DEPART:MENT OFENVIRONMEl\iAL QUALITY 

DMSION OF AIR QUALITY 

Michael O. Leavin 150 North 1950 Wesl
 

Governor
 P.O. Box 144820 

..mne R. Nielson. Ph.D. Salt Lake City. Utah 841144820 

Exccuuvc Ducetor (80l) 5364000 Voice
 

Russell A. Robens (801) 5364099 Fax
 D1rcctar (801) 536-4414 T.D.D. 

DAQE-163-96 

February 9. 1996 

James R. Van Orman 

Hill Air Force Base 

Headquaners 

Ogden Logistics Center (AFM:C) 

Hill Air Force Base, Utah 84056 

Dear Mr. Van Orman: 

Re:	 Approval Order for Medium Pressure Water & Chemical Paint Stripping of Aircraft
 

Davis County. CDS-AI. Non-Aitainment, Title V
 

The attached document is an Approval Order for the above referenced project. 

Future correspondence on this Approval Order should include the engineer's name as well as the DAQE 

number as shown on the upper right-hand comer of this letter. Please direct any technical questions you may 

have 0 s pr ~ect to Mr. Nando Meli. He may be reached at (801) 536-4052. 

RAR:NM:aj 

cc:	 Davis County Health Depanment 

28 East State Street 

POB 618 

Farmington, UT 84025-618 

• ' .
 

lAo 

. 4.2A-7
 
DAQE-163-96 

February 9. 1996 

Page 2 -

STATE OF UTAH
 

Department of Environmental Quality
 

Division of Air Quality
 

APPROVAL ORDER FOR MEDIUM PRESSURE WATER &
 

CHEMICAL PAINT STRIPPING OF AIRCRAFT
 

Prepared By: Nando Meli, Engineer
 

801·536-4052
 

APPROVAL NUMBER
 

DAQE-163-96
 

Date: February 9,1996
 

Source 

Hill Air Force Base 

James R. Van Orman 

801-777-2050 

Russell A. Roberts
 

Executive Secretary
 

Utah Air Quality Board
 

4.2.4-8
 
DAQE-163-96
 

February 9, 1996
 

Page 3
 

Abstrtul 

Hill Air Force Base (HAFB) is requesting approval to use a Medium Pressure Water (MPW) stripping 

system to strip paint offofaircraft. In the past a chemical paint stripping method using methylene chloride 

was used to strip paint offan aircraft. The VOC and Hazardous Air Pollutanrs will be less when the MPW 

system is utilized. The VOC emissions in building 206 from the Medillm Pressure Water and Chemical 

Paint Stripping operations shall be 5.41 tons per 12-month period. 

The above-referenced project has been evaluated and found to be consistent with the requirements of the Utah 

Air Conservation Rules (UACR) and the Utah Air Conservation Act. A 30-day public comment period was 

held and all comments received were evaluated. The conditions of this AO reflect any changes to the 

proposed conditions which resulted from the evaluation of the comments received. This air quality AO 

authorizes the project with the following conditions and failure to comply with any of the conditions may 

constitute a violation of this order: 

General Conditions: 

1.	 This AO applies to the following company: 

FacWry Location 

.--	 Depanment of the Air Force 

Headquaners Ogden Logistics Center (AFMC) 

Hill Air Force Base. Utah 

PHONE NUMBER (801) 777-0359 

FAX NUMBER (80l) 777-6742 

The equipment listed below in this AO shall be operated at the following location: 

PLANT LOCATION' 

East of Exit 336 on Interstate 15 

Universal Transverse Mercator (UTM) Coordinate System: 

4.551 kilometers Northing; 418 kilometers Easting; Zone 12 

2.	 Definitions of terms. abbreviations, and references used in this AO conform to those used in 

the UACR. Utah Administrative Codes (UAC). and Series 40 of the Code of Federal 

Regulations (40 CFR). These definitions take precedence unless specifically defined 

otherwise herein. 

3.	 Hill Air Force Base (AFB) shall install and operate the Medium Pressure Water & Chemical 

Paint Stripping of Aircraft in Building 206 according to the tenns and conditions of this AO 

as requested in the Notice of Intent dated November 27.1995. and additional infonnation 

submitted to the Executive Secretary dated December 7. 1995. 

4.2.4-9 
DAQE-163-96 

February 9. 1996 

Page 4 

4.	 A copy of this AO shall be posted on site. The AO shall be available to the employees who 

operate the air emission producing equipment. These employees shall receive instruction as 

to their responsibilities in operating the equipment according to all of the relevant conditions 

listed below. 

5.	 The approved installations shall consist of the following equipment or equivalent: 

A.	 Aqua Miser Medium Pressure Water Paint Strippers 

B.	 Air Operated Drum Pumps and Spray Wands with non-atomizing tips 

* Equivalency shall be detennined by the Executive Secretary. 

Limitations and Tests Procedures 

6.	 Visible emissions from any stationary point or fugitive emission source associated with the 

source or with the control facilities shall not exceed 10% opacity. Opacity observations of 

emissions from stationary sources shall be conducted in accordance with 40 CFR 60. 

Appendix A. Method 9. 

7.	 The following production limits shall not be exceeded without prior approval in accordance 

with R307-1-3.1, UAC: 

A.	 3300 gallons of Paint Stripper per rolling 12-month period 

B.	 150,000 Ibs of Sodium Bicarbonate per rolling 12-month period 

Compliance with the annual limitations shall be determined on a rolling 12-month total. The 

owner/operator shall calculate a new 12-month total based on the first day of each month 

using data from the previous 12 months. TIris total shall be calculated by the tenth day of the 

following month. Records of consumption shall be kept for all periods when the plant is in 

operation. Records of consumption, including rolling 12-month totals shall be made 

available to the Executive Secretary or his representative upon request and shall include a 

period of two years ending with the date of the request. Consumption shall be determined 

by purchase records and operations log. The records shall be kept on a daily basis. 

Fugitive Dust 

8.	 The moisture content of the material used containing sodium bicarbonate shall be maintained 

at a minimum of 80.0% by weight as the material is blasted from the Aqua Miser. All of the 

sodium bicarbonate shall be periodically swept or sprayed clean from all surface areas as dry 

conditions warrant or as determined necessary by the Executive Secretary. The moisture 

content shall be tested if directed by the Executive Secretary using the appropriate American 

Society of Testing and Methods (ASIM) method. 

4.2.4-10
 
DAQE-163-96 

February 9. 1996 

Page 5 

VolatHe Organic Compound (VOel Limitations 

9.	 The facility shall abide by all applicable requirements of UAC R307-14 for volatile organic 

compound (VOC) sources located in an ozone Nonanainment area. At a minimum. RACT 

control measures are required and BACf will be no less stringent than RACf. These 

requirements include but are not limited to: 

"14-5.A.(5) Written procedures for the operation and maintenance of the degreasing 

or solvent cleaning equipment shall be permanently posted in an accessible and 

conspicuous location near the equipment." 

The full text of UAC R307-14 is included as Appendix A. However. to be in compliance. 

this facility must operate in accordance with the most current version of R307-14 or the 

applicable section(s). if renumbered. 

10.	 The emissions of VOCs in building 206 from the Medium Pressure Water and Chemical 

Paint Stripping operations. etc. and associated operations shall not exceed: 

5.41 tons per rolling 12-month period for VOCs 

This value shall not be exceeded without prior approval in accordance with R307-1-3.1. 

UAC. Compliance with the limitation shall be determined on a rolling 12-month total. 

Based on the first day of each month a new 12-month total shall be calculated using data from 

the previous 12 months. 

The emissions of VOCs emitted to the atmosphere from Building 206 shall be determined by 

maintaining a record of volatile organic compound potential contained in materials used each 

month. The record shall include the following data for each item used: 

A.	 Name of the VOC emitting material. such as: paint. adhesive, solvent. thinner. 

reducers, chemical compounds, isocyanates. etc. 

B.	 The weight and use location of the volatile organic compound potential and 

hazardous air pollutant potential of the material(s) listed in A in pounds per gallon. 

C.	 Percent by weight of all volatile organic compound potential and hazardous air 

pollutant potential for each individual material listed in A. The percent by weight 

of the volatile and hazardous air pollutant potentials can be obtained from the 

manufacturers' MSDSs. The owner/operator can obtain MSDS data from the 

manufacturers of the materials and retain the information on-site. 

D.	 Amount and location of materials containing VOCs used on a monthly basis and 

summed for every location and for the entire plant each month. 

E.	 To calculate the above potentials contained in the material listed in D use the 

following procedure: 

4.2.4-11 
DAQE-163-96 

February 9, 1996 

Page 6 

VOC = (% Volatile by Wei~ht) x (Density lb) x (Gal Consumed) x (l...!Qn) 

(100) (gal)	 (2,000 Ib) 

F.	 The amount of volatile organic content potential (potential air emissions) and 

hazardous air pollutant potential (potential air emissions) in pounds contained in 

materials deposited as solid or hazardous waste for the month shall be quantified, and 

can be subtracted from the quantities calculated above. This is done to allow 

quantification by the source of the total VOCs emissions. (The assumption is that 

all the two above potentials of the materials applied to a product evaporate and are 

therefore considered emissions). 

G.	 Records of consumption of VOCs shall be kept for all periods when the plant is in 

operation. Records of consumption shall be made available to the Executive 

Secretary upon request, and shall include a period of two years endin~ with the date 

of the request. 

11.	 TIlis source is a major Title V source needing an Operating Pennit. It is required to pay an 

annual emission fee upon stan-up, or if an existing facility, upon issuance of this AO. The 

fee will be based on calculated annual emissions listed at the end of this AO. This fee is valid 

until inventory data for one year are available for the source. The owner or operator of this 

source will be billed upon start-up for all emissions that are considered "chargeable" as of that 

date. 

Records & MiscellaneoUS 

12.	 All installations and facilities authorized by this AO shall be adequately and properly 

maintained. All pollution control vendor recommended equipment shall be installed, 

maintained, and operated. Instructions from the vendor or established maintenance practices 

that maximize pollution control shall be used. All necessary equipment control and operating 

devices, such as pressure gauges, amp meters, volt meters, flow rate indicators, temperature 

gauges, etc., shall be installed and operated properly and easily accessible to compliance 

inspectors. A copy of all manufacturers' operating instructions for pollution control 

equipment and pollution emitting equipment shall be kept on site. These instructions shall 

be available to all employees who operate the equipment and shall be made available to 

compliance inspectors upon their request. 

13.	 The owner/operator shall comply with R307-1-3.5, UAC. This rule addresses emission 

inventory reporting requirements. 

14.	 The owner/operator shall comply with R307-1-4.7, UAC. This role addresses unavoidable 

breakdown reporting requirements. The owner/operator shall calculate/estimate the excess 

emissions whenever a breakdown occurs. All excess emissions shall immediately be reported 

to the Executive Secretary. The total of excess emissions shall be reported to the executive 

secretary as directed for each calendar year. 

4.2.4-12 
DAQE-163-96 

February 9, 1996 

Page 7 

15.	 All records referenced in this AO which are required to be kept by the owner/operator, shall 

be made available to the Executive Secretary or his representative upon request and shall 

include a period of two years ending with the date of the request. All records shall be kept 

for a period of two years. Examples of records to be kept at this source shall include the 

following as applicable: 

A. Production rate (Condition number 7) 

B. VOC consumption records (Condition number 10) 

C. Maintenance records (Condition number 12) 

D. Upset, breakdown episodes (Condition number 14) 

Any furore modifications to the equipment approved by this order must also be approved in accordance with 

R307-1-3.1.1, UAC. 

This AO in no way releases the owner or operator from any liability for compliance with all other applicable 

federal, state, and local regulations including the UACR. 

Annual emissions from the Medium Pressure Water & Chemical Paint Stripping of Aircraft in Building 206 

are currently calculated at the following values: 

Pollutant	 Tons/yr 

PMIO ···························0.65 

VOC 5.41 

These calculations are for the purposes of determining the applicability of Prevention of Significant 

Deterioration and nonattainment area major source requirements of the UACR. Except for VOe's they are 

not to be used for purposes of determining compliance. 

In accordance with the requirements of Title V of the 1990 Clean Air Act, the following pollutants may be 

subject to an operating permit fee. Emissions of the following pollutants from all sources, including preNovember 19, 1969 sources, may be subject to the operating permit fee. Both the fees rate and the class of 

pollutants are subject to change by State, the federal agencies, or both. 

