### 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 Orderfor Medium Pressure Water & Chemical Paint Stripping ofAircraft 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 upperright-hand comer ofthis 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-7DAQE-163-96 February 9. 1996 

# - Page 2 

# STATE OF UTAH Department ofEnvironmental Quality Division ofAir Quality APPROVAL ORDER FORMEDIUM 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

4.2.4-8DAQE-163-96 February 9, 1996 Page 3 

### Abstrtul HillAir Force Base (HAFB) is requesting approval to use a Medium Pressure Water (MPW) stripping system to strippaintoff of aircraft. In thepasta chemicalpaintstripping method using methylene chloride was usedto 

### strippaintoff anaircraft. The VOC andHazardousAirPollutanrs willbeless when theMPW system is utilized. The VOC emissions in building 206from the Medillm Pressure Water and Chemical Paint Stripping operations shallbe 5.41 tonsper 12-monthperiod. The above-referenced project has been evaluated and found to be consistent with the requirements ofthe 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 ofthis order: General Conditions: 1. This AO applies to the following company: FacWry Location


# .-- Depanment ofthe AirForce Headquaners Ogden Logistics Center (AFMC) Hill AirForce 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: PLANTLOCATION' East ofExit 336 on Interstate 15 Universal Transverse Mercator (UTM) Coordinate System:

4.551 kilometers Northing; 418 kilometers Easting; Zone 12 2. Definitions ofterms. 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 AirForce Base (AFB) shall install and operate the Medium Pressure Water & Chemical Paint Stripping of

### Aircraft in Building 206 according to the tenns and conditions ofthis AO as requested in the Notice ofIntent dated November 27.1995. and additional infonnation submitted to the Executive Secretary dated December7. 1995.


### 4.2.4-9DAQE-163-96 February 9. 1996 Page 4 4. A copy ofthis AO shall be posted on site. The AO shall be available to the employees who operate the airemission producing equipment. These employees shall receive instruction as to theirresponsibilities in operatingthe equipment according to all ofthe relevant conditions listed below. 

### 5. The approved installations shall consist ofthe following equipment or equivalent: A. Aqua Miser Medium Pressure WaterPaint 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 orwith 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 ofPaint Stripperper rolling 12-month period B. 150,000 Ibs ofSodium Bicarbonate perrolling 12-monthperiod Compliance with the annual limitations shall be determined on a rolling 12-monthtotal. The owner/operator shall calculate a new 12-month total based on the first day of each month using datafrom the previous 12 months. TIris total shall be calculated by the tenth day ofthe following month. Records of consumption shall be kept for all periods when the plantis 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 oftwo years ending with the date ofthe 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 ofthe material used containing sodium bicarbonate shall be maintained ata minimum of80.0% by weightasthe material is blasted from the Aqua Miser. All ofthe sodium bicarbonate shallbe 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 ifdirected by the Executive Secretary using the appropriate American Society ofTesting andMethods (ASIM)method.

4.2.4-10DAQE-163-96 February 9. 1996 Page 5 

### VolatHe Organic Compound (VOel Limitations 9. The facility shall abide by all applicable requirements ofUAC 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 ofthe 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). ifrenumbered. 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 perrolling 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. Basedon the first day ofeach month a new 12-month total shallbe calculated using datafrom the previous 12 months. Theemissions ofVOCs emittedto the atmosphere from Building 206 shall be determined by maintaining a record ofvolatile 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 airpollutant potential ofthe 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 ofthe 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:



### 4.2.4-11DAQE-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 orhazardous 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 ofthe total VOCs emissions. (The assumption is that all the two above potentials ofthe materials applied to a product evaporate and are therefore considered emissions). G. Records ofconsumption ofVOCs 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 oftwo years**endin~** with the date ofthe 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, orifan existing facility, upon issuance ofthis AO. The fee will be based on calculated annual emissions listed atthe end ofthis AO. This fee is valid until inventory datafor one year are available for the source. The owner or operator ofthis source will be billed upon start-up for all emissions thatare considered "chargeable" as ofthat 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 orestablished maintenance practices thatmaximize pollution control shall be used. All necessary equipmentcontrol 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 theirrequest. 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 whenevera breakdown occurs. All excess emissions shallimmediately bereported to the Executive Secretary. The total ofexcess emissions shall be reported to the executive secretary as directed for each calendaryear.

