1

OMB Control No. 2060-NEW 

Approval expires XX/XX/XX 

The public reporting and recordkeeping burden for this collection of information is 

estimated to average 47 hours per response. Send comments on the Agency's need for this 

information, the accuracy of the provided burden estimates, and any suggested methods for 

minimizing respondent burden, including through the use of automated collection techniques to 

the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822T), 

1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in 

any correspondence. Do not send the completed survey to this address.

ENCLOSURE 1

AEROSPACE MANUFACTURING AND REWORK INDUSTRY

INFORMATION REQUEST QUESTIONNAIRE

INSTRUCTIONS FOR COMPLETING THE QUESTIONNAIRE

I. Introduction

This information request is to be completed for operations that comprise the Aerospace 

Manufacturing and Rework source category at your facility. The Aerospace 

Manufacturing and Rework source category includes any facility engaged, either in 

whole or in part, in the manufacture or rework of commercial, civil, or military aerospace

vehicles or components. Aerospace vehicle or component means any fabricated part, 

processed part, assembly of parts, or completed unit, with the exception of electronic 

components, of any aircraft including but not limited to airplanes, helicopters, missiles, 

rockets, and space vehicles.

The North American Industrial Classification System (NAICS) codes that describe 

facilities that may manufacture or rework aerospace vehicles, components, or parts are 

listed in Table 1 below. This table is not meant to be exhaustive; facilities classified 

under other NAICS codes may also be required to complete this information request if

they perform activities as defined above.

The reporting year for this information request is 2008. If you cannot provide 2008 

data, you must contact Kim Teal of the U.S. EPA at 919-541-5580 or teal.kim@epa.gov

prior to completing this information request to explain why 2008 data are not available 

and obtain permission to submit data from another year.
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Table 1. North American Industrial Classification System Codes for the 

Aerospace Manufacturing and Rework Industry

NAICS Code Description

336411 Aircraft Manufacturing

336412 Aircraft Engine and Engine Parts Manufacturing

336413

Other Aircraft Parts and Auxiliary Equipment 

Manufacturing

336414 Guided Missile and Space Vehicle Manufacturing

336415

Guided Missile and Space Vehicle Propulsion Units and 

Propulsion Units Parts Manufacturing

336419

Other Guided Missile and Space Vehicle Parts and 

Auxiliary Equipment Manufacturing

481111 Scheduled Passenger Air Transportation

481112 Scheduled Freight Air Transportation

481211 Nonscheduled Chartered Passenger Air Transportation

481212 Nonscheduled Chartered Freight Air Transportation

481219 Other Nonscheduled Air Transportation

You must complete this information request for ALL manufacturing operations that 

constitute aerospace manufacturing and rework at your facility, regardless of whether 

the operations are presently regulated under the National Emission Standards for 

Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities 

(aerospace NESHAP). For example, information must be submitted for the following 

operations even though they are not regulated by the aerospace NESHAP: chemical

milling, metal finishing, electrodeposition, composites processing, manufacture of 

aircraft transparencies, and wastewater operations, among others. Additionally, you 

must submit information for operations that may be exempted from regulation under the 

aerospace NESHAP including, but not limited to, low volume usage coatings, activities 

associated with the manufacture or rework of space vehicles, certain waterborne 

coatings, certain cleaning operations, certain primer and topcoat operations, and certain 

depainting operations. Finally, you must submit information where control requirements 

are not specified for operations under the aerospace NESHAP, including the use of 

specialty coatings, adhesives, adhesive bonding primers, or sealants. 

However, this information request does not apply to aerospace manufacturing or rework 

operations that are regulated under NESHAP other than the aerospace NESHAP, with 

the exception of halogenated solvent cleaning. For example, you should not include in 
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your response information regarding chromium electroplating operations regulated 

under the chromium electroplating NESHAP.

Please complete the forms included in this attachment for all of the operations subject to 

this request and return them to:

U.S. Mail:

Ms. Kim Teal

U.S. EPA Mailroom (E143-03)

United States Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC 27711

Express Mail:

Ms. Kim Teal

U.S. EPA Mailroom (E143-03)

109 T.W. Alexander Drive

Research Triangle Park, NC 27709

The questionnaire forms contained in this attachment are also available in electronic 

format (Excel® spreadsheet) at [insert web address]. You may e-mail a completed 

electronic file to teal.kim@epa.gov.

As discussed in the cover letter, if you believe that disclosure of any specific information 

that you submit would reveal confidential business information (CBI) or a trade secret, 

you should clearly identify such specific information. Please do not label an entire 

response "confidential" if only certain portions consist of CBI or trade secrets.

Enclosures 2, 3, and 5 contain more information about CBI. If you elect to provide this 

information via the electronic format and your responses CBI, please mail a compact 

disc containing the files to the address above. Do not e-mail a file that contains CBI.

The questionnaire forms are separated into the following sections.

