SPOTA Solvent SubstitutionDem/Val & Implementation of Alternative Cleaners for DoD

Application

Wayne ZieglerUS Army Research Lab

JSEM 07

May 24, 2007

Outline

• SPOTA Program Update• Laboratory testing• Demonstration/validation• Implementation

• 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-46168 Types II & IV, MIL-DTL-53039 Type I, MIL-P-53022 Types I & II, MIL-PRF-22750

• 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

The DLSME NESHAP

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., non-tactical)

• 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

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

SPOTA Solvent Substitution Thrust Area

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

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

Cleaners Downselected by TACOM and AMCOM

Vendor Water Soluble OrganicBrulin 2 815 GD

Inland Technology 5 Breakthrough

PCI America 6 Hurrisafe Paint Prep

AG Environmental 8 Soygold 1000

Dynamold Solvents 9 DS 1089 DS 108

West Penetone 11 Penair HD-3A

Petroferm 16 Bioact 105

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

LEAD Small Scale Technology Demonstration

• Paint gun cleaning – leveraging an existing project

• Replacing 81772• Three down selected products• One out for incompatibility with

equipment (lab & soak test)• Baseline & one alternative complete

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

Additional Demonstrations

• Fort Rucker – hand wipe application• Sierra AD – hand wipe application• Rock Island – immersion application• Tobyhanna AD – application related to

shelters, etc.

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

ImplementationSPOTA 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

Document Control Issues

• Administrative cost to change TM/TO pages

• Use specifications for commodity management

• Example: Controlling CARC formulation

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 3.5.

• 3.5 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.

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

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

Standardization Documents

Handbook

or

Specification with QPL

MIL-C-1234

Or both

Cautionary TaleExample: MIL-STD-40051

• 5.3.5.3.8 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). ...

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 -40051 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.

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

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

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

To Find Information on Army Solvent Substitution Efforts

Good Morning! Welcome to the Joint Group on Pollution Prevention web site!

JG-PP Charter

Joint Service Solvent Substitution (JS3) Database**

This site last updated September 30, 2005

Send all questions and comments to jgpp@ctc.com

Contact Us

System Program ManagerMaintenance and Repair FacilityOriginal Equipment ManufactureResource and Academia

www.jgpp

.com

http://www.jgpp.com/JGPP_Charter_02_2005-complete.pdfhttp://js3.ctc.com/mailto:jgpp@ctc.comhttp://www.jgpp.com/guestbook_test.htmhttp://www.jgpp.com/index.htmlhttp://www.jgpp.com/whats_new/whatsnew_index.htmlhttp://www.jgpp.com/about/about_index.htmlhttp://www.jgpp.com/contacts/contacts_index.htmlhttp://www.jgpp.com/projects/projects_index.htmlhttp://www.jgpp.com/publications/publications_index.htmlhttp://www.jgpp.com/p2/p2_index.htmlhttp://www.jgpp.com/calendar_index.htmlhttp://www.jgpp.com/glossary/glossary_index.htmlhttp://www.jgpp.com/search/search_index.html

Contact Information

Mr. Wayne ZieglerUS Army Research Laboratory

410-306-0746wziegler@arl.army.mil

OutlineThe DLSME NESHAPThe DLSME NESHAPThe DLSME NESHAPSPOTA Solvent Substitution Thrust Area Status Laboratory TestingDown SelectCleaners Downselected by TACOM and AMCOM Identifying Applications & Locations for Demo ProjectsLEAD Small Scale Technology DemonstrationRIA Small Scale Technology DemonstrationAdditional DemonstrationsCompliance SchemeImplementation�SPOTA StrategyDocument Control IssuesSuccess Story:�MIL-PRF-680 revisionsImplications of MIL-PRF-680revBCleaning During Coating Operations SpecificationStandardization DocumentsCautionary Tale�Example: MIL-STD-40051Typical ResponseCautionary Tale ImpactPath ForwardConclusionContact Information