Pollutant	 Tons/yr 

PMIO ···························0.65 

VO 5.41 

4.2.4-13
 
DEPARTMENT OF ENVIRONMENTAL QUALITY 

DIVISION OF AIR QUALITY 

Michael O. Leavin 150 North 1950West Govcmor P.O. Box 144820 

Dianne R. Nielson. Ph.D. Salt Lake City. Utah 84114-4820 Execuu.< DiRaor (801) 536-4000 Voice 

RusseU A. Roberts (801) 536-4099 Fax
 

Direclor
 (80l) 536-4414 T.D.D. 

DAQE-014-96 

January 5, 1996 

Newspaper Agency
 

Legal Advertising Depanment
 

157 Regent Street
 

Salt Lake City, UT 84111
 

This letter will confinn the authorization to publish the attached NOTICE in the Newspaper Agency on -" 

January 9, 1996. 

Please mail the invoice and affidavit of publication to the Utah State Depanment of Environmental Quality, 

Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. 

Sincerely, 

/I' 

-~Q~000rr~U melia 1aram' 0
 

Office Technician
 

Utah Division of Air Quality
 

Enclosure 

-


4.2.4-14
 
DAQE~014-96

Page 2 

NOTICE 

The following notice of intent to construct, submined in accordance with Section 3.1. Utah Air Conservation 

Rules. has been received for consideration by the Executive Secretary. Utah Air Quality Board: 

1.	 lohn Vidik
 

Hill Air Force Base
 

OO-ALCIEM
 

7274 Wardleigh Road
 

Hill Air Force Base. lJT 84056-5137
 

Medium Pressure Water & Chemical Paint Stripping of Aircraft
 

The Net Increase in Approved Emissions will be ( A negative sign indicates a decrease in 

emission rates.): 

TSP	 0.65 tons/year 

0.65 tons/year 

VOC 5.41 tons/year 

The engineering evaluation and air quality impact analysis have been completed and no adverse air quality 

impacts are expected. It is the intent of the Executive Secretary to approve the construction project. 

The construction proposal and estimates of the effect on local air quality are available for public inspection 

and comment at the Division of Air Quality, Utah State Department of Environmental Quality, 1950 West 

North Temple, Salt Lake City, Utah 84114-4820. Wrinen comments received by the Division, at the same 

4.2.4-15 
DAQE-014-96 

Page 3 

address on or before February 8. 1996. will be considered 10 making the final decision on the 

approval/disapproval of the proposed construction. 

If anyone so requests to the Executive Secretary in writing. within 15 days of publication of the Notice. a 

hearing will be held to explain the project and technical rationale for proposed action. A hearing will be 

scheduled as close as practicable to the proposed project location. Comments obtained during a hearing will 

be evaluated and considered by the Executive Secretary before making a final decision on the 

approval/disapproval of the project. 

Date of Notice: January 9, 1996 

-


4.2.4-16
 
. .

. '. 

TURCO 6813 (US PAT~~ 15387363) PAOZ 4 OF 4
 

MIXING:
 

Usa eare to avoid splashinq. GSQ aopropri~te orctec~ivQ equipment.
 ,..... RiPA!~ A.HD !o'..AIm'EN.AJ{C,£ OF COtr:'AMINATED EQO'lPH!h: ~e11.v. any pr.ssu~e. Cover openin~s to 4void apurti~q. Clean 

e%terior and int.r~or by flush~nq w~tb water. Collect flusninqs for 

di.posal. Use proteetiva equipment for eyes, .k~n and inhalation. 

,**.*•••• *~**•• ***~********.******.*.9******a.*••*.* •••••*** •• ***** •••***_ •• 

CBECXED BY: John r. Grainger, Clreetor Tech. Servo 

APPROVED BY: ~ohn F. Gr~ingQr, Director Tech. Servo 

DATE PREPA.RtD: 06/14/95 DATX :PRI~EP: 06/16/95 FlU NO: 6813'}.005/ 

'­

" 

-

-


4.24-60
 
TUaCO 6813 (OS PATE~ 1~387363) PAGE 3 OF • 

SAZAADOOS OZCQMPOSITI05 PRODUCTS: 

Thermal decomposition may produce carbon mODo%ide, dio%ide and other .- tone volatile orqanie compounc:1• 

•••••••••• ***••••••• .** *** ••w ••• * •••••• **w ••••••**•••*.****•••••••••••* 

SECTION VII - SPILL, LEU AND DISPOSAL PROCEDURE: 

-------~----------~---------~~-------------~-------------- ---------------- SPILL OR R!LElSE PROCEDURE: COBC!~TRATE
 

Contain 8pill~qe. Stop leak at source if ~his can be aono sa~ely.
 

ve~tila~e area. ~onessen~i&l personnel should leave tbe area until
 

cleanup is eomplotQd. Pump liquid. into DOT-approved drums tor .
 di.aposil. Absorb ramain.inq liquid on~o inert absorbent \lnd place. fn
 

DOT-approved drums tor dispo8al. Wash arQ4 with water. Collect
 

washinqs and place in DOT-appro~ed tor disposal. K••D
 

coneantra~. and wash water from en~erinq sewers or waterways.
 tiS! SOLUTION:
 

As for concentrate, it applicable.
 

DISPOSAL 11i70RHATION: CONCElrI'RATt:
 

(1) Transfer to reclaiming-centar for recycling or reUS8, if possible. (2) Tran.!er to licensed waste treatman: or di~osal sits for 

disposition unae= applicable local, state and reqional regulations.

sPIn SOLO'l'ION .um RINSES: . , D1spo•• per (1) or (2) above, or spent solution and rinses can b. 

neutralized, and flo4~able 3011 and secarated solvent ~k~.d ott. 

Residual orqanic matter may be ramoved·by oxidat1on and/or carbon 

treatment. ~larif1ed water may be released to sewer it local regu1a~1gna permit. 

SECTIO~VIIr - SPECIAL PROTXCTI0N INFORMATION: 

"" -------~-------~-------~-------~~-----------~-~----------~---------------

RESPIRATORY PR~CTIOH:

If TLV is 8%c••dad, a NIOSS-approved self-contained breathing appara~us, positive pressure hOSQ mask or an air line m~8k is advised. 

Those should have a full face piece and be operated in a pos1~iv~

pressure mode. Por limi~&d expo.ure tim~, in-areas of good ventilation, a full face mask with cartridge or canister ratsd for 

ammonia or Aminas may be used. These must not be used i~ any areas 

where a danq.~ of ozvqen deficiency exists, such ~s partly' enclosed or 

low lrinq aroas, including ~umps or t&nka. !f r.8~irators arB used, a 

forma trai~ing anc screening program must'be init~atad. s•• 29 CFR 

1910-13•• 

VEJITILATION: 

Maintain 8utticiant mechanical ventilation to. keep concent=ation below 

1LV. 

PROTrCTI~ EQUIPMENT:
 Protoetive equipmsnt: race shiald or goggles, gloves} boots ana apron
 mad. of solvent ra.~.tan~ materia~ (c.g. neoprene, viton, .~c.).
 

Protec~ive suit not normally r~~~rQd.
 

RECOMMEBD~D PERSONAL HYQIENE
 Wash hands and face wi~h soap and weter before smok~n9 Qr ea~inq.

I~~ately ramgv~ al~ con~aminatad clo~bing. ;aunder sep~a~.ly . betore reus.. D~seard shoes thAt beCOMA con~am~~&~ed on the in~er~or.

SECTIOli IX - OTRER INFORMATION: 

-------------~-----------------------------------------------~-------------~ __. S~!c:~AL PJtEC~CTIONS - STORAGE AND aANDLINQ:
 

Store Ln dry protected ar-a away from ~~ronq ox~d~~~nq dgents .
 

.­ 4.2.4-59
 
,-_~ i...i_ 

;};.~ _~: l-j~~ _,:j: ~J. :;.1. ~=.::;~::'

. ..,-..­ _ - ~'=~5 .j;':~3

TaRCO 6913 (US PA~HT JS3S736~) P~GE 2 OF 4 ._••*.*•••••••••*•••**.w* •• ~y.*.*w•••• *.w•• ***~.K••• *•• e ••••••"'•••••• 

SECT!O~ !V - lIRE L~ ZXPLOSION RAZ~S;

...--_..---------....------....-_-..~----_ .._------------------------...----_.._-_.. 

:rLASH FOINT AND ¥.!THOD USED: None to boi1 (Tee) 

ZXTI~GU!9HInG Mi~ll:
 

~oam, c~rbon dioxide, dry chomical
 S~ICLAL FIRE FIGHTING f~OCEDU~ AND ~RECAUTIONS:
 

Use se~£-containad r ••pirAtory protection.
 

UNUSUAL FIQ Ami EXPLOSION tiUARDS:
 

Mone
 

***._ *.~ *••• tr* ••**.. ."••***•••••*****..*.2:.*. * ~lf. 'Ill. **. 'Ill_ ~'* 'lilT tt':t:l'''. 

SiCTION V - SEALTH AND ~RGENCY !NFORMATION: . 

~---------~--~~----------------------------------~----------------------- EFFECTS OP OVER-EXPOSURE: ZYES:
 ContAe~ with ey•• ~y c~use rnod.ra~e ~o aever9 ~rri~ation.
 

SJ;IS:
 

Contact. with akin ::l~Y cAusa ~oder~te to severe irrit!1tio:a:. d:y1nq.,
 c1.:I!att~n<1.
 

Ilm:.U..AT!OI:f:
 

VapQra: Uoderate irrit~~~on, a~z:inesst headachs. Mists: Severe
 re~piratory irrita~~Qn, na~5ea.
 

INGESTION:
 

Moderate to severe irri~A~icn of qastroin~esti~al trac~, nausea.
 

KtDICAL CONDITIOliS i.-RICH MAY 6E AGGRAVA.TED:
 

No known chro~c ef:ee~s ~hat differ from ecute ef£ecta.
 " . 

......,,,•••••••* *...... •• ok_ *,. **••*Ill **.**•• lir _ "ir. 

SECTICN VA - 7IRST AID tNFORMA~ION:

--~--~-~-~--------~--~~-------~------------------------ ..--~------~ FIRST ~: EYES:
 

Flush ay•• wi~h larqQ volUMes of water far at least 15 mi~ut••. If
 

irritation persi3ta, obtain ~edical sttention.
 

9ltIlf:
 

Plush affected area with large volumes of ~ater. W~sh witb soap ana
 

watar. RinsQ thorou~hly. If irritation i3 eVidant O~ bli3~er1nq
 

occurs, obt4in medical att.ntio~.
 

nm.1,LA'1'ION:
 

R-=cve to fr.sb air. !f braatbing is dif:icult, adm~s~~r ~%yqen. If
 braa~nq ha~ stopped, 4pply a~iiicial r.s~irAtion. O~~ain ~edieal
 

4tt.D:t.:"O~.
 

!XGESTION: 

Do not induce vo~tinq except on aavicG of ccmpe~aDt medical 

personnel. If voQitinq occurs apontaneouslYI keep teaa nelow hip level to reauce possibility of espir&tion pneumc~~1s. r! victim is 

Goo8cicU3, dilute by giving large vol~es of milk O~ ~~atQr. Ob~ain

i.mm.d.iata medical 4~tent.io:o. llBver a.ttsilipt ·to induce ';1om.itinc;l or g1ve anYt:hi~g by mouth to an unconscioU3 person. 

PRIMARY ROCTtS OP eNTRY AU ZWll.AT!OIl aD SitUl CONTACT. 

S~CT!ON VI - AEACTIVITY DATA: 

~~--~---~--~-------~-~~---~~----------------------_._----------------- STABILITY: STULl 

COND.ITIOHS TO AVOID: 

,-Coutact with atronq o%1dizi~g ~atsriAls

.­

4.2.4-58 
_ ... -.. --_.­

, '. 

- TtrRC:O M1.TIRI.1.I. SUETY 

._. DATA SREET

-- TURCO 6813 (US PATENT 153a7363) CS No.: 03580 Da~.: 06/16/95 Page 1 of 4 •• *.*•••••••• * •• *.9.*** •••••*•• Y.1~.*.*W.*••*****••• ~. ••t**  ••••••**•• 

srCTION I ~7ACTUR£~'S HAKE AND ADDRESS 

;~~t;~~~;;7;-;;;;~-~~~~~:~~~~iF--~~::-:::::-::::~~:--\~~-~------~l
 Add.resS!: 7320 aOLSA AV'ENiJE	 l'"3 '\ "It.. 