A. Company and Facility Information

A-1. Parent Company Information

A-2. Facility Information

B. Spray Booth Information

C. Coatings Information

C-1. Coatings (English units)

C-2. Coatings (metric units)
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D. Chemical Milling and Metal Finishing Operations

E. Cleaning Operations

E-1. Blast Depainting/Cleaning Operations

E-2. Solvent Depainting Operations

E-3. Solvent Cleaning Operations

F. Composite Processing Operations

F-1. Composite Processing (English units)

F-2. Composite Processing (metric units)

G. Storage Tanks

H. Wastewater Treatment Operations

I. Air Pollution Control Device Startup and Shutdown

J. Control Devices

J-1. Electrostatic Precipitator

J-2. Scrubber

J-3. Mechanical Collector

J-4. Fabric Filter

J-5. Thermal Incinerator

J-6. Condenser

J-7. Carbon Adsorber

J-8. High Velocity Air Filter

J-9. Mist Eliminator

J-10. Ventilation System

J-11. Other

K. Air Pollution Control Device Cost

II. Instructions for Completing the Forms

All fields in the forms that apply to your operations must be completed, even if you enter 

“N/A.”

For the purposes of this information request, all hazardous air pollutants (HAP) 

concentrations and emissions are to be quantified. Do not report concentrations of 

emissions as “trace” or “minimal.” If a concentration is at or below the applicable 

method’s detection level, then provide information about the method (title and source), 

the calculated detection level in units of the applicable raw material or emissions 

concentration or mass rate, and the procedure for determining the detection level.
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Throughout these forms, many of the cells for your data input have drop-down lists for 

you to choose an appropriate response. If the specific choice that characterizes your 

situation is not included in the list, please select “other” and provide a description of 

your situation in the comments section.

Form A-1. Parent Company Information

Complete this form to identify the parent company of this facility. This information will 

allow EPA to distinguish small businesses in any economic analysis that may be 

required. Section I, Question 8 (size of parent company) is an important factor that EPA 

will use to identify small businesses. Please note that the total of all full-time and parttime employees should be reported. This information is required for the parent 

company, not this facility.

The Regulatory Flexibility Act (Public Law 96-354, September 19, 1980) (RFA) requires 

consideration of the impacts of regulations on small businesses. The major purpose of 

the RFA is to keep regulatory requirements from getting out of proportion to the scale of 

the businesses being regulated, without compromising the objectives of, in this case, 

the Clean Air Act (CAA). If a regulation is likely to have a significant economic impact 

on a substantial number of small businesses, EPA may, to the extent allowed by the 

CAA, give special consideration to those small businesses when analyzing regulatory 

alternatives and drafting a regulation. The Small Business Administration uses 

employment ranges to separate businesses into "large" and "small" categories. The 

actual cutoff between large and small facilities is dependent on the NAICS code of the 

establishments in question. 

Form A-2. Facility Information

Provide the information requested in this form for this specific facility.

Section I

In Question 1, provide the actual address (not the mailing address) of this facility. You 

must also provide latitude and longitude coordinates for the facility. Latitude and 

longitude must be reported in decimal degrees to six decimal places.

Question 2 asks you to indicate whether this facility manufactures or reworks aerospace 

components or parts. If you answer “No” to this question, please provide an explanation 

in the Comments section of what activities are carried out at this facility and why you 

should not be considered an aerospace manufacturing or rework facility. If you answer 

“No” then you do not have to complete any other parts of this information request other 

than Forms A-1 and A-2.
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Note that Question 2 is NOT asking whether the facility is subject to the aerospace 

NESHAP. If your facility performs any activities for the manufacture or rework 

aerospace components or parts, you should answer “Yes” to this question and complete 

the rest of the information request.

Question 3 - Enter all applicable NAICS that apply to the aerospace activities at this 

facility. NAICS codes may be found at http://www.census.gov/eos/www/naics/. Do not 

enter Standard Industrial Classification codes.

Question 5 – Answer “Yes” or “No” whether this facility manufactures or reworks 

aerospace components or parts for each of the listed market segments.

Question 6 – Enter the typical operating schedule for this facility for the reporting year 

(2008). You may provide estimates if you do not track the hours/day and days/year the 

facility is in operation.

Section II

Provide the name and contact information for the technical contact for your response to 

this information request. The technical contact should be able to answer inquiries from 

EPA concerning any information provided in your response.

Section III

Question 1 – Identify whether this facility is a major source of HAP emissions. Section 

112(a)(1) of the CAA defines a major source “as any stationary source or group of 

stationary sources located within a contiguous area and under common control that 

emits or has the potential to emit considering controls, in the aggregate,10 tons per year 

or more of any HAP or 25 tons per year or more of any combination of HAP.”

Question 2 – If you answer “No” to Question 1 of this section, specify whether the facility 

has a federally enforceable permit limitation to limit HAP emissions to less than the 

major source thresholds and, if so, identify any such limits.

Questions 3 and 4 – identify any non-aerospace products manufactured at this facility.

Question 5 – As part of this project, EPA may conduct air dispersion modeling of the 

emissions from facilities that respond to this information request. This modeling 

requires the input of the maximum hourly emissions from each emission point. 

