor to account for the transfer of coating so lids to the part being coated (assumed 65%) and fallout for coa tings 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 de vice (organic); Filter control efficiency = the percent reduction achieved by the booth filt er (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 (9 5% emission control for
carbon adsorbers and scrubbers and 98% control for thermal incinerators). If no control device was listed, the control efficiency w as assumed to be zero.

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

• If no filter control efficiency was provided, a val ue 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 we re assumed to be as follows: (open/open face/other: 90%, permanent tota l 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% wa s assumed.

o For inorganic pollutants, the capture efficiencies were assumed to be as follows: (open/open face/other: 99%, permanent tota l enclosure (PTE): 100%; enclosed but not a PTE: 99.5%); if the facili ty did not provide a capture efficiency or booth type, a value of 99% wa s assumed.

• It was assumed that inorganic fugitive emissions fr om application of coatings outside of the booth are zero if the coatings were not spray applied. If the coatings were spray applied, the transfer efficienc y 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 wer e required to report emissions directly instead of providing the usage/composition data required to calculate emissions (such as in C1). Therefore, the only calc ulation 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 wer e 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 cap ture and control, and it was therefore necessary to back-calculate the fugit ive emissions from the stack emissions. The following equations were used to cal culate emissions for E1, E2, and G1 operations in tons per year.

• Stack emissions:

# ∗ (1/2000)

• Fugitive emissions for units not equipped with a co ntrol device:

(#/("
	#$$
/100)) ∗ (1

− ("
	#$$
/100)) ∗ (1/2000)

• Fugitive emissions for units equipped with a contro l device:

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

Assumptions

• As stated above, it was assumed that the emission v alues reported in the survey are stack emissions after capture and contro l.

• If no capture efficiency was provided, a value of 7 0% 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 emi ssions were reported instead of stack emissions after control, then the emission s were adjusted to take into account the capture and control efficiencies as req uested.

Solvent Cleaning Operations – Point and Fugitive So urces (E3)

Facilities conducting solvent cleaning operations w ere required to report emissions directly as either stack or fugitive emissions. The refore, the only calculation required was to convert emissions from pounds per year to to ns per year.

Composite Processing Operations (F1 Resins)

Emissions were calculated for each HAP within the r esin and for each booth in which the resin was used. The following equations were us ed 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 t o 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 ar e assumed to be as follows: (open/open face/other: 90%, permanent tota l 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% wa s assumed.

o For inorganic pollutants, the capture efficiencies are assumed to be as follows: (open/open face/other: 99%, permanent tota l enclosure (PTE): 100%; enclosed but not a PTE: 99.5%); if the facili ty did not provide a capture efficiency or booth type, a value of 99% wa s assumed.

• For outside the booth application, if the percent H AP emitted was not provided, a value of 100 percent was assumed for or ganic pollutants. For inorganic pollutants from resins that are applied o utside of a booth that are not spray applied, it was assumed that 0% was emitt ed. If the out of booth resins are spray applied, the transfer efficiency w as assumed to be 65% (or 35% emitted). If the application method for resins appl ied 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 tran sfer 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 operatio ns were required to report emissions directly as either stack or fugitive emis sions. Therefore, the only calculation required was to convert emissions from pounds per y ear to tons per year.7 Assumptions

It was assumed that the reported stack emission val ues 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 Assignme nts

i. The regulatory code “63GG” was assigned for process es 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 co de (SCC) were assigned as shown below based on information provided in the IC R 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; Ab rasive Blasting of Metal Parts; General

Blast Depainting 68241001 MACT Source Categories; Miscellaneous Processes; Pa int Stripper Users - Non-chemical Strippers; Media Blas ting

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; Pa int 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 - Electrop lating

Tank8 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, includi ng strike) - Electroplating Tank

Chemical Milling and Metal Finishing 30901048 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Copper (general) - Elect roplating 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 wat ts) - Electroplating Tank 1000 amp-hr current

Chemical Milling and Metal Finishing 30901068 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Nickel (general) - Elect roplating

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; Co nversion Coating of Metal Products; Alkaline Cleaning Bath

Chemical Milling and Metal Finishing 30901102 Industrial Processes; Fabricated Metal Products; Co nversion Coating of Metal Products; Acid Cleaning Bath (Pick ling)

