The National Emission Standards for Hazardous Air Pollutants (“NESHAP”) established specific standards, tests and procedures for aerospace manufacturing and rework facilities.

What are the NESHAP paint requirements?

Specifically with respect to paint application and removal, NESHAP requires:

• All operations to be conducted in a spray booth or hangar;

• Air flow must be downward or across the part and exhausted through a control device; and

• A control device can be a dry particulate filter (also known as a paint arrestor) but such particulate filter / paint arrestor must meet certain minimum standards.

The Environmental Protection Agency’s (“EPA”) developed a test protocol known as Method 319 to determine if a dry particulate filter / filter complies with NESHAP. Method 319 attempts to simulate dry and wet overspray characteristics of hazardous air pollutants (“HAPs”) and volatile organic compounds (“VOCs”).

For paint systems installed after October 29, 1996, a 3-Stage filtration process similar to the one depicted below, is required.