However, we realize there are typically a large number of emission points at aerospace 

manufacturing and rework facilities, and determining the maximum hourly emissions 

from each and every emission point could be difficult and burdensome. Rather than 

asking for maximum hourly emissions for each emission point, we are instead 

requesting that you provide a single multiplier that we can use to scale up average 

hourly emissions to maximum hourly emissions. We will determine average hourly 

emissions from the data you provide in your response to this information request. 
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Therefore, you must provide a response to this question, even if the multiplier you 

provide is 1. You must also provide a description of how you determined the multiplier 

in the comments section of this form.

Form B-1. Spray Booth Information

This form has space for entering data for 10 spray booths. If you are providing data for 

more than 10 spray booths, please add additional columns as necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each spray 

booth.

Question 2 – Choose one of the booth types from the drop-down list.

Question 3 – Enter the latitude and longitude coordinates for the location of this booth. 

The coordinates must be in decimal degrees to at least 6 decimal places.

Question 4 – Enter the overall dimensions in feet of the building in which the booth is 

located (not the dimensions of the booth itself).

Question 5 – From the drop-down list, select “Cross Draft” if the airflow exits from the 

side of the booth, or “Down Draft” if the airflow exits from the bottom of the booth.

Question 6 – For the reporting year, enter the average number of hours per day this 

booth is in operation.

Section II

Question 1 – From the drop-down list, select the type of particulate filter system used for 

this booth.

Question 2-3 – Enter the particulate control efficiency for the particulate filters, and

indicate how that efficiency was determined.
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Section III

Question 1 – Enter the latitude and longitude coordinates for the location of the exhaust 

stack for this booth. The coordinates must be in decimal degrees to at least 6 decimal 

places.

Questions 2-5 – Enter the diameter and height of the exhaust stack in feet, temperature 

of the exhaust stream in degrees Fahrenheit, and the flow rate of the exhaust stream in 

actual cubic feet per minute.

Section IV

Complete this section if this spray booth is vented to a control device that reduces the 

amount of organic emissions.

Question 1 – Enter a unique identification number of your choosing for this control 

device. You must also complete a Form J for this control device and the identification 

number entered here must match the identification number entered in Form J.

Question 2 – Choose the appropriate control device type from the drop-down list.

Question 3-4 – Enter the capture efficiency for the organic emissions, and indicate how 

that efficiency was determined.

Form C-1 and C-2. Coatings

Use Form C-1 if you are reporting coating information in English units, or use Form C-2 

if you are reporting coating information in metric units. DO NOT complete both Form C1 and Form C-2.

This form has space for entering data for 20 coatings. If you are providing data for more 

than 20 coatings, please add additional columns as necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each coating.

Question 4 – Enter whether this coating is regulated under the aerospace NESHAP.

Question 5 – If you entered “Yes” for Question 4 of this section, select the coating type 

from the drop-down list. The coatings in the drop-down list are the only ones regulated 

under the aerospace NESHAP, so you must choose one of these coating types if you 

entered “Yes” for Question 4.
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Question 6 – If you entered “No” for question 4 of this section, then the coating is a 

specialty coating. Choose the appropriate specialty coating type from the drop-down 

list. If you select “other,” you must provide a coating type in the comments section.

Section II

Question 1 – Enter the total volume of this coating that your facility used for all coating 

operations (e.g., all spray booths) for the reporting year.

Question 2 – Enter the requested physical property data for this coating. This 

information must be provided for the coating in its as-applied condition.

Question 3 – Enter the name of each HAP (organic and inorganic) contained in this 

coating, the Chemical Abstracts Service (CAS) Number for the HAP, and the mass 

fraction of the HAP in the as-applied coating. If you do not know the CAS Number, it is 

often provided on the material safety data sheet for the coating. You may also find CAS 

Numbers at 

http://iaspub.epa.gov/sor_internet/registry/substreg/home/overview/home.do. There are 

also various other Internet sources that provide CAS Numbers.

To avoid double counting, do not report the same HAP emissions under different CAS 

numbers or as different compounds. For example, do not report both “total chromium” 

and “hexavalent chromium” for a single chromium compound contained in a coating. 

The correct reporting method, particularly for chromium compounds, glycol ethers, and 

polycyclic organic matter, is to report the specific compound (e.g., strontium chromate, 

ethylene glycol dibutyl ether) rather than the general class of HAP (e.g., chromium 

compounds, glycol ethers).

This form has space for entering data for five HAP components of the coating. If this 

coating has more than five HAP components, please add rows as necessary.

Section III

For each spray booth in which this coating was applied during the reporting year, enter 

the booth identification number (must match the identification number provided on Form 

B-1), and the percent of the total usage of that coating applied in this booth. The sum of 

the percent usage by booth should equal 100 percent for each coating. If a portion of 

the coating was not applied in a spray booth, then the sum of the percent usage by 

booth will be less than 100 percent. In this case, provide details in the comments 

section of the non-spray booth areas where the coating was used including the latitude 

and longitude coordinates, and volume of coating used in these areas. If your facility 

does not maintain adequate records of the volume of coatings used by spray booth, 

provide an engineering estimate and note this in the comments section.

