Solvent Management Plan
for
Eirtech Aviation Limited
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CONTENTS
1
2
2.1
3
3.1
3.2
3.3
4
4.1
4.2
4.3
5
5.1
5.2
6
6.1
SUMMARY
INTRODUCTION
Summary of achievements to date
COMPLIANCE WITH THE EU SOLVENTS DIRECTIVE
Requirements for compliance
Recycle and Re-use Opportunities
Demonstration of Compliance for Eirtech until 20 10
QUANTIFYING REDUCTION IN VOC
Evaluating VOC Reduction
Methodology Used and Approximations Made
Significant Sources of VOC Use and Emissions
VOC REDUCTIONS ACHIEVED
The Impact of High Transfer Efficiency Spray Guns
Future Developments in Paint Manufacture
FUTURE TARGETS AND OPTIONS FOR VOC REDUCTIONS
Calculation of Options for Achieving VOC Reductions by 20 10
Page
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7
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15
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16
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LIST OF TABLES
Table 1
Table 2
Table 3
Table 4
Table 5
VOC EmittedRaint Solids used at Eirtech Aviation Limited
Verification of Compliance, as per Annex I11 of the Solvents Directive
Comparison of Current Situation and Best Scenario for 20 10
Options for Achieving VOC Reductions by 2010
Best and Worst Possible Outcomes of Action Based on the Three Highest Ranking
Options
LIST OF FIGURES
Figure 1
Figure 2
Sources of VOC Use
Aircraft Repainting Process and VOC Use based on materials used in 2009
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1. SUMMARY
Eirtech 2000 - 2001
This document reports on reductions in the use and emission of Volatile Organic Compounds
(VOCs) achieved at Eirtech Aviation Limited over recent years in Shannon. Eirtech Aviation Ltd.
Dublin is new open operations site in Dublin Airport in Hangar 3. Operations carry on in that site is
the same like in Shannon site. VOC level it will be similar. Future VOC reduction options are also
evaluated. This document can be viewed as an Emission Reduction Plan/Solvent Management Plan,
as required under Condition 6.12.2 of IPPC licence 736 for Eirtech Aviation Ltd. in Shannon, the
EU Solvents Emissions Directive EU 1999/13/EC and S.I. No. 543 of 2002 (Emissions of Volatile
Organic Compounds from Organic Solvent Regulations 2002).
4.93
Sources of VOC use were identified based on the study of the materials consumed in aircraft
repainting jobs. It was found an average of 1,804kg of VOC was used per aircraft for the period
2006-2009, with an average of 714Kg of VOC being used in 2009. The actual emission is lower
because much VOC is recycled or treated offsite. An accurate value for VOC emission is not
determined however due to uncertainty surrounding quantities of VOC recycled or treated per
project (see Section 3.2 for further details on solvent waste).
Eirtech 2002
Eirtech 2005
Eirtech 2006
The EU solvent emissions directive sets target ratios Solvent emitted /Solids used in the aerospace
coatings sector. (See Annex IIB). Values for this ratio at Eirtech are compared with the EU targets
in table 1.1. @JJ No values for VOC contained were available so a pessimistic estimate of 200 Kg
of VOC contained per project was used - this figure is based on amount of solvent waste produced.)
2.77
2.98
2.28
Tablel. VOC Emitted/ Paint Solids Used at Eirtech:
Eirtech 2007
Eirtech 2008
Eirtech 2009
VOC Emitted / Paint Solids Used
3.30
3.40
1.44
EU 2005 Target
EU 2007 Target
< 3.5
< 2.33
These figures show that Eirtech has implemented significant VOC reductions and is in compliance
with Best Available Technique (BAT) in relation to VOC management. Reductions in VOC use that
have occurred were achieved through the substitution of high VOC Paint. The reason for the
significant drop in VOC emitted/paint solids for 2009 is due to a change in calculation for solids
content - other years should also have lower VOC emitted/paint solids than previously estimated.
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2.
2.1
2.2
Future options for reducing VOC emitted/ Solids used in 2010 are evaluated (see section 6 for
details). Three areas are identified as representing the best opportunities for achieving further
reductions.
1. Improving General Work Practices in the Painting Department, including Minimization of, and
Improved Management of, Waste Solvent and Paint.
The development of new low VOC products and technologies that satisfy the Aviation
Authority and customer requirements.
Substitution with lower VOC paint materials.
2.
3.
