National Emission Standards for Hazardous Air Pollutants (NESHAP), Aerospace Manufacturing and Rework Facilities Rule: Operational and economic impacts at U.S. Air Force Air Combat Command (ACC) installations

The recently promulgated Aerospace Manufacturing and Rework Facilities National Emission Standards for Hazardous Air Pollutants (NESHAP), found in 40 CFR 63 Subpart GG, is expected to significantly impact operations at US Air Force (USAF) bases. At the request of the USAF`s Air Combat Command (ACC), Armstrong Laboratory`s Air Quality Branch performed a compliance assessment for all ACC bases in the summer of 1996 to determine more clearly the rule`s impact on operations at these bases. This assessment included first determining the base`s current major source standing for hazardous air pollutants (HAPs), as defined by Title III of the Clean Air Act. In addition, this assessment ascertained the volatile organic compound (VOC) and HAP content levels for both the primers and topcoats currently being used in base aircraft maintenance operations. Finally, the survey determined the type of solvents used in cleaning aerospace parts, as well as the types of control equipment currently in place at each base. The results of the compliance assessment suggest a prohibitive impact on operations at ACC bases, including total potential direct monetary costs of up to $25M. Additional personnel requirements will be incurred as a result of increased monitoring, recordkeeping, and reporting. Substitution of low VOC/HAPmore » primers and topcoats and/or redefining maintenance operations to meet touch-up and repair definitions are discussed as possible alternatives, but the results indicate the best solution is to reassess each ACC base`s status as a major source for HAPs, with the intent of having each base defined as a minor source for HAPs. In this manner, the ACC bases can avoid the Aerospace NESHAP compliance requirements altogether, at substantial savings to the US Air Force.« less