This form has space for entering coating usage for 10 spray booths. If this coating was 

applied in more than 10 spray booths, please add rows as necessary.
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Form D-1. Chemical Milling and Metal Finishing Operations

Use this form to report HAP usage and emissions from chemical milling and metal 

finishing operations. Examples of metal finishing operations include electrolytic nickel 

plating, anodizing, passivation, and phosphating. Report the requested information for 

each process tank/vat that contains HAP in the chemical milling and metal finishing 

operations. 

This form has space for entering data for 10 tanks. If you are providing data for more 

than 10 tanks, please add additional columns as necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each tank.

Question 2 – Enter the latitude and longitude coordinates for the location of this tank. 

The coordinates must be in decimal degrees to at least 6 decimal places.

Question 3 – Enter the overall dimensions in feet of the building in which the tank is 

located (not the dimensions of the tank itself).

Question 4 – Enter a brief description of the purpose of this tank in the chemical milling 

or metal finishing process (e.g., cleaning prior to electroplating, electroplating of nickel).

Question 5 - For the reporting year, enter the average number of hours per day this tank 

is in operation.

Section II

Question 1 – Enter the name of each HAP (organic and inorganic) contained in this 

tank, the CAS Number for the HAP, and the annual emissions of the HAP from this 

tank. If you do not know the CAS Number, it is often provided on the material safety 

data sheet for the material in the tank. You may also find CAS Numbers at 

http://iaspub.epa.gov/sor_internet/registry/substreg/home/overview/home.do. There are 

also various other Internet sources that provide CAS Numbers.

To avoid double counting, do not report the same HAP emissions under different CAS 

Numbers or as different compounds. For example, do not report both “total chromium” 

and “hexavalent chromium” for a single chromium compound. The correct reporting 

method, particularly for chromium compounds, glycol ethers, and polycyclic organic 

matter, is to report the specific compound (e.g., strontium chromate, ethylene glycol 

dibutyl ether) rather than the general class of HAP (e.g., chromium compounds, glycol 

ethers).

This form has space for entering data for five HAPs. If the material in the tank has more 

than five HAP components, please add rows as necessary.
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Question 2 – If a control device is used to reduce the emissions of HAP from this tank, 

enter a unique identification number of your choosing for this control device. You must 

also complete a Form J for this control device and the identification number entered 

here must match the identification number entered in the Form J. 

Question 3 – Choose the appropriate control device type from the drop-down list.

Question 4-5 – Enter the capture efficiency for the organic emissions and indicate how 

that efficiency was determined.

Section III

Describe any work practices that you use to reduce the emissions of HAP from this 

tank.

Form E-1. Blast Depainting/Cleaning Operations

Use this form to report HAP emissions from depainting and cleaning operations that use 

blasting methods such as sand blasting, plastic bead blasting, carbon dioxide blasting, 

sodium bicarbonate blasting, etc.

This form has space for entering data for three blasting operations. If you are providing 

data for more than three blasting operations, please add additional columns as 

necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each blasting 

operation.

Question 2 – Enter the latitude and longitude coordinates for the location of this blasting 

operation. The coordinates must be in decimal degrees to at least 6 decimal places.

Question 3 – Identify where the blasting operation actually takes place. For example, 

the blasting operation could be located outside, in a partially enclosed booth or hanger, 

in a fully enclosed booth, etc.

Question 4 – Specifically identify the blasting material used. Be as specific as possible. 

For example, instead of reporting steel shot, report specifics about shape and size such 

as round steel balls, 40-50 mesh.

Question 5 – Enter the overall dimensions in feet of the building in which the blasting 

operation is located.
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Question 6 – Enter a brief description of the purpose of this blasting operation (e.g., 

rework operation to remove paint; cleaning to remove oil and grease from parts).

Question 7 - For the reporting year, enter the average number of hours per day this 

blasting operation is in operation.

Section II

Question 1 – Enter the name of each HAP (organic and inorganic) emitted by this 

blasting operation, the CAS Number for the HAP, and the annual emissions of the HAP 

from this blasting operation. If you do not know the CAS Number, it is often provided on 

material safety data sheets. You may also find CAS Numbers at 

http://iaspub.epa.gov/sor_internet/registry/substreg/home/overview/home.do. There are 

also various other Internet sources that provide CAS Numbers.

To avoid double counting, do not report the same HAP emissions under different CAS 

Numbers or as different compounds. For example, do not report both “total chromium” 

and “hexavalent chromium” for a single chromium compound. The correct reporting 

method, particularly for chromium compounds, glycol ethers, and polycyclic organic 

matter, is to report the specific compound (e.g., strontium chromate, ethylene glycol 

dibutyl ether) rather than the general class of HAP (e.g., chromium compounds, glycol 

ethers).

This form has space for entering data for five HAPs. If this blasting operation emits 

more than five HAPs, please add rows as necessary.

