solvent management plan - environmental protection … · project (see section 3.2 for further...

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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15

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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.

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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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