WESTMIHSTER, CA 9268' 

Bftergency ~elephoDe% (202) 483-7616 (800) 424-9300~,~~~~~/~,\; For ~formatio~: (714) 690-3600 •••••••••••••* ••••••••••*s ••••••***•••••••••r ••*•••••••••••••**.*••***•••• 

SEC'l'IO%f I: HA..ZARD IlfFOR1QTIOH 

----------~--------~--~--------~----~-~----~----------~-~----------_

TKE FOLLOWING IliG'RED!!NTS ARE VEI"r1iEn TO BE HAZARDOUS 

PER 29CYR 1910-1200: 

NAME (CAS) 

CERCLA RCRA SARA
 

RO NO REPORTAatE
 

BENZYL ~COHOL (100-51-6)


ROT LISTED NOT LISTED NO 40 

~CGIB TLV: ~OT tSTABLIS~D

OSHA PEL: YOT iSTUl.ISHED 

LINEAR ALXYLkT~D	 ARYL HYDROCARBON (6864e-87-3)
 

~OT ~ISTXD ~OT LISTED NO <S
 

ACGIB TLV: NOT rSTABLrSBZD
 

OSHA. PEI.: NOT ESTA:BLISHED
 " 

FOLLOWING INGREDIENTS ARE NOT RECUIRED TO BE LISTtD BY 

29C7R 1910-1200, sUT AR% ~IST!D IN CONFORMANCE WlTH 

1'RE ' RIGH'1'-'I'O-lQiOt,f' lAWS O}~ CER'l'AIN STl.T!S, INCLUD;rNG 

PENNSYLVANIA ANn NlW JERSEY: 

WAT~R (773~-18-5), AMMONIUM HYDROXIDE (AMMONI~) (1336-21-6), 

KEXYNOL (l05-31-7) 

CARCINOGENS: NONt (AS O~Y!NED IN 29CY~ 1910-1200, .\FPENDIX A{l) 

DOT I N'TORMATI ON PROP~R SRIPP1NG NAME: NOT REGULATE~ BY DOT IN NORMAL GROUND TRANSPORTATTCN 

IN CONTAINERS OF 110 GALLONS OR LESS 

" ••*••_*.... **.~~.**.*•••••••• *.*.***.*.~~~.*._*•••••••••••••••*-* •••••••••. SECT~ON rrI P~lSICAL PROFERTIES (TYPICAL) 

--------~---------------------------------~-~-----------------~----------

So~l~~q po~nt! Ap~rox. ~l~ deq.~. Specific gravi~y: 1.01
 

SCAOMD vOC co~s~te vapor pressure: <O.1mm Hq (calc. by R4oult'~ Law)
 

S~QMD voe: 393 q/:.(calcUla~ed from ncmi~al co~pos1t1on)
 

Vapor density: >1 ~vapo.ation rata: <1
 

r- (ALr-l) (BuAC-l) To~a.l v&por pre.sure (i~cl'Udinq ~at.r, :z..pprO%. J.~mru.Bq

Total ~olAt~le (incl~~ing water), by volume: Approx. 97\ 

Solubility in WA~e~: Appreciable pH: A# is 12.0 

Appearanca and Qdor: . Liqht blue emulsion, ammon1acal odor 4.2.4-57 
-


Historically, HAFB has processed approximately 50 aircraft per year, however. 

not all aircraft were fully stripped and painted. The projected chemical usage is worst 

case and assumes that all aircraft will require paint removal. 

A formal test report will be forwarded as soon as it is available. Please contact 

David Budak, at (801) 777-1449, for additional information. 

r 

J~R.JWv1D~ JAMES R. VAN ORMAN 

Director of Environmental Management 

Attachment: 

MSDS 

cc:
 

EMP
 

LAOPE (ATTN: John Vidic)
 

4.2.4-56
 
DEPARTMENT OF THE AIR FORCE - RECEIVED

HEADQUARTERS OGDEN AIR LOGISTICS CENTER (AFMC) .' NOV 2 7 1995 HILL AIR FORCE BASE. UTAH	 -­

Air Quality 

Mr. James R. Van Orman 

OO-ALCIEM 

7274 Wardleigh Road 

Hill AFB UT 84056-5137 

Mr. Russell A. Roberts 

Executive Secretary 

Division of Air Quality 

1950 West North Temple 

PO Box 144820 

Salt Lake City, LIT 84114-4820 

RE: Notice of Intent for Medium Pressure Water and Chemical Paint Stripping of C-130 

Aircraft at Hill Air Force Base (DAQE-1000-95 , 2 Nov 95) 

Dear Mr. Roberts 

The Experimental Approval Order (DAQE-lOOO-95 ,2 Nov 95) authorized Hill 

Air Force Base (HAFB) to determine if a lower VOC emission paint removal process 

could be developed. Experimental testing for paint stripping of C-130 aircraft has 

proceeded in accordance with the referenced approval order and actual test data supports 

this request for a permit. 

HAFB requests approval to strip paint from a maximum of 50 C-130 aircraft per 

year utilizing the Medium Pressure Water (MPW) paint strip process augmented by 

chemical stripping. The following are the estimated operating parameters: 

a.	 Process description: Selected aircraft parts are masked, chemical stripper is 

applied to soft skinned areas of the aircraft, medium pressure water at 15,000 

psi (3.2 gallon/minute) with sodium bicarbonate (2.5 ounce/gallon) is blasted 

at the paint surface, paint solids entrained in the blast water are captured in the 

industrial drain system. 

b.	 Chemical paint stripper usage: 105,000 pounds/year of Benzyl Alcohol (see 

attached MSDS) 

c.	 Sodium Bicarbonate usage: 750,000 pounds/year. 

d.	 Projected air emissions: 105,000 lbs of VOC's 

e.	 Proposed method to track air emissions: Log chemical use, hours of 

operation, and number of aircraft stripped. 

f.	 Tentative schedule to start operations: 30 January 1996. 

4.2.4-55 
­

?~~ i:L \)0 c. ::­ /())i~tl i! LJoc. 

.rJ - ~,(-( I J#.u vO C. ... 

I 

j-;r-, (, .5 /11 Sc) ~U"7 Ii' ;c~r~

_-;), c::' """' 6\ (, (9 /.? :::>0 

J 3,). 

4.2.4-54
 
-- The paint softener ~hall be applied with a stainless seed application gun (car wash type) 

with a non-aLomizing tip, and I or hand applied with a brush. 

4.2.4-53
 
AIRCRAFT OPERATIONS 

TELEFAX COVER SHEET 

HILL AIR FORCE BASE 

OOALe/ 

BLDG. 225 

HILL AF8. UT 84056 

PHONE: 

FAX: 

FAX; DATE: / I 

DE Ll VER TO: 1\J~ el~ fV1 e.f; 

FROM: ~~~..... V-:J r L_ NUMBER/PAGES 1 OF~

MESSAGE:
 

A) Of'k 

) 

-t\..<- J,J-$vrJf7 f:, ..... 

4.2.4-52
 
f. Tentative schedule to start operations: 30 January 1996. 

Historically, HAFB has processed approximately 50 aircraft per year. however, 

not all aircraft were fully stripped and painted. For our request of 27 November, the 

process engineers assumed worse case conditions. However they now believe this 

revision is closer to the actual requirements. 

A formal test report will be forwarded prior to 4 February, 1996. Please contact 

David Budak, at (801) 777-1449, for additional information. 

p/f/()1 4. )lJJI M SR. VANORMAN 

Director of Environmental Management 

cc:
 

EMP
 

LAOPE (AnN: John Vidic)
 

4.2.4-51
 
DEPARTMENT OF THE AIR FORCE
 

HEADQUARTERS OGDEN AIR LOGIS1'CS CENTER (AFMC)
 

HILL AIR FORCE BASE, UTAH
 

December 7. 1995 

Mr. James R. Van Onnan 

OO-ALCJEM 

7274 Wardleigh Road. 

Hill AFB UT 84056-5137 

Mr. Russell A. Robens 

Executive Secretary 

Division of Air Quality 

1950 West Nonh Temple 

PO Box 144820 

Salt Lake City, UT 84114-4820 

RE: Notice ofIntent for Medium Pressure Water and Chemical Paint Stripping ofC-130 

Aircraft at Hill Air Force Base 

Dear Mr. Roberts 

The Experimental Approval Order (DAQE-l000-95 ,2 Nov 95) authorized Hill 

Air Force Base (HAFB) to determine if a lower VOC emission paint removal process 

could be developed. Experimental testing for paint stripping of C-130 aircraft proceeded 

in accordance with the referenced approval order and actual test data suppons this request 

for a pennit. On 27 November 1995, RAFB requested approval to strip up to fifty aircraft 

per year for a total maximum annual release of 105,000 pounds VOe's. However. funher 

analysis of the test data indicate only 10,800 lbs of VOC will be required per year. . 

Based upon the results of the test, HAFB requests approval to strip paint from
 

aircraft utilizing the Medium Pressure Water (MPW) paint strip process augmented by
 

chemical stripping. The following are the estimated operating parameters:
 

a.	 Process description: Selected aircraft pans are masked, chemical stripper is 

applied to soft skinned areas of the aircraft, medium pressure water at 15,000 

psi (3.2gallonlminute) with sodium bicarbonate (2.5 ounce/gallon) is blasted 

at the paint surface, paint solids entrained in the blast water are captured in the 

industrial drain system. 

b.	 Chemical paint stripper usage: 10,800 pounds/year of Benzyl Alcohol 

c.	 Sodium Bicarbonate usage: 150,000 pounds/year. 

d.	 Projected air emissions: 10,800 lbs of VOe's 

e.	 Proposed method to track air emissions: Log chemical use and hours of 

operation. 

4.2.4-50 
.I."" 'tspaper Agency L-orporatlor 143 SOUTH MAI~ ST. 

P.O. BOX 45838 ..-Jt ,ialt ~kt iribunt (~) DESERET NEWS CUSTOMER'S 

SALT LAKE CITY, UTAH 8414S COPY FED. TAX LD. # 87-0211663 PROOF OF PUBLICATION 

UT ST DEPI' OF ENVR QULTY 

DIV OF AIR QUALITY 

P.O. BOX 144820 

SALT LAKE CITY, UT 84114 

]ACCOUNT 

U 364000L-07 01/0 06 

,....:"'../. ACCOUNT NAME . .. 

UT ST DEPI' OF ENVR OULTY .. ·····'··,,········,,·,·····INVOICE NUMBER 

801-536-4000 

TELEPHONE 

TL158201261 

SCHEDULE 

START Ol/OQ/q6 END Ql/OQ/q6
 

~-~~l· CUST. REF." NO.
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:3.t.\lICII\ All, s,..~Deeru HILL AIR

lIS'ffl!!I:III' .~.,

-'mM .. CAPTION 

~tl NOTICETHE FOLLOWING NOTICE OF S137. : 

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.I...~vel 70 LINES 1. 00 COLUMN ..-.. ,~'In TIMES ~~~-;~~~)'."'"

:6S=~r' . UClnItv-a' 1 

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1.64
 

AD CHARGES
 ~AN 161996 , 

114.80 Air Quality 

.···.TOTAL COST 

114.80 

;

---- --~"--------. 

THIS IS NOT A STATEMENT BUT A "PROOF OF PUBLICATION" 

PLEASE PAY FROM BILLING STATEMENT. 4.2.4-49 
These instn..ctiol1s shall be available to all employees who operate the equipment and shall 

be made available to compliance inspectors upon their request. 

13.	 The owner/operator shall comply with R307-1-3.5. UAC. This rule addresses emission 

inventory reporting requirements. 

14.	 The owner/operatorshall comply with R307-1 ....U. UAC. 'This rule addresses unavoidable 

breakdown reponing requirements. The owner/operator shall calculate/estimate the excess 

emissions whenever a breakdown occurs. All excess emissions shall immediately be 

reponed to the executive secretary. The total of excess emissions shall be reponed to the 

executive secretary as directed for each calendar year. 

15.	 All records referenced in this AO which are required to be kept by the owner/operator. 

shall be made available to the Executive Secretary or his representative upon request and 

shall include a period of two years ending with the date of the request All records shall 

be kept for a period of twO years. Examples of records to be kept at this source shall 

include the following as applicable: 

A. Production rate (Condition number 7) 

B. VOC consumption records (Condition number 1Q) 

C. Maintenance records (Condition number 12) 

D. Upset. breakdown episodes (Condition number 14) 

Any future modifications to the equipment approved by this order must also be approved in accordance 

with R307-1-3.1.1. UAC. 