Question 2 – If a control device is used to reduce the emissions of HAP from this 

blasting operation, enter a unique identification number of your choosing for this control 

device. You must also complete a Form J for this control device and the identification 

number entered here must match the identification number entered in the Form J. 

Question 3 – Choose the appropriate control device type from the drop-down list.

Question 4-5 – Enter the capture efficiency for the HAP emissions, and indicate how 

that efficiency was determined.

Section III

Describe any work practices that you use to reduce the emissions of HAP from this 

blasting operation.
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Form E-2. Solvent Depainting Operations

Use this form to report HAP emissions from depainting operations that use solvent 

materials (liquid materials as opposed to blasting operations reported on Form E-1) to 

remove paint from aerospace components.

This form has space for entering data for three depainting operations. If you are 

providing data for more than three depainting operations, please add additional columns 

as necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each depainting 

operation.

Question 2 – Enter the latitude and longitude coordinates for the location of this 

depainting operation. The coordinates must be in decimal degrees to at least 6 decimal 

places.

Question 3 – Enter the overall dimensions in feet of the building in which the depainting 

operation is located.

Question 4 – Enter a brief description of the purpose of this depainting operation (e.g., 

remove paint from landing gear components, depainting of aircraft exterior).

Question 5 - For the reporting year, enter the average number of hours per day this 

depainting operation is in operation.

Section II

Question 1 – Enter the name of each HAP (organic and inorganic) emitted by this 

depainting operation, the CAS Number for the HAP, and the annual emissions of the

HAP from this depainting operation. If you do not know the CAS Number, it is often 

provided on material safety data sheets. You may also find CAS Numbers at 

http://iaspub.epa.gov/sor_internet/registry/substreg/home/overview/home.do. There are 

also various other Internet sources that provide CAS Numbers.

To avoid double counting, do not report the same HAP emissions under different CAS 

Numbers or as different compounds. For example, do not report both “total chromium” 

and “hexavalent chromium” for a single chromium compound. The correct reporting 

method, particularly for chromium compounds, glycol ethers, and polycyclic organic 

matter, is to report the specific compound (e.g., strontium chromate, ethylene glycol 

dibutyl ether) rather than the general class of HAP (e.g., chromium compounds, glycol 

ethers).
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This form has space for entering data for five HAPs. If this depainting operation emits 

more than five HAPs, please add rows as necessary.

Question 2 – If a control device is used to reduce the emissions of HAP from this 

depainting operation, enter a unique identification number of your choosing for this 

control device. You must also complete a Form J for this control device and the 

identification number entered here must match the identification number entered in the 

Form J. 

Question 3 – Choose the appropriate control device type from the drop-down list.

Question 4-5 – Enter the capture efficiency for the HAP emissions, and indicate how 

that efficiency was determined.

Section III

Describe any work practices that you use to reduce the emissions of HAP from this 

depainting operation.

Form E-3. Solvent Cleaning Operations

Use this form to report HAP emissions from solvent cleaning operations such as handwipe cleaning of aerospace components, cleaning of spray guns, and cleaning of spray 

booths.

Do not report cleaning operations subject to the Halogenated Solvent Cleaning 

NESHAP (40 CFR part 63, subpart T) on this form. Use Form E-4 for those 

operations.

This form has space for entering data for three cleaning operations. If you are providing 

data for more than three cleaning operations, please add additional columns as 

necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each cleaning 

operation.

Question 2 – Enter the latitude and longitude coordinates for the location of this 

cleaning operation. The coordinates must be in decimal degrees to at least 6 decimal

places.

Question 3 – Enter the overall dimensions in feet of the building in which the cleaning 

operation is located.
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Question 4 – Enter a brief description of the purpose of this cleaning operation (e.g., 

cleaning of aerospace components after machining; cleaning to remove protective oils).

Question 5 - For the reporting year, enter the average number of hours per day this 

cleaning operation is in operation.

Section II

Question 1 – Enter the name of each HAP (organic and inorganic) emitted by this 

cleaning operation, the CAS Number for the HAP, and the annual emissions of the HAP 

from this cleaning operation. If you do not know the CAS Number, it is often provided 

on material safety data sheets. You may also find CAS Numbers at 

http://iaspub.epa.gov/sor_internet/registry/substreg/home/overview/home.do. There are 

also various other Internet sources that provide CAS Numbers.

To avoid double counting, do not report the same HAP emissions under different CAS 

Numbers or as different compounds. For example, do not report both “total chromium” 

and “hexavalent chromium” for a single chromium compound. The correct reporting 

method, particularly for chromium compounds, glycol ethers, and polycyclic organic 

matter, is to report the specific compound (e.g., strontium chromate, ethylene glycol 

dibutyl ether) rather than the general class of HAP (e.g., chromium compounds, glycol 

ethers).

This form has space for entering data for five HAPs. If this cleaning operation emits 

more than five HAPs, please add rows as necessary.

Question 2 – If a control device is used to reduce the emissions of HAP from this 

cleaning operation, enter a unique identification number of your choosing for this control 

device. You must also complete a Form J for this control device and the identification 

number entered here must match the identification number entered in the Form J. 

