1. Solvent Emissions From the Organic Coating Process Jim Rowbotham Pexa Ltd. © Pexa 2009

2. Nearly there © Pexa 2009

3. What’s the Problem? Climate Change Carbon Footprint © Pexa 2009

4. Leadership “a step that will also reduce our carbon emissions 80% by 2050”. “commits Britain to cut carbon emission by 34 per cent by 2020” © Pexa 2009

5. Contribution  Paints based on organic solvents  Carbon derived from fossil sources  Used as a carrier in paints, evaporates and adds to the environmental carbon compound concentration © Pexa 2009

6. Regulation  This paper focuses on The EU Solvent Emission Directive 13/1999.  Embodied in the UK for Aerospace as guidance notes. - PG6-40 Painting - PG6-45 Surface Cleaning © Pexa 2009

7. Thresholds Defined for Coating by Size of Activity  0 - 5000 Kg of solvent used - Not controlled  5 – 15,000 Kg – “small process”  15 – 200,000 Kg – “large process”  >200,000 Kg - special process (IPPC) © Pexa 2009

8. Objectives of Presentation  Simplify the directive  Focus on most important items  Desktop methods for estimating current emissions  Propose simple tools for evaluating compliance  Some ideas for improvement  Sound basis for regulator © Pexa 2009

9. Painting Process © Pexa 2009

10. Painting Activity – How to Comply?  “Non toxic” (non CMR R40 etc) solvents 1) Reduce to < 5000Kg 2) Control of emission concentrations 3) Mass reduction scheme 4) (BAT)  CMR R40 solvents (essentially not used) 1) Control of emission concentrations 2) Nothing © Pexa 2009

11. Painting Process – 2 Emission Control  VOC’s (as carbon) must be <50 mg/cubic metre of air. For R40s etc is <20 mg/cubic metre (as compound)  Particulates must be <50 mg/cubic metre of air  Can be continuously monitored, or periodically monitored, must be retested when process changed  Can be reduced by rate management, incineration, cryogenics, carbon/polymer absorption, biodegradation. NOT by Dilution.  Time weighted average, batch vs continuous process  Previous rules will not be relaxed © Pexa 2009

12. Painting Process - 3 Mass Reduction Scheme  Annual solvent emission to be less than target emission (Te)  Te = M x F1 x (FEV + F2) 100  M = mass of solids/year  F1 = multiplication factor (sector related)  FEV = fugitive emission value (solvent use related)  F2 = 15 or 5 (solvent use related) © Pexa 2009

13. Worked Back to 100 Tonnes (%) Te = M x F1 x (FEV + F2) 100 © Pexa 2009

14. Conclusion Painting Process SizeMax average VOC into process 5,000 – 15,000 Kg531 g/l >15,000 Kg405 g/l © Pexa 2009

15. Whole Aircraft Painting © Pexa 2009

16. Whole Aircraft Painting 3 – Mass Reduction Using High Solids paint System Compare to Max 531 g/l or 405 g/l © Pexa 2009

17. Whole Aircraft Painting 2 – Emission Concentration Note – Regulation is weighted over 30 minutes Limit 50mg/M3 as carbon © Pexa 2009

18. Whole Aircraft Painting 1 – Thresholds © Pexa 2009

19. Whole Aircraft Painting 4 – BAT Article 5 (3) (b) allows that processes which cannot be contained e.g. aircraft painting, may be exempted from the annex II A controls. Providing that BAT can be demonstrated. © Pexa 2009

20. Surface Cleaning Process © Pexa 2009

21. Surface Cleaning – Permit Required GroupDescription 1.either, 1 tonne or more of cleaning solvents that are labelled (classified) with any of the R phrases R45, 46, 49, 60 or 61 (the product label and Safety Data Sheet give this information) 2.or, 1 tonne or more of halogenated cleaning solvents that are labelled (classified) with the R phrase R40 (the product label and Safety Data Sheet give this information) 3.or, 2 tonnes or more of any other organic cleaning solvent BCF Guidance Note E018 © Pexa 2009

22. Surface Cleaning – Emission Limits BCF Guidance Note E018 group: 12 month usageStack (e.g. exhaust flue) emissions Fugitive (all other) emissions Group 1: 1-5 tonnes 2 mg cleaning solvent/m 3 (20 mg if mass flow below 10g/hour) 15% of solvent used Group 1: more than 5 tonnes 2 mg cleaning solvent /m 3 (20 mg if mass flow below 10g/hour) 10% of solvent used Group 2: 1-5 tonnes 20 mg cleaning solvent/m 3 (mass flow above 100g/hr) 15% of solvent used Group 2: more than 5 tonnes 20 mg cleaning solvent/m 3 (mass flow above 100g/hr) 10% of solvent used Group 3: 2-10 tonnes 75 mg carbon/m 3 20% of solvent used Group 3: more than 10 tonnes 75 mg carbon/m 3 15% of solvent used Note: the Group 3 limits do not apply if the average organic solvent content of cleaning solvents is below 30% © Pexa 2009

23. Practical Reductions © Pexa 2009

24. Structural Paint System VOCs HS vs Water Based With an average 70% primer and 30% topcoat HS Primer 37092 350 g/l HS Topcoat 67348 420 g/l 371 g/l Aerowave Primer 2001 250 g/l Aerowave Finish 3003 250 g/l 250 g/l Conclusion – Mass reduction is well within limits and the best way to comply – water based = HEADROOM © Pexa 2009

25. Laminar Flow Spray Technology Dux British Patented Design © Pexa 2009

26. Laminar Flow Spray Technology Particle Image Velocimetry Images Particle Density is greatest where image is darkest © Pexa 2009

27. Laminar Flow Spray Technology Application at Major UK Based Aero-Engine MRO Cascade Vents Paint consumption reduced from 225ml to 125ml = 44% © Pexa 2009

28. Impregnated Cleaning Wipes vs. Solvent Washing - In European Aerostructures manufacture we have reduced solvent consumption by 75%-95% changing from traditional fluid solvent (MEK) and cotton rags to Satwipes Diestone DLS. - Presaturated wipes with controlled surface area and controlled measure of solvent applied to each wipe. - Self closing Lids © Pexa 2009

29. Aqueous Cleaning vs Vapour Degreasing Moving from vapour degreasing with Trike (and other solvents) to aqueous washing using a new generation of approved aqueous cleaning products such as Sococlean A3433, gives a 100% reduction in VOC emission. © Pexa 2009

30. Recommendations  Understand the requirements.  Use the desktop exercises to determine thresholds and actual contributions.  Implement proven, practical VOC reduction methods and recalculate contributions.  Get ahead of the regulator. © Pexa 2009