SPOTA Solvent Substitution Dem/Val & Implementation of Alternative Cleaners for DoD Application

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1 SPOTA Solvent Substitution Dem/Val & Implementation of Alternative Cleaners for DoD Application Wayne Ziegler US Army Research Lab JSEM 07 May 24, 2007

2 Outline SPOTA Program Update Laboratory testing Demonstration/validation Implementation

3 The DLSME NESHAP Who will be affected? Facilities owned or operated by the Armed Forces of the United States, National Guard, Coast Guard, NASA Major Sources: All requirements listed below Area Sources: Chemical depainting and motor vehicle and mobile equipment refinishing requirements only All government and commercial facilities that coat military munitions No other OEM facilities affected What will be the requirements? Painting, coating, marking, stenciling, etc. Limits on MIL-C Types II & IV, MIL-DTL Type I, MIL-P Types I & II, MIL-PRF Specifications will be revised to require compliant HAP contents Solvent cleaning and thinning Must be HAP-free unless authorized in Standardization Document, Equipment Publication or Technical Data

4 The DLSME NESHAP What will be the requirements (cont.)? Chemical depainting Existing large dip tanks must apply work practice standards (freeboard, cover, etc.) New large dip tanks must be HAP-free Organic HAP emissions outside of large dip tanks limited to 1,000 pounds / yr Rubber-to-metal bonding Numerical limit based on Army qualified products list Not the same limits or units as promulgated in MMPP NESHAP Motor vehicle and mobile equipment refinishing (i.e., nontactical) Requirements likely to focus on training / certification of painters Military munitions coating, cleaning, depainting No HAP limits due to performance criticality Where on a source will the requirements apply? Operations not already subject to another NESHAP Operations not performed for janitorial, building maintenance, personal use, or certain other non-dlsme purposes Some DLSME operations related to aerospace equipment may comply with requirements of Aerospace NESHAP for simplicity

5 The DLSME NESHAP When will the regulation take effect? EPA prioritization of Area Source rules will not effect release Draft DLSME expected August 2007 Effective date likely three years after final rule promulgated How will a source comply with the requirements? Option 1: Use only compliant materials Option 2: Meet facility-wide emission rate Option 3: Use add-on controls to meet facility-wide emission rate What is the bottom line for compliance? Sources will be in compliance as long as they obtain paints conforming to latest MILSPEC revisions and follow TMs (or other controlling documents) for cleaning, thinning and paint removal

6 SPOTA Solvent Substitution Thrust Area

7 Status Laboratory Testing Laboratory testing complete Stakeholders provided requirements Down select based on blind test results Objective Establish criterion Provide basis for down select based on objective performance

8 Down Select Down select based on lab results without product identification TARDEC/TACOM down select to 3 products for dem/val AMCOM/AMRDEC down select to 3 products for dem/val

9 Cleaners Downselected by TACOM and AMCOM Vendor Water Soluble Organic Brulin GD Inland Technology 5 Breakthrough PCI America 6 Hurrisafe Paint Prep AG Environmental 8 Soygold 1000 Dynamold Solvents 9 DS DS 108 West Penetone 11 Penair HD-3A Petroferm 16 Bioact 105

10 Identifying Applications & Locations for Demo Projects Selection criteria Scale of operation Pervasiveness of application Respect for location Level of PM/PEO cooperation Focus on two primary commodity groups aviation & ground vehicles Follow JS3 methodology CECOM commodities added FY07

11 LEAD Small Scale Technology Demonstration Paint gun cleaning leveraging an existing project Replacing Three down selected products One out for incompatibility with equipment (lab & soak test) Baseline & one alternative complete

12 RIA Small Scale Technology Demonstration Hand wipe application Immersion application to be completed at future date planned FY08 Demonstration plan approved Demo will occur late spring early summer subject to production schedules

13 Additional Demonstrations Fort Rucker hand wipe application Sierra AD hand wipe application Rock Island immersion application Tobyhanna AD application related to shelters, etc.