Eirtech was unable to meet the 2007 targets but is still in compliance with EU legislation because it
is using Best Available Technique (BAT) with regards to VOC management. Eirtech, Shannon
Aerospace and FLS Aerospace have worked in association with Akzo Nobel to produce a BAT
guidance note for the Irish aerospace industry.
INTRODUCTION
Introduction
This solvent management plan is prepared in accordance with Condition 6.12.2 of IPPC licence no.
PO497-02. The format of this Solvent Management Plan follows the format of the solvent
management plans submitted to the EPA on 5/12/2003 as part of a joint Irish Aerospace submission
in relation to VOC limits etc.
Summary of achievements to date
In addition to the advances made to date, this coatings sector is undergoing rapid technological
developments. The entire technology of surface preparation and finishes has undergone and will
continue to undergo marked changes.
The result has been the displacement of higher hazard materials with lower hazard substitutes. The
following details some of the major changes to date.
2.2.1 High Solids Paints
Currently Eirtech Aviation Limited recommends the use of high solids paints as its default paint
types, unless the customer specifies the use of a certain paint type.
2.2.2 Strippers
Eirtech operate an in-house restriction on chemical stripper, Turco 5873 (containing methylene
chloride), and only use this stripper if requested by the customer. This stripper has only been used
once in the company’s operating history - only used due to customer request as two previous
applications of normal stripper failed to work.
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This restriction on the use of methylene chloride strippers means that VOC emissions are reduced.
The main chemical strippers in use Turco 6776 LO and E-1004J are known as “environmentally
advantaged” products as they are less harmful to the environment than previous stripper types.
In 2009, paint stripper E-1004J was the sole paint stripper type used.
3. COMPLIANCE WITH THE EU SOLVENTS DIRECTIVE
3.1 Requirements for Compliance
The EU Solvent directive (1999/13/EC) responds to concerns surrounding the emission of VOC to
the environment particularly the production of ground level photochemical pollution which can be
harmful to public health and to vegetation when concentrations are high enough. (This might indeed
be a relevant concern in the vicinity of Dublin airport considering the photochemical pollution from
aircraft taking off and landing, and the operations others).
This directive gives three possibilities for an operator to achieve compliance:
3.1.1 Compliance with Emission Limit Values
The directive states that compliance with emission limit values is not the primary method of
achieving VOC reduction with regards to the painting of aircraft, See Annex IIA, and article
5(3 As will be seen from the initial process description the majority of the solvent lost in stripping and
painting is total loss, hence the exemption from containment. Therefore it is not clear on what
percentage the reference fugitive emission should be based. Referring to Annex IIA of the Solvents
Directive the reference to 20% fugitive emissions is equally covered by the exemption under
footnote 4 and is not applicable in a like manner to the emission limit values. Therefore the basis of
our calculations is that all solvent used in the stripping and painting process is 100% loss.
Notwithstanding that fact, the industry does employ as part of a BAT approach the following
general housekeeping measures to reduce other fugitivehncidental emissions:
0 Close containers after use
0
0
Use of lidded bins for wipe rags
Only mix correct amount of paint and mix immediately prior to use
Enclosed gun cleaning where ever practical
Barrel stripper waste as soon as reasonably practical after stripping has taken place.
3.1.2 Compliance with Reduction Scheme Targets
The directive sets target ratios of solvents emitted/ solids used in a process. For aerospace coatings
this target was set as 2.33 for 2007, with a target of 3.5 to be achieved by 2005. (These targets are
given in the Reduction Scheme of Annex ID. The table at the end of the annex gives the value of
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2.33 while the other table gives the 2005 value of Target emission * 1.5.) The directive requires that
a Solvent Management Plan be drawn up by the operator in order to verify compliance, identify
future reduction options, and in order to communicate information on VOC use to the national
authorities and to the public.
Previously, when estimating VOC content and solids content of paints - if no information was given
on solids content then solids content was taken as being zero. However, after researching further
most VOC calculations assume that after VOC content is excluded, the remainder can be assumed
to be the solids content (unless further information is supplied). Hence the calculations for 2009
have been updated to reflect this change and this is the reason for the decrease in the VOC
emittedpaint solids used. This means that the other years will have lower VOC emittedpaint solids
used values than previously estimated.
3.1.3 Compliance with Best Available Technique
In the case where it is not technically or economically feasible to achieve compliance with the
reduction scheme targets, the directive then states that the operator must demonstrate to the
satisfaction of the national authorities that ‘Best Available Technique’ with regard to VOC use has
been implemented. However no standard has yet been referenced for BAT in the aerospace sector.