This AO in no way releases the owner or operator from any liability for compliance with all other 

applicable federal. state. and local regulations including the Utah Air Conservation Rules. 

Annual emissions from the Medium Pressure Water & Chemical Paint Stripping of Aircraft in Building 

206 are currently calculated at the following values: 

Pollutant	 Tons/vr 

PMIO ••••••••••••••••••••••• 0.65 

VOC 5.41 

These calculations are for the purposes of determining the applicability of Prevention of Significant 

Deterioration and nonanaimnent area major source requirements of the UACR. Except for VOC's they 

are not to be used for purposes of determining compliance. 

In accordance with the requirements of Title V of the 1990 Clean Air Act. the following pollutants may 

be subject to an operating permit fee. Emissions of the following pollutants from all sources. including 

pre-November 19. 1969 sources. may be subject to the operating permit fee. Both the fees rate and the 

class of pollutants are subject to change by State. the federal agencies. or both. 

Pollutant	 Tons/vr 

PMIO ••••••••••••••••••••••• 0.65 

VOC 5.41 

F:\AQ\ENGINEER\NMeli\WP\Hl-Strip.Rev 

4.2.4-48 Hill AFB Water Paint Strip Engineering Review
 

December 8, 1995
 

Page 15
 
A.	 Name v. me VOC emining material. such as: pail••. adhesive. solvent. thirrner. 

reducers. chemical compounds. isocyanares. etc. 

B.	 The weight and use location of the volatile organic compound potential and 

hazardous air pollutant potential of the marerial(s) listed in A in pounds per 

gallon. 

C.	 Percent by weight of all volatile organic compound potential and hazardous air 

pollutant potential for each individual material listed in A. The percent by weight 

of the volatile and hazardous air pollutant potentials can be obtained from the 

manufacturers' MSDSs. The owner/operaror can obtain MSDS data from me 

manufacturers of the materials and retain the information on-site. 

D.	 Amount and location of materials containing VOCs used on a monthly basis and 

summed for every location and for the entire plant each month. 

E.	 To calculate the above potentials contained in the material listed in D use the 

following procedure: 

VOC :: (91: Volatile hv Wei£!ht) x (Densitv Ih) x (Gal Consumed) x (I ton) 

(100) (gal)	 (2.000 lh) 

F.	 The amount of volatile organic content potential (potential air emissions) and 

hazardous air pollutant potential (potential air emissions) in pounds contained in 

materials deposited as solid or hazardous waste for the month shall be quantified 

and subtracted from the quantities calculated above. This is done to allow 

quantificarion by the source of the total VOCs emissions. (The assumption is that 

all the two above potentials of the marerials applied to a product evaporate and 

are therefore considered emissions). 

G.	 Records of consumption of VOCs shall be kept for all periods when the plant is 

in operation. Records of consumption shall be made available to the executive 

secretary upon request. and shall include a period of two years ending with the 

dare of the request. 

II.	 This source is a major Title V source needing an Operating Permit. It is required to pay 

an annual emission fee upon stan-up. or if an existing facility. upon issuance of this AO. 

The fee will be based on calculated arrnual emissions listed at the end of this AO. This 

fee is valid until inventory data for one year are available for the source. The owner or 

operator of this source will be billed upon stan-up for all emissions that are considered 

"chargeable" as of thar dare. 

Records & Miscellaneous 

12.	 All installations and facilities authorized by this AO shall be adequately and properly 

maintained. All pollution control vendor recommended equipment shall be installed. 

maintained. and operated. Instructions from the vendor or established maintenance 

practices that maximize pollution control shall be used. All necessary equipment control 

and operating devices. such as pressure gauges. amp meters. volt meters. flow rate 

indicators. temperature gauges. etc.• shall be installed and operated properly and easily 

accessible to compliance inspectors. A copy of all manufacturers' operating insouctions 

for pollution control equipment and pollution emitting equipment shall be kept on site. 

4.2.4-47 HiU AFB Water Paint Strip Engineering Review
 

December 8, 1995
 

Page 14
 
7. The following production limits shall not be exceeded without prior approval in 

accordance with R307-1-3.1. UAC: 

A.	 3300 gallons of Paint Stripper per rolling 12-month period 

B.	 150.000 Ibs of Sodium Bicarbonate per rolling 12-month period 

Compliance with the annual limitations shall be determined on a rolling 12-month total. 

The owner/operator shall calculate a new 12-month total based on the first day of each 

month using data from the previous 12 months. Records of consumption shall be kept 

for all periods when the plant is in operation. Records of consumption. including rolling 

l2-month totals shall be made available to the executive secretary or his representative 

upon request and shall include a period of two years ending with the date of the request. 

Consumption shall be determined by purchase records and operations log. The records 

shall be kept on a daily basis. 

Fugitive Dust 

8.	 The moisture content of the material used contammg sodium bicarbonate shall be 

maintained at a minimum of 80.0% by weight. All of the sodium bicarbonate shall be 

periodically swept or sprayed clean from all surface areas as dry conditions warrant or as 

determined necessary by the Executive Secretary. The moisture content shall be tested 

if directed by the Executive Secretary using the appropriate American Society of Testing 

and Methods (ASTM) method. 

Volatile Organic Compound (Voq Limitations 

9.	 The facility shall abide by all applicable requirements of UAC R307-l4 for volatile 

organic compound (VOC) sources located in an ozone Nonanairunent area. At a 

minimum. RACf control measures are required and BACf will be no less stringent than 

RACf. These requirements include but are not limited to: 

"14-5.A.(5) Written procedures for the operation and maintenance of the 

degreasing or solvent cleaning equipment shall be permanently posted in an 

accessible and conspicuous location near the equipment." 

The full text of UAC R307-l4 is included as Appendix A. However. to be in compliance. 

this facility must operate in accordance with the most current version of R307-l4 or the 

applicable section(s). if renumbered. 

10.	 The emissions of VOCs in building 206 from the Medium Pressure Water and Chemical 

Paint Stripping operations. etc. and associated operations shall not exceed: 

5.41 tons per rolling t2-month period for VOCs 

This value shall not be exceeded without prior approval in accordance with R307-l-3.1. 

UAC. Compliance with the limitation shall be determined on a rolling 12-month total. 

Based on the first day of each month a new l2-month total shall be calculated using data 

from the previous 12 months. 

The emissions of VOCs emitted to the atmosphere from Building 206 shall be determined 

by maintaining a record of volatile organic compound potential contained in materials 

used each month. The record shall include the following data for each item used: 

Hill AFB Water Paint Strip Engineering Review 4.2.4-46 

December 8, 1995
 

Page 13
 
V. RECOMMENDED Arr'ROVAL ORDER CONDITIONS 

General Conditions: 

.- I. 'This Approval Order (AO) applies to the following company: 

Facilitv Location 

Deparnnent of the Air Force 

Headquaners Ogden Logistics Center (AFMC) 

Hill Air Force Base. Utah 

PHONE NUMBER (80 I) 777-0359 

FAX NUMBER (801) 777-6742 

The equipment listed below in this AO shall be operated at the following location: 

PLANT LOCATION: 

East of Exit 336 on Interstate 15 

Universal Transverse Mercator (UTM) Coordinate System: 

4.551 kilometers Northing; 418 kilometers Easting; Zone 12 

2.	 Defmitions of terms. abbreviations. and references used in this AO conform to those used 

in the Utah Air Conservation Rules (UACR). Utah Administrative Codes (UAC). and 

Series 40 of the Code of Federal Regulations (40 CFR). These definitions take 

precedence unless specifically defined otherwise herein. 

3.	 Hill Air Force Base (AFB) shall install and operate the Medium Pressure Water & 

Chemical Paint Stripping of Aircraft in Building 206 according to the terms and 

conditions of this AO as requested in the Notice of Intent dated November 27. 1995 and 

additional information submined to the Executive Secretary dated December 7, 1995. 

4.	 A copy of this AO shall be posted on site. The AO shall be available to the employees 

who operate the air emi~sion producing equipment. These employees shall receive 

instruction as to their responsibilities in operating the equipment according to all of the 

rel~vant conditions listed below. 

5.	 The approved installations shall consist of the following equipment or equivalent: 

A.	 Aqua Miser Medium Pressure Water Paint Stripper 

B.	 Air Operated Drum Pump and Spray Wand with non-atomizing tip 

* Equivalency shall be determined by the Executive Secretary. 

Limitations and Tests Procedures 

.­ 6. Visible emissions from any stationary point or fugitive emission source associated with 

the source or with the control facilities shall not exceed 10% opacity. Opacity 

observations of emissions from stationary sources shall be conducted in accordance with 

40 CFR 60, Appendix A. Method 9. 

4.2.4-45 

Hill AFB Water Paint Strip Engineering Review
 

December 8, 1995
 

Page 12
 
B. Use of an alternative fuel or raw material by reason of an order under Sections 

2a and 2b of the ESECA of 1974 or by reason of a narural gas cunailmem plan 

pursuant to the Federal Power Act 

C.	 Use of an alternative fuel by reason of an order under Section 125 of the CAA 

D.	 Use of an alternative fuel at a steam generating unit to the extent that the fuel is 

generated from municipal solid waste 

E.	 Use of an alternative fuel or raw material by a source: 

1)	 which the source was capable of accommodating before January 6. 1975. 

unless such change would be prohibited under any enforceable permit 

condition 

2)	 which the source is otherwise approved to use 

F.	 An increase in the hours of operation or the production rate unless such change 

would be prohibited under any enforceable permit condition 

G. Any change in ownership at a source 

This Notice of Intem is not a major modification. 

4.2.4-44 

Hill AFB Water Paint Strip Engineering Review
 

December 8,1995
 

Page 11
 
For VOC emisSIOns. there is no model that can predi':t an ozone impact directly from 

VOC emissions. However. since VOCs are precursors to ozone formation. this new 

source will contribute to the existing exceedances of the ozone standard in Davis County. 

The amount of that contribution has not been decided. The ozone Nonanainment area of 

Davis and Salt Lake Counties must show reasonable further progress toward anainrnem 

of the standard. This source. along with all other VOC sources having emissions above 

ten tons per year. may have to apply more controls to lower the VOC emissions. lllis 

would be a SIP change action. 

29.	 40 CFR 60.14. Definition of Modification - Any physical or operational change to an 

existing facility that results in an increase in the emission rate to the atmosphere of any 

pollutant to which an NSPS standard applies. The following are not by themselves 

considered modifications: 

A.	 Maintenance. repair. and replacement 

B.	 An increase in production rate of an existing facility. if that increase can be 

accomplished without a capital expendirure on that facility 

C.	 An increase in the hours of operation 

D.	 Use of an alternate fuel or raw material if. before the date any standard under this 

part becomes applicable to that source type. as provided by 60.1. the existing 

facility was designed to accommodate that alternative use 

E.	 The addition or use of any system or device whose primary function is the 

reduction of air pollutants 

F.	 Relocation or change in ownership 

Also see R307-1-1 (Modification). which is the State's defInition. This Notice of Intent 

is a modification. 

30.	 40 CFR 60.15. Definition of Reconstruction - the replacement of components of an 

existing facility to such an extent that: 

A.	 The fIxed capital cost of the new components exceeds 50% of the fixed capital 

cost that would be required to construct a comparable entirely new facility and 

B.	 It is technologically and economically feasible to meet the applicable standards 

set forth in this part 

This Notice of Intent is a reconstruction. 

3 I.	 R307-1-1. Defmition of Major Modification - It means any physical change in or changes 

in the method of operation of a major source that would result in a significant net 

emission increase of any pollutant. A net emissions increase that is significant for VOC 

shall be considered significant for ozone. A physical change or change in the method of 

operation shall not include: 

A.	 Routine maintenance. repair. or replacement 

4.2.4-43 Hill AFB Water Paint Strip Engineering Review
 

December 8. 1995
 

Page 10
 
9) tlulk Gasoline Plants 

10) Storage of Petrolewn Liquids in Fixed Roof Tanks 

11) Wastewater Separators and process unit turnarounds 

12) Use of Cutback Asphalt 

13) Tank Truck Gasoline Loading Tenninals 

14) Stage I Vapor Control Systems - Gasoline Service Stations 

15) Leaks from Petrolewn refmery Equipment 

16) Manufacture of Vegetable Oils 

17) Petroleum Liquid Storage in External Floating Roof Tanks 

18) Perchloroethylene Dry Cleaning Systems 

19) Leaks from Gasoline Tank Trucks and Vapor Collection Systems 

20) Large Petrolewn Dry Cleaners 

21) Synthetic Organic Chemical. Polymer. and Resin Manufacturing 

Equipment 

22) Leaks from Natural Gas/Gasoline Processing Plants 

23) Solvent Metal Cleaning 

24) Synthesized Pharmaceutical Products 

25) Pnewnatic Rubber Tires 

26) Stationary Sources 

27) Air Oxidation Processes in Synthetic Organic Chemical Manufacturing 

Industry 

28) High-Density Polyethylene. Polypropylene. and Polystyrene Resins 

29) Fugitive Emission Sources of Organic Compounds 

30) Synthetic Organic Chemical Manufacturing Industry - Reactor and 

Distillation Operations Processes 

31) Measurement of Volatile Organic Compounds 

For ozone attainment areas the requirements of UACR 3.1. I (BACT) apply. 

