Maintaining High-Volume, Low-Pressure Surface-Coating Regulatory Compliance Using the U.S. Environmental Protection Agency’s Data Quality Objectives Process

Abstract

To effectively reduce the environmental compliance costs associated with meeting specific requirements under the Aerospace Manufacturing and Rework Facility’s National Emission Standard for Hazardous Air Pollutants rule, the U.S. Environmental Protection Agency’s (EPA) Data Quality Objective (DQO) process has been proposed as a suitable framework for developing a scientifically defensible surface compliance monitoring program. By estimating the variability associated with the air cap pressure of high-volume, low-pressure (HVLP) surface-coating spray equipment, the number of monitoring samples necessary for an affected facility to claim compliance with a desired statistical confidence level was established. Using data taken from the pilot test facility, the DQO process indicated that the mean of at least 21 HVLP air cap pressure samples taken over the compliance period must be ≤10 pounds per square inch (psig) gauge for the facility to claim regulatory compliance with 99.99% statistical confidence. Fewer compliance samples could be taken, but that decision would lead to a commensurate reduction in the compliance confidence level. Implementation of the DQO-based compliance sampling plan eliminates the need for an affected facility to sample all regulated HVLP surface-coating processes while still maintaining a high level of compliance assurance.