Question 3 – Choose the appropriate control device type from the drop-down list.

Question 4-5 – Enter the capture efficiency for the HAP emissions, and indicate how 

that efficiency was determined.

Section III

Describe any work practices that you use to reduce the emissions of HAP from this 

cleaning operation.
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Form E-4. Halogenated Solvent Cleaning Operations

The EPA is requesting that you provide the information requested in Form E-4 for all 

cleaning operations at your facility that are subject to the Halogenated Solvent Cleaning 

NESHAP (40 CFR part 63, subpart T). Even though halogenated solvent cleaning 

operations are not subject to the aerospace NESHAP, the EPA is concerned that some 

aerospace facilities may have mistakenly reported emissions from these operations as 

emissions from operations subject to the aerospace NESHAP in past reporting to state 

or local agencies. The EPA is currently evaluating the residual risk from aerospace 

operations and halogenated solvent cleaning operations. In order to estimate the 

residual risk accurately from each of these categories, the EPA is attempting to first 

develop accurate emissions estimates. Your efforts to properly report halogenated 

solvent cleaning operations on Form E-4 and not on Form E-3 will play an important role 

in the EPA’s development of emissions estimates for these two categories.

In order to assist you in determining which cleaning operations should be reported on 

Form E-4, the following description is reproduced from § 63.460(a) identifying the 

sources subject to subpart T:

each individual batch vapor, in-line vapor, in-line cold, and batch cold solvent 

cleaning machine that uses any solvent containing methylene chloride (CAS No. 

75–09–2), perchloroethylene (CAS No. 127–18–4), trichloroethylene (CAS No. 

79–01–6), 1,1,1-trichloroethane (CAS No. 71–55–6), carbon tetrachloride (CAS 

No. 56–23–5) or chloroform (CAS No. 67–66–3), or any combination of these 

halogenated HAP solvents, in a total concentration greater than 5 percent by 

weight, as a cleaning and/or drying agent. The concentration of these solvents 

may be determined using EPA test method 18, material safety data sheets, or 

engineering calculations. Wipe cleaning activities, such as using a rag containing

halogenated solvent or a spray cleaner containing halogenated solvent are not

covered under the provisions of this subpart.

NOTE: Not all cleaning operations that use methylene chloride, perchloroethylene,

trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride, or chloroform are subject 

to subpart T. Before reporting a cleaning operation on this form, make sure that the 

cleaning operation uses one or more of these halogenated solvents AND that the 

solvent is used in a batch vapor, in-line vapor, in-line cold, or batch cold solvent 

cleaning machine as these machines are defined in subpart T.

This form has space for entering data for three cleaning operations. If you are providing 

data for more than three cleaning operations, please add additional columns as 

necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each cleaning 

operation.
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Question 2 – Enter the latitude and longitude coordinates for the location of this 

cleaning operation. The coordinates must be in decimal degrees to at least 6 decimal 

places.

Question 3 – Enter the overall dimensions in feet of the building in which the cleaning 

operation is located.

Question 4 – Enter a brief description of the purpose of this cleaning operation (e.g., 

cleaning of aerospace components after machining; cleaning to remove protective oils).

Question 5 - For the reporting year, enter the average number of hours per day this 

cleaning operation is in operation.

Section II

Question 1 – For each halogenated solvent listed, enter the annual emissions of the 

HAP from this cleaning operation.

This form includes all six of the halogenated solvents covered under subpart T. Enter a 

value of zero for halogenated solvents not used in this cleaning operation.

Question 2 – If a control device is used to reduce the emissions of HAP from this 

cleaning operation, enter a unique identification number of your choosing for this control 

device. You must also complete a Form J for this control device and the identification 

number entered here must match the identification number entered in the Form J. 

Question 3 – Choose the appropriate control device type from the drop-down list.

Question 4-5 – Enter the capture efficiency for the HAP emissions, and indicate how 

that efficiency was determined.

Section III

Describe any work practices that you use to reduce the emissions of HAP from this 

cleaning operation.

Forms F-1 and F-2. Composite Processing Operations

Use Form F-1 if you are reporting resin information in English units, or use Form F-2 if 

you are reporting resin information in metric units. DO NOT complete both Form F-1 

and Form F-2.
18

This form has space for entering data for 10 resins used in composite processing 

operations. If you are providing data for more than 10 resins, please add additional 

columns as necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each resin.

Question 2 – Enter the name of the manufacturer of this resin

Question 3 – Enter the manufacturer’s name or designation for this resin.

Section II

Question 1 – Enter the total volume of this resin that your facility used for all composite 

processing operations for the reporting year.

Question 2 – Enter the requested physical property data for this resin. This information 

must be provided for the resin in its as-applied condition.

Question 3 – Enter the name of each HAP (organic and inorganic) contained in this 

resin, the CAS Number for the HAP, and the mass fraction of the HAP in the as-applied 

resin. If you do not know the CAS Number, it is often provided on the material safety 

data sheet for the resin. You may also find CAS Numbers at 

http://iaspub.epa.gov/sor_internet/registry/substreg/home/overview/home.do. There are 

also various other Internet sources that provide CAS Numbers.