However. BACT for these sources should be evaluated in light of the RACT 

requirements that have been established by UACR 14. BACT in an attainment 

area may be determined to be less stringent than the RACT requirements 

established in rule 14 or a published Control Tectmiques Guidance document 

(which apply to a Nonattairunent area) however. a detailed BACT analysis should 

be conducted by the source to justify a less stringent control measure in an 

anairunent area. This source is located in Davis County. Therefore. this rule 

applies to this source. 

26.	 40 CFR. Pan 60 - New Source Performance Standards (NSPS) - There is no NSPS for 

this industrial process. There is a NSPS for this industrial process. 

27.	 40 CFR. Part 61 - National Emission Standards for Hazardous Air Pollutants (NESHAP) ­

There is no NESHAP for this industrial process. There is a NESHAP for this industrial 

process. 

28.	 40 CFR. Part 50 - National Ambient Air Quality Standards (NAAQS) - ntis source is 

located in Davis Countv, which is a Nonattairunent area for ozone. 

The Division of Air Quality guidelines do not call for this source to be modeled for any 

pollutant. The Division has found through experience that a source or emission point of 

this small size is very unlikely to cause a new violation of the NAAQS. ntis is because 

of the small quantity of emissions involved and the conservative predictions made by 

modeling. However. it will make a small contribution to the existing violation for ozone 

of the NAAQS. 

Hill AFB Water Paint Strip Engineering Review 4.2.4-42 December 8. 1995
 

Page 9
 
4.8 wastewater separators 

4.C Process unit turnaround 

4.0 Catalytic cracking units 

4.E Safety pressure relief valves 

- 4.F Leaks from petroleum refinery equipment 

E. Section 14-5 - Oegreasing and solvent cleaning operations 

1) Cold cleaning facilities
 

2) Open top vapor degreasers
 

3) Conveyorized degreasers
 

F. Section 14-6 - Cutback asphalt 

G. Section 14-7 - Surface Coating Processes 

1) Section 7.A - General Provisions 

2) Section 7.8 - Paper Coating 

3) Section 7.C - Fabric and Vinyl Coating . 

4) Section 7.0 - Metal Furniture Coating VOC Emissions 

5) Section 7.E - Large Appliance Surface Coating VOC Emissions 

6) Section 7.F - Magnet Wire Coating VOC Emissions 

7) Section 7.G - Rat Wood Coating 

8) Section 7.H - Miscellaneous Metal Pans and Products VOC Emissions 

9) Section 7.I - Graphic Arts 

10) Section 7.1 - Exemptions 

II) Section 7.K - Capture Systems 

12) Section 7.L - Testing and Monitoring 

H. Section 14-8 - Perchloroethylene Ory Cleaning Plants 

1. Section 14-9 - Compliance Schedule 

J. Section 14-10 - Stage II Vapor Recovery Systems 

For painting operations this rule specifies specific limits on the VOC content in paints and 

coatings used. In addition there is a provision for allowing use of coatings with higher 

VOC content if. because of emission control measures. "equivalent" emissions will res~lt.

Therefore. sources proposing to use coatings that do not meet the VOC contents specified 

in rule 14. must submit an analysis of their control measure that demonstrates equivalency 

with the VOC limitations of rule 14. 

The published erGs as of April 1. 1995 include: 

1) Control Methods for Surface Coating Operations 

2) Surface Coating of Cans. Coils. Paper. Fabrics. Automobiles. and LightDuty Trucks 

3) Surface Coating of Metal Furniture 

4) Surface Coating of Insulation of Magnet Wire 

5) Surface Coating of Large appliances 

6) Surface Coating of Miscellaneous Metal Pans and Products 

7) Surface Coating of Flat Wood Paneling 

8) Graphic Arts - Rotogravure and Flexography 

Hill AFB Water Paint Strip Engineering Review 4.2.4-41 

December 8.1995 

Page 8 
represent a new major source or a major modification under UACR rules. Therefore. this 

rule does not apply. 

21.	 R307-1-4.1.2. UAC - 20% opacity limitation at all emission points. Unless a more 

stringent limitation is required by New Source Performance Standards (NSPS) or BACT 

or National Emission Standards for Hazardous Air Pollutants (NESHAPS). In this case. 

an opacity limitation of 10% is recommended as BACT. 

22.	 R307-1-4.1.9. UAC - EPA Method 9 shall be used for visible emission observations. This 

rule applies. 

23.	 R307-1-4.7. UAC - Unavoidable breakdown reponing requirements. This rule applies. 

Section 4.7.1 discusses reponing requirements. A breakdown for any period longer than 

two hours must be reponed to the executive secretary within three hours of the beginning 

of the breakdown. if reasonable. but in no case longer than 18 hours after the beginning 

of the breakdown. A written repon is required within seven calendar days. The repon 

shall include the estimated quantity of pollutants (total and excess). R307-1-4.7.2 

discusses penalties. 

24.	 R307-1-5. UAC - Emergency episode requirements. This rule requires the executive 

secretary to determine the stage and extent of an air pollution episode based on pollution 

levels and meteorological conditions. Under Section 40 of the Code of Federal 

Regulations. Part 51. Subpart H (51.150 to 153). it is required that sources plan 

emergency measures based upon the severity of the Nonattairunent area in which they 

operate. In Utah. these rules require that CO sources in CO Nonattairunent areas and 

sources of ozone precursors in ozone Nonattainment areas. who emit at least 25 tons per 

year (SIP. Section VII.B.) of either pollutant. submit an Emergency Episode Plan which 

provides for additional pollution reductions in the event of an Air Pollution Alen. 

Warning or Emergency Episode. These plans can include total shut-down of the process. 

(Some sources are required to submit an emergency episode plan according to Section 

Vll.B. of the SIP). This rule applies. 

25.	 R307-14. UAC - Review requirements for volatile organic compound (VOC) sources 

located in an ozone Nonattainment area. For sources located in ozone Nonattainment 

areas (Salt Lake and Davis Counties) this rule specifies the minimum (RACT) control 

measures promulgated by the Utah Air Quality Board. In addition. UACR 3.1.1 requires 

application of BACT for all new or modified sources in the stare. However. within an 

ozone Nonartainment area BACT can not be less stringent than RACT. Therefore. for 

ozone Nonartainment areas the more stringent requirement is applicable (Le.. BACT as 

required by UACR 3.1.1 or RACT as defmed by rule 14 or as defined in a published 

Control Tectmiques Guidance document). 

This 14 rule covers the following processes: 

A.	 Section 14-1 - General 

B.	 Section 14-2 - Petroleum liquid storage 

C.	 Section 14-3 - Gasoline transfer/storage 

D.	 Section 14-4 - Control of hydrocarbon emissions in refineries 

4.A.	 Vacuum producing systems 

4.2.4-40 

Hill AFB Water Paint Strip Engineering Review
 

December 8, 1995
 

Page?
 
, Class I Area . . . . . . . . .. 25 5 ................ ­

Class II Area 512 91 ............... 20
 

Class I Area . . . . . . . .. N/A N/A 2.5 

Class II Area N/A N/A 25 

There are also Class III increments. which do not apply in Utah. The above increments 

apply at all locations. unless the area is already Nonanainment The entire increment may 

not be available at all locations due to previously permined sources consuming increment. 

16.	 R307-1-3.6.5 (b). UAC - Prevention of Significant Deterioration (PSD) review 

requirements for new major sources or major modifications. This Notice of Intent does 

not represent a new major source or a major modification under PSD rules. Therefore. 

this rule does not apply. 

17.	 R307-1-3.6.6. UAC - Increment violations. TIlls rule requires the UAQB to promulgate 

a plan and implement rules to eliminate any PSD increment violations mat occur in the 

state. No known violations have yet occurred. TIlls proposed Notice of Intent will not 

consume any increments. 

18.	 R307-1-3.7. UAC - Air Quality Modeling - All estimates of ambient concentrations 

required in meeting the requirements of the regulations shall be based on appropriate air 

quality models. data bases. and other requirements specified in the Utah Guidelines to Air 

Quality Models. Modeling analysis is not routinely performed for air pollution sources 

with emissions below the following levels: 

Criteria for Screen Modeling 

(~ Tons per Year) 

TSP 10 

PMIO ••.•••••••• 5 

SO, 20 

N01 20 

CO 50 

VOC 20 °

3 , ••.••••••• : . 5

HAPs 10 

The increase in emissions will be less than the amounts listed above. Therefore. modeling 

will not be required. 

19.	 R307-1-3.8. UAC - Stack height rule. TIlls rule limits the creditable height of stacks to 

that height determined to be good engineering practice. The formulas used to determine 

good engineering practice are found in 40 CFR 51.100. The maximum creditable height 

of 65 meters (213.2 feet) is allowed. Hill AFB has no stacks that exceed 65 meters in 

height. Therefore. this source/facility is in compliance with this rule. 

20.	 R307-l-3.1O, UAC - Visibility screening analysis requirements. This rule requires all new 

major sources or major modifications to undergo a visibility screening analysis to 

determine visibility impact on any mandatory Class I area. TIlls Notice of Intent does not 

Hill AFB Water Paint Strip Engineering Review
 4.2.4-39

December 8. 1995
 

Page 6
 
8.	 R307-1-3.1.9. UAC - Rules for relocation of temporary sources. This source is a 

permanent source. Therefore. this rule does not apply. 

9.	 R307-1-3.1.12. UAC - Requirement for installation of low-NO, burners on all existing 

sources whenever existing fuel combustion burners are replaced. unless the replacement 

is not physically practical or cost effective. The effective date is November 15. 1990. 

There will be no burners replaced at this time. Therefore. this rule does not apply. 

10.	 R307-1-3.2.1, UAC - Particulate emission limitations for existing sources that are located 

in a Nonattairunent area. This rule has been superseded by the Section IX. Pans A and 

H of the SIP except for Weber County. TIlls source is not listed in the SIP. Therefore. 

this rule does not apply. 

11.	 R307-1-3.3.2. UAC - Review requirements for new major sources or major modifications 

that are located in a Nonanairunent area or which impact a Nonattainment area. TIlls 

Notice of Intent does not represent a new major source or a major modification. 

Therefore. this rule will not apply. 

12.	 R307-1-3.3.3.B (3), UAC - Enforceable offset of tl required for new sources or 

modifications that would produce an emission increase greater than or equal to 25.00 tons 

per year but less than 50 tons per year of any combination of PM IO• S01' and NO,. This 

is required in Salt Lake. Davis. and Utah Counties and in any area that affects these three 

counties as defined in the rule. The effective date is November 15. 1990. TIlls source 

will have no increase in PM10' S01' and NO, emissions. Therefore. an offset will not be 

required. 

13.	 R307-1-3.3.3.C. UAC - Enforceable offset of 1.15:1 required for new sources or 

modifications of sources as defined in Section 182 of the CAA. Section 182(b)(l)(A)(i) 

of the CAA defines these sources as sources of volatile organic compounds and as sources 

of oxides of nitrogen. TI1.is is required in Salt Lake and Davis Counties and in any area 

that affects these three counties as defined in the rule. The effective date is August 16. 

1993. If it is an existing Major source with a 40 tpy increase or a new major source 

offsets of 1.15: 1 are required. The emissions increase will be less than 40 tpy. Therefore. 

an offset will not be required. 

14.	 R307-1-3.5. UAC - Emission inventory reporting requirements. TIlls rule requires any 

source that emits 25 tons or more per year of any pollutant or any Part 70 source to 

submit an emission inventory to the Division of Air Quality every year or as determined· 

necessary by the executive secretary. This source must comply with this rule. 

