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DoD NESHAP Compliance through P2: Implementing Environmentally Compliant Alternatives to VOC/HAP Solvents

DoD NESHAP Compliance through P2: Implementing Environmentally Compliant Alternatives to VOC/HAP Solvents. Mr. Wayne Ziegler US Army Research Laboratory wziegler@arl.army.mil. Outline. Regulatory Background Joint Solvent Substitution Working Group Approach

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DoD NESHAP Compliance through P2: Implementing Environmentally Compliant Alternatives to VOC/HAP Solvents

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  1. DoD NESHAP Compliance through P2:Implementing Environmentally Compliant Alternatives to VOC/HAP Solvents Mr. Wayne Ziegler US Army Research Laboratory wziegler@arl.army.mil

  2. Outline • Regulatory Background • Joint Solvent Substitution Working Group Approach • DoD HAP/VOC Solvent Substitution Vision • Summary • Back Up Slides • Long Term Objectives – SERDP • Individual Service Efforts

  3. 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

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

  5. Prior 2003: What NESHAP is it?

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

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

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

  9. 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

  10. 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

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

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

  13. Joint Service Solvent Substitution Working Group Objectives • Facilitate open communication and collaboration • Implement P2 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

  14. 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

  15. Joint Service Solvent Substitution Working Group Approach • Develop Framework • Maximize Coordination • Joint Service Solvent Substitution Working Group • Joint Service Solvent Substitution Methodology • Joint Service Solvent Substitution Tracking Database • Industry Participation

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

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

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

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

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

  21. Joint Protocols Test Results DoD Solvent Substitution Vision Industry3rd PartyAnalysis DataBase Procurment DataBase Industry

  22. 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

  23. Summary • Defense/NASA Committed to P2 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

  24. 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

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

  26. Summary • Results Support Development of New Solvent Chemistry • Problem Statement Supporting FY05 SON • Handwipe • FY05 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?””

  27. SPOTASustainable 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

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

  29. 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

  30. Navy Solvent Survey

  31. Air Force Tech Needs Survey300+ New AF Needs CY00

  32. Solvent Substitution MethodologyFlowchart Start Approval Approval Stakeholders Market Research Demonstration Validate Develop Implementation Strategy Approval Approval Process Evaluation Demonstration Plan Implementation Acceptance Criteria

  33. Environmental, Safety and Occupational Health, and Chemical Parameters

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

  35. 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

  36. Joint Group on Pollution Prevention Chartered by Joint Logistics Commanders JGPP Solvent Substitution Execution Committee

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