To avoid double counting, do not report the same HAP emissions under different CAS 

Numbers or as different compounds. For example, do not report both “total chromium” 

and “hexavalent chromium” for a single chromium compound. The correct reporting 

method, particularly for chromium compounds, glycol ethers, and polycyclic organic 

matter, is to report the specific compound (e.g., strontium chromate, ethylene glycol 

dibutyl ether) rather than the general class of HAP (e.g., chromium compounds, glycol 

ethers).

This form has space for entering data for five HAP components of the resin. If this resin 

has more than five HAP components, please add rows as necessary.

Section III

For each spray booth in which this resin was applied during the reporting year, enter the 

booth identification number (must match the identification number provided on Form B1), and the percent of the total usage of that resin applied in this booth. The sum of the 

percent usage by booth must equal 100 percent for each resin. If a portion of the resin 

was not applied in a spray booth, then the sum of the percent usage by booth will be 

less than 100 percent. In this case, provide details in the comments section of the non-
19

spray booth areas where the resin was used including the latitude and longitude 

coordinates, and volume of resin used in these areas. If your facility does not maintain 

adequate records of the volume of resins used by spray booth, provide an engineering 

estimate and note this in the comments section.

This form has space for entering resin usage for three spray booths. If this resin was 

applied in more than three spray booths, please add rows as necessary.

Section IV

Question 1 – If a control device is used to reduce the emissions of HAP from this 

composite processing operation, enter a unique identification number of your choosing 

for this control device. You must also complete a Form J for this control device and the 

identification number entered here must match the identification number entered in the 

Form J. 

Question 2 – Choose the appropriate control device type from the drop-down list.

Question 3-4 – Enter the capture efficiency for the HAP emissions, and indicate how 

that efficiency was determined.

Form G-1. Storage Tanks

Use this form to report HAP emissions from storage tanks used to store materials used 

in aerospace manufacturing and rework operations (e.g., solvents used for cleaning or 

for thinning coatings, depainting materials, waste treatment chemicals). Tanks and 

mixing vessels in centralized paint mixing and distribution rooms are considered storage 

tanks for the purposes of this form. 

Do not complete this form for the following: 1) storage tanks that did not contain HAP 

during the reporting year; 2) storage tanks that contain fuel for engines, boilers, or other 

combustion devices; 3) storage tanks that operate at greater than atmospheric 

pressure; 4) storage tanks that contain HAP only as impurities; 5) vessels used to 

transport materials to the facility (e.g., 55 gallon drums of solvent as received from the 

supplier); 6) tanks used to store or process wastewater (see Form H-1), and tanks that 

are regulated under a NESHAP other than the Aerospace Manufacturing and Rework 

NESHAP.

Section I

Question 1 – Enter a unique identification number of your choosing for each tank.

Question 2 – Enter the type of tanks (e.g., fixed roof, internal floating roof, external 

floating roof, etc.).
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Question 3 – Enter the latitude and longitude coordinates for the location of this tank. 

The coordinates must be in decimal degrees to at least 6 decimal places.

Question 4 – Enter the diameter and height of the tank.

Question 5 – Specifically identify the liquid stored in the tank. Do not enter a generic 

term such as “solvent.” Rather, enter the specific name of the stored liquid, such as 

“VM&P Naphtha.” You may enter the trade name of the stored liquid.

Question 6 – If this storage tank is located indoors, enter the overall dimensions in feet 

of the building in which the tank is located.

Section II

Question 1 – Enter the annual throughput of the tank in gallons. If specific records are 

not available, you may estimate this value using purchase records, production records, 

or engineering estimates.

Question 2 – Enter each HAP component stored in the tank, the mass fraction of each 

HAP in the stored liquid, annual emissions of the HAP (not of the entire liquid, unless 

the liquid consists only of this HAP), and the method used to estimate the emissions.

You may use EPA’s TANKS Emissions Estimation Software to calculate emissions from 

each tank. The TANKS software is available at 

http://www.epa.gov/ttn/chief/software/tanks/index.html. If you use TANKS to estimate 

emissions, you must provide all of the input values you used, as well as the model 

outputs.

This form has space for entering data for five HAP components of the stored liquid. If 

the stored liquid has more than five HAP components, please add rows as necessary.

Question 3 – If a control device is used to reduce the emissions of HAP from this tank, 

enter a unique identification number of your choosing for this control device. You must 

also complete a Form J for this control device and the identification number entered 

here must match the identification number entered in the Form J. 

Question 4 – Choose the appropriate control device type from the drop-down list.

Question 5-6 – Enter the capture efficiency for the HAP emissions, and indicate how 

that efficiency was determined.

Section III

Describe any work practices that you use to reduce the emissions of HAP from each 

storage tank.
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Form H-1. Wastewater Treatment Operations

Use this form to report wastewater treatment operations for treating wastewater 

generated by aerospace manufacturing and rework operations. You only need to report 

those wastewater treatment operations that either treat HAP-containing wastewater or 

that use HAP-containing materials to treat wastewater. Do not report those operations 

that treat only wastewater from non-aerospace operations.