4.2.4-12DAQE-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 oftwo years ending with the date ofthe request. All records shall be kept for a period of two years. Examples ofrecords 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 oroperatorfrom 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 ofAircraft in Building 206 are currently calculated at the following values: Pollutant Tons/yr PM IO 

### ···························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 ofthe UACR. Except for VOe's they are not to be used for purposes ofdetermining compliance. In accordance with the requirements ofTitle V ofthe 1990 Clean Air Act, the following pollutants may be subject to an operating permit fee. Emissions ofthe following pollutants from all sources, including preNovember 19, 1969 sources, may be subjectto the operating permit fee. Both the fees rate and the class of pollutants are subject to change by State, the federal agencies, orboth. Pollutant Tons/yr PM IO 

### ···························0.65 VO 5.41



### 4.2.4-13

### DEPARTMENT OFENVIRONMENTAL QUALITY DIVISION OFAIR 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 SaltLake 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 ofpublication to the Utah State Depanment ofEnvironmental Quality, Division ofAir Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. Sincerely, /I'

# -~Q~000rr~U

melia 

### 1aram' 0 Office Technician Utah Division ofAir Quality Enclosure



# - 4.2.4-14**DAQE~014-96** Page 2 NOTICE The following notice ofintent 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 AirForce Base. lJT 84056-5137 Medium Pressure Water & Chemical Paint Stripping ofAircraft

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 airquality impact analysis have been completed and no adverse airquality impacts are expected. It is the intent ofthe Executive Secretary to approve the construction project.

The construction proposal and estimates ofthe effect on local airquality are available for public inspection and comment at the Division ofAir Quality, Utah State Department ofEnvironmental 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 ofthe proposed construction.

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



### Date ofNotice: 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 boi 1 (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 g1 ve**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 ofEnvironmental Management Attachment: MSDS

cc: EMP LAOPE (ATTN: John Vidic)

4.2.4-56

# - RECEIVED DEPARTMENT OFTHE AIR FORCE 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 ofAir Quality 1950 West North Temple PO Box 144820 Salt Lake City, 

### LIT 84114-4820 

### RE: Notice ofIntent for Medium Pressure Water and Chemical Paint Stripping ofC-130 Aircraft at Hill 

### Air Force Base (DAQE-1000-95 , 2 

### Nov 95) Dear Mr. Roberts The Experimental Approval Order (DAQE-lOOO-95 ,2Nov 95) authorized Hill 

### Air Force Base (HAFB) 

### to determine ifa lower VOC emission paint removal process could be developed. Experimental testing for paint stripping ofC-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 of50 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 ofthe 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 ofVOC's e. Proposed method to track air emissions: Log chemical use, hours of operation, andnumber ofaircraft stripped. f. Tentative schedule to start operations: 30January 1996. 4.2.4-55

# ­**?~~** i:L \)0 

### c. ::­

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# J#.u vO C.



### ...

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## .5 

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# _-;), c::' """' 6\ (, 

# (9 /.? :::>0 J

# 3,).

4.2.4-54

# -- Thepaint softener**~hall** 

### be

### applied with

### a stainless seed application gun (car wash 

### type) with a non-aLomizing tip, and I 

### orhand applied 

### with a brush.

4.2.4-53AIRCRAFT 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:,

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4.2.4-52

### f. Tentative schedule to start operations: 30 January 1996. Historically, HAFB has processed approximately 50 aircraft peryear. however, not all aircraft were fully stripped and painted. Forourrequest of27 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 ofEnvironmental 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 ofAir 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 AirForce Base DearMr. Roberts The Experimental Approval Order (DAQE-l000-95 ,2 Nov 95) authorized Hill AirForce Base (HAFB) 

### to determine ifa lower VOC emission paint removal process could be developed. Experimental testing for paint stripping ofC-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 ofthe test data indicate only 10,800 lbs ofVOC will be required per year. . Based upon the results ofthe 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 ofthe aircraft, mediumpressure 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: 150,000pounds/year. d. Projected airemissions: 10,800 lbs ofVOe's e. Proposed method to track airemissions: 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. 1IT"1:ICCOl"' • :3.t.\lICII\All,**s,..~Deeru** 