Shannon Aerospace, Eirtech and FLS Aerospace have worked together with Akzo Nobel to produce
an Irish BAT Note. This BAT Note describes best available techniques in relation to cleaning of
tools and equipment, paint types etc. (2).
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In Germany, the French-German Institute of Environmental Research worked on the German
contribution to a BREF about paint and adhesive application. In their report the following are the
recommended Best Available Techniques for painting aircraft (4):
0 Paint removal via a mixture of benzyl alcohol and formic acid
0 Application of chrome-free ground coats
0 Application of high-solids topcoats without an additional clear coat layer
Electrostatic spray application for paint materials.
3.2 Recycle and Re-use Opportunities
There are limited opportunities for recycling as the industry is highly regulated and all chemicals
used in an aircraft environment are specified by the airframe manufacturers. Due to potential
contamination and damage to aircraft structures and systems solvent cannot be recycled for use on
the aircraft.
However, there are the following opportunities for re-use:
Gun cleaning - a small percentage can be re-used for gun cleaning purposes
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0 The vast majority of waste solvent is currently sent off-site to licensed waste contractors for re-
use.
E/Solids for EIRTECH
3.3
Yearly Situation Predicted Scenario for
2003” 2005” 2006 2007 2008 2009
2010
2.77 2.98 2.58 3.3 3.4 1.44 1.44
All solvent waste produced in EIRTECH is sent off-site to a licensed waste contractor for recycling
and recovery. The volume of solvent waste produced each year varies depending on numbers of
aircraft processed, size and type of aircraft etc.
E/Solids Target for the Aerospace Coatings sector (As per Annex Iib)
In 2009: 22.8 tonnes of solvent waste was contained and sent off-site for recycling, giving a figure
of 3041t recycled per aircraft. Estimating the waste to have an average VOC content of 235g/1, gives
a figure of 71.5kg VOC recycled per aircraft. An accurate value for VOC emission cannot be
determined however due to uncertainty surrounding quantities of VOC recycled or treated per
project. Also, the VOC value for each project will depend on types of paint used etc. In order to
account for this variability a pessimistic value of 200 kg VOC contained is used, which would be
the worst-case scenario in relation to VOC contained.
3.5 3.5 2.33 2.33
(2005 (2005 (2007 (2007 N/A N/A N/A Target) Target) target) target)
Demonstration of Compliance for EIRTECH until 2010
Table 2 displays the results of the repainting projects studied. The categories ‘Ol’, ‘11’ etc. are
those given in Annex I11 of the Directive. A worst possible scenario where only 200Kg of VOC is
contained (recycled or incinerated offsite) per project and the rest is emitted as ‘waste gas
emissions’ has been assumed. This means that the value for VOC emitted Solids used is in all
likelihood lower than what is shown below.
A best possible scenario for 2009 is also given. This is based on 100% implementation of the three
highest-ranking VOC reduction options, (see section 6 Future Targets and Options for VOC
Reduction and Table 5).
These figures demonstrate current compliance with the solvents directive.
Table 2 Verification of Compliance, as per Annex I11 of the Directive
Table3. Comparison of Current Situation (based on 2009 figures) and Best Possible Scenario for
2010 (assuming 100% implementation of the 3 highest-ranking VOC reduction options described in
Section 7)
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Values as defined in Annex I11
Current Situation
I Kg I % of Total I Kg I % of Total I
Best Scenario for 2010
E = 0 1 + 0 2 + 0 3 + 0 4 + 0 9
Solids
I1 (total use)
I2 (internally reusedrecycled)
Ol(waste gas emissions)
0 2 (lost to water)
0 3 (product residue)
0 4 (fkgitive emissions)
0 5 (lost to chemical reaction)
0 6 (waste)
product) 0 7 (sold as commercial
0 8 (reuse in other process)
0 9 (released in other ways)
4. QUANTIFYING REDUCTION IN VOC
514 72 514 72
497 497 -
714 714 -
Negligible opportunities (see section 3.1) section 3.1)
Negligible opportunities (see
514 72 514 72
Assumed to be negligible
0 0 0 0
< 1 Yo
0 0 0 0
Assumed to be negligible
< 1 Yo
200 28 200 28
0 0 0 0
0 0 0 0
0 0 0 0
Based on a review of paint jobs carried out to date, it is clear that there are a large number of
variables, which can affect the indicators. For example, when aircraft stripping is required it can
significantly increase the VOC usage purely through the requirement for the stripping product. In
addition, it has been found that a number of aircraft are extremely difficult to strip due to factors
such as the age of the paint job, type of paint applied, climatic conditions which can affect the VOC
usage even further. Similarly an aircraft requiring a simple paint scheme (basic white) will require
significantly less paint than a complex paint scheme.