This form has space for entering data for 10 wastewater treatment tanks or operations. 

If you are providing data for more than 10 tanks or operations, please add additional 

columns as necessary.

Section I

Question 1 – Enter a unique identification number of your choosing for each wastewater 

processing tank or operation.

Question 2 – Enter the latitude and longitude coordinates for the location of this tank or 

operation. The coordinates must be in decimal degrees to at least 6 decimal places.

Question 3 – Enter the overall dimensions in feet of the building in which the tank or 

operation is located.

Question 4 – Describe the purpose of this tank or operation (e.g., adjust pH of 

wastewater prior to discharge; removal of heavy metals by precipitation).

Question 5 – For the reporting year, enter the average number of hours per day this 

tank or operation is in operation.

Section II

Question 1 – For each HAP (organic and inorganic) in the wastewater or used in the 

treatment of the wastewater, enter the name of the HAP, the CAS Number of the HAP, 

the annual emissions in pounds/year, and whether the emissions are emitted through a 

stack or are fugitive emissions. 

If you do not know the CAS Number, it is often provided on material safety data sheets. 

You may also find CAS Numbers at 

http://iaspub.epa.gov/sor_internet/registry/substreg/home/overview/home.do. There are 

also various other Internet sources that provide CAS Numbers.

To avoid double counting, do not report the same HAP emissions under different CAS 

Numbers or as different compounds. For example, do not report both “total chromium” 

and “hexavalent chromium” for a single chromium compound. The correct reporting 

method, particularly for chromium compounds, glycol ethers, and polycyclic organic 

matter, is to report the specific compound (e.g., strontium chromate, ethylene glycol 
22

dibutyl ether) rather than the general class of HAP (e.g., chromium compounds, glycol 

ethers).

This form has space for entering data for five HAPs. If this tank or operation processes 

or uses more than five HAPs, please add rows as necessary.

Question 2 – If a control device is used to reduce the emissions of HAP from this tank or 

operation, enter a unique identification number of your choosing for this control device. 

You must also complete a Form J for this control device and the identification number 

entered here must match the identification number entered in the Form J. 

Question 3 – Choose the appropriate control device type from the drop-down list.

Question 4-5 – Enter the capture efficiency for the HAP emissions, and indicate how 

that efficiency was determined.

Section III

Describe any work practices that you use to reduce the emissions of HAP from each 

tank or operation.

Form I-1. Startups and Shutdowns

This form is used to report startup and shutdown events that resulted in excess HAP 

emissions AND that caused a NESHAP emission limit to be exceeded or caused a 

deviation of any requirement of the NESHAP. Each aerospace manufacturing and 

rework operation that emits HAP and each add-on control device used to reduce the 

emissions of HAP from aerospace manufacturing and rework operations is subject to 

reporting on this form.

For the purposes of this form, particulate filters and waterwash systems used to capture 

overspray in paint spray booths are considered to be add-on control devices.

The following examples are provided as guidance for which startup and shutdown 

events must be reported:

Example 1: A facility has several spray booths in which aerospace primers and 

topcoats are applied. The ventilation fans on each spray booth are shut off when 

the booth is not being used and turned on again when parts are ready to be 

coated. No coating is applied when the fans are not operating. Even though 

each time the fans are turned on and off is a startup or shutdown event, Form I-1 

does not need to be completed. Because no coatings are applied when the fan 

is not operating, emission limits would not be exceeded during the startup and 

shutdown events.
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Example 2: A facility uses a thermal oxidizer to meet the 81 percent organic 

HAP emission reduction requirement of 40 CFR 63.745(d) for aerospace primer 

and topcoat operations. The thermal oxidizer has been shut down for 

maintenance. Following the repairs, the thermal oxidizer is restarted from a cold 

start, and the facility immediately starts to apply primers and topcoats. The 

emissions while the thermal oxidizer was not at the operating temperature

resulted in an exceedence of the 81 percent emission reduction requirement. 

This event must be reported on Form I-1.

Example 3: A facility applies primers containing hexavalent chromium to 

aerospace parts in a spray booth. One operator turns off the ventilation fan for 

the spray booth, but another operator is still in the booth applying the primer. 

This shutdown event must be reported on Form I-1.

Provide the requested information if it is readily available. You are not required to 

perform additional testing or data gathering for these events in order to complete this 

form.

Form J-1 to J-11. Air Pollution Control Devices

Complete the appropriate form for each air pollution control device that you use to 

reduce HAP emissions from aerospace manufacturing and rework operations. You are 

not required to complete these forms for particulate filters and waterwash systems used 

to capture overspray in paint spray booths. Spray booth particulate filter information is 

reported on Form B-1, Section II, Particulate Filters.

Provide the requested information if it is readily available. You are not required to 

perform any additional testing or data gathering in order to complete these forms.

Form K-1. Air Pollution Control Device Costs

Complete this form as completely as possible using readily available information for 

each air pollution control device for which you completed a Form J.