### HILL AIR



## -'mM lIS'ffl!!I:III'**.~.,** .. 

### CAPTION**~tl** 

### NOTICETHE FOLLOWING NOTICE OF

S137. : 

### SIZE

## _:;;t~11**~~** ... ! "In' /opplOVoll .I

...**~vel** 

### 70 LINES 1.00 COLUMN 

## ..-..**,~'In** 

### TIMES**~~~-;~~~)'."'" :6S=~r'** 

. UClnItv-a' 1

## -'~·MISC .. CHARGES

ted CIIlCl.no' jmpaClSOl& Ir'll«'Idltle: 1O«lPlOY& 

### .00

## ~;4f~~\**n-.and":~** otf;ilQuQlI-· olEn­ '."}

..'

. RATE ". ':".)

## ~\ \ 

# 'ftI;CEJVED 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/operatorshall calculate/estimatethe excess emissions whenever a breakdown occurs. All excess emissions shall immediately be reponed to the executive secretary. The total ofexcess 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 PM IO ••••••••••••••••••••••• 

### 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 ofdetermining 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 PM IO ••••••••••••••••••••••• 

### 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 15A. 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 eachindividual 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 ofthe 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 147. 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 oftwo 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 ifdirected by the Executive Secretary using the appropriate American Society ofTesting 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 ofUAC 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 ofeach month a new l2-month total shall be calculated using data from the previous 12 months. The emissions ofVOCs 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 13V. 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 (80I) 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 ofterms. 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 ofthis 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 12B. 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 11For 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 ofthat 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. 3I. R307-1-1. Defmition ofMajor 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 109) 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 AirPollutants (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 94.8 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 ofemission 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 oftheircontrol 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 8represent a new major source or a majormodification 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 ofthe 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 orEmergency 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 PM IO ••.•••••••• 

### 5 SO, 20 N01 20 CO 50 VOC 20 

# °

, ••.••••••• : . 

### 5

3 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 ofIntent does not


### 4.2.4-39 Hill AFB Water Paint Strip Engineering Review December 8. 1995 Page 68. 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 ormajor 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 PM 10' 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) ofthe CAA defines these sources as sources ofvolatile 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: 1are required. The emissions increase will be less than 40tpy. 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 (pM 10)' S01' and NO,.
.The allowable increments 

### are as follows:

Three Hour 24 Hour Annual Class I Area
. . . . . . . .. Nt A 

### 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 ormore spaces and adding 350 ormore 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. ifthe 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% ofa 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 AirForce Base (HAFB) is requesting approval to use a Medium Pressure Wacer rMPW) scnpping 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 Hazp.rdous AirPollutants 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 ofthe large quality ofwaste 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 ofsoda (Na HC0 3) 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 PM 10 0.0 0.65 0.65 VOC 0.0 5.41 5.41 There will be no PM lO 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 PM 10 •••••••••••••••••••••••••••••••• 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 ofthe 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) 

## /l-(/ 

# tirF:\AQ\f.NGINEER\NMeli\WNil-Slrip.Rev Lynn Menlove

4.2.4-34DAQE-O 13-96 ')age 7 C. Maintenance records (Condition number 12) D. Upset., breakdown episodes (Condition number 14) Any future modifications to the equipment approved by this ordermust also be approved in accordance with R307-1-3.l.1, UAC. This AO in no way releases the owneror operatorfrom 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 ofAircraft in Building 206 are currently calculated at the following values: Pollutant Ions/yr PM lO •••.••••••• " .••••••••••••• 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 ofthe UACR. Except for VOe's they are not to be used for purposes ofdetermining compliance. In accordance with the requirements ofTitle V ofthe 1990 Clean Air Act., the following pollutants may be subject to an operating permit fee. Emissions ofthe 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 PM 10 " ••••••••.•••••••••.•••••• 0.65 VOC 5.41 TheDivision ofAirQuality is authorized to charge a fee for reimbursement ofthe actualcosts incurred in the issuance ofan AO. Unless public comments are received which require additional work, the fee for this AO 

### will be $1,000.00. Aninvoice will follow. You may pay this fee priorto the end ofthe comment period. If there are comments or additional fees, you will be notified. Sincerely,