Chemical Milling and Metal Finishing 30901103 Industrial Processes; Fabricated Metal Products; Co nversion Coating of Metal Products; Anodizing Kettle

Chemical Milling and Metal Finishing 30901199 Industrial Processes; Fabricated Metal Products; Co nversion Coating of Metal Products; Other Not Classified

Chemical Milling and Metal Finishing 30901501 Industrial Processes; Fabricated Metal Products; Ch emical Milling of Metal Products; Milling Tank

Chemical Milling and Metal Finishing 30904001 Industrial Processes; Fabricated Metal Products; Me tal Deposition Processes; Metallizing: Wire Atomization and Spraying
Chemical Milling and Metal Finishing 30904010 Industrial Processes; Fabricated Metal Products; Me tal Deposition Processes; Thermal Spraying of Powdered Metal

Chemical Milling and Metal Finishing 30999999 Industrial Processes; Fabricated Metal Products; Ot her Not Classified; Other Not Classified9 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 Plas tics Products; Fiberglass Resin Products; General

Storage Tanks 40100550 Petroleum and Solvent Evaporation; Organic Solvent Evaporation; Solvent Storage; General Processes: Dr um Storage - Pure Organic Chemicals

Wastewater Treatment 40282001 Petroleum and Solvent Evaporation; Surface Coating Operations; Wastewater, Aggregate; Process Area Dra ins

III. Testing ICR

a. The test data were reviewed to confirm there were n o additional source ID or pollutant matches that were missed when incorporati ng test data into the modeling
file.

b. The methodology that was used to include (or not in clude) emissions test data in the modeling file was reviewed. Findings were as fo llows:

 Test data were compiled for 15 facilities.

 The compiled test data for one facility were not in cluded 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 t he modeling file updates,
because it overlapped with a different test point t hat was included in the
modeling file updates.

 With the exception of the test point noted above, t est data for the remaining
14 facilities were added to the modeling file if th e data met three criteria:

• There was at least one test run where emissions wer e not below
detection limits. For the purpose of the aerospace source category risk
analysis, test points where all three runs were bel ow detection limits
were assumed to not emit that HAP from that process type and these
emissions were not included in the risk modeling fi le. This assumption
was made for this source category because of the va riability in
processes and input materials used at aerospace fac ilities (for example,
some coatings do not contain certain HAP and, there fore, are not
expected to be sources of those HAP).

• The data that could be mapped to source IDs were al ready included in
the modeling file.

• The test pollutants were not reported in the origin al ICR data. If the test
pollutants were already reported in the original IC R data for the10 corresponding source ID, then the stack test data w ere not added to the
modeling file.

 If the test data met the three criteria, then the a verage 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 wa s used for any runs that were

below the detection limit. If all three runs were b elow the detection limit, then
emissions of that HAP were assumed to not be presen t for that process in the
aerospace source category. Stack test data were add ed to the modeling file for
11 out of 14 facilities. (Although it is common pra ctice to use one half of the

detection limit for below detection limit in other source categories, the
methodology used in developing the aerospace risk m odeling 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 e mitted.)

c. Industry-supplied materials and prior EC/R analysis of emissions test data and
capture efficiencies were reviewed to determine whe ther any calculations or
assumptions currently used should be revised.

d. Emissions test data amendments and results of coati ngs test data were reviewed to:
1) identify which pollutants in the emissions test data were not being reported
under material balance-based coatings records alrea dy (i.e., should be added to the
coatings category records); 2) which pollutants wer e measured in the emission
tests, but were not found in coatings tests, and th erefore should not be allocated to
the coatings process group; 3) confirm that those p ollutants in the emissions test
data that were not flagged for appending were refle cted in material balance-based
coatings records; and 4) provide analytical test da ta instead of MSDS-supplied
metals content values where the tested coating coul d 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 res ults 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 co mpound 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 d ata 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 fo rms (elemental gaseous, particulate divalent, and gaseous divalent) using S CC-based NEI defaults. If a SCC from the modeling file did not match the NEI defaul ts, the generic 20% particulate divalent, 30% gaseous divalent, and 50% elemental g aseous profile was used.

