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Do. D NESHAP Compliance through P 2: Implementing Environmentally Compliant Alternatives to VOC/HAP Solvents Do. D NESHAP Compliance through P 2: Implementing Environmentally Compliant Alternatives to VOC/HAP Solvents Mr. Wayne Ziegler US Army Research Laboratory [email protected] army. mil

Outline ØRegulatory Background ØJoint Solvent Substitution Working Group Approach ØDo. D HAP/VOC Solvent Substitution Outline ØRegulatory Background ØJoint Solvent Substitution Working Group Approach ØDo. D HAP/VOC Solvent Substitution Vision ØSummary ØBack Up Slides ØLong Term Objectives – SERDP ØIndividual Service Efforts

Regulatory Drivers • Many Petroleum-based Solvents are: - Hazardous Air Pollutants (HAPs) - Photo Regulatory Drivers • Many Petroleum-based Solvents are: - Hazardous Air Pollutants (HAPs) - Photo Reactive Volatile Organic Compounds (VOCs) • Clean Air Act – National Emissions Standards for Hazardous Air Pollutants (NESHAP) • Requires tracking of 189 HAPs – National Ambient Air Quality Standards (NAAQS) for ozone • Air Quality Management Districts regulate VOCs – Require emission control equipment – Limit VOC content of solvents – Process ban

DOD Major HAP Sources NAS Whidbey Island NSY Puget Sound Fort Lewis Lima Army DOD Major HAP Sources NAS Whidbey Island NSY Puget Sound Fort Lewis Lima Army Tank Plt NTC Great Lakes Rock Island Arsenal Crane AAA Iowa AAP Sierra AD Hill AFB Fort Carson Lake City AAP Edwards AFB NAWS China Lake NAS North Island NADEP North Island Tinker AFB MCLB Barstow Schofield Barracks Mc. Alester AAP AF Plant 4 NSY Pearl Harbor FISC Pearl Harbor NAVSTA Pearl Harbor PWC Pearl Harbor Fort Hood Corpus Christi AD Fort Wainwright Fort Richardson Pine Bluff Arsenal Red River AD Lone Star AAP Letterkenny AD SUBASE New London NSWC Indian Head NAVSTA Fort Knox Norfolk Radford AAP NSY Norfolk NAS Fort Campbell Holston AAP Oceana MCAS Cherry Fort Bragg Arnold Eng. Dev. Point Center NADEP MCB Camp Cherry Milan Point Redstone Lejeune MCAS New AAP Arsenal Fort Jackson River Anniston AD AF Plant 6 Fort Gordon Fort Benning Fort Stewart Robins Fort Rucker AFB NAS Jacksonville NADEP Jacksonville NSWC Crane Fort Riley Tobyhanna Army Depot Wright-Patterson AFB Eglin AFB Installation Owner Army Air Force Navy Marine Corps

Prior 2003: What NESHAP is it? Prior 2003: What NESHAP is it?

Pre-2003 Coating NESHAP Applicability for Do. D Miscellaneous Metal Parts and Products Plastic Parts Pre-2003 Coating NESHAP Applicability for Do. D Miscellaneous Metal Parts and Products Plastic Parts and Products Shipbuilding & Ship Repair Metal Furniture Department of Defense Installations Wood Building Products Aerospace Manufacturing & Rework Large Appliances Printing, Coating, and Dyeing of Fabric & Other Textiles Source: Kim Teal, CCPG EPA

Do. D Compliance • • What is a coating? What is a coating operation? Do. D Compliance • • What is a coating? What is a coating operation? Coating operations on what? Coating operations where? • Compliance was going to be a disaster.

What’s a coating? • Materials Included? – Wash primers – Dry Film Lubricants? – What’s a coating? • Materials Included? – Wash primers – Dry Film Lubricants? – Paints (topcoats, primers) – CPCs? – Inks – NDIs? – Lacquers • Materials / Processes Excluded – Sealants – Metal Plating – Adhesives – Inorganic – Caulks Pretreatments Working Defn: Any organic-based material that leaves a solid film

What’s a Coating Operation? • Process that results in application of coating • Includes What’s a Coating Operation? • Process that results in application of coating • Includes all activities that result in coating application – Cleaning of part/system • Cleaners and solvents • Strippers – Coating application • Coatings • Thinners – Post coating clean-up • Overspray removal • Line, gun, brush and roller cleaners • Paint booth cleaners

Coating Operations on What? • Maintenance and production of weapon systems – Not already Coating Operations on What? • Maintenance and production of weapon systems – Not already covered by aerospace or shipbuilding • • Combat vehicles & Tactical vehicles Engineer equipment Communication equipment Support equipment Personnel items Medical equipment Armament Munitions (not missiles and rockets) • Maintenance of installation items? – Fork lifts, trucks, buses, vans – Rail equipment – On-site containers

Coating Operations Where? • Industrial operations sites – – – Motor pools Hangars Maintenance Coating Operations Where? • Industrial operations sites – – – Motor pools Hangars Maintenance shops Production shops Commercial tenants Paint booths – – Not those already covered by architectural Not operations on quarters or ‘hobby shops’ Industrial facilities Industrial process equipment • Installation operations sites? » But……. What is facility maintenance?