..--**~ynn** R. Menlove, Manager New Source Review Section


# - 4.2.4-33DAQE-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 depositedas solid orhazardous waste for the month shall be quantified and subtracted from the quantities calculated above. This is done to allow quantification by the source ofthe 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 oftwo years ending with the date ofthe 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. orif an existing facility, upon issuance ofthis AO. The fee will be based on calculated annual emissions listed atthe end ofthis AO. This fee is valid until inventory datafor one year are available for the source. The owneror operator ofthis source will be billed upon start-up for all emissionsthat are considered "chargeable" as ofthat 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 vendororestablished maintenance practices that maximize pollution conuel shallbeused. All necessary equipmentcontrol 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 theirrequest. 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 whenevera breakdown occurs. Allexcessemissions shall immediately be reported to the executive secretary. The total ofexcess 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 oftwo years ending with the date ofthe 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) 

### 4.2.4-32DAQE-013-96 Page 5 Volatile Organic Compound (VQC) Limitations 9. The facility shall abide by all applicable requirements ofUAC 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 ofthe degreasing or solvent cleaning equipment shall be permanently posted in an accessible and conspicuous location nearthe 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), ifrenumbered. 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. Basedonthe first day ofeach month a new 12-month total shall be calculated using datafrom the previous 12 months. The emissions ofVOCs emitted to the atmosphere from Building 206 shall be determined by maintaining a record ofvolatile organic compoundpotential 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 airpollutant potential ofthe 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 ofthe 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) 

### 4.2.4-31DAQE-013-96 Page 4 3. Hill AirForce Base (AFB) shall install and operate the Medium Pressure Water & Chemical Paint Stripping ofAircraft in Building 206 according to the terms and conditions ofthis AO as requested in the Notice of Intent dated November 27. 1995. and additional information submitted to the Executive Secretary dated December7. 1995. 4. A copy ofthis AO shall be posted on site. The AO shall be available to the employees who operate the airemission producing equipment. These employees shall receive instruction as to theirresponsibilities in operating the equipment according [0 all ofthe relevant conditions listed below. 5. The approved installations shall consist ofthe following equipment orequivalent: 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 pointorfugitive emission source associated with the source orwith 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 ofPaint Suipperperrolling l2-month period B. 150.000 lbs ofSodium Bicarbonate per rolling 12-month period Compliance with the annual limitations shall be determined on a rolling 12-monthtotal. The owner/operator shall calculate a new 12-month total based on the first day ofeach month using datafrom the previous 12 months. Records ofconsumption shall bekeptfor all periods when the plant is in operation. Records ofconsumption. including rolling 12-monthtotals shall be made available to the executive secretary orhis representative upon request and shall include 

### a period oftwo 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 contentofthe material used containing sodiumbicarbonate shall be maintained ata minimum of80.0% by weight. Allofthe sodiulP bicarbonate shallbe periodically swept orsprayed 

### clean from all surface areas as dry conditions warrant oras determined necessary bythe Executive Secretary. Themoisture content shall be tested ifdirectedby the Executive Secretary using the appropriate AmericanSociety ofTesting and Methods (ASTM)method.
4.2.4-30DAQE-OI3-96

..-., Page 3 

### Abstract HillAir Force Base (HAFB) is 

### requesting approval to use a Medium Pressure Water (MPW) stripping system to strippaintoff of aircraft. In thepasta chemicalpaintstripping method using methylene chloride was usedto strippaint off of aircraft. The VOC andHauudousAirPollutants willbe less when the MPW system is utilized. The VOC emissions in shallbe 5.41 tonsperI2-monthperiod. TheNotice ofIntent for the above-referenced project has been evaluated and has been found to be consistent with the requirements ofthe 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 ofIntent 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 ofits impact on air quality will be available for both you and the public to review and comment. Ifanyone 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 ofthe source. Any comments received during the 30-day period and the hearing, ifheld., 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 ofthe AO may be changed as a result ofthe 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 ofthe AirForce Headquaners Ogden Logistics Center (AFMC) Hill Air Force Base. Utah PHONE NUMBER (801) 777-0359 FAXNUMBER (80l) 777-6742 The equipment listed below in thisAO shall be operated at the following location: PLANTLOCATION' East ofExit 336 on Interstate 15 Universal Transverse Mercator (UTM) Coordinate System:

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

. 2. Definitions ofterms, abbreviations, andreferences 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-O 13-96 Page 2



# STATE OF UTAH Department ofEnvironmental Quality Division ofAir Quality INTENT TO APPROVE Medium Pressure Water & 

# Chemical Paint Stripping ofAircraft

Prepared By: Nando Meli, Engineer 801·536·4052 

### INTENTTO APPROVE NUMBER DAQE·013·95 Date: January 5, 1996

Source 

# Hill AirForce Base James R. VanOrman 801-777-2050 

### Russell A. Roberts 

### Executive Secretary Utah Air Quality Board

4.2.4-28

### DEPARTh1ENT OF**ENVIRONME~'T** 

### AL 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 AirForce Base. Utah 84056 DearMr. Van annan: Re: Intent to Approve Medium Pressure Water & Chemical Paint Stripping ofAircraft 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 numberas shown on the upperright-hand comerofthis lener. Please direct any technical questions you may have on this projectto 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 ofAir 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, page4. 

## voe**emiss~ons** 

### shouldbe changed to 1000Ibslaircraft. Also note this process is BAafor theHAP Methylene chloride (from 10.000 lbs to 0 lbs). Theprocess 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 n1ediumpressme waterprocess, BenzyleAlcohol 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 ofAPPLICABILITY 

### OF GENERAL REGULATrONS 

### AND UTAH



### . $MINISTRATIVE CODES (UAC),

### page 4, 

### the following statement appears

"hasonably Achievable Control Technology (RACT) 

### applies 

### innon-attainment areas."

### I~ this correcr] Or, should we be doing 

### aRACT analysis?

, . 

### ; 6. Itemi3 in 

### the general conditions section states "the Chemical Processing Line Building

### 53g~·. The statement shouldbe replaced with: "the MPW operations 

### in206" 

### \ 7. On

## p~e 13 item7. 

### B. indicates the use of5161bs of SodiumBicarbonate. It should

### be 150;CX)() Ibs.

\ 8. Pagel 13, item 

### 9 "written procedures for the operation and maintenance ofthe 

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

### ~rationand maintenance ofthe striping eguipment..
....

. !

I 

# i As we

### ~ve indicated in our 

### 8 Decemberletter, a formal testreport will be fqrwarded

# priorto 

### 4 

### February, 1996. Please contact DavidBudak.. at 

### (801) 777-1449, for additional

### information. 

# I I

I·



### Chief, EnvironmentalCompliance Div. 

### Environmental Management Directorate

. I

I : 

### ,

, I I I I I I 4.2.4-26 I 

### \

. II

### DEPARTMENT OFTHE AIR FORCE

. HEADQUARTERSOGDEN AIR LOGISTlCS CENTER (AFMC) 

# RECEIVED HILLAIRFORCE BASE, UTAH 

# DEC 15 

# 1995

# ~'}' 

# Air QUality"U::­

, . 

### December 14. 1995 

# Jr. Lynn s. 

## Hill 

# oP-ALClEME: 7274 WardleighRoacf 

## Hfll AFB UT 84056-5137

J I

# r. Nando

## Meli D vision ofAir Quality 1 

### 50West North Temple**p~** 

### Box 144820 

# Sft Lake**City~** 

# pr 84114-4820

# ~: Edits for Notice ofIntentfor Medium Pressure Water and Chemical Paint Stripping 

### 011 C-130 Aircraft 

### in 

### Bldg. 206 (DAQE-lOOO-95 ,2Nov95) I

. I 

### The

# Draft Approval

### OrderMedium Pressure Water & 

### Chemical PaintStriping of 

### Atcraft, Dm'is CounTy, dated December 8 1995 was reviewed andthe following comments are 

### provided for consideration: I '

. 