1 .dJ
4.1 Evaluating VOC Reduction
When evaluating reduction in VOC there are many possible choices of indicator. The indicator used
is this report is Mass of VOC ernittedMass of Solids used. This indicator is of particular importance
because it is the indicator used in the EU Solvents directive for the setting of VOC reduction targets
(see Annex lib). It takes application method and site specific factors into account. A significant
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proportion of VOC used for painting is contained, and then sent off-site for recycling and treatment.
The difficulty in trying to take this important consideration into account is actually in getting
reliable values for the amount of SolventIPaint VOC contained per project. A pessimistic estimate
of 200kg of VOC contained per project is used, based on average estimate of yearly production of
PaintISolvent Waste.
4.2 Methodology Used and Approximations Made
The main method used to investigate the use of VOC was the analysis of “Material Consumption
Reports” for aircraft-paint projects.
4.3 Significant Sources of VOC Use and Emission
The repainting process accounts for approximately 100% of VOC use in Eirtech Aviation Ltd., and
there are three significant sources of VOC use/emission involved in this process:
1. Paints, thinners, and hardeners account for (24 +/-5)% of process VOC used.
With regards to emission, some of this VOC will be emitted regardless of best practice. The VOC
contained in waste paint can be roughly estimated as (20 +/- lo)% of the total paint VOC. This
VOC need not be emitted if managed properly.
Solvents, used for gun cleaning and for the solvent wipe, account for (61 +/-5)% of process VOC
used.
With regards to emission, all of the solvent wipe VOC will be automatically emitted. The gun
cleaning solvent can be mostly conserved as waste, and need not be emitted at all if managed
properly. It was not possible however to differentiate between solvents used for gun cleaning and
those used for the solvent wipe step in the material consumption reports.
Paint Strippers account for (1 6 +/- 5)Yo of VOC process VOC used.
The proportion of VOC that the paint strippers contribute is highly dependent on whether the
aircraft sanded or chemically stripped. Also, the age of the aircraft and the number of coats applied
is also a factor in how much paint stripper is needed. Due to the increased prevalence of charter
aircraft and low-budget airlines, some aircraft now are painted with a number of coats before an
aircraft check is due. This makes the paint much harder to remove and so greater quantities of
stripper are required.
2.
3.
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Figurel. Sources of VOC Use in 2009
I Sources of VOC Use in 2009
7%
0% n CI Primer
Topcoats
Paint Strip
Solent Wipe/ Gun Cleaning
The above situation is presented as a flow chart in Figure 2
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Figure 2 Aircraft Repainting Process and VOC use based on materials used in 2009
Input to Repainting Process
Aircraft (last Painted 5-10 Years
7 14Kg of VOC
Paint Strip 17%
- or
I Sanded I
o/ \ /
I Solvent I
Gun Cleaning
56%
Painting 27%
I
Output of Repainting Process
Aircraft in Service for another 5-10
Years
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5 VOC Reductions Achieved
The Impact of High Transfer Efficiency Spray Guns
Eirtech Aviation Ltd. has favoured the use of high transfer efficiency electrostatic spraying systems
since the commencement of operations. This minimizes overspray (wastage of paint) and therefore
reduces VOC emissions. Obviously no VOC reduction can be observed seeing as how Eirtech
Aviation Ltd. has never used less efficient technology, but the US EPA CTG document reports that
reductions of between 10 and 50% in paint VOC have been achieved by various facilities when they
switched from less efficient equipment to this technology (3).
According to a UK Guidance Note reductions of up to 38% in paint consumption are possible with
high efficiency spray guns compared to conventional spray guns (8).
Spray gun manufacturers Graco, state that air spray can go from 30% to 65% transfer efficiency
with the use of electrostatics (13).
Some of the benefits of using electrostatic spray guns are:
.e,-
0 Lower material consumption
Lower emissions and smaller amounts of paint sludge
0 Smaller air consumption - therefore lower energy demand(4).
Lufthansa Technik (Hamburg) work with electrostatic spray guns so as to eliminate spraying losses
when painting aircraft. This method has reduced spraying losses from their former 30 to 35% to
their present level of only 10% (5).