New Source Category Shipbuilding & Ship Repair Plastic Parts and Products Miscellaneous Metal Parts New Source Category Shipbuilding & Ship Repair Plastic Parts and Products Miscellaneous Metal Parts and Products Aerospace Manufacturing & Rework Metal Furniture Defense Land Systems and Miscellaneous Military Equipment (DLSME) Wood Building Products Printing, Coating, and Dyeing of Fabric & Other Textiles Large Appliances Source: Kim Teal, CCPG EPA

Joint Service Solvent Substitution Working Group Objectives • Facilitate open communication and collaboration • Joint Service Solvent Substitution Working Group Objectives • Facilitate open communication and collaboration • Implement P 2 solutions to issues of NESHAP compliance (HAP Free) • A coordinated response to solvent issues related to NESHAPs • Support DLSME working group Joint Group on Pollution Prevention Chartered by Joint Logistics Commanders

Why HAP Free? • • Reduced Record-keeping Lowers Potential To Emit (PTE) Improved ESH Why HAP Free? • • Reduced Record-keeping Lowers Potential To Emit (PTE) Improved ESH properties (Safer materials) Production Issues • Three Prong Approach – Reformulation/Qualification/Implementation of Alternatives – Field Reformulated Materials – Work With EPA Through Stake-holder Process

Joint Service Solvent Substitution Working Group Approach • Develop Framework ØMaximize Coordination ØJoint Service Joint Service Solvent Substitution Working Group Approach • Develop Framework ØMaximize Coordination ØJoint Service Solvent Substitution Working Group ØJoint Service Solvent Substitution Methodology ØJoint Service Solvent Substitution Tracking Database Ø Industry Participation

Collaboration Concept of Operations Army Navy Joint Methodology JG-PP Execution Committee Joint Protocols NASA Collaboration Concept of Operations Army Navy Joint Methodology JG-PP Execution Committee Joint Protocols NASA Joint Tracking Database Air Force Marine Corps DCMA

Common Defense/NASA Market Industry Concept of Operations Joint Methodology Joint Tracking Database Joint Protocols Common Defense/NASA Market Industry Concept of Operations Joint Methodology Joint Tracking Database Joint Protocols Army JG-PP Execution Committee Navy DCMA NASA Marine Corps Air Force

Solvent Substitution Process Targeted Processes • Aircraft Maintenance • Ship Maintenance • Facility Maintenance Solvent Substitution Process Targeted Processes • Aircraft Maintenance • Ship Maintenance • Facility Maintenance • Etc. Partners NAVSEA • NAVAIR • Marine Corps • Army • Air Force • NASA • Candidate Solutions • Aqueous Solvents • Biobased Solvents • Ozone • Etc. Joint Services Solvent Substitution Methodology Screening Methodology Test Protocol Lab Testing Field Testing Process Approval Update Manuals User Awareness Implementation Support Processes not requiring extra record keeping & control measures

Joint Service Solvent Substitution Methodology Information contained within Document: • Description of Methodology • Joint Service Solvent Substitution Methodology Information contained within Document: • Description of Methodology • Procedures to follow (Start to Finish) • Flow Chart • Acceptance Criteria ü Environmental Parameters ü Health and Safety Parameters ü Cleaner Characteristics ü Compatibility Tests and Methods ü Cleaning Efficiency Test Methods

Database Requirements: ü Web Based ü Tracks Project Status ü Stores Project Information ü Database Requirements: ü Web Based ü Tracks Project Status ü Stores Project Information ü Stores Developed Acceptance Criteria ü Stores Historical Information ü Industry Access (Populate and Retrieve)

Do. D Solvent Substitution Vision Test Results Industry 3 rd Party Analysis Joint Protocols Do. D Solvent Substitution Vision Test Results Industry 3 rd Party Analysis Joint Protocols Industry

Where are we now? • • • Finalizing Joint Service Solvent Substitution Methodology Developing Where are we now? • • • Finalizing Joint Service Solvent Substitution Methodology Developing Joint Service Solvent Substitution Tracking Database Identifying and Quantifying Solvent Usage within the Defense and NASA Continuing Coordination Recruiting Participants

Summary • Defense/NASA Committed to P 2 Solutions • Pursuing Near, Mid and Long Summary • Defense/NASA Committed to P 2 Solutions • Pursuing Near, Mid and Long Term Solutions • Joint Services Solvent Substitution Tracking Database – Defense/NASA Efforts Coordinated thru Web Based Information Exchange Tool – Seeking Industry Participation thru Web Based Tool – Provides a Common Defense/NASA Market

Back Up Slides • SERDP Special Study – Solvent Issues Related to NESHAPs • Back Up Slides • SERDP Special Study – Solvent Issues Related to NESHAPs • SPOTA – Sustainable Painting Operations for the Total Army • Navy Depot Solvent Use Study • Air Force Tech Needs Survey • Solvent Substitution Methodology Details

Special Study -Solvent Issues related to NESHAPs • Identify green chemistry or technology gaps Special Study -Solvent Issues related to NESHAPs • Identify green chemistry or technology gaps • Status quo and state-ofthe-art relative to military use of “green” solvents and technologies • What is the future of Do. D cleaning?