### 1.**The~footer** 

### at

### thebottom ofeachpage indicates this OA

### is 

### for our ChemMill 

### L e. It should 

### read "MediumPressurePaintStripping"



### . ' 

### 2. The;sr.a.ternent 

### "The

# vee emissions is estimated at 750 1bs using the MPW arid 10,000 lbswhen Methylene Chloride is used." is not entirely accurate. We estimate at!Proximately 1000 Ibs of

# vee perC-130with 

### MPW but zeroHAP emissions. The Nkthylene 

### chlondeprocess emits 10.000 lbs ofHAP (Methylene chloride) and 4,000 Ibs 

### o voe. (14oo:gal stripper 

## * 10.3Ibs/gal 

## * 0.681bs Methylene chloride perlb. of s 'pper 

### =**10,OOO~** 

### 1400 

### gal stripper oj: 

### 10.31bslgal 

## * 027 lbs 

### voe perlb. ofstripper :::: 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 shouldread "MediumPressure PaintStripping". 

### In addition this seCtion scates there 

### will be no PMlO 

### emission\). We feel the PM10 

### emissions 

## win beextremely small (- 130 lbs I 

### aircraft, .87% PMlO 

### x 15,000 lbs. conservatively 

# Ft uminS!: 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

### beused. 1 I I I 

### 4.2.4-25

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# CMH

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# (i01) m-Cll(l.

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### "

. Do 

### not; transmit classified information overunsecured telecommunications**~ems.** Offlciaf 000 telecommunications systems are subject TO monitoring and use of000 I 

# I te/ecommunicottonssystems cof'lStitutes cansent to monitor. This device /5 suoJectto 

### I I 

### , mon;;oring

### atell tfmes. Use of this device constttutes conset1T to monitor.
­ 

### I

# ~caW 

# ce**p~ r~~**  Cov", Slta

# -~.;.,."z.-

. I I I 

### 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 softenerwill be allowed to dwell on the surface from 4 to lO hours and then will be sprayed offwith 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 ofthese limitations andbecause ofthe large quality of waste water and hazardous waste generated from this process another alternative was explored. Review ofindustrial 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 ofa 15,000 psi 3.2 gallon per minute waterpump and a bicarbonate ofsoda (Na HC03) 

### injection system with control and peripheral equipment. The system includes a hand-held wand withvarious nozzle configurations that are matchedto the function beingperformed. Currently a nozzle with a tuned portthat 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 offdistance > 

### 18 inches Impingement angle 45

- 60 degrees Estimated stripping rate
The MPW process withwaterpressure alone is not effective for removal ofthe paint systems used onC-130s. Also, in some areas ofthe aircraftwith 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 1 EJan 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 & 

### Bthe 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~)** 

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# Air Quality

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Do not rransmtt c1assttied Information over unsecured telecommunications systems. Official**~O** telecommunications systems ore subject to monitoring and use ofDoD telecommunications systems consrttures consent to monrtor. This device Is sUbjecTfa moniforlnp atall times. Usa ofthis device constttutes consent fa monitor. ' . ! 

## , !

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## I 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 ofVOC per aircraft (3 applications @ 

### 11 drums each). With the medium pressure waterprocess. Benzyle Alcohol is used only on areas where the MPW will not workthus reducing emissions ro 

### approximately 1,000 lbs 

### I aircraft. 5. 

### In item 6 

### ofAPPLICABll..ITY OFGENERAL REGULAnONS AND UTAH ADMINISTRATIVE CODES (UAC), page4, 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 of5l6lbs ofSodiumBicarbonate. It should be l50,OOO lbs. 

### 8. Page 13, item 

### 9 "written procedures forthe operation and maintenance ofthe degreasing or solvent cleaning eguipment...", should read "written procedures for the operation and maintenance ofthe striping equipment.:.".
As 

### we have indicated in our 8 Decemberletter, 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 ofAir Quality 1950 West North Temple PO Box 144820 SaltLake City, UT 84114-4820 RE: 

### Edits for Notice ofIntent for Medium Pressure Water and Chemical Paint Stripping ofC-130 Aircraft in Bldg. 206 (DAQE-1 000-95 , 

### 2Nov 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 ofeach page indicates this OA is for our Chern Mill Line. It should read "MediumPressure 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 ofVOC per C-130 with MPW but zero HAP 

### emissions. The Methylene chloride process emits 10,000 lbs ofHAP (Methy1ene chloride) and 4,000 1bs ofVOe. (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. ofstripper 

# = 4,000 1bs ofVOC) 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> PMIO 

### 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