Standing on the MACT Floor

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Courtesy of Weston Solutions, Inc

ABSTRACT

Three MACT standards have impacted manufacturing operations at the Boeing Philadelphia site. These standards apply to Aerospace Manufacturing and Rework, Halogenated Solvent Cleaning, and Chromium Anodizing.

In order to meet the requirements imposed by the standards, qualifications programs were established and conducted by the Materials and Process Engineering group to approve several candidate compliant materials and processes. Engineering specifications were revised to include qualified alternatives, primarily for cleaning and surface treatment of aerospace hardware. Operation and maintenance plans; startup, shutdown, and malfunction plans; work practice standards; housekeeping methods; and training procedures specified in the standards had to be implemented by the effective dates of the regulations. In addition, periodic monitoring of procedures, methods, and processes is required to document due diligence and support compliance certifications in the mandatory reports submitted to the EPA and the Pennsylvania environmental regulatory agency. Boeing utilizes its Hazardous Materials Management System (HMMS) and Material Safety Data Sheet (MSDS) databases as aids in providing accountability for material usage, characteristics, and emissions, to comply with recordkeeping requirements contained in the MACT standards.
Boeing has converted fifteen waterwash paint booths to dry filters for particulate control to facilitate compliance with the inorganic MACT standards of the Aerospace NESHAP. Cross-functional coordination of MACT requirements has been critical not only for ensuring compliance with those requirements, but also for identifying and implementing suitable alternatives not subject to any MACT standards. For instance, the applicability of the Chromium MACT standard at the Boeing Philadelphia facility was eliminated by replacing a chromic acid anodizing process with a boric/sulfuric acid anodizing process in 1998. Chromium electroplating at the Boeing Philadelphia facility was out-sourced prior to the effective date of the MACT standard. Ongoing research and development efforts seek alternatives to the two remaining trichloroethylene vapor degreasers on site. Viable alternatives will not utilize halogenated solvent cleaners subject to the Subpart T NESHAP. Currently, the majority of the batch cleaning is performed using either spray or immersion aqueous cleaning.

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