Aerospace NESHAP: A collaborative approach to implementation
The purpose of the Aerospace National Emission Standard for Hazardous Air Pollutants (NESHAP) is to minimize emissions of hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) from major sources who manufacture or rework aerospace vehicles or components. The NESHAP requires emission reductions through implementation of work practices, application of slower evaporating solvents and coatings with low-HAP and low-VOC content, usage of high transfer efficiency spray equipment, and installation of high capture efficiency exhaust filtration for coatings containing metals. The rule also requires extensive monitoring, recordkeeping, and self-reporting to track compliance. For existing sources the rule becomes effective September 1,1998. Over the past year the Puget Sound Air Pollution Control Agency (PSAPCA) has worked with the Boeing Company and EPA to identify the requirements of the aerospace NESHAP, understand what it means in everyday practice, and develop an enforcement strategy for ensuring compliance. A workshop was held with aerospace manufacturers, local regulators, and EPA to discuss implementation of the rule. Issues regarding compliance efforts and determinations were openly discussed. Subsequent to the workshop, PSAPCA and the Boeing Company participated in several mock inspections to review facility compliance efforts before the rule became effective. Collaborative efforts also ensued to develop operating permit monitoring requirements. Aerospace NESHAP requirements were incorporated into these permits. There are still questions regarding compliance determinations that must be further discussed and resolved. But by using the collaborative approach and having regulators and sources working together, there is a process to work out answers and approaches that will lead to an increased mutual understanding of the aerospace NESHAP and eventual compliance with the standard.
- OSTI ID:
- 679315
- Report Number(s):
- CONF-980632-; TRN: IM9940%%135
- Resource Relation:
- Conference: 91. annual meeting and exhibition of the Air and Waste Management Association, San Diego, CA (United States), 14-18 Jun 1998; Other Information: PBD: 1998; Related Information: Is Part Of Proceedings of the 91. annual meeting and exhibition. Bridging international boundaries: Clean production for environmental stewardship; PB: [5000] p.
- Country of Publication:
- United States
- Language:
- English
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