Summary • Results Support Development of New Solvent Chemistry • Problem Statement Supporting FY Summary • Results Support Development of New Solvent Chemistry • Problem Statement Supporting FY 05 SON – Handwipe • FY 05 SON Number: PPSON-05 -01, “HAP-FREE SOLVENTS FOR DOD HAND WIPE CLEANING APPLICATIONS” • Leaders who engage in thinking strategically begin with where they want to go. Then they look backward from the future and ask, “What will it take to create that new tomorrow? ””

SPOTA Sustainable Painting Operations for the Total Army • The Army strategy for addressing SPOTA Sustainable Painting Operations for the Total Army • The Army strategy for addressing issues related to NESHAPs • Army’s #1 Priority under Army Environmental Requirements and Technology Assessments (AERTA) • Purpose – to ensure continued operations at impacted Army facilities

SPOTA Technology Thrust Areas • • • Solvents/Cleaners/Thinners CARC/Non-CARC Coatings Rubber-to-Metal Bonding De-Painting Miscellaneous SPOTA Technology Thrust Areas • • • Solvents/Cleaners/Thinners CARC/Non-CARC Coatings Rubber-to-Metal Bonding De-Painting Miscellaneous Coatings, Adhesives & Sealants • Munitions Coatings

Army Solvent Survey Findings • In 2002, the 14 Army facilities surveyed reported using Army Solvent Survey Findings • In 2002, the 14 Army facilities surveyed reported using over 46, 000 gallons of HAP-containing solvents containing almost 215, 000 pounds of organic HAPs. • 95% of the 125 HAP-containing solvents identified at these facilities have a HAP content of 5% or greater. • If the EPA sets the solvents limit at 5% immediately, the Army will have significant compliance issues. • Many off-the shelf alternatives have been identified, but will require validation prior to Army acceptance

Navy Solvent Survey Navy Solvent Survey

Air Force Tech Needs Survey 300+ New AF Needs CY 00 Thrust Area Chemicals Air Force Tech Needs Survey 300+ New AF Needs CY 00 Thrust Area Chemicals Adhesive/Sealant (29) MEK (18) Toluene (15) Cleaning (118) MEK (56) HCFC 141 B (17) Toluene (7) PCE (7) Coating (82) VOC/HAP (64) Cr (16) Conversion Coat (19) Cr (19) Depaint (20) Methylene Chloride (9) MEK (3) Oxygen Line. Clean (15) CFC-113 (2) HCFC 141 B (3) Plating (26) Cr (7) Cd (4) Soldering (2) Lead Ni (4)

Solvent Substitution Methodology Flowchart Start Approval Stakeholders Market Research Develop Implementation Strategy Demonstration Validate Solvent Substitution Methodology Flowchart Start Approval Stakeholders Market Research Develop Implementation Strategy Demonstration Validate Approval Process Evaluation Demonstration Plan Acceptance Criteria Implementation

Parameter HAPS Environmental, Safety and Occupational Health, and Chemical Parameters Environmental VOC Screening Ozone Parameter HAPS Environmental, Safety and Occupational Health, and Chemical Parameters Environmental VOC Screening Ozone Depleting Substance Ozone Forming Potential Global Warming Personnel Exposure Limit Threshold Limit Value Occupational Lower/Upper Explosion Limit Screening Warning Odor Below PEL/TLV Objectionable Odor Bioacummulative Hansens Solubility Parameter K-Butanol Number Chemical Property Specific Gravity Screening Flash Point Composite Partial Pressure (CPP) Vapor Pressure

Common Material Compatibility Test Types • • • Corrosion Flash Point Flammability p. H Common Material Compatibility Test Types • • • Corrosion Flash Point Flammability p. H Appearance Toxicity Nonvolatile Residue Biodegradability Chloride Cleaning Efficiency Storage Stability

Cleanliness Test Methods – – – Wetting Behavior Breath Test Water Break Test Spray Cleanliness Test Methods – – – Wetting Behavior Breath Test Water Break Test Spray Pattern or Mist Test Atomizer Test Talc Test Copper Displacement Test Potassium Ferricyanide Test Fluorescence Test Dye Test Clock Reaction for Copper and Its Alloy Spreading Wetting Test

Joint Group on Pollution Prevention Chartered by Joint Logistics Commanders JGPP Solvent Substitution Execution Joint Group on Pollution Prevention Chartered by Joint Logistics Commanders JGPP Solvent Substitution Execution Committee Andrew Del Collo Naval Facilities Engineering Command Maryalice Miller HQ RDECOM Gerry Mongelli HQ AFMC/LGPE (CTC) Ron Patun CTC Mischa C. Sharpe Marine Corps Logistics Command Tom Torres NFESC Wayne Ziegler ARL