Deutsche Aerospace Airbus (DASA) GmbH, one of Europe’s largest airbus manufacturer’s found
that by switching to electrostatic spray guns, over-spray has been reduced 30% (14).
“Compared to conventional spray painting, electrostatic spraying greatly reduces the amount of
paint lost to rebound and over-spray. The electrostatically charged paint particles are attracted by
the grounded work-piece, resulting in transfer efficiencies of 60 to 90%’’ (6).
/
Future Developments in Paint Manufacture
The aerospace industry is a specification-driven business with a detailed specification for every
product used on an aircraft. Initiatives to eliminate harmful materials (e.g. lead and cadmium
pigments, chromates and solvent emissions) from formulations over the years has forced high levels
of research before development can even take place.
Aerospace coatings manufacturers are under constant pressure to improve the quality and durability
of the products used to protect and decorate aircraft. They are trying to balance all the influencing
factors including the environment and manufacturers requirements such as weight reduction and
accelerating application and dry times.
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B
The primary development topics at present are in water-based technologies for structural primers
and lower VOC products in several special use coating applications (1 5).
6 FUTURE TARGETS, AND OPTIONS, FOR VOC REDUCTION
EIRTECH is already meeting EU targets for 2005, but is above the 2007 target of 2.33 Kg
Solvent/Kg Solids used. EIRTECH now has to maintain compliance with BAT requirements.
Calculation of Options for Achieving VOC Reductions by 2009
TABLE 4 CONSIDERS SOME OPTIONS FOR REDUCING VOC USE AND
EMISSION AT EIRTECH.
Quantity Weighting
Ability Weighting
Option Rating
Options are weighted according to how much VOC is involved.
For the purposes of this analysis: 40kg = 1.
Based upon an estimation of EIRTECH ability to achieve
improvements by 2008. No reduction possible = 0. 100%
elimination possible = 6. In some cases the ability weighting is
given as a range of values in order to express uncertainty about
Eirtech ability to achieve a VOC reduction. The possibility of new
industry developments such as the development of new products
before 2009 is not considered when expressing these values. (In
reality there may be developments and this would bring an added
VOC reduction over that considered here).
The ability weighting is multiplied by the quantity weighting to
given an option rating for each factor. The higher the option rating,
the more attractive that option is for action by Eirtech.
The result of the option evaluation is that two main options stand out as giving the best opportunity
for achieving a reduction in VOC, (mainly in emission) and these are:
1. Improving General Work Practices in the Painting Department including Minimization of,
and Improved Management of Paint and Solvent Waste.
Development of new low VOC products and technologies that satisfy the Aviation Authority
and Customer Requirements.
2.
A third Option also presents the possibility of a moderate reduction and this is:
3. Substitution with lower VOC paint materials.
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Table 5 then shows the impact of implementing these options on the VOC emittedsolids used
ration. The best possible scenario based on entirely successful implementation of improvements, is
that a reduction of 40 Kg in VOC used and a total of 300 Kg of VOC contained per project would
be achieved giving a value of 3.19 for Solvents emittedsolids used. The worst imaginable scenario
is that no improvements are made and that only 200Kg of VOC is contained per project. This gives
a VOC emittedsolids used value of 3.4, same as the current value. In any given year, the VOC
emittedSo1id.s used value is dependent on numbers and type of aircraft, whether a chemical strip or
sanding was carried out etc.
Table 4Options for achieving VOC Reductions by 2009
I
Reducing the incidence of Chemical Stripping
This factor has not been addressed in this report. However it would appear that Eirtech has little or no influence in reducing the occurrence of the need for chemical stripping, at least until approved alternative technologies become available to the industry in general. Water blasting, which was favoured because of environmental reasons, is no longer applied as it caused excessive mechanical stress. The use of plastic media blasting would only be feasible for a new building. The draft German BREF note advocates as BAT, paint removal via a mixture of benzyl alcohol and formic acid - this is the type of stripper currently in use in Eirtech. Also, not all aircraft are chemically stripped, some are sanded. Substitution of Lower VOC Stripper
Very little room for improvement exists here as the use of the formic acidhenzyl alcohol based stripper used, is regarded as BAT in other countries. A new stripper product SPC 909 (with zero VOC’s) was used on a few occasions in 2006. However, this paint stripper does not work on all aircraft paint types at present. However, new strippers are being developed at present. With fiu-ther developments and research lower VOC strippers may be used in the future, but is unlikely that any significant changes can be made in 2009-2010. Improving the Management of Stripper Waste
If stripper waste could be sealed into airtight containers as soon as possible after stripping, a slight reduction on the stripper related VOC emitted could be achieved. In reality, however, this can’t really occur as the emphasis is on getting the aircraft stripped properly and prepared for painting.