14 Compliance Scheme DOD will use HAP free solvents/cleaners unless the controlling document specifically requires or allows the use of HAP cleaners. Includes DoD commitment to move toward HAP Free cleaners in the future

15 Implementation SPOTA Strategy Key to implementation is control Supply control Process control Document control We do not have control Options Better document control Educated users Ongoing commodity management requirement

16 Document Control Issues Administrative cost to change TM/TO pages Use specifications for commodity management Example: Controlling CARC formulation

17 Success Story: MIL-PRF-680 revisions 3.6 Hazardous Air Pollutants. The solvent shall contain no chemicals listed as Hazardous Air Pollutants (HAPs) (see 6.7). Any HAP components in the solvent in a concentration of 1.0 percent (%) or greater by weight (wt) or volume (vol) will be regarded as the presence of a HAP in the solvent. The product containing less than 1 % of HAP shall be considered as a HAP free solvent. For carcinogenic HAPs see Carcinogenicity. The solvent shall contain no chemicals listed as carcinogens (see 6.7). Any carcinogenic components in the solvent in a concentration of 0.1 percent (%) or greater by weight (wt) or volume (vol) will be regarded as the presence of a carcinogen in the solvent.

18 Implications of MIL-PRF-680revB All current operations specifying MIL- PRF-680 will be in compliance Known entity in maintenance community implementation of MIL- PRF-680 in operations with no governing document Old NSNs - A-A-59601B (CID P-D-680) are still in the system

19 Cleaning During Coating Operations Specification Alternative to MIL-PRF-680B - petroleum based hydrocarbon solvents Logistics control commodity management User training is essential Incorporated into Army SPOTA implementation plan & Navy VOHAP elimination plan Specification development No additional funding Timeline (3 years) Specs & standards and logistics personnel

20 Standardization Documents Handbook or MIL-C-1234 Or both Specification with QPL

21 Cautionary Tale Example: MIL-STD Cleaning. Cleaning procedures, methods, special equipment, and materials that are required shall be specified. Cleaning materials used for the cleaning of systems, subsystems and components in order to prepare them for painting, bonding, applying sealants or adhesives, and the removal thereof, shall be Hazardous Air Pollutant (HAP) free (See defn)....

22 Typical Response For field level pubs (less than depot) how can we cite a cleaning standard in those TMs? Will the troops have access to that standard? I believe the TMs must reflect the cleaning procedures appropriate for the equipment, using cleaning materials approved for such use via engineering review. For depot level pubs, citing a standard (MIL or FED etc.) would be appropriate but not in field level TMs. Simply including a statement in that cleaning will be IAW HAP-free cleaners is inadequate. It's a motherhood statement without specificity. The related TMs/depot pubs must contain the specifics.

23 Cautionary Tale Impact Can a cleaning specification impact the whole system and be part of an overall compliance plan? Changing TMs and other local documents will not happen in a reasonable timeline (too expensive to change outside of normal review cycle) Need for more comprehensive implementation plan

24 Path Forward Dem/val of alternatives Cleaning specification development with QPL and associated NSN s DoD coordination New spec to support 509 manual Develop implementation plan for installation level maintenance facilities Commodity management plan

25 Conclusion Finding alternatives is the easy part Environmental benefit will not drive change without performance and economic benefits No one size fits all implementation strategy Commodity management / logistics control key to successful implementation

26 To Find Information on Army Solvent Substitution Efforts Good Morning! Welcome to the Joint Group on Pollution Prevention web site! JG-PP Charter System Program Manager Maintenance and Repair Facility Original Equipment Manufacture Resource and Academia Contact Us Joint Service Solvent Substitution (JS3) Database** This site last updated September 30, 2005 Send all questions and comments to

27 Contact Information Mr. Wayne Ziegler US Army Research Laboratory