V. Industry Reviews

a. Draft modeling file records were provided to all pa rent 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 faci lities. 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 cha nges to emission values, control device types, stack parameters, locational coordina tes, fugitive area dimensions, pollutant information, and removal of units or proc esses that are shutdown or otherwise not part of the facility. Revisions to th e coating calculations included adding missing coatings and pollutants, removing po llutants no longer emitted, and revising the coating calculation inputs (volume, de nsity, HAP mass fraction, coating usage percent, booth type and capture percent, cont rol efficiency, filter control efficiency, and the adjustment factor).

VI. Development of Allowable Emissions for Category

Facilities were asked to provide a multiplier in th e ICR survey to scale up average hourly emissions to maximum hourly emissions for air dispe rsion modeling. As there are typically a large number of emission points at a facility, dete rmining 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 emission s to allowable annual emissions. The allowable emissions multiplier is based on the diff erence 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 appr opriate 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 Emiss ions

a. Non-category emissions for aerospace manufacturing facilities were obtained from the 2011 NEI. Non-category emissions were not avail able in the 2011 NEI or 2008 NEI for three facilities; emissions were pulled from th e 2005 National-Scale Air Toxics Assessment (NATA) inventory for these three facilit ies.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 wer e included in the non-category records only if the record had the specific unit de scription shown. Individual chromium records were excluded if they were found t o 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 defaul t, the Cr profile for ICR processes was used.

ii. Mercury Mercury (Hg) emissions were speciated into three fo rms (elemental gaseous, particulate divalent, and gaseous divalent) using S CC-based NEI defaults. If a SCC from the modeling file did not match the NEI defaul ts, 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 Sec tion 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 revise d Quality Assurance Project Plan (QAPP) dated June 6, 2014 were implemented for the aerospa ce manufacturing and rework emissions estimates, locational coordinates, stack parameters, fugitive parameters, and non-category emissions records. Manual and computer ized verification by a team member who did not perform the original data entry or calc ulations was conducted to ensure that all ICR data were correctly incorporated, and that all automated emission calculations were implemented correctly. Additional computerized QA/Q C checks were then implemented, thereby conducting checks on close to 100% of the r ecords.

a. Aerospace Manufacturing and Rework Facilities Emiss ion Estimates

The Aerospace Manufacturing and Rework Facilities e mission records included in the modeling file were reviewed to verify that no emiss ions were double counted, and that the emitted pollutants were consistent with th e reported SCCs/unit or process descriptions. HAPs not typically emitted from the p rocesses were removed. For example, EPA removed homopolymers from coating emis sions where facilities reported both the homopolymer and hexamethylene dii socyanate (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 Spr ay Booth Operations 2 .” Outliers (e.g., HAPs emitted in very large quantities relati ve to similar processes at other facilities) were flagged for investigation. For exa mple, one facility reported specialty coating emissions in pounds per year instead of rep orting coating inputs; EPA adjusted these emissions to tons per year. EPA contacted fou r facilities and made revisions for two facilities as needed based on responses. For ex ample, specialty coating emissions were reassigned to non-category processes and dupli cate emission values were removed for one facility, and fugitive chromium emi ssions 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 rel ease points over facility buildings, stacks, hangers, etc., were considered suitable. If coordinates placed an emission release point over parking lots, vegetation, reside ntial housing, or other non-facility building, new coordinates were assigned. Fugitive e mission release points are represented in modeling files as rectangles or squa res. 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 f ugitive 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 coordina tes 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 Paramet ers 3

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 c alculated based on stack diameter and flow rate. If one or more of the ICR stack para meters was not provided, aerospace stack parameter defaults were assigned using the av erage of stack parameters reported in the ICR for other aerospace release poi nts. 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 ft 3 /sec

The QA ranges for stack parameters for the aerospac e modeling file are listed below. One exception to the QA ranges is for engine testin g and internal combustion engines where the temperature can exceed the normal QA maxi mum. If either diameter or velocity was out of range for category records, dia meter, 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 Non

Category 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 ft 3 /sec

d. Fugitive Parameters

Fugitive parameters in the modeling file include th e same stack parameters as well as fugitive length, width, and angle. The fugitive are a 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 w hich the area is rotated in relation to the southwest corner. The fugitive angle must be be tween 0 and 90 degrees. The national defaults for fugitive parameters are liste d 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 ft 3 /sec

e. Addition of new HAPs to RTR file

There were several new HAPs provided in the facilit y ICRs that were not yet included in the RTR (or NEI) pollutant look-up tables. The H APs 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 1 04) 12656858