Quantity Weighting 40Kg =I
3
Ability Weighting
No Reduction Possible =
0
100% Elimination
0
0
0 - 0
Option Rating
= Quantity Weighting * Ability
Weighting
Low 0
0
0
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Substitution with Lower VOC Paint Materials
This factor has already been addressed by Eirtech, see section 7.2. Future improvement will depend on the continued development of lower VOC paint materials by suppliers. There have been problems with certain paint types but in future years, and with more research and development by paint manufacturers, these problems should be resolved. The primary paint manufacturers PPG Aerospace and Akzo Nobel have indicated that no further significant improvements will be made prior to 2007. Also, Eirtech is also restricted by customer requirements in relation to pamt tvDe used. Improving General Work Practices in the Painting Department, including Minimization of, and Improved Management of Paint and Solvent Waste
Small improvements in work practices could lead to significant VOC reductions. Therefore it is appropriate that improvements be identified and implemented with the direct input of the painting staff. This should include training and raising of awareness of the VOC issue in the painting department. This would form a part of the General BAT requirements. Adherence to already existing procedures (such as keeping solvent containers capped at all possible times) would be one immediately apparent issue.
Approximately 200 Kg of waste paint and solvent VOC is produced per project and some room for improvement in the management of this waste exists. For example, the large waste solvent drums are usually not kept airtight until they are full. If the solvent drums are open and evaporating until full, then a large quantity of VOC, perhaps as much as 100 Kg, is being needlessly evaporated per project. A system should be agreed with the painters so that the drums are actually kept sealed in practice at all possible times. The production of paint waste and the use of gun cleaner might be reduced by examining work practices while keeping VOC reduction in mind. In general the addressing of these factors would form a art of the general BAT reauirem ents. Substitution of Lower VOC Gun Cleaning/ Solvent Wipe Products
Substitution has already given significant reductions with paints and strippers but not with gun cleaners and solvent wipes. This is due to the fact that aircraft surfaces need to be perfectly clean and free from dirt or grease before painting can begin. If not, it can result in a poor quality paint job, which may require sanding, stripping and repainting to fix it - resulting in greater VOC usage
Increasing Average Paint lifetime
In the context of maintenance, the paint coats are removed every 5-10 years. If an airline changeover takes place, then paint removal is undertaken sooner, this is most common for leasing companies. The paint removal (and new paint application) is done for optical reasons and for examining the structure for wear and corrosion. Eirtech have no control over paint manufacture and do not approve paints.
The development of new low VOC products and technologies that satisfy Aviation Authority and Customer requirements
Eirtech is a small non-research based organisation when viewed in the context of the global Aerospace manufacturing and maintenance industry, and the development of Low VOC products is carried out by the relevant manufacturers in any case. Therefore Eirtech most effective contribution is to identify and purchase those products with the Lowest
5
14
10
5
18
0 - 0.2
0-3
0
0
0-0.2
Low 0 - 1
Low - High 0-42
0
Low 0
Low- Medium 0 - 3.6
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VOC content available, thereby helping to increase market demand for the development of lower VOC products. However, it is unlikely that any significant new products will have been developed by 201 2. Lufthansa Hamburg is currently evaluating low VOC products and technologies e.g. pre-impregnated solvent wipes. New strippers also being developed which may reduce VOC emissions in future years. The changeover to new products is a slow process, which involves getting manufacturers approval e.g. Boeing and Airbus.
Reduction in Solvent Cleaning VOC
The current practice of solvent cleaning involves pouring solvent from a 251t container onto wipes. If closed lidded containers could be used for holding solvent then a reduction in solvent cleaner usage would be achieved as the solvent cleaner used is 100% volatile. However, solvent cleaning is carried out according to aircraft manufacturer's approval, and No significant changes to this practice have occurred recently. Eirtech are currently looking into the possibility of reusing solvent waste for gun-cleaning, but is unlikely to happen in 20 10. This could result in a reduction of VOC and a reduction in solvent waste being sent off-site.
