New environmental regulation for the aerospace industry: The aerospace NESHAP

40 CFR Part 63, Subpart GG, the National Emission Standard for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities, commonly referred to as the Aerospace NESHAP, was issued on September 1, 1995 and requires compliance by September 1, 1998. The regulation affects any facility that manufactures or reworks commercial, civil, or military aircraft vehicles or components and is a major source of Hazardous Air Pollutants (HAPs). The regulation targets reducing Volatile Organic Compound (VOC) and Hazardous Air Pollutant (HAP) emissions to the atmosphere. Processes affected by the new regulation include aircraft painting, paint stripping, chemical milling masking, solvent cleaning, and spray gun cleaning. Regulatory requirements affecting these processes are summarized, and different compliance options compared in terms of cost-effectiveness and industry acceptance. Strategies to reduce compliance costs and minimize recordkeeping burdens are also presented.