15.	 R307-1-3.6.3. UAC - Prevention of Significant Deterioration (PSD) Increment 

Consumption - TI1.is rule lists the allowable PSD increment consumption. Under the PSD 

rules. the entire state has been triggered for Particulate (pM10)' S01' and NO,. .The 

allowable increments are as follows: 

Three Hour 24 Hour	 Annual 

Class I Area . . . . . . . .. NtA 8 4
 

Class II Area NtA 30 17
 

4.2.4-38 

Hill AFB Water Paint Strip Engineering Review 

December 8. 1995 

PageS 
III. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) A!\'ALYSIS 

The VOC emissions from the MPW system is 1000 lbs/aircraft. \Vhen the more traditional paint stripping 

- system with methylene chloride is utilized there is 1O.000-lbs of HAPS (memylene chloride) and 4.000 

lbs of VOCs per airplane. 

The New Source Review section recommends mat me new medium pressure water and chemical stripping 

of C-130 aircraft with a 10% opacity limit be accepted as BACT. 

IV.	 APPLICABILITY OF FEDERAL REGULATIONS AND ETAH ADMINISTRATIVE 

CODES mAC) 

TItis Notice of Intent is for grandfamered source. It is not a new major source or a major modification. 

The following federal regulations and state rules have been examined to determine their applicability to 

this Notice of Intent: 

1.	 R307-1-3.1. UAC - Notice of Intent required for a modified source. TItis rule applies. 

A Notice of Intent is required for me new medium pressure water and chemical paint 

stripping of C-130 aircraft operations.. 

2.	 R307-1-3.1.5. UAC - Continuous program of construction required to begin within 

eighteen months of Approval Order date. If a continuous program of construction is not 

proceeding. me executive secretary may revoke me Approval Order. 

3.	 R307-1-3.1.7 (A), UAC - A Notice of Intent is not required for all natural gas fuel 

burning equipment with a total rated capacity of less than 5 MMBTU per hour. There 

will be no new natural gas devices installed. Therefore. this rule applies. and a Notice 

of Intent is not required based on this rule but is required based on R307-1-3.1. UAC. 

4.	 R307-1-3.1.7 (E), UAC - Notice of Intent required for a new parking lot of 600 or more 

spaces and adding 350 or more spaces to an existing IOl TItis rule will not apply because 

a new lot or addition is not being consoucted. 

5.	 R307-1-3.1.7 (F). UAC - Notice of Intent not required for sources wim emissions less 

than 10 tons/yr of me following compounds: 1.1.l-trichloroethane. memylene chloride. 

trichlorofluoromethane. dichlorodifluoromemane. chlorodifluoromemane. trifluoromethane, 

1.1.2-trichloro-l.2.2-trifluoroemane. 1.2-dichloro 1.1.2.2-tetrafluoroethane. methane. ethane 

and chloropentafluoroethane. However. if the source is emitting more man 10 tons/yr of 

any of mese compounds. a Notice of Intent must be filed and an annual repon of 

emissions thereafter. This emission point will not emit 10 tons/year of any of mese 

regulated pollutants. Therefore. this rule applies. and a Notice of Intent is not required 

based on this rule. 

6.	 R307-1-3.1.8 (A), UAC - Application of best available control teclmology (BACT) 

required at all emission points. TItis rule applies to all sources throughout me state unless 

mey are located in a Nonattainment area. RACT applies in Nonanainment areas. 

7.	 R307-1-3.1.8 (C). UAC - Approval of me Utah Air Quality Board (UAQB) is required 

before me executive secretary can approve a source under Section 3.6.5 that conswnes 

more than 50% of a PSD increment. This rule does not apply to this NOI because a PSD 

permit is not being issued. 

4.2.4-37 Hill AFB Water Paint Strip Engineering Review
 

December 8, 1995
 

Page 4
 
Abstract 

Hill Air Force Base (HAFB) is requesting approval to use a Medium Pressure Wacer rMPW) scnpping 

system to strip paint off of aircraft. In the past a chemical paint stripping method using methylene 

chloride was used to strip paint off of aircraft. The VOC and Hazp.rdous Air Pollutants will be less 

when the MPW system is utilized. The VOC emissions in shall be 5.41 tons per 12-monch period. 

1. DESCRIPTION OF PROPOSAL 

Historically aircraft paint removal has been accomplished with methylene chloride based paint stripper. 

However. methylene chloride is a hazardous air pollutant (HAP). and its use will be severely limited by 

the NESHAPs and proposed Aerospace Control Teclmology Guide. Because of these limitations and 

because of the large quality of waste water and hazardous waste generated from this process Hill Air Force 

Base (HAFB) explored another alternative. 

HAFB's review of industrial paint removal processes revealed the most promising alternative to chemical 

paint stripping is medium (15.000 psi) pressure water (MPW). Emissions from this process are 

significantly less than chemical paint stripping. The MPW process erodes paint from the aircraft surface 

and entrains it in the water stream. There is 1000 Ibs of VOC emissions per airplane when the MPW 

system is used and when Methylene Chloride is used there is 10.000 Ibs of HAPS (methylene chloride) 

and 4.000 Ibs of VOCs per airplane. 

The medium pressure water stripping system consists of a 15.000 psi 3.2 gallon per minute water pump 

and a bicarbonate of soda (Na HC03) injection system with control and peripheral equipment. The system 

includes a hand-held wand with various nozzle configurations that are matched to the function being 

performed. Currently a nozzle with a tuned pon that produces a fan-like blast panern is used for aircraft 

paint stripping. 

The }.1PW process with water pressure alone is not effective for removal of the paint systems used on 

C-130s. Also, in some areas of the aircraft with exceptionally thin skins (where full pressure can not be 

applied) and in areas with difficult to remove coatings, a chemical paint softener will be needed to remove 

the paint. 

The softener, containing Benzyl Alcohol. will be spray applied on the aircraft using an air operated drum 

pump and spray wand. The softener will be allowed to dwell on the surface from 4 to 10 hours and then 

will be sprayed off with water. 

II. EMISSION SUMMARY 

The emissions from the Hill Air Force Base Medium Pressure Water & Chemical Paint Stripping of 

Aircraft will be as follows: 

Current Emissions Emission Changes Total Emissions 

Pollutant tons/year tons/vear tons/vear 

PM10 0.0 0.65 0.65 

VOC 0.0 5.41 5.41 

There will be no PMlO emissions because the sodium bicarbonate solution contains a 2.5 OW1ces of Na 

HC03 per gallon of water. Water is 8.3 Ib/gallon (132.8 oz/gal). TIlls is less about 2% Na HC03 per 

gallon of water. 

Hill AFB Water Paint Strip Engineering Review 

December 8. 1995 4.2.4-36 

Page 3 
TYPE OF IMPACT AREA 

Nonattainment Area 

PM10 •••••••••••••••••••••••••••••••• Yes 

S01 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. No 

NO, No 

CO No 

Ozone Yes 

NSPS No 

NESHAP No 

Hazardous Air Pollutants No 

Hazardous Air Pollutants Major Source No 

New Major Source . . . . . . . . . . . . . . . . . . . . . . . . . . . .. No
 

Major Modification No 

PSD Permit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. No
 

PSD Increment No 

(modeling) 

Send to EPA No 

Operating Permit Program Yes 

FOR MODIFIED SOURCES 

The Notice of Intent is for a modification to an existing source. The following standards apply in this 

review: 

NSPS applies to modification? No 

PSD review of entire source required? No 

NESHAPS applies to modification? '. . . . . . . . . .. No 

HAPs involved in modification? No 

TITLE V required for entire source? Yes 

HAPs MAJOR for modification? . . . . . . . . . . . . . . . . . .. No 

NONATT MAJOR for entire source? Yes 

4.2.4-35 

Hill AFB Water Paint Strip Engineering Review
 

December 8, 1995
 

Page 2
 
U u\.H DIVISION OF AIR OUALITI'
 

NEWIMODIFIED SOURCE PLAN REVIEW
 

James R. Van Orman 

Director, Envirorunental Management 

Deparnnent of the Air Force 

Headquaners Ogden Logistics Center (AFMC) 

Hill Air Force Base. Utah 

RE:	 Medium Pressure Water & Chemical Paint Stripping of Aircraft 

Davis County, CDS AI; NA; HAPs. TITLE V MAJOR 

REVIEW ENGINEER:	 Nando Meli 

DATE:	 December 8. 1995 

NOTICE OF INTENT DATED:	 December 7. 1995 

PLANT CONTACT: JOM Vidic 

PHONE NUMBER: (80l) 777-2050 

FAX NUMBER (80l) 777-6742 

PLANT LOCATION: East of Exit 336 on Interstate 15 Freeway 

UTM COORDINATES: 4,552.0 kIn Northing. 418.0 kIn Easting, Zone 12 

APPROVALS: ./ 

Peer Engineer~~= A 

We request that you read the proposed Approval Order conditions; if you do not understand or do not agree 

with the contents of the conditions. please contact the review engineer within five days. However. when you 

understand the anached proposed/draft Approval Order conditions. please sign below and return. Thank You. 

Applicant Contact :'i¥ ttl k To 111. /),), Je l/~r- lJa I~ ..-( .	 (Silnarure & Dare) 

F:\AQ\f.NGINEER\NMeli\WNil-Slrip.Rev /l-(/ tirLynn Menlove 

4.2.4-34
 
DAQE-O13-96 

')age 7 

C. Maintenance records (Condition number 12) 

D. Upset., breakdown episodes (Condition number 14) 

Any future modifications to the equipment approved by this order must also be approved in accordance with 

R307-1-3.l.1, UAC. 

This AO in no way releases the owner or operator from any liability for compliance with all other applicable 

federal. state, and local regulations including the Utah Air Conservation Rules. 

Annual emissions from the Medium Pressure Water & Chemical Paint Stripping of Aircraft in Building 206 

are currently calculated at the following values: 

Pollutant Ions/yr 

PMlO •••.••••••• " .••••••••••••• 0.65 

VOC 5.41 

These calculations are for the purposes of determining the applicability of Prevention of Significant 

Deterioration and nonattainment area major source requirements of the UACR. Except for VOe's they are 

not to be used for purposes of determining compliance. 

In accordance with the requirements of Title V of the 1990 Clean Air Act., the following pollutants may be 

subject to an operating permit fee. Emissions of the following pollutants from all sources, including preNovember 19, 1969 sources, may be subject to the operating permit fee. Both the fees rate and the class of 

pollutants are subject to change by State, the federal agencies, or both. 

Pollutam Ions/yr 

PM10 " ••••••••.•••••••••.•••••• 0.65 

VOC 5.41 

The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the 

issuance of an AO. Unless public comments are received which require additional work, the fee for this AO 

will be $1,000.00. An invoice will follow. You may pay this fee prior to the end of the comment period. If 

there are comments or additional fees, you will be notified. 

Sincerely, 

..-- ~ynn R. Menlove, Manager 

New Source Review Section 

-


4.2.4-33
 
DAQE-013-96 

Page 6 

F.	 The amount of volatile organic content potential (potential air emissions) and 

hazardous air pollutant potential (potential air emissions) in pounds contained in 

materials deposited as solid or hazardous waste for the month shall be quantified and 

subtracted from the quantities calculated above. This is done to allow quantification 

by the source of the total VOCs emissions. (The assumption is that all the two above 

potentials of the materials applied to a product evaporate and are therefore 

considered emissions). 

G.	 Records of consumption of VOCs shall be kept for all periods when the plant is in 

operation. Records of consumption shall be made available to the executive 

secretary upon request, and shall include a period of two years ending with the date 

of the request. 

11.	 This source is a major Title V source needing an Operating Permit. It is required to pay an 

annual emission fee upon start-up. or if an existing facility, upon issuance of this AO. The 

fee will be based on calculated annual emissions listed at the end of this AO. This fee is valid 

until inventory data for one year are available for the source. The owner or operator of this 

source will be billed upon start-up for all emissions that are considered "chargeable" as of that 

date. 

Records & Miscellaneous 

12.	 All installations and facilities authorized by this AO shall be adequately and properly 

maintained. All pollution control vendor recommended equipment shall be installed, 

maintained, and operated. Instructions from the vendor or established maintenance practices 

that maximize pollution conuel shall be used. All necessary equipment control and operating 

devices, such as pressure gauges, amp meters, volt meters, flow rate indicators, temperature 

gauges. etc., shall be installed and operated properly and easily accessible to compliance 

inspectors. A copy of iill manufacturers' operating instructions for pollution control 

equipment and pollution emitting equipment shall be kept on site. These instructions shall 

be available to all employees who operate the equipment and shall be made available to 

compliance inspectors upon their request. 