Manganese Ferrite Black Spinel (C.I. Pigment Black 26) 68186947 Magnesium Dichromate 14104859 Phosphoric Acid, Reaction Products with Aluminum Hy droxide 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 co unted, and that the emitted pollutants were consistent with the reported SCCs/u nit or process descriptions. HAPs not typically emitted from the processes were removed. Outliers (e.g., HAPs emitted in very large quantities relative to simila r processes at other facilities) were flagged for investigation. For example, the NEI emi ssions from a wastewater treatment process at one facility were adjusted. EP A contacted three facilities and made revisions as needed based on responses. For ex ample, combustion emissions16 were corrected at two facilities, and tetrachloroet hylene emissions were removed from the third facility.A-1Appendix A. Coatings Test Data where Chromium andChromium (VI) Data are AvailableFacilityMSDS Coating IDAvg CrVI Content (mg/kg)Avg Chromium Content (mg/kg)Fraction ChromeVIAdjusted Fraction ChromeVI1Black Super Koropon base#528x31031.148.60.6399176950.6399176951Eco Prime Yellow-Green #EWDEO72 A Base 19590210050.9326350870.9326350872515X349 BASE COMPONENT 25033.3333330015.333330.8340181680.8340181682BR 127 Corrosion InhibitingPrimer 2080.6666672699.3333330.7708076070.770807607510P20-44_High Solids EpoxyPrimer3691249047.964110.7525694630.752569463610P8-10NF; Fluid ResistantEpoxy Primer 14814.6666721178.159750.6995256830.6995256836515X346 Room TemperatureBonding Primer 15944.537971.395580.419908190.419908198463-6-4; Aluminized EpoxyPrimer Base639.528010.2283113170.2283113178BMS10-11AA-TYPE I-CLASS AGRADE E BASE 64922.5652260.9953469480.995346948910P8-11LC Primer 18874.5229010.8241779830.82417798310MIL-PRF-85582D, TYPE I, CLASSC2 BASE34477403650.8541310540.85413105410MIL-PRF-85582D-TYPE I-CLASSC2-CATALYST2.531.921.317708333a111MIL-PRF-23377K TYPE 1 CLASSC2 PART A BASE 35750366910.9743533840.97435338411MIL-PRF-23377K TYPE 1 CLASSC2 PART B CATALYST 3.073.031.01320132a111MIL-PRF-85582D, TYPE I, CLASSC2, 44GN072 BASE 66158840020.7875764860.7875764861310P8-10NMF Base 19021.521092.50.9018134410.90181344113BMS10-11A Type I Class A Cat 7.543.81.984210526a1A-2Appendix A. Coatings Test Data where Chromium andChromium (VI) Data are AvailableFacilityMSDS Coating IDAvg CrVI Content (mg/kg)Avg Chromium Content (mg/kg)Fraction ChromeVIAdjusted Fraction ChromeVI13BMS10-11A Type I Class APrimer64112.567715.50.9467920930.94679209314AQUAPRIME PRIMER, MIL-PRF-85582D, TYPE I, CLASS C2,PART A30680394400.7778904670.777890467Average:0.807aMeasured Cr VI was greater than Cr; all reported Cr is assumed to be Cr VI.B-1Appendix B. Non-category SCCsSCCSCC Description10100224 External Combustion Boilers; Electric Generation; Subbituminous Coal; Boiler, Spreader Stoker10100501 External Combustion Boilers; Electric Generation; Distillate Oil - Grades 1 and 2; Boiler, Normal firing10100602 External Combustion Boilers; Electric Generation; Natural Gas; Boiler < 100 Million BTU, except tangential10102101 External Combustion Boilers; Electric Generation; Other Oil; All10200204 External Combustion Boilers; Industrial; Bituminous Coal; Spreader Stoker10200206 External Combustion Boilers; Industrial; Bituminous Coal; Underfeed Stoker10200212 External Combustion Boilers; Industrial; Bituminous Coal; Pulverized Coal: Dry Bottom (Tangential)10200401 External Combustion Boilers; Industrial; Residual Oil - Grade 6; Boiler10200404 External Combustion Boilers; Industrial; Residual Oil; Grade 5 Oil10200501 External Combustion Boilers; Industrial; Distillate Oil - Grades 1 and 2; Boiler10200502 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/hr10200602 External Combustion Boilers; Industrial; Natural Gas; 10-100 Million BTU/hr10200603 External Combustion Boilers; Industrial; Natural Gas; < 10 Million BTU/hr10200799 External Combustion Boilers; Industrial; Process Gas; Other: Specify in Comments10300203 External Combustion Boilers; Commercial/Institutional; Bituminous Coal; Cyclone Furnace10300209 External Combustion Boilers; Commercial/Institutional; Bituminous Coal; Spreader Stoker10300402 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 Oil10300501 External Combustion Boilers; Commercial/Institutional; Distillate