1
Table 5 Best and Worst Possible Outcomes of action based on the three highest ranking options
Improving General Work Practices in the Painting Department, Minimization of, and Improved Management of Paint and Solvent Waste The development of new low VOC products and technologies that satisfy manufacturer approvals, Aviation Authority and customer requirements Substitution with lower VOC paint materials
Total
VOC Emitted/ Solids Used
Best Scenario for 2010
(This is based on the highly successful addressing of the three VOC reduction options)
VOC Contained K g
300
0
0
300
Reduction in UseKg
20
0
40
60
1.31
0 0
Worst Imaginable Scenario for 2010
(This is based on total failure with future VOC reductions, and a worst possible assessment of the current situation)
VOC Contained / Kg
200
0
0
Reduction in Use/Kg
0
0
0
200
1.44
0
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BIBLIOGRAPHY
1) EU Solvents Emissions Directive EU 1999/13/EC
2) Rowbottom, Jim (May 2002) Proposal for description of BAT, Akzo Nobel.
3) US EPA (December 1997) Control of VOC emissions from Coating Operations at Aerospace Manufacturing and Rework Operations, (EPA-453/R-97-004).
4) DFIU (2002) Best Available Techniques (BAT) for the Paint and Adhesive Application in Germany
5) Lufthansa Technik, High Tech Protection and Beauty www.lufthansa-technik.de/e/didvou/article~technical-prot.html
6) Greene, Brian E. (1994) Conventional Spray Painting Alternatives for Aerospace Applications www .dppr.ctc.com/paints/fspraerohtm
7) Emissions of Volatile Organic Compounds from Organic Solvent Regulations 2002 (S.I. No. 543 of 2002)
8) Environmental Technology Best Practice Programme (1997) Good Practice Guide (GC53) Cost Effective Paint and Powder Coating: Application Technology
9) TMS Consultancy Ltd. (2002) Air Dispersion Modelling Study - Screen Modelling of VOC Emissions from Stacks EF 8/9 and EF 10/11
10) Amp Consulting Engineers (2001) Upgrading of Existing Painting Ventilation & Heating P1M5 Hangar Feasibility Study for Shannon Aerospace.
1 1) UK Secretary of State (2003) Process Guidance Note Draft PG6/40 - Coating and Re-Coating of Aircraft and Aircraft Components
12) US EPA Method 25A - Determination of Total Gaseous Organic Concentration using a Flame Ionisation Detector.
13) Muir, Glen (1 997) Improving Liquid Spray Efficiency
14) Graco Publications (1 995) Manufacturer Reduces Material Waste by 30% with New Electrostatic
i
Finishing System
15) Brown, Roger (200 1) Roger Brown Offers Three Decades of Experience; Akzo Nobel Aerospace Coatings (Summer 2001) Reflections
16) Eirtech Aviation Limited (2003) Health and Safety Policy and Procedure - Safety Statement
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TEST REPORT
Analysing Testing Consulting Calibrating
I Client: BHP Ref No.: 93449 Order No.: Date Received: 2nd July 2010
Test Specification: Nil Limerick
Eirtech Aviation,
Dublin Airport, Co. Dublin Date Tested: 9th July 2010 Thomondgate
Hangar 3 BHP New Road
FAO: Ms. Monika Wasniowska Ireland Tel +353 61 455399 Fax+35361455447 E Mail bhpcem2Bbhp.ie
Item: Total Organic Emissions (as Carbon) from Emksion points A2-1 and A2-2 *
Date Issued: 14fh July 2010 Supplement to report No. N/A
Test results relate only to this item. This test report shall not be duplicated except in full and with the permission of the test laboratory 1
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SURVEY OF EMISSIONS TO ATMOSPHERE.
1 .O Introduction
2.0 Scope of survey
3.0 Survey Protocols
3.1 Sampling Protocols 3.2 Analysis Protocols 3.3 Reporting
4.0 Results
5.0 Interpretation of results
6.0 Conclusions
7.0 Appendix
BHP CEM Laberatow
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1.0 INTRODUCTION
Emission source
Eirtech Aviation is a newly formed company involved in the stripping and painting of commercial aircraft. They were formed from a management buyout of Lufthansa Aircraft Painting Shannon, based at Shannon Airport. A second site has been acquired at Hangar 3 in Dublin Airport to carryout similar operations.
Parameters measured
Eirtech will continue to operate from their base in Shannon under IPPC Licence PO497-02 (736). An IPPC licence will be sought for their Dublin base.