13.	 The owner/operator shall comply with R307-1-3.5, UAC. This rule addresses emission 

inventory reporting requirements. 

14.	 The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses unavoidable 

breakdown reporting requirements. The owner/operator shall calculate/estimate the excess 

emissions whenever a breakdown occurs. All excess emissions shall immediately be reported 

to the executive secretary. The total of excess emissions shall be reported to the executive 

secretary as directed for each calendar year. 

15.	 All records referenced in this AO which are required to be kept by the owner/operator, shall 

be made available to the Executive Secretary or his representative upon request and shall 

include a period of two years ending with the date of the request. All records shall be kept 

for a period of two years. Examples of records to be kept at this source shall include the 

following as applicable: 

A.	 Production rate (Condition number 7) 

B.	 VOC consumption records (Condition number 10) 4.2.4-32 
DAQE-013-96 

Page 5 

Volatile Organic Compound (VQC) Limitations 

9.	 The facility shall abide by all applicable requirements of UAC R307-14 for volatile organic 

compound (VOC) sources located in an ozone Nonattainment area. At a minimum, RACT 

control measures are required and BACT will be no less stringent than RACT. These 

requirements include but are not limited to: 

"14-5.A.(5) Written procedures for the operation and maintenance of the degreasing 

or solvent cleaning equipment shall be permanently posted in an accessible and 

conspicuous location near the equipment." 

The full text of UAC R307-14 is included as Appendix A. However, to be in compliance, 

this facility must operate in accordance with the most current version of R307-14 or the 

applicable section(s), if renumbered. 

10.	 The emissions of VOCs in building 206 from the Medium Pressure Water and Chemical 

Paint Stripping operations, etc. and associated operations shall not exceed: 

5.41 tons per rolling 12-month period for YOCs 

This value shall not be exceeded without prior approval in accordance with R307-1-3.1, 

UAC. Compliance with the limitation shall be determined on a rolling 12-month total. 

Based on the first day of each month a new 12-month total shall be calculated using data from 

the previous 12 months. 

The emissions of VOCs emitted to the atmosphere from Building 206 shall be determined by 

maintaining a record of volatile organic compound potential contained in materials used each 

month. The record shall include the following data for each item used: 

A.	 Name of the VOC emitting material, such as: paint, adbesive, solvent, thinner, 

reducers, chemical compounds, isocyanates, etc. 

B.	 The weight and use location of the volatile organic compound potential and 

hazardous air pollutant potential of the material(s) listed in A in pounds per gallon. 

C.	 Percent by weight of all volatile organic compound potential and hazardous air 

pollutant potential for each individual material listed in A. The percent by weight 

of the volatile and hazardous air pollutant potentials can be obtained from the 

manufacturers' MSDSs. The owner/operator can obtain MSDS data from the 

manufacturers of the materials and retain the information on-site. 

D.	 Amount and location of materials containing VOCs used on a monthly basis and 

summed for every location and for the entire plant each month. 

E.	 To calculate the above potentials contained in the material listed in D use the 

following procedure: 

VOC =(% Volatile by Wejght) x (Density Ib) x (Gal Consumed) x U...t.Qn) 

(100) (gal)	 (2,000 Ib) 

4.2.4-31 
DAQE-013-96 

Page 4 

3.	 Hill Air Force Base (AFB) shall install and operate the Medium Pressure Water & Chemical 

Paint Stripping of Aircraft in Building 206 according to the terms and conditions of this AO 

as requested in the Notice of Intent dated November 27. 1995. and additional information 

submitted to the Executive Secretary dated December 7. 1995. 

4.	 A copy of this AO shall be posted on site. The AO shall be available to the employees who 

operate the air emission producing equipment. These employees shall receive instruction as 

to their responsibilities in operating the equipment according [0 all of the relevant conditions 

listed below. 

5.	 The approved installations shall consist of the following equipment or equivalent: 

A.	 Aqua Miser Medium Pressure Water Paint Stripper 

B.	 Air Operated Drum Pump and Spray Wand with non-atomizing tip 

* Equivalency shall be determined by the Executive Secretary. 

Limitations and Tests Procedures 

6.	 Visible emissions from any stationary point or fugitive emission source associated with the 

source or with the control facilities shall not exceed 10% opacity. Opacity observations of 

emissions from stationary sources shall be conducted in accordance with 40 CFR 60. 

Appendix A. Method 9. 

7.	 The following production limits shall not be exceeded without prior approval in accordance 

with R307-1-3.1. UAC: 

A.	 3300 gallons of Paint Suipper per rolling l2-month period 

B.	 150.000 lbs of Sodium Bicarbonate per rolling 12-month period 

Compliance with the annual limitations shall be determined on a rolling 12-month total. The 

owner/operator shall calculate a new 12-month total based on the first day of each month 

using data from the previous 12 months. Records of consumption shall be kept for all periods 

when the plant is in operation. Records of consumption. including rolling 12-month totals 

shall be made available to the executive secretary or his representative upon request and shall 

include a period of two years ending with the date of the request. Consumption shall be 

determined by purchase records and operations log. The records shall be kept on a daily 

basis. 

Fu~tiye Dust 

8.	 The moisture content of the material used containing sodium bicarbonate shall be maintained 

at a minimum of 80.0% by weight. All ofthe sodiulP bicarbonate shall be periodically swept 

or sprayed clean from all surface areas as dry conditions warrant or as determined necessary 

by the Executive Secretary. The moisture content shall be tested if directed by the Executive 

Secretary using the appropriate American Society of Testing and Methods (ASTM) method. 

4.2.4-30 
DAQE-OI3-96 

..-., Page 3 

Abstract 

Hill Air Force Base (HAFB) is requesting approval to use a Medium Pressure Water (MPW) stripping 

system to strip paint offofaircraft. In the past a chemical paint stripping method using methylene chloride 

was used to strip paint offofaircraft. The VOC and Hauudous Air Pollutants will be less when the MPW 

system is utilized. The VOC emissions in shall be 5.41 tons per I2-month period. 

The Notice of Intent for the above-referenced project has been evaluated and has been found to be consistent 

with the requirements of the Utah Air Conservation Rules (UACR) and the Utah Air Conservation Act. Air 

pollution producing sources and/or their air control facilities may not be constructed. installed, established, 

or modified prior to the issuance of an Approval Order (AO) by the Executive Secretary of the Utah Air 

Quality Board. 

A Notice of Intent to issue an AO will be published in the Newspaper Agency on January 9, 1996. A 30-day 

period following the publishing date will be allowed during which the proposal and evaluation of its impact 

on air quality will be available for both you and the public to review and comment. If anyone so requests 

within 15 days of publication of the notice, a hearing will be held. The hearing will be held as close as 

practicable to the location of the source. Any comments received during the 30-day period and the hearing, 

if held., will be evaluated. 

Please review the proposed AO conditions during this period and make any comments you may have before 

its closure. The proposed conditions of the AO may be changed as a result of the comments received. Unless 

_ changed. the AO will be based upon the following conditions: 

General Conditjons: 

1. This AO applies to the following company: 

Faci!jty Location 

Depanmem of the Air Force 

Headquaners Ogden Logistics Center (AFMC) 

Hill Air Force Base. Utah 

PHONE NUMBER (801) 777-0359 

FAX NUMBER (80l) 777-6742 

The equipment listed below in this AO shall be operated at the following location: 

PLANT LOCATION' 

East of Exit 336 on Interstate 15 

Universal Transverse Mercator (UTM) Coordinate System: 

4,551 kilometers Northing; 418 kilometers Easting; Zone 12 

.- 2. Definitions of terms, abbreviations, and references used in this AO confonn to those used in 

the UACR. Utah Administrative Codes (UAC), and Series 40 of the Code of Federal 

Regulations (40 CFR). These definitions take precedence unless specifically defined 

otherwise herein. 4.2.4-29 
DAQE-O13-96 

Page 2 

STATE OF UTAH
 

Department of Environmental Quality
 

Division of Air Quality
 

INTENT TO APPROVE Medium Pressure Water & Chemical
 

Paint Stripping of Aircraft
 

Prepared By: Nando Meli, Engineer 

801·536·4052 

INTENT TO APPROVE NUMBER 

DAQE·013·95
 

Date: January 5, 1996
 

Source
 

Hill Air Force Base 

James R. VanOrman 

801-777-2050 

Russell A. Roberts
 

Executive Secretary
 

Utah Air Quality Board
 

4.2.4-28
 
DEPARTh1ENT OF ENVIRONME~'TAL QUALITY 

DIVISION OF AIR QUALITY 

Michael O. Leavin 150 North 1950 West
 

Govomor
 P.O. Bo;{ 144820 

Dianne R. Nielson. Ph.D. Salt Lake City. Utah 841 14-4820 E.lCCUUYC Director (80l) 536-4000 Voice 

Russell A. Roberts (801) 5364099 Fax.
 DinI:Ior
 (801) 536-4414 T.D.D. 

DAQE-013-96 

January 5, 1996 

James R. Van annan
 

Hill Air Force Base
 

Headquaners
 

Ogden Logistics Center (AFMC)
 

Hill Air Force Base. Utah 84056
 

Dear Mr. Van annan: 

Re:	 Intent to Approve Medium Pressure Water & Chemical Paint Stripping of Aircraft
 

Davis County, CDS-AI, Non-Attainment, Title V
 

The attached document is an Intent to Approve for the above referenced project. 

Future correspondence on this Approval Order should include the engineer's name as well as the DAQE 

number as shown on the upper right-hand comer of this lener. Please direct any technical questions you may 

have on this project to Mr. Nando Meli. He may be reached at (801) 536-4052. 

Sincerely, 

v;:f"	 C )/J,~ / 

.~~ /~ , / t' ~'"G~'
 

~n R. Menlove, Manager
 

New Source Review Section
 

Utah Division of Air Quality
 

LRM:NM:aj 

cc:	 Davis County Health Depanment
 

28 East State Street
 

POB 618
 

Farmington, UT 84025-618
 

• '. 

N A 4.2.4-27 . 
i 

4. In the Best Available Control Technology (BACT) Analysis section, page 4. 

voe emiss~ons should be changed to 1000 Ibslaircraft. Also note this process is 

BAa for the HAP Methylene chloride (from 10.000 lbs to 0 lbs). The process is BAC[ 

fdr VOC because using Benzyle Alcohol stripper alone on the entire aircraft would emit 

approximately 6000 Ibs ofVOC per aircraft (3 applications @ 11 drums each). With the 

n1edium pressme water process, Benzyle Alcohol is used only on areas where the MPW 

win not work thus reducing emissions to approximately 1.000 Ibs / aircraft. 

i 5. In iteb 6 of APPLICABILITY OF GENERAL REGULATrONS AND UTAH 

. $MINISTRATIVE CODES (UAC), page 4, the following statement appears 

"hasonably Achievable Control Technology (RACT) applies in non-attainment areas." 

I~ this correcr] Or, should we be doing a RACT analysis? , . 

; 6. Item i3 in the general conditions section states "the Chemical Processing Line 

Building 53g~·. The statement should be replaced with: "the MPW operations in 206" 

\ 7. On p~e 13 item 7. B. indicates the use of 5161bs of Sodium Bicarbonate. It 

should be 150;CX)() Ibs. 

\ 8. Pagel 13, item 9 "written procedures for the operation and maintenance of the 

cIegreasing or solvent cleaninsr equipment...... should read "Vlntlen procedures for the 

~rationand maintenance of the striping eguipment...... . ! 

I 

i As we ~ve indicated in our 8 December letter, a formal test report will be 

fqrwarded prior to 4 February, 1996. Please contact David Budak.. at (801) 777-1449, for 

additional information. 

I 

I 

I· 

Chief, Environmental Compliance Div. 

