October 15, 1998
Mr. Jay M. Willenberg
Puget Sound Air Pollution Control Agency
110 Union Street, Suite 500
Seattle, Washington 98101-2038

Re: Preval Spray Units Applicability to the Aerospace NESHAP

Dear Mr. Willenberg:

This letter is in response to your correspondence to Gregg Wagner, B.F. Goodrich Aerospace, dated August 18, 1998, regarding the applicability of Preval® spray units to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Aerospace Manufacturing and Rework Facilities, 40 CFR Part 63, Subpart GG. Specifically, you determined that the Preval® spray units are exempt from the Aerospace NESHAP and requested concurrence from the Environmental Protection Agency (EPA). EPA concurs with your determination for the reasons explained below.

You have stated that the Preval® system used at B.F. Goodrich Aerospace is a hand-held aerosol can that has a non-refillable pressurized portion. In Appendix A - Specialty Coating Definitions of the Aerospace NESHAP, EPA defines "aerosol coating" as a hand-held, pressurized, non-refillable container that expels an adhesive or a coating in a finely divided spray when a valve on the container is depressed. Based on your description, we agree that the Preval® system meets the criteria for being classified as an aerosol coating. Since aerosol coatings are considered specialty coatings, and specialty coatings are exempt from the Aerospace NESHAP [63.741(f)], we have concluded that the Preval® system is exempt from the Aerospace NESHAP.

If, at any time, EPA amends this NESHAP such that specialty coatings are no longer exempt, this applicability determination will need to be revisited. If you have any questions regarding this determination, please contact Andrea Wullenweber at (206) 553-8760.

Sincerely,

/ signed /

Douglas E. Hardesty, Manager

Federal & Delegated Air Programs Unit

Lisa Rutan, Hexcel Corporation

Jim Szykman, EPA OAQPS

Gregg Wagner, B.F. Goodrich Aerospace