Oil - Grades 1 and 2; Boiler10300502 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 Oil10300601 External Combustion Boilers; Commercial/Institutional; Natural Gas; > 100 Million BTU/hr10300602 External Combustion Boilers; Commercial/Institutional; Natural Gas; 10-100 Million BTU/hr10300603 External Combustion Boilers; Commercial/Institutional; Natural Gas; < 10 Million BTU/hrB-2Appendix B. Non-category SCCsSCCSCC Description10301002 External Combustion Boilers; Commercial/Institutional; Liquified Petroleum Gas (LPG); Propane10500105 External Combustion Boilers; Space Heaters; Industrial; Distillate Oil10500106 External Combustion Boilers; Space Heaters; Industrial; Natural Gas10500206 External Combustion Boilers; Space Heaters; Commercial/Institutional; Natural Gas20100102 Internal Combustion Engines; Electric Generation; Distillate Oil (Diesel); Reciprocating20100107 Internal Combustion Engines; Electric Generation; Distillate Oil (Diesel); Reciprocating: Exhaust20100201 Internal Combustion Engines; Electric Generation; Natural Gas; Turbine20100202 Internal Combustion Engines; Electric Generation; Natural Gas; Reciprocating20100901 Internal Combustion Engines; Electric Generation; Kerosene/Naphtha (Jet Fuel); Turbine20200102 Internal Combustion Engines; Industrial; Distillate Oil (Diesel); Reciprocating20200103 Internal Combustion Engines; Industrial; Distillate Oil (Diesel); Turbine: Cogeneration20200104 Internal Combustion Engines; Industrial; Distillate Oil (Diesel); Reciprocating: Cogeneration20200201 Internal Combustion Engines; Industrial; Natural Gas; Turbine20200202 Internal Combustion Engines; Industrial; Natural Gas; Reciprocating20200203 Internal Combustion Engines; Industrial; Natural Gas; Turbine: Cogeneration20200252 Internal Combustion Engines; Industrial; Natural Gas; 2-cycle Lean Burn20200253 Internal Combustion Engines; Industrial; Natural Gas; 4-cycle Rich Burn20200254 Internal Combustion Engines; Industrial; Natural Gas; 4-cycle Lean Burn20200401 Internal Combustion Engines; Industrial; Large Bore Engine; Diesel20200402 Internal Combustion Engines; Industrial; Large Bore Engine; Dual Fuel (Oil/Gas)20200901 Internal Combustion Engines; Industrial; Kerosene/Naphtha (Jet Fuel); Turbine20201001 Internal Combustion Engines; Industrial; Liquified Petroleum Gas (LPG); Propane: Reciprocating20201012 Internal Combustion Engines; Industrial; Liquified Petroleum Gas (LPG); Reciprocating Engine20300101 Internal Combustion Engines; Commercial/Institutional; Distillate Oil (Diesel); Reciprocating20300102 Internal Combustion Engines; Commercial/Institutional; Distillate Oil (Diesel); Turbine20300201 Internal Combustion Engines; Commercial/Institutional; Natural Gas; Reciprocating20300203 Internal Combustion Engines; Commercial/Institutional; Natural Gas; Turbine: Cogeneration20300301 Internal Combustion Engines; Commercial/Institutional; Gasoline; ReciprocatingB-3Appendix B. Non-category SCCsSCCSCC Description20301001 Internal Combustion Engines; Commercial/Institutional; Liquified Petroleum Gas (LPG); Propane: Reciprocating20400101 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Turbojet20400102 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Turboshaft20400110 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Jet A Fuel20400199 Internal Combustion Engines; Engine Testing; Aircraft Engine Testing; Other Not Classified20400201 Internal Combustion Engines; Engine Testing; Rocket Engine Testing; Rocket Motor: Solid Propellant20400302 Internal Combustion Engines; Engine Testing; Turbine; Diesel/Kerosene20400305 Internal Combustion Engines; Engine Testing; Turbine; Kerosene/Naphtha20400402 Internal Combustion Engines; Engine Testing; Reciprocating Engine; Diesel/Kerosene20400406 Internal Combustion Engines; Engine Testing; Reciprocating Engine; Kerosene/Naphtha (Jet Fuel)30101602 Industrial Processes; Chemical Manufacturing; Phosphoric Acid: Wet Process; Gypsum Pond30188801 Industrial Processes; Chemical Manufacturing; Fugitive Emissions; Specify in Comments Field30400360 Industrial Processes; Secondary Metal Production; Grey Iron Foundries; Castings Finishing30400401 Industrial Processes; Secondary Metal Production; Lead; Pot Furnace30400409 Industrial Processes; Secondary Metal Production; Lead; Casting30400867 Industrial Processes; Secondary Metal Production; Zinc; Kettle (Pot) Melting Furnace30400873 Industrial Processes; Secondary Metal Production; Zinc; Casting30402201 Industrial Processes; Secondary Metal Production; Metal Heat Treating; Furnace: General30499999 Industrial Processes; Secondary Metal Production; Other Not Classified; Specify in Comments Field30501050 Industrial Processes; Mineral Products; Coal Mining, Cleaning, and Material Handling; VehicleTraffic: Light/Medium Vehicles30600101 Industrial Processes; Petroleum Industry;Process Heaters; Oil-fired **30601301 Industrial Processes; Petroleum Industry;Coke Handling System; Storage and Transfer30622003 Industrial Processes; Petroleum Industry;Underground Storage Remediation & Other Remediation; Soil: Natural Gas30700752Industrial Processes; Pulp and Paper and Wood Products; Plywood Operations; Softwood Plywood, Veneer Dryer, DirectNatural Gas-Fired, Heated Zones30900500 Industrial Processes; Fabricated Metal Products; Welding; General30901003 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Entire Process: Nickel30901006 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Entire Process: ChromeB-4Appendix B. Non-category SCCsSCCSCC Description30901018 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Hard Chromium - Electroplating Tank30901028 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Decorative Chromium - Electroplating Tank30901098 Industrial Processes; Fabricated Metal Products; Electroplating Operations; Other Not Classified30901102 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; Acid Cleaning Bath (Pickling)30901103 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; Anodizing Kettle30901104 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; Rinsing/Finishing30901199 Industrial Processes; Fabricated Metal Products; Conversion Coating of Metal Products; OtherNot Classified30905100 Industrial Processes; Fabricated Metal Products; Shielded Metal Arc Welding (SMAW); General30905200 Industrial Processes; Fabricated Metal Products; Gas Metal Arc Welding (GMAW); General30990003 Industrial Processes; Fabricated Metal Products; Fuel Fired Equipment; Natural Gas: Process Heaters30999999 Industrial Processes; Fabricated Metal Products; Other Not Classified; Other Not Classified31299999 Industrial Processes; Machinery, Miscellaneous; Miscellaneous Machinery; Other Not Classified31399999 Industrial Processes; Electrical Equipment; Other Not Classified; Other Not Classified31499999 Industrial Processes; Transportation Equipment; Other Not Classified; Other Not Classified39000699 Industrial Processes; In-process Fuel Use;Natural Gas; General39001299 Industrial Processes; In-process Fuel Use;Solid Waste; General39090001 Industrial Processes; In-process Fuel Use;Fuel Storage - Fixed Roof Tanks; Residual Oil: Breathing Loss39090003 Industrial Processes; In-process Fuel Use;Fuel Storage - Fixed Roof Tanks; Distillate Oil (No. 2): Breathing Loss39090004 Industrial Processes; In-process Fuel Use;Fuel Storage - Fixed Roof Tanks; Distillate Oil (No. 2): Working Loss39090011 Industrial Processes; In-process Fuel Use;Fuel Storage - Fixed Roof Tanks; Dual Fuel (Gas/Oil): Breathing Loss39091004 Industrial Processes; In-process Fuel Use;Fuel Storage - Floating Roof Tanks; Distillate Oil(No. 2): Withdrawal Loss39091011 Industrial Processes; In-process Fuel Use;Fuel Storage - Floating Roof Tanks; Dual Fuel (Gas/Oil): Standing Loss39900601 Industrial Processes; Miscellaneous Manufacturing Industries; Process Heater/Furnace; NaturalGas39990003Industrial Processes; MiscellaneousManufacturing Industries; Miscellaneous Manufacturing Industries; Natural Gas: ProcessHeaters39999992 Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes; Other Not Classified39999993 Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes; Other Not Classified39999999 Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes; Other Not ClassifiedB-5Appendix B. Non-category SCCsSCCSCC Description40100198 Petroleum and Solvent Evaporation; OrganicSolvent Evaporation; Dry Cleaning; Other Not Classified40200801 Petroleum and Solvent Evaporation; SurfaceCoating Operations; Coating Oven - General; General40301001Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying Sizes); Gasoline RVP13: Breathing Loss (67000 Bbl. Tank Size)40301005Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (VaryingSizes); Gasoline RVP10: Breathing Loss (250000 Bbl. Tank Size)40301007Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (VaryingSizes); Gasoline RVP13: Working Loss (Tank Diameter Independent)40301016Petroleum and Solvent Evaporation;Petroleum Product Storage at Refineries; Fixed RoofTanks (Varying Sizes); Jet Kerosene:Breathing Loss (67000 Bbl. Tank Size)40301017Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (VaryingSizes); Jet Kerosene:Breathing Loss (250000 Bbl. Tank Size)40301018Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (VaryingSizes); Jet Kerosene:Working Loss (Tank Diameter Independent)40301019Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (Varying Sizes); Distillate Fuel#2: Breathing Loss (67000 Bbl. Tank Size)40301020Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (VaryingSizes); Distillate Fuel#2: Breathing Loss (250000 Bbl. Tank Size)40301021Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (VaryingSizes); Distillate Fuel#2: Working Loss (Tank Diameter Independent)40301098Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Fixed Roof Tanks (VaryingSizes); Specify Liquid:Breathing Loss (250000 Bbl. Tank Size)40301099Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; FixedRoof Tanks (Varying Sizes); Specify Liquid:Working Loss (Tank Diameter Independent)40301114Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Floating Roof Tanks (Varying Sizes); Jet Kerosene:Standing Loss (250000 Bbl. Tank Size)40301119Petroleum and Solvent Evaporation; Petroleum Product Storage at Refineries; Floating Roof Tanks (Varying Sizes); Jet Kerosene:Withdrawal Loss40400102Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); BulkTerminals; Gasoline RVP 10: Breathing Loss(67000 Bbl Capacity) - Fixed Roof Tank40400108 Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Terminals;Gasoline RVP 10: Working LossB-6Appendix B. Non-category SCCsSCCSCC Description(Diameter Independent)-Fixed Roof Tank40400131Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Terminals; Gasoline RVP 13: Standing Loss-Ext. Floating Roof w/ Primary Seal40400250 Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Plants; Loading Racks40400254 Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Plants; Tank Truck Vapor Losses40400270Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Bulk Plants;Specify Liquid: Standing Loss-Int.Floating Roof w/ Secondary Seal40400316Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Oil and Gas Field Storage and Working Tanks;Fixed Roof Tank, Diesel, working+breathing+flashinglosses40400402Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products-Underground Tanks;Gasoline RVP 13: Working Loss40400411Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products-Underground Tanks; JetKerosene: Breathing Loss40400412Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products-Underground Tanks; JetKerosene: Working Loss40400497Petroleum and SolventEvaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products-Underground Tanks;Specify Liquid: Breathing Loss40400498Petroleum and Solvent Evaporation; Petroleum Liquids Storage (non-Refinery); Petroleum Products-Underground Tanks;Specify Liquid: Working Loss40600131Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Tank Cars and Trucks; Gasoline:Submerged Loading (Normal Service)40600133Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Tank Cars and Trucks; Jet Naphtha:Submerged Loading (Normal Service)40600136Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Tank Cars and Trucks; Gasoline:Splash Loading (Normal Service)40600301Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Gasoline RetailOperations-Stage I;Splash Filling40600302Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products;Gasoline Retail Operations-Stage I;Submerged Filling w/o Controls40600306Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Gasoline RetailOperations-Stage I;Balanced Submerged FillingB-7Appendix B. Non-category SCCsSCCSCC Description40600307Petroleum and Solvent Evaporation; Transportation and Marketing ofPetroleum Products; Gasoline Retail Operations-Stage I;Underground Tank Breathing and Emptying40600401Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Filling Vehicle Gas Tanks-Stage II;Vapor Loss w/o Controls40600402Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Filling VehicleGas Tanks-Stage II;Liquid Spill Loss w/o Controls40600503Petroleum and SolventEvaporation; Transportation and Marketing of Petroleum Products; Pipeline Petroleum Transport-General - All Products; Pump Station40600707Petroleum and Solvent Evaporation; Transportation and Marketing of Petroleum Products; Consumer (Corporate) FleetRefueling - Stage I; Underground Tank Breathing andEmptying40799997 Petroleum and Solvent Evaporation; OrganicChemical Storage; Miscellaneous; Specify in Comments41082001 Petroleum and Solvent Evaporation; Dry Cleaning; Petroleum Solvent - Wastewater, Aggregate; Process Area Drains42500101 Petroleum and Solvent Evaporation; Fixed Roof Tanks (210 Bbl Size) Breathing Loss42500102 Petroleum and Solvent Evaporation; Fixed Roof Tanks (210 Bbl Size) Working Loss50100402 Waste Disposal; Solid Waste Disposal - Government; Landfill Dump; Fugitive Emissions50100404 Waste Disposal; Solid Waste Disposal - Government; Landfill Dump; Trench Method50100406 Waste Disposal; Solid Waste Disposal - Government; Landfill Dump; Gas Collection System: Other50100601 Waste Disposal; Solid Waste Disposal - Government; Fire Fighting; Structure: Jet Fuel50200103 Waste Disposal; Solid Waste Disposal - Commercial/Institutional; Incineration; Controlled Air50200602Waste Disposal; Solid Waste Disposal-Commercial/Institutional; Landfill Dump; Municipal:Fugitive Emissions ** (Use 5-01-004-02)50300205 Waste Disposal; Solid Waste Disposal - Industrial; Open Burning; Rocket Propellant50300702 Waste Disposal; Solid Waste Disposal - Industrial; Liquid Waste; Waste Treatment: GeneralC-1Appendix C. Additional Non-Category SCCs with UnitDescriptionsEmission Unit DescriptionSCCSCC DescriptionBuilding 1665-open topchemical tank 39999995IndustrialProcesses; Miscellaneous Manufacturing Industries;Miscellaneous Industrial Processes;Other Not ClassifiedExplosives Manufacturing 49099998Petroleum and Solvent Evaporation; Organic SolventEvaporation; Miscellaneous Volatile OrganicCompound Evaporation; Identify the Process and Solvent in CommentsFIRING RANGE TRAININGOPERATIONS 40200101Petroleum and Solvent Evaporation; Surface CoatingOperations; Surface Coating Application-General; Paint: Solvent-baseSolids Handling 39999994Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes;Other Not ClassifiedAutoclave (from facility ID5555) 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasAutoclave (NTR) 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasBoilers and Humidifiers (Iand S) 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasClean Line-Heating Units(I and S) 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasCoating Ovens (NTR) 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasGAS OVENS-PAINTCURING 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasHEATERS (I and S andNTR) 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasOvens 1-10 (from facilityID 5555)(I and S) 40201001Petroleum and Solvent Evaporation; Surface CoatingOperations; Coating Oven Heater; Natural GasFire training pit 39999994Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes;Other Not ClassifiedBuilding No. 4035-hardchrome plating tank[MACT, Subpart N] 39999994Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes;Other Not ClassifiedCADMIUMELECTROPLATING LINE 39999995Industrial Processes; Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes;Other Not ClassifiedWastewater Treatment 39999995Industrial Processes; Miscellaneous Manufacturing Industries;Miscellaneous Industrial Processes;Other Not ClassifiedC-2Appendix C. Additional Non-Category SCCs with UnitDescriptionsEmission Unit DescriptionSCCSCC DescriptionWastewater treatmentfacility 40188898Petroleum and Solvent Evaporation; Organic SolventEvaporation; Fugitive Emissions; Specify inComments FieldWelding Sources 39999995Industrial Processes;Miscellaneous Manufacturing Industries; Miscellaneous Industrial Processes;Other Not Classified