Environmental Management Directorate 

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: , 

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I 4.2.4-26 I 

\ 

. II 
DEPARTMENT OF THE AIR FORCE . HEADQUARTERS OGDEN AIR LOGISTlCS CENTER (AFMC) RECEIVED 

HILL AIR FORCE BASE, UTAH 

DEC 15 1995 ~'}'

Air QUality"U::­

, . December 14. 1995 Jr. Lynn s. Hill oP-ALClEME: 

7274 Wardleigh Roacf 

Hfll AFB UT 84056-5137 J I 

r. Nando Meli 

D vision of Air Quality 

1 50 West North Temple 

p~ Box 144820 Sft Lake City~ pr 84114-4820 

~: Edits for Notice of Intent for Medium Pressure Water and Chemical Paint Stripping 

011 C-130 Aircraft in Bldg. 206 (DAQE-lOOO-95 ,2 Nov 95) I . 

I The Draft Approval Order Medium Pressure Water & Chemical Paint Striping of 

Atcraft, Dm'is CounTy, dated December 8 1995 was reviewed and the following 

comments are provided for consideration: I ' . 

1. The~footer at the bottom of each page indicates this OA is for our Chem Mill 

L e. It should read "Medium Pressure Paint Stripping" . ' 

2. The;sr.a.ternent "The vee emissions is estimated at 750 1bs using the MPW 

arid 10,000 lbs when Methylene Chloride is used." is not entirely accurate. We estimate 

at!Proximately 1000 Ibs ofvee per C-130 with MPW but zero HAP emissions. The 

Nkthylene chlonde process emits 10.000 lbs of HAP (Methylene chloride) and 4,000 Ibs 

o voe. (14oo:gal stripper * 10.3Ibs/gal * 0.681bs Methylene chloride per lb. of 

s 'pper = 10,OOO~ 1400 gal stripper oj: 10.31bslgal * 027 lbs voe per lb. of stripper 

:::: 4,000 1bs of yOC) 

3. In th~ Emissions Summary section. page 3. the first line indicates this is for the 

C emical ~g Process Line. It should read "Medium Pressure Paint Stripping". In 

addition this seCtion scates there will be no PMlO emission\). We feel the PM10 emissions 

win be extremely small (- 130 lbs I aircraft, .87% PMlO x 15,000 lbs. conservatively 

FtuminS!: none is entrained in the water and minimal > PMlO material fractures to PMlO ) 

. nU~ber is based on a particle size distribution analysis conducted on the sodium 

bi bonate to be used. 

1 

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4.2.4-25 
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CMHIEMPIEHX 

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I " . Do not; transmit classified information over unsecured telecommunications ~ems.

Offlciaf 000 telecommunications systems are subject TO monitoring and use of 000 

I 

I 

te/ecommunicottons systems cof'lStitutes cansent to monitor. This device /5 suoJect to I

I

, mon;;oring at ell tfmes. Use of this device constttutes conset1T to monitor. ­

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~caW I ce p~ r~~ Cov", Slta -~.;.,."z.- I 

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4.2.4-24
 
(where full pressure can not be applied) and in areas with difficult to remove coatings, a 

chemical paint softener will be needed to remove the paint. 

The softener, containing Benzyl Alcohol, will be spray applied on the aircraft using an air 

operated drum pump and spray wand. The softener will be allowed to dwell on the 

surface from 4 to lO hours and then will be sprayed off with water. 

-


4.2.4-23
 
UTM COORDINATES: 4552.0 km Northing, 418.0 kIn Easting, Zone 12 

GENERAL DESCRIPTION 

Historically aircraft paint removal has been accomplished with methylene chloride based 

paint stripper. However, methylene chloride is a hazardous air pollutant (HAP), and its 

use will be severely limited by the NESHAPs and proposed Aerospace Control 

Technology Guide. Because of these limitations and because of the large quality of 

waste water and hazardous waste generated from this process another alternative was 

explored. 

Review of industrial paint removal processes revealed the most promising alternative to 

chemical paint stripping is medium (15,000 psi) pressure water. Emissions from this 

process are significantly less than chemical paint stripping. The MPW process erodes 

paint from the aircraft surface and entrains it in the water stream. 

The medium pressure water stripping system consists of a 15,000 psi 3.2 gallon per 

minute water pump and a bicarbonate ofsoda (Na HC03) injection system with control 

and peripheral equipment. The system includes a hand-held wand with various nozzle 

configurations that are matched to the function being performed. Currently a nozzle with 

a tuned port that produces a fan-like blast pattern is used for aircraft paint stripping. 

The system used is an Aqua Miser model E25 manufactured by Carolina Equipment, 

North Charleston, SC, 29418. The system will be operated with the following nominal 

perimeters: 

Stripping medium Sodium bicarbonate water suspension 

Mean feed rate 3 Lb I min 

Nozzle design 0.5 inch diameter, # 8 

Stand off distance > 18 inches 

Impingement angle 45 - 60 degrees 

Estimated stripping rate 

The MPW process with water pressure alone is not effective for removal of the paint 

systems used on C-130s. Also, in some areas ofthe aircraft with exceptionally thin skins 

4.2.4-22 
UTAH DIVISION OF AIR QUALITY
 

FAX COVER SHEET 

150 NORTH 1950 WEST CANNON L770 FAX # (801) 536-4099 

SALT LAKE CITY, UTAH 84114-4820 CONFIRMAnON # (801) 536-4000 

FROM: Nando Meli Jr. PHONE: (801) 536 - 4052 

-. 

TO: J 0/1(1 ()) J, c PHONE: 77)- -;) t):; 0 

AGENCY/FIRM ..---:.....:fJ....:..:...:.../(~--','-'-4......J.F-----<:(1:=!.....- _ 

FAX NUMBER _7_7--,7:..--_ )....l.<=---::1-=- _ L.L-I.... CONFIRMATION #: 

NUMBER OF PAGES TO FOLLOW: ) SSUBJECT: ENGINEERING REVIEW 

REMARKS: Could you reply as soon as possible with any comments that you may have on 

this Engineering Review. 

Thank you. 

LOGGED: 1?z8 SENT:/ j-/g RECEIVED: ~/--,I_'X CONFIRMED: 

4.2.4-21 
-'. .~ ­

To: HOBSTERB
 

From: John Vtdic
 

CC:. BUDAM.D.LAODOMAIN:LAO WCHRISTEJ
 

Subject: Comments on DAQE-013-95- Notlc~ of intent to Approv~ your Itr 1E Jan
 

Date wedne~day. January 2'. 1996 307 PM 

I 

Bonnie. 

J haNe the folloWing comments on the subject notice. . : 

1. On page 3, tKe last sentence of the first paragraph appears to have a typo. It should 

read •". emissiohs shall be 5.411on5,.... ; 

I 

2. On page 4, items 5, A & B the notice indicates the equipment in the singular tense. 

For example"Palint stripper", However, we have several strippers. so the notice should 

read "paint stripper(s)" for item 5, A and "Drum Pump(s) and Spray Wands(s) with 

non~automizing ~ip(s)" for item 5. 8. 

3. Under item 7.[ page 4. we request the rolling total for a particular month be 

calculated by the 5th of the following month rather than on the 1st of the following 

month. 

, 

4. In talking witH the permit writer we understand the requirement for mainta,jning 

minimum 80% moisture content in the bicarbonate. However the notice should be . I ...-.,..

cl.ar~ied (page 4.; item 8) to indicate 80% is the moisture content as blasted from the 

Aqua Miser for the fOllowing reason. . . I 

i 

To functionproper1y the sodium bicarbonate must be loaded into the Aqua Miser dry 

(wet sodium bieSrbonate will plug the hopper and feed mechanism), The Aqua Miser 

then adds water to the sodium bicarbonate to a level of at least 80% moisture (98% 

typical) before bllasting the sodium bicarbonate on the aircraft. 

, 

5. Item 10. requirement F. page 6. directs us to subtract out voe and HAP emissions 

. potential that is disposed of in our hazardous and solid waste streams. However based 

on data from our!experimental approval order testing we estimate. very little HAPs and 

VOCs will make to these waste streams. Therefore. we request this not be a 

.requirement but amly an option Since it is more conservative to assume all emissions 

potential is relea~ed neglectinq what may be found in hazardous WA~tP. ~Ant tn 

TOTRL P.02 

4.2.4-20
 
OD-ALC!I91 

.,tl4 WARbLBQH ROAD FEB 0 li~)

HrUAFE lIT i40s~Sf>J Air Quality 

. Toi _Vn: Q Y\ D 0 Y!J---..;e ~_~i-......- : V.,Iv j S f~ 0 F IJ:.t'v­

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S3&-L[o91 

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DSN 4Si-'742 

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Do not rransmtt c1assttied Information over unsecured telecommunications systems. 

Official ~O telecommunications systems ore subject to monitoring and use of DoD 

telecommunications systems consrttures consent to monrtor. This device Is sUbjecT fa 

moniforlnp at all times. Usa of this device constttutes consent fa monitor. ' 

. ! 

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T.:tJ. ~.e p~ ,~ Slut _""2-_ 

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4.2.4-19 
4. In the Best Available Control Technology (BACT) Analysis section. page 4. 

the VOC emissions should be changed to WOO lbs/aircraft. Also note this process is 

BACT for the HAP Methylene chloride (from 10.000 lbs to 0 lbs). The process is BACT 

for VOC because using Benzyle Alcohol stripper alone on the entire aircraft would emit 

approximately 6000 lbs of VOC per aircraft (3 applications @ 11 drums each). With the 

medium pressure water process. Benzyle Alcohol is used only on areas where the MPW 

will not work thus reducing emissions ro approximately 1,000 lbs I aircraft. 

5. In item 6 of APPLICABll..ITY OF GENERAL REGULAnONS AND UTAH 

ADMINISTRATIVE CODES (UAC), page 4, the following statement appears 

"Reasonably Achievable Control Technology (RACT) applies in non-attainment areas." 

Is this correct? Or, should we be doing a RACT analysis? 

6. Item 3 in the general conditions section states "the Chemical Processing Line 

in Building 538". The statement should be replaced with: "the MPW operations in 206" 

7. On page 13 item 7. B. indicates the use of 5l6lbs of Sodium Bicarbonate. It 

should be l50,OOO lbs. 

8. Page 13, item 9 "written procedures forthe operation and maintenance of the 

degreasing or solvent cleaning eguipment...", should read "written procedures for the 

operation and maintenance of the striping equipment.:.". 

As we have indicated in our 8 December letter, a formal test report will be 

forwarded prior to 4 February, 1996. Please contact David Budak. at (80l) 777-1449, for 

additional infonnation. 

Chief, Environmental Compliance Div.
 

Environmental Management Directorate
 

4.2.4-18
 
DEPARTMENT OF THE AIR FORCE
 

HEADQUARTERS OGDEN AIR LOGISTICS CENTER {AFMCl 

HILL AIR FORCE BASE. UTAH R~CEIVED

'--DEC 18 1~:1:J

Air Quality 

December 14. 1995 

Mr. Lynn S. Hill 

OO-ALC/EME 

7274 Wardleigh Road 

Hill AFB UT 84056-5137 

Mr. Nando Meli 

Division of Air Quality 

1950 West North Temple 

PO Box 144820 

Salt Lake City, UT 84114-4820 

RE: Edits for Notice of Intent for Medium Pressure Water and Chemical Paint Stripping 

of C-130 Aircraft in Bldg. 206 (DAQE-1 000-95 , 2 Nov 95) 

The Draft Approval Order Medium Pressure Water & Chemical Paint Striping of 

Aircraft. Davis County, dated December 8 1995 was reviewed and the following 

comments are provided for consideration: 

1. The footer at the bottom of each page indicates this OA is for our Chern Mill 

Line. It should read "Medium Pressure Paint Stripping" 

2. The statement "The VOC emissions is estimated at 750 1bs using the MPW 

and 10,000 1bs when Methylene Chloride is used." is not entirely accurate. We estimate 

approximately 1000 1bs of VOC per C-130 with MPW but zero HAP emissions. The 

Methylene chloride process emits 10,000 lbs of HAP (Methy1ene chloride) and 4,000 1bs 

of VOe. (1400 gal stripper * 10.3 1bs/gal * 0.68 1bs Methylene chloride per lb. of 

stripper = 1O,000~ 1400 gal stripper * 10.3 lbs/gal * 0.27 1bs VOC per lb. of stripper 

=4,000 1bs of VOC) 

3. In the Emissions Summary section, page 3, the first line indicates this is for the 

Chemical Milling Process Line. It should read "Medium Pressure Paint Stripping". In 

addition this section states there will be no PMIO emissions. We feel the PMIO emissions 

will be extremely small (- 130 lbs / aircraft, .87% PMIO x 15,000 lbs, conservatively 

assuming none is entrained in the water and minimal> PM IO material fractures to PMIO ) 

This number is based on a particle size distribution analysis conducted on the sodium 

bicarbonate to be used. 

42.4-17