A2- 1
A2-2
This report deals with the air emissions monitoring of Total Organics (as Carbon) from the two stacks, at Hangar 3 in Dublin Airport, during priming operations within the hangar. This was carried out in preparation for Eirtech Aviation’s application for an IPPC Licence for the operation at Dublin Airport.
Total Organics as Carbon.
Total Organics as Carbon.
2.0 SCOPE OF SURVEY
At the request of Ms. Monika Wasniowska of Eirtech Aviation, BHP undertook to monitor total organics (as carbon) emissions to atmosphere from emission points A2-1 and A2-2 at Hangar 3, Dublin Airport, during the priming of a n Airbus A320. The sources of emissions are identified in table 1.1.
Table 2.1 Scope of sampling and analysis Program
I I
BHP CEM Labontory 3
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3.0 SURVEY PROTOCOLS
3.1 Sampling Protocols
A Portable Flame Ionisation Detector (FID) Model Signal 3010 was connected to tubing leading from emission points A2-1 and A2-1. The unit was calibrated using a reference gas mixture containing 500ppm methane prior to survey.
Temperature and velocity profiles of the emission sources were determined during particulates monitoring on lSt July 2010 (see BHP Report No. 93447).
Table 3.1 summarizes the techniques employed.
Table 3.1 Techniques used in sampling program.
Parameter
Temperature
Velocity
Total Organics
3.2 Analysis Protocols
Sampling Method
Thermocouple
Pitot Tube
Flame Ionisation Detector
A Portable Flame Ionisation Detector (FID) Model Signal 3010 was connected to tubing leading from emission points A2-1 and A2-1. The unit was calibrated using a reference gas mixture containing 5OOppm methane prior to survey.
Readings were taken directly from the unit at 60 second intervals throughout and after the aircraft priming operations.
Sampling notes were also taken to record the progression of priming of the aircraft during the survey.
3.3 Reporting
Temperature and velocity profiles of the emission sources were determined during particulates monitoring on lSt July 2010 (see BHP Report No. 93447) when air emission fans were fully operational, and are presented as averages of the sum of
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all the measurements taken fiom each source. All other results are reported in terms of concentration and mass flow rates per unit time.
Parameter
Area
Temperature
Velocity
The reference conditions for concentrations of substances in emissions to air fiom non-combustion sources are 273K; 10 1.3kPq with no correction for water vapour content.
Measured output from source Units
4.84 m2
20.2 "C
3.7 d S
Under these conditions lppm Methane = 0.53mg/nm3 as C.
Total Organics (ma.)
4.0 RESULTS
139 m m m 3
Table 4.1 Emission point A2-1.
Area
Temperature
Velocity
Sampled on 3rd July 2010 between 11541trs and 13031trs during application of FCR primer.
4.84 m2
21 -8 "C
6.9 m l S
107 Total Organics (ma.)
m@m3
Table 4.2 Emission point A2-2.
Sampled on 3'd July 2010 between 14lOhrs and 1550hrs during application of secondary primer.
1 Parameter 1 Measured output from source 1 Units 1
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5.0 INTERPRETATION OF RESULTS
There is currently no emission concentration limit for Total Organics (as Carbon) at monitoring points A2- 1 and A2-2. The emission concentration limits for the equivalent stacks at Shannon are 300mgNm’. The concentration of Total Organics never exceeded this limit.
Total Organic emission concentrations measured at monitoring points A2-1 and A2-2 at Hangar 3 in Dublin Airport are belo\%T the EPA limit set similar operations in Shannon Airport (see IPPC Licence PO497-02).
b- 6.0 CONCLUSIONS
Total Organic emission concentrations are below the EPA limits set for similar operations in Shannon (see IPPC Licence PO497-02).
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Appendix 1
Total organic emissions concentration from Stacks A2-1 and A2-2, Hangar 3
during priming of an Airbus A320 aircraft
~---__1_ -___ _____l__ll_______ll__I ----I.II "- - Total Organic Emissions at A2-1 during Aircraft Priming
120.0
100.0
80.0
60.0
40.0
20.0
Pnrnmg of fuseage
M aI 11
0.0
11:45 12:oo 12:14 12:28 12:43 1257 13:12
160
140
120
100
80
GO
40
20
0
Total Organic Emissions at AZ-2 during Aircraft Priming
Priming of front and nose
13:55 14:09 14:24 14:38 14:52 15:07 15:21 15:36 15:SO 16:04
